Grants: Cradle to Grave Post Award Processes and Effort Reporting

Today’s Agenda What is Post Award? What are the PI’s Responsibilities? What are Compliance Requirements? I am a researcher why do I have to approve expenditures and monitor budgets? SRAS Review of Expenditures Advance Policy Cost Transfer Policy CAS Exemptions What is cost sharing? What is Effort Reporting OMNI Overview PI Resources 2New Fac Post Awd

What is Post Award? Activities that occur after award documents have been executed by appropriate institution authority  Award is to the Institution, not the PI  Budget number assigned  Cost sharing expenditure accounting  Research can begin  Adhere to scope of work  Collaboration/subcontracting to other individuals/institutions  Status reports  Technical reports NOTE some invoices require submission prior to payment 3New Fac Post Awd

What is Post Award?  Spending occurs  Plan ahead to meet deadlines  Personnel – Human Resources policies and procedures  Non Personnel – Purchasing/Travel/Subcontract/Non PO policies and procedures  Central Offices have role in reviewing allow ability of expenditures  Billing/Collecting from agencies (central office responsibility)  Financial reporting to agencies (central office responsibility)  Amendments (SOW & Budgetary)  Contracting Officer for grantor and grantee 4New Fac Post Awd

What are the PI’s Responsibilities? Understand agency rules/guidelines/restrictions Conduct work timely/professionally Comply with terms & conditions of award Ensure expenditures benefit the project and are in compliance with award Monitor budget vs. expenditure over life of project Ensuring commitments are met including cost share requirements Monitor subcontractor performance 5New Fac Post Awd

What are Compliance Requirements? Federal OMB Circulars applicable to University A-21 (more on this later!) A-110 A-133 Available on OMB website at: Agency specific requirements Terms and Conditions in award Non Federal Terms and Conditions rule!! FSU SR Related Policies and Procedures ml# ml# 6New Fac Post Awd

What are Compliance Requirements? Hot button issues frequently cited in audits Cost transfers onto or between projects – do it right the first time! Expenditures late in the project – using up available balance Cost share accounting/reporting Effort reporting processes Charging costs normally considered overhead directly to projects 7New Fac Post Awd

OMB Circular A-21 SRS/SRAS use this resource daily Allowable means: Reasonable (prudent person) Allocable (relative benefits) Treatment is consistent (direct vs. indirect) Conforms to limitations or exclusions (e.g. salary caps) Direct costs “identified specifically with a particular sponsored project” Facilities & Administrative (F&A) costs “incurred for common or joint objectives and therefore cannot be identified readily and specifically with a particular sponsored projects” 8New Fac Post Awd

OMB Circular A-21 Cost Accounting Standards (CAS) Selected Cost Items (Section J) 54 types of expenses and whether allowable vs. unallowable Any costs allocable to a particular sponsored agreement may not be shifted to any other sponsored agreements for the purpose of (Cost Transfer Policy)  Convenience – includes charging a project while waiting for another project/budget to be set up (Advance Policy)  Meeting deficiencies caused by overruns  Avoiding restrictions imposed by law or terms 9New Fac Post Awd

Sponsored Research Financial Policies/Procedures Advances Advances Cost Accounting Standards (CAS) Cost Accounting Standards (CAS) Cost Sharing Cost Sharing Cost Transfers Cost Transfers Effort Commitments Fixed Price Residual Funds Indirect Cost Recovery Participant Support Costs Program Income Sub recipient Monitoring Unallowable Costs Closeout Authority – Memorandum dated September 24, New Fac Post Awd

How do I collaborate with another researcher? Often included in proposal Institution approval vs. researcher Participates in research (sub recipient) vs. provider of goods/services (vendor) Starts with SRS Subcontract Coordinator Standard agreement Incorporates Federal requirements Encumbered in OMNI as PO Numbers = RXXXX PI approves invoices (deliverables met) New Fac Post Awd11

Why do I approve expenditures and monitor budgets? Award is to the University…however PI responsible for ensuring expenditures benefit the project Timing of when personnel need to be appointed Timing of when supplies will be used Collaboration with subcontractor in accordance with SOW Periodic budget vs. actuals reports (OMNI) Ensure anticipated expenditures charged Review for expenditures that do not belong on project Rate of expenditures reasonable for pace of research progress New Fac Post Awd12

SRAS Review of Expenditures Transactions SRAS Coordinators evaluate Requisitions > $1,000 Travel and Expense reports > $1,000 Unencumbered expenses (pay requests/stipends) All personnel appointments All journal entries Cost Transfer Justification Form All interdepartmental requisitions 13New Fac Post Awd

SRAS Review of Expenditures Compliance Evaluation Criteria Authorized Signature Sponsored Project Manager or PI Chartfield Information DeptID, Fund Code, Project Combination Performance Period Goods or Services received and consumed within Dates of Award period Available Balance Direct Cost Funds available for Expense by budget category line item Account or Job Code Appropriate for nature of expense Allowable Terms and Conditions support expense 14New Fac Post Awd

Advance Policy Purpose: Ensure timely start up or uninterrupted continuation effort prior to having a fully executed award document Criteria Written/verbal assurance from sponsor Delays would adversely impact the program or increase costs Department assumes risk by financially backing the direct cost amount to be advanced No work is to be initiated until authorized by SRS (as evidenced by a project budget) DO NOT charge expenses for pending award to another funding source Transfers will not be approved Transfers will not be approved 15New Fac Post Awd

Cost Transfer Policy Purpose: Ensure that funds are properly managed Indicators of inadequate fiscal monitoring Frequent cost transfers Late cost transfers Inadequately documented or justified cost transfers Examples of improper/unallowable cost transfers Utilizing unexpended funds Avoiding/alleviating an over expenditure Moving unallowable costs on one project to another Circumventing award restrictions Reimbursing a temporary “loan” of funds from another project 16New Fac Post Awd

Cost Transfer Policy Examples of proper cost transfers The transfer represents an adjustment for an erroneous charge Split purchase Timeliness of identification and correction of errors is essential to evidence sound fiscal management Policy Payroll – within 30 days of end of the month in which error occurred (agrees with RDF Policy) Non-Payroll – within 90 days of end of month in which error occurred (or within 30 days of the project expiration date. 17New Fac Post Awd

Cost Accounting Standards (CAS) FSU is required to disclose “costing practices” in a formalized document (Disclosure Statement-2) Describes how FSU treats Direct F&A costs Facilities Administration 18New Fac Post Awd

CAS – F&A Costs Examples of Costs that are normally treated as F&A: Administrative and Clerical Salaries Postage Local Telephone Office Supplies Data Processing/Computer Supplies General Purpose Software Memberships Subscriptions Cannot charge expenses typically treated as an indirect cost directly to a sponsored project unless there are exceptional circumstances 19New Fac Post Awd

CAS Exception Process Must be documented for all federally-funded awards Pertains to direct charge costs that are normally treated as indirect costs Inclusion in the budget in the award document does not automatically grant the exception Form at s.html s.html Submit to Director, Sponsored Research Services 20New Fac Post Awd

What is Cost Sharing? Policy at Definition = Costs borne by FSU Criteria for tracking/reporting Committed—Mandatory vs. Voluntary Committed Must account for and report Project Enhancement Do not have to account for and report Include in the proposal budget Cost Share Commitment Form Signed by Chair/Dean/Director Cost Share budgets are set up in OMNI Does not include 3 rd party Transfer the cash for PI, SRAD, Auxiliary, FSU Fdtn, Research Fdtn funding sources 21New Fac Post Awd

What is Effort Reporting? Federal government expects Universities to Meet commitments Provide evidence that commitments have been met FSU certification cycle Certify after each academic term Application = Faculty Assignments effort Certification Tracking (FACET) Provide reasonable estimate of time spent on various activities (instruction, advising, projects, etc.) 22New Fac Post Awd

OMNI Overview Financial/Human Resource Systems Project financial information Job Aids on Division of Sponsored Research at Available project balance inquiry Generating project financial report Running query of project expenditure detail Generating HR report of payroll detail Budget check against direct cost budget Expenditures (costs incurred) Encumbrances (POs, T-Auths, personnel appointments) Not encumbered (f uture personnel appointments, tuition, rent, F&A) 23New Fac Post Awd

PI Resources New Fac Post Awd24

Training Opportunities CReATE Compliance and Research Administration Training and Education Next session in Fall 2010 SP2089 Proposal Development for Sponsored Programs Training Lunch & Learn series 1-2 per month Wednesdays 11:30am – 12:30pm Current schedule ps.html) ps.html 25New Fac Post Awd

Web Resources Office of Research ( Division of Sponsored Research ( Staff Contact Information (SRAS assignments attached) Policies and Procedures Forms Funding Resources OMNI Information Training Information /Newsletter Services (recommend getting on these list serves) 26New Fac Post Awd

Web Resources Controller’s Office ( General Accounting Payroll Services Property Accounting Accounts Payable Travel Office of Graduate Studies ( Tuition Waiver Information Purchasing ( Human Resources ( OMNI Resources ( 27New Fac Post Awd

QUESTIONS OMB A-21 28New Fac Post Awd