RCC Update ORS Quarterly Meeting April 28, 2016 Julie Cole, Director Research Costing Compliance

Topics UG Website Clerical and Administrative Salaries Research and Technical Personnel Computers 2 ORS Quarterly Meeting 2016 Research Costing Compliance

3 resources/ug/index.php Uniform Guidance Communications Individual Agency Terms and Conditions (pending posting ) ORS Quarterly Meeting 2016 Research Costing Compliance

Due to changes mandated by federal agencies, Duke University is clarifying the policy regarding charging clerical and administrative salaries to federal awards made after December 26, Duke has been waiting for final clarification from federal sponsors, but is making this change to comply with anticipated audit reviews. If agencies relax requirements, RCC will notify departments. Clerical and Administrative Salaries 4 ORS Quarterly Meeting 2016 Research Costing Compliance Clerical and administrative functions/salaries may be charged directly to a federal award that is subject to the Uniform Guidance, but only if all of the following conditions pertain. Administrative or clerical services are integral to a project or activity Individuals involved can be specifically identified with the project or activity; Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and The costs are not also recovered as indirect costs.

Timing 5 ORS Quarterly Meeting 2016 Research Costing Compliance Effective April 1, 2016, Duke University required prior agency approval for clerical/administrative salaries charged to federal awards, if these items have not been included in the original proposal budget. Charges for clerical/administrative functions/salaries that do not have agency approval, or are not justified in the budget submitted to the federal agency must be removed within three accounting periods and charged to a university source.

PROCESS 6 ORS Quarterly Meeting 2016 Research Costing Compliance 1.Check budget for inclusion of these costs in the proposal budget. 2.If not showing in the budget plan as G/L (but included in the proposal), prepare a Rebudgeting/CAS form for correction. 3.If not in proposal budget, request sponsor approval through ORS by completing the necessary requirements for your pre-award office. 4.Once the sponsor has approved the expenses, submit the online CAS form, attaching the relevant approval document from the sponsor and any other supporting documentation. 5.Non-compliant charges must be moved to a university source within three accounting periods; exceptions may be made if sponsor approval is pending. 6.NOTE: If sponsor approval is not provided, charges must be removed

Important Points…. 7 ORS Quarterly Meeting 2016 Research Costing Compliance Please refer to UGC 2.2 for detailed information

Important Points…. 8 ORS Quarterly Meeting 2016 Research Costing Compliance It is the role/function of the person that determines if what is being done is clerical/administrative work, not the job title It is possible for a person paid from a sponsored project to be doing clerical work, even if their job title doesn’t reflect this. Departments should be careful in charging clerical/administrative functions directly to a federally sponsored project without consulting ORS Review the table of clerical duties included in the UGC for Clerical/Administrative charging to determine if the work performed is clerical or administrative Ask for clarification from ORS if unsure, or you may contact RCC Review the new UGC on charging research personnel (those performing scientific work, regardless of job title) for further information on related issues.

Clerical and Administrative or Research and Technical? 9 ORS Quarterly Meeting 2016 Research Costing Compliance Both functions related to the project should be included in the proposal budget and clearly justified. Clerical and administrative functions are different from research functions performed by administrative staff. Please refer to UGC 2.3 and UGC 9.1 for clarification of the difference between these functions.

Research/Technical Functions 10 Appropriate G/L Coding UGC 9.1 ORS Quarterly Meeting 2016 Research Costing Compliance

Computers (UGC 3.0) 11 Key Points: The Uniform Guidance (UG) recognizes that computing devices are essential components of research activities; Duke has determined that communication devices such as cell phones are not included in the definition of computing devices and require special approvals (See below). The UG allows for purchase of computing devices at the discretion of the recipient; however, best guidance suggests that these items should be included and justified in proposal budgets. Computing devices need not be 100% allocable to the sponsored project; however, there should be adequate justification to demonstrate that these items are necessary to the project. Special exemptions for cell phones must be documented at the department level. Computing device charges do not require an internal CAS form for approval. Purchasing computing devices through is highly recommended to ensure appropriate review and internal control procedures. Important: The Rebudgeting/CAS form no longer recognizes the computer G/Ls and the form will not process CAS approval for these items ORS Quarterly Meeting 2016 Research Costing Compliance

MORE INFORMATION 12 ORS Quarterly Meeting 2016 Research Costing Compliance Log in to the RCC Uniform Guidance Website for UGC’s : Questions? Please contact