Office of Post-Award Management Purchasing & Travel Office of Post-Award Management

Post-Award Management Know Your Sponsor and Award Details Learn How to Apply the Rules: Award Terms Departmental Policies Accounting & Financial Policies University Polices & Procedures Sponsor Policies A-21 A-110 FARs Federal Policies and Governmental Law

Post-Award Management Policies and Procedures All expenditures must be made in accordance with the policies and procedures of The University of Texas at Dallas as published in the University Business Policies and Procedures Manual. Applicable federal and sponsor rules and regulations also must be followed. As a condition of receiving federal funding, we agree to follow federal policies applicable to work performed on contracts and grants. Below are the OMB Circulars (instructions/information issued by the Office of Management and Budget (OMB) to federal agencies) that The University of Texas at Dallas follows: OMB Circular A-21 - Cost Principles for Educational Institutions As stated in A-21 there are four guiding principles or criteria used to determine whether a cost can be charged to a sponsored agreement: allowability, allocability, reasonableness ,and consistency. These criteria apply for both direct and indirect (or Facilities & Administrative) costs. For a given cost to be charged to a sponsored agreement, all four (4) of these criteria must be met. OMB Circular A-110 - Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations OMB Circular A-133 - Audits of States, Local Governments, and Non-Profit Organizations

Post-Award Management Allowable, Allocable, Reasonable and Consistent Costs Allowability: A cost is allowable when allowed by OMB Circular A-21 - Cost Principles for Educational Institutions, it serves the grant purpose (instruction, research, public service), federal regulations, and is allowed by the University’s policy. The tests of allowability of costs under these principles are: They must be reasonable. They must be allocable to sponsored agreements under the principles and methods provided herein. They must be given consistent treatment through application of those generally accepted accounting principles appropriate to the circumstances. They must conform to any limitations or exclusions set forth in these principles or in the sponsored agreement as to types or amounts of cost items.

Post-Award Management Allowable, Allocable, Reasonable and Consistent Costs Examples of allowable costs: Salaries and fringe benefits of faculty, technicians, post docs, research assistants and other personnel directly engaged in performing sponsored grant's scope of work Laboratory supplies and materials necessary for performing sponsored grant's scope of work Other costs such as travel, subcontracts, specialty equipment repairs and maintenance, and other directly related costs necessary for performing sponsored grant's specific scope of work Capital equipment that is approved by the sponsor Service/maintenance agreements on capital equipment approved by the sponsor Typically unallowable on federal awards: Advertising for general promotion of the University, including printed materials, promotional items, memorabilia, gifts, and souvenirs Entertainment Fine/original art Fines and penalties Advertising for recruitment purposes that includes color or is excessive in size First-class/business-class air travel differentials Flowers Alcoholic beverages Gifts, prizes, and awards Alumni or fund-raising activities Goods or services for personal use Bad debt write-offs Lobbying Donations or Contributions Memberships in airline travel clubs Commencement expenses Faculty and exempt staff salary in excess of base rates paid by the institution. Cost Overruns Costs on Industry, Foreign Government or Other Non-Government Grants/Contracts Selling or marketing products or services of the University Decorative objects for private offices

Post-Award Management Allowable, Allocable, and Reasonable Costs Allocability: The cost is allocable to a federally sponsored agreement if: The cost has been incurred solely to advance the work under the sponsored agreement. It benefits both the agreement and other work of the institution, in proportions that can be approximated through use of reasonable methods. It is necessary to the overall operation of the institution and is deemed to be assignable in part to sponsored projects. Reasonableness: The cost must be able to withstand public scrutiny, i.e. objective individuals not affiliated with the institution would agree that a cost is appropriate on a sponsored research award. Recognized as necessary for the operation of the institution or the performance of the agreement Consistent with the requirements imposed by arms-length bargaining, federal or state laws and regulations, and ethical business practices Related to an action and/or in an amount deemed within the norms of business conduct (i.e., passes the "prudent person" test). Consistency: it must be treated in the same manner (i.e., as either direct or indirect) when used in like circumstances. This means that for all categories of costs, all activities within the University must account for such in the same manner when incurred in similar circumstances

Post-Award Management Travel With the exception of the Principal Investigator or Co-P.I., travel costs can only be charged to a federal project when the traveler is exerting effort on the project during the time of travel. Written Sponsor approval is required to pay travel expenses on a federal sponsored project for a traveler that is not exerting effort on the project at the time of travel. Foreign Travel: Is allowable as long as prior approval from federal agency was received and documented. Air fare to the foreign destination must be purchased on an American flag carrier (Fly America Act). If foreign travel is not listed in the approved budget, some Sponsors require prior written approval. In some cases, a Sponsor will require prior written approval for foreign travel even if it is listed in the proposal/application. All requests to obtain prior Sponsor approval for travel on a sponsored project should be submitted well in advance of the desired travel. The request should provide information regarding the purpose of the travel, number of persons traveling, destination, number of days, and estimated cost.

Post-Award Management Travel Travel Expenses Allowable - as long as the travel is allowed on the grant. Foreign Travel Allowable as long as prior approval from federal agency was received and documented. Air fare to the foreign destination must be purchased on an American flag carrier (Fly America Act). Foreign Air carrier plane ticket Not allowable. Please see the Fly America Act. http://www.tvlon.com/resources/FlyAct.html Meals for persons other than the traveler Not allowable. The cost of meals other than the traveler must be deducted from meal receipts prior to submitting reimbursement. Alcoholic beverages Not allowable. Alcohol must be deducted from meal receipts prior to submitting reimbursement. Side Trips Not Allowable. UTD does not pay for any travel involving personal side trips.

Post-Award Management Sub-Award Sub- Awards: third party organization performing a portion of UTD research projects or other Sponsored Program. The terms of UTD Sub-Recipient relationships are documented in Subgrant/Subcontract or consortium agreements. Difference between a Sub recipient and a Vendor, per Office of Management and Budget Circular A-133 A Sub Recipient: Has a responsibility to carry out a portion of the grant program as defined in the Subcontract, Has its performance measured against the grant program objectives Has responsibility for programmatic decision making Has responsibility for adherence to applicable federal program compliance requirements A Vendor: Provides goods and services within normal business operations, Provides similar goods and services to many different purchasers Operates in a competitive environment Provides goods and services that are ancillary to the operation of the grant or contract Is not subject to compliance requirements of a federal grant or contract Vendor purchases are not to be charged to Subcontractor or federal Pass-through object codes Sub-recipient Monitoring The University of Texas at Dallas is also responsible for ensuring that sub recipients are in compliance with the requirements of appropriate standards for good business practices, including internal controls in accordance with OMB Circular A-133 Audits of States, Local Governments, and Non-Profit Organizations.

Post-Award Management Best Practices The Principal Investigator (PI) has overall responsibility for the technical and fiscal management of a sponsored project, including the management of the project within funding limitations, and assuring that the sponsor will be notified when significant conditions related to the project status change. While responsibility for the day to day management of project finances may be delegated to administrative or other staff, accountability for compliance with UTD policy and sponsor requirements ultimately rests with the PI. The role of the Office of Post-award Management (OPM) is to assist departments in monitoring grant cost. When working with your grant funds, always remember that you have a limited amount of money, and keep in mind your expenditure rate. Ask yourself: Am I pacing myself? You should make sure to set out and accomplish that which you laid out in your proposal without deviating from the approved budget Am I spending all my money in the first month or two of the project? This could lead to over expenditure, OPM can help by reviewing and interpreting the information on financial reports and troubleshooting problems that may be contributing factors. Am I not spending the money fast enough? Am I reviewing account activity on a consistent basis? Prepare ahead for closeout

Post-Award Management Audit Perspective How do I know that the cost belongs to this specific project? Was the cost included in the budget? Is it generally allowable according to A-21? Is the cost reasonable as a direct charge to this project? Was the cost charged directly to this project? Timing of the cost relative to the project period No costs should ever be charged to a project to spend the money up because a project is ending No costs should ever be charged to a project just because that is “where I have money at” Large purchases at the end of a grant's life indicate poor or mismanaged spending practices to the sponsor

Post-Award Management Summary Take a proactive approach to fund management. It is imperative that all parties work as a team. Proper fund management involves Adhering to institutional and sponsor guidelines and regulations, Establishing a proper financial accountability structure, and Ensuring proper financial management with attention to the integrity of data by completing monthly Account Reconciliations on a timely basis and addressing all issues.

Post-Award Management Who to Contact All Others questions: Lori Taccino Director of Post Award Management 972-883-2173 ldt091000@utdallas.edu For question with Award setup, budgets, cost centers, cost share and re-budgeting: Lesley Stephenson Lakeshia Stringfellow, MBA Post Award Management Specialist Post Award Management Specialist 972-883-4837 972-883-2689 las091000@utdallas.edu Lxs091000@utdallas.edu For Questions on Payroll charged on Awards: Kelly McKinney Assistant Director of Post Award Management 972-883-4540 kellymc@utdallas.edu Cindy Sutton Natasha Hinton Financial Analyst Financial Analyst 972-883-4809 972-883-2315 csutton@utdallas.edu natasha.hinton@utdallas.edu

Post-Award Management Further Information Office of Research - http://www.utdallas.edu/research/ Research Development, Research Integrity, Sponsored Projects, Technology Commercialization Post Award Management - http://www.utdallas.edu/research/opm/ Allowable Cost -http://www.utdallas.edu/research/opm/admins_and_faculty/allowable_cost/ Office of Management & Budget Circular A-21 - http://www.whitehouse.gov/omb/circulars_a021_2004 Research Travel - http://www.utdallas.edu/research/opm/admins_and_faculty/travel/ Sub Award Management - http://www.utdallas.edu/research/opm/admins_and_faculty/sub_award_management/ Over Expenditure - http://www.utdallas.edu/research/opm/admins_and_faculty/overexpenditure_policy/ FAR – Federal Acquisition Regulations http://acquisition.gov/comp/far/index.html Certificate Series - https://explorer.utdallas.edu/classes/ Next presentation COST SHARE – February 7th, 2013