1 I have the grant, now what!? Presented by John Hulvey, Director Sponsored Programs Admin & Accounting

2 Introduction This presentation covers: –Understanding the basics Common MisconceptionsCommon Misconceptions –What’s the PI’s role? –What’s Sponsored Programs Accounting’s Role? –Expenditure Compliance –Reading PS Financial Reports –“Gotcha’s”! & Summary

3 Vocabulary Department ID = Org. Code = Grant NumberDepartment ID = Org. Code = Grant Number Account # = Expenditure CodeAccount # = Expenditure Code PI = Principal InvestigatorPI = Principal Investigator Facilities and Administration (F&A) (indirect costs or “overhead)Facilities and Administration (F&A) (indirect costs or “overhead) Finance System = General LedgerFinance System = General Ledger

4 Common Misconceptions All sponsored program awards are “grants.”All sponsored program awards are “grants.” –Also Contracts and Cooperative Agreements That funds are totally controlled by the PI.That funds are totally controlled by the PI. –JMU Policy 2201 states “All funds received for sponsored programs are under the fiscal control of the assistant vice president for finance.”

Common Misconceptions That we can change the scope of work or use of funds without the sponsor’s permission.That we can change the scope of work or use of funds without the sponsor’s permission. –Must be good stewards of the funds; they were given for a purpose. There is a ‘pool of money’ with an award.There is a ‘pool of money’ with an award. –Most cash is received on an expenditure reimbursement basis. –Sponsor may refuse to reimbursement unallowable expenses 5

Common Misconceptions Standard JMU rules don’t apply to these funds.Standard JMU rules don’t apply to these funds. –Very wrong; in fact, control over expenditures may be more strict. –Everyone wants to add a regulation! Specific grant instructions; JMU policy (2201 states awards must follow JMU procedures); state regulations; federal regulations; federal law.Specific grant instructions; JMU policy (2201 states awards must follow JMU procedures); state regulations; federal regulations; federal law. 6

Common Misconceptions: The rules don’t apply (continued) Grants & Coop Agreements are governed by OMB Circular A-21; Contracts by FAR clauses (Federal Acquisition Regulation).Grants & Coop Agreements are governed by OMB Circular A-21; Contracts by FAR clauses (Federal Acquisition Regulation). Costing standards and allowable costsCosting standards and allowable costs All awards governed by A-110All awards governed by A-110 Administrative requirementsAdministrative requirements Federal Agencies “codify” FAR and A- 110 independentlyFederal Agencies “codify” FAR and A- 110 independently Code of Federal Regulations (CFR)Code of Federal Regulations (CFR) Regulations apply to federal agency, applied to award recipients through CFRRegulations apply to federal agency, applied to award recipients through CFR 7

8 What’s the PI’s Role? Person of many hatsPerson of many hats –Researcher, Manager, Accountant. Has DIRECT responsibility for awardHas DIRECT responsibility for award –Must complete responsibilities of award –Must work within approved budget –Must ensure “Matching” is met and “Effort” is applied –Maintain Adequate Documentation –May delegate workload

9 What’s Sponsored Programs Accounting’s Role? Establish Financial FrameworkEstablish Financial Framework –Department ID(s); Budgets Maintain ‘auditable’ fileMaintain ‘auditable’ file Post-award compliance officers for the UniversityPost-award compliance officers for the University Billing/Collection from SponsorsBilling/Collection from Sponsors Prepare Financial ReportsPrepare Financial Reports Timely close-out of grantTimely close-out of grant

10 Purchasing Rules Same for Grants as other University fundsSame for Grants as other University funds –(Unless stated in Award) May actually be more restrictive May actually be more restrictive – Must relate to grant work & budget. – Must comply with A-21 or FAR regulations – No Membership fees, subscriptions

11 Purchasing Rules EVa must be usedEVa must be used SP Cards must be used & reconciledSP Cards must be used & reconciled Forms:Forms: –Accounting Voucher –Travel Authorization –Travel Reimbursement Voucher –Agency Transfer Voucher (ATV) –Personnel Action Request (PAR)

Procurement Rules Required for all purchases of goods and services $5000 or more.Required for all purchases of goods and services $5000 or more. Must use Va State ContractsMust use Va State Contracts Some procurements can be built into the Sponsored Program as a Sub-agreementSome procurements can be built into the Sponsored Program as a Sub-agreement 12

Expenditures (Travel and Business Meals) This is one area where otherwise rational people loose their minds with Sponsored awards!!This is one area where otherwise rational people loose their minds with Sponsored awards!! Simply stated: VA State (JMU) rules apply (Unless specifically addressed in the award)Simply stated: VA State (JMU) rules apply (Unless specifically addressed in the award) 13

Expenditures (Travel and Business Meals) Common Unallowable Expenses:Common Unallowable Expenses: –A business meal with no non-JMU employee attending (this is a “meeting”, not a “business meal”) –‘Pizza parties’ for student employees –Staying at over-priced hotels or eating at over-priced restaurants. –Charging a rental vehicle when cab fare to and from the airport was reasonable. This is particularly obvious when the family accompanies the traveler to the conference.This is particularly obvious when the family accompanies the traveler to the conference. 14

Additional Travel Regulations Foreign flights (Coach Class)Foreign flights (Coach Class) –Must be on US flag bearer when using Federal dollars! Cost is not a factor; however, there are some exceptions related to service destinations or arrival/departure timesCost is not a factor; however, there are some exceptions related to service destinations or arrival/departure times Use a JMU authorized Travel Agency and indicate “” must be followedUse a JMU authorized Travel Agency and indicate “Fly America Act” must be followed –JMU approval still needed for Travel Authorizations Not automatic with the sponsored program awardNot automatic with the sponsored program award 15

Personnel Considerations Employee vs. ContractorEmployee vs. Contractor –Has bearing on taxes withheld –What ‘control’ exists over person? See 20 questions on Payroll WebsiteSee 20 questions on Payroll Website If in doubt, contact PayrollIf in doubt, contact Payroll Must follow immigration rules to hire non-US Citizen on AwardMust follow immigration rules to hire non-US Citizen on Award –Contact office of international programs with questions 16

17 F&A (Facilities and Administration) Part of the award budgetPart of the award budget –Seldom reduces direct expense budget 50% returned to Institution50% returned to Institution –30% Department; 10% Dean; 10% Provost –Must be spent in support of Grants Withheld from award budget loaded to Finance System.Withheld from award budget loaded to Finance System. –Budget then increased with each monthly F&A charge.

Matching (Cost Sharing) Mandatory vs. VoluntaryMandatory vs. Voluntary –Voluntary Match is discouraged by University policy and restricted by some funding agencies What is allowed?What is allowed? –Must have a basis for value –Space/Equipment must be 100% designated to the project. –Must be documented / reported at the conclusion of the project. 18

Effort Percentage of time applied to a project related to all PAID JMU activities.Percentage of time applied to a project related to all PAID JMU activities. –Must ALWAYS equal 100% –Does not change based on number of hours worked –Cannot ‘over commit’ effort –JMU certifies effort each semester 19

20 Why should the PI keep records? PI’s responsibility! (Stewardship)PI’s responsibility! (Stewardship) –Like reconciling a checkbook –Tie expenditures to award budget Ensure accuracy of keyed dataEnsure accuracy of keyed data Track Timing differencesTrack Timing differences Track ATV (automatic) chargesTrack ATV (automatic) charges –Postage, telephone, Copy Center, JMU car rental Document ‘matching’ and ‘effort’Document ‘matching’ and ‘effort’ Up to 5 year record retentionUp to 5 year record retention

Budget Revisions May require sponsor’s written approvalMay require sponsor’s written approval Processed through Office of Sponsored ProgramsProcessed through Office of Sponsored Programs PI must justify how a budget line can be reduced and how the new budget would improve the projectPI must justify how a budget line can be reduced and how the new budget would improve the project 21

Close out Most projects have defined ending date where work must be completed and expenditures incurredMost projects have defined ending date where work must be completed and expenditures incurred –Processing of incurred expenditures generally may continue after project end-date, but NO NEW expenses. PI records are a MUST at this time and are difficult to construct if not already prepared.PI records are a MUST at this time and are difficult to construct if not already prepared. 22

Close out (No cost extension?) PI should request a ‘no-cost extension’ through Office of Sponsored Programs if neededPI should request a ‘no-cost extension’ through Office of Sponsored Programs if needed –At least 30 days before the project end date –Not just for convenience or to spend remaining funds 23

24 GOTCHA’s Timing of transactions to General LedgerTiming of transactions to General Ledger Grant Period ending before project is doneGrant Period ending before project is done Forgetting that FICA is added to Lump Sum salary amount on PAR formForgetting that FICA is added to Lump Sum salary amount on PAR form Not following the awarded budget and budget justificationNot following the awarded budget and budget justification

25 Summary Generally, JMU rules applyGenerally, JMU rules apply Buck stops with PI (and department)Buck stops with PI (and department) Sponsored Programs Accounting provides assistance and reviews for complianceSponsored Programs Accounting provides assistance and reviews for compliance When in doubt, refer to the awardWhen in doubt, refer to the award

26 Where to Get More Information Sponsored Program Accounting - MSC 5713Sponsored Program Accounting - MSC 5713 JMAC Building 6, Suite 30 JMAC Building 6, Suite 30 John HulveyJohn Hulvey Brenda Wilburn SeifriedBrenda Wilburn Seifried Donna CrumptonDonna Crumpton Kyra ShifletKyra Shiflet