2. Cost Transfers Discussion & New Form – Catherine Sandifer, GCA Grants Administrator Recent Notices/Updates Conflict of Interest Form Changes Reminders & Announcements

3. Cost Transfers Grants and Contracts Accounting

4. What is a cost transfer? A cost transfer is the reallocation of recorded expense to, from or between sponsored projects. Institutions have a responsibility to ensure that funds are being used in accordance with applicable law, sponsor terms and conditions, and written institutional policies. Required to correct errors or achieve proper, consistent, and equitable distribution of costs. Federal government expects costs will be charged appropriately at the time incurred. Federal government scrutinizes cost transfers closely, looking for indication of misallocation of funds.

5. Evaluation of Cost Transfers to and from Federal Sponsored Awards

6. A need for a review of the cost transfer process was identified during our annual risk assessment and performed by Internal Audit under their 2016 Audit Plan. Review Objective: To determine if costs transfers are in accordance with applicable Federal and MUSC policies and procedures.

7. Scope: Evaluated cost transfer process for Federal sponsored awards from July 1, 2014 through June 30, 2015. Awards issued on or after December 26, 2014 were evaluated in accordance with the Uniform Guidance requirements which became effective on that date.

8. Audit Conclusion: Adequate internal controls for processing cost transfers in accordance with Federal and MUSC policies exist. Some exceptions in the application of the controls were identified and process improvements are being implemented to strengthen controls, reduce risks, and resolve problems or perceptions of problems.

9. Justification - Adequate justification was not documented for several cost transfers that occurred during the period of the review. For some transfers, the justification was omitted. For others, the justification was too generic in nature. Document Dates - Signatories were not required to date their signatures when completing Cost Transfer forms. In addition, dates are not included for GCA approvals on unposted journal entry forms used as a part of the cost transfer approval process.

10. Cost Transfer Forms Use a PEAR/PAR form for personnel expenditures Request for Cost, Commitment, or Encumbrance Transfer form is used for everything else (cost overruns, non-personnel expenditures, etc)

11. AllowableUnallowableCautions o Expenses not allowable on a Sponsored Project moved to a Non-Sponsored Project due to sponsor guidelines. o Retro personnel (salary and fringe) expenditures moved to a new award if award notification from the sponsor has been delayed. o Personnel expenditures necessary to align payroll charges with certified Quarterly Activity Report. o Cost overruns that have occurred once a Sponsored Project has terminated. o Expenses posted to a Sponsored Project with an invoice date or pay period after the Sponsored Project has terminated o Transferring charges from either an over-expended or terminated sponsored project to another sponsored active sponsored project with available funding. o Moving equipment and supply charges within 90 days of termination. o Transfers expenses to a project that is soon terminating to spend out an available balance. o Moving charges from a corporate award to a Federall award, particularly if the area of research is the same for both awards. o Transfers to avoid the 25% carryover approval o Transfers to or between federal grants o Transfers at the end of the project period o Transfers older than 90 days of the month in which the original transaction posted o Transfers in the last month of the award or after the award has expired o Large numbers of cost transfers o Grants or contracts with a zero balance at the end of the award

14. 1. DATE, FROM, EMAIL, DEPT : department contact responsible for the transfer request 2. From UDAK: where expense is currently posted. 3. To UDAK: where the expense will be received. 4. Posting Date: date expense posted in SmartStream for each referenced expense. (The posting date can be obtained through a Transaction Detail Report.) 5. Account Posted To: 5-digit account object code to which the expense is currently posted 6. Reference Number: MarketPlace Reference #, RQ#, PO#, FA#, TR#, or Purchasing Card #. (If project is overspent in a budget category that was not caused by one particular expense, enter “MASS”) 7. Account Transfer To: 5-digit account object code to receive the transfer. 8. Amount: expense dollar amount or the cost overrun dollar amount. You must use amount posted in SmartStream (money bags). 9. Total: Sum of all line items. (If continuation page is completed is used total from both pages)

16. Cost Transfer Justifications Good ExamplesPoor Examples Allowable pre-award costs incurred prior to receipt of the award notice; include start date of the award Supplies were originally purchased for project 8A123 but were actually used on project 8B123. Lab manager informed business manager of change in plans in the month of occurrence P-Card charge was not allocated and the charge posted to the default UDAK. Error discovered during monthly reconciliation of the UDAK and allocations. To correct animal recharge billing which was charged to the wrong award. Error discovered by PI during reconciliation Two similar purchases from the same vendor, for two different awards. One award incorrectly charged for both items. Error discovered by PI during monthly review of statements Error made in original entry when “x” occurred; problem has been corrected with the implementation of “y.” To transfer items that were incorrectly charged Per PI instructions, move charges to clear an overdraft To clear my deficit To utilize my available funding “Error” or “To correct an error” Error was discovered during “routine” monitoring of account – but no detail. We don’t have enough personnel to monitor the accounts. Transfer credit from Dr. X’s (Non-Federal) to Dr. Y’s (Federal) to close account

17. PI Signature: Cost Transfers over $200 require Principal Investigator’s signature (reference policy 4.3.12) DOCUMENTATION: Transfers will only be approved if backup documentation is attached. Copies of the original transaction approvals Check requests Invoices Credit Card Transactions Receipts Purchase Orders Travel Reimbursement Requests

18. Uniform Guidance § 200.415 Required certifications

19. Cost Transfer Questions? Questions regarding cost transfers should be addressed to the appropriate Grants and Contracts Accounting Team based on departmental assignment (see Distribution of Grants by Administrator) or at 792-2850.Distribution of Grants by Administrator Forms can be found at : http://academicdepartments.musc.edu/vpfa/forms/f ormlib.htm

20. NOT-HS-16-008 AHRQ now adhering to NIH Public Access Policy Feb 22, 2013 memo from White House Office of Science and Technology Policy (OSTP) Feb 22, 2013 memo – ALL federal agencies must have a Public Access Plan NOT-OD-16-059 Clarifies and supersedes NOT-OD-16-045NOT-OD-16-045 – NIH Salary Cap ($185,100 as of Jan 10, 2016) applies exclusively to grants and cooperative agreements – NIH Salary Cap DOES NOT APPLY to NIH Contract awards

21. NOT-OD-16-062 FY 2016 Ruth L. Kirschstein National Research Service Award (NRSA) Stipends, Tuition/Fees and Other Budgetary Levels Frequently Asked Questions Related to NRSA Tuition, Fees, and Health Insurance Policies: http://grants.nih.gov/training/nrsa_tuition_q&a.htmhttp://grants.nih.gov/training/nrsa_tuition_q&a.htm Career LevelYears of ExperienceStipend for FY 2016Monthly Stipend Freshmen/SophomoresUndergraduate$8,808$734 Juniors/SeniorsUndergraduate$12,236$1,028 PredoctoralAll$23,376$1,948 Postdoctoral0$43,692$3,641 1$45,444$3,787 2$47,268$3,939 3$49,152$4,096 4$51,120$4,260 5$53,160$4,430 6$55,296$4,608 7+$57,504$4,792

22. NOT-OD-16-066 Reminds ALL awardee institutions that the HHS 568 (Final Invention Statement) must be filed at the conclusion of a grant or contract All subject inventions must also be reported in iEdison Failure to report may result in your organization’s loss of rights in the invention or other actions as appropriate NOT-OD-16-067 NIH’s implementation of Federal Awardee Performance and Integrity Information System (FAPIIS) requirements under the Duncan Hunter National Defense Authorization Act (Public Law 110-417) – Database of information related to past performance, organizational integrity and business ethics, suspension/debarment, etc. ORSP handling this for MUSC as part of subaward preparation

23. Transition to NIH FORMS-D application packages, summary information: Changes: – FORMS-D application guides are to be made available by NIH on March 25 – Annotated form set: http://grants.nih.gov/grants/ElectronicReceipt/files/Annotated_Forms_General_FO RMS-D.pdf http://grants.nih.gov/grants/ElectronicReceipt/files/Annotated_Forms_General_FO RMS-D.pdf – List of changes: http://grants.nih.gov/grants/funding/FORMS-D-pre-award-form- changes.docxhttp://grants.nih.gov/grants/funding/FORMS-D-pre-award-form- changes.docx – Forms have not significantly changed, but have been significantly reorganized Timing: – Must use FORMS-D for applications with due dates on/after May 25, 2016 – Choice of forms package is determined by the due date listed in FOA, NOT the date the application is submitted – May not use FORMS-D for due dates prior to May 25, 2016 – May not use FORMS-C for due dates on/after May 25, 2016

24. Transition to NIH FORMS-D application packages, summary information (continued): Selecting the correct FORMS: – During transition, there is a chance to submit using wrong forms (computer review may not catch error) – NIH receipt & referral staff will manually validate, if the wrong FORMS version is used NIH will not accept the application for consideration – Should receive warning messages with validation of submission – If unsure you’re using the correct FORMS, use this resource: Do I Have The Right Forms For My Application?Do I Have The Right Forms For My Application? Continuous Submission: – Use the due date that would have applied if not utilizing continuous submission to select the correct FORMS packagecontinuous submission The full text of this message from NIH has been posted on the ORSP web page: http://academicdepartments.musc.edu/research/orsp/federal_forms_d_transition http://academicdepartments.musc.edu/research/orsp/federal_forms_d_transition

25. FORMS-D - Forms in development NIH posted mock-ups of new application forms for viewing Intended for system-to-system solution developers NOT FINAL and are subject to change NOT-OD-16-064 Impact of Grant Application Form Update (FORMS-D) on Late and Continuous Submission Applications – Use the forms and instructions for the intended due date (not actual submission date) – The intended due date is the date listed in the Application Due Date or AIDS Application Due Date row of the Key Dates table in the funding opportunity announcement (FOA) – NOTE: The continuous submission policy only applies to R01, R21 and R34 activities that follow the standard submission schedule. The dates specified for these three activities are the intended due dates for continuous submission applicationsstandard submission schedule – Be sure to use the FOA with the FORMS-C application package if applying to an intended due date before May 25

26. NOT-OD-16-068 FORMS-D Transition Plan for Administrative Supplement, Successor-in- Interest (Type 6) and Change of Institution (Type 7) Announcements without Specific Due Dates – On May 25, 2016 NIH will reissue FOAs with new numbers and will include FORMS-D application packages – Applications started on or after May 25, 2016 must use the new FOAs and FORMS-D – FORMS-C FOAs will close on May 25, 2016 and new applications cannot be started. Applicants will have 30 days after the close date to submit any in- progress applications and complete the submission process. – FORM-C submissions will not be accepted after June 24, 2016

27. NOT-OD-16-068NOT-OD-16-068 (continued) FORMS-D Transition Plan for Administrative Supplement FOAs with Specific Due Dates – On May 25, 2016 NIH will close FORMS-C and add FORMS-D application packages to administrative supplement FOAs with specific due dates – FORMS-C application packages will close on May 25, 2016 and new applications cannot be started. Applicants will have 30 days after the close date to submit any in-progress applications and complete the submission process – FORM-C submissions will not be accepted after June 24, 2016

28. Resources for NIH Rigor & Transparency Requirements NIH Rigor & Transparency home page: – http://grants.nih.gov/reproducibility/index.htm http://grants.nih.gov/reproducibility/index.htm NIH Rigor & Transparency FAQs: – http://grants.nih.gov/reproducibility/faqs.htm http://grants.nih.gov/reproducibility/faqs.htm Blog posts by Dr. Mike Lauer, NIH Deputy Director for Extramural Research: – Scientific Premise in NIH Grant Applications Scientific Premise in NIH Grant Applications – Scientific Rigor in NIH Grant Applications Scientific Rigor in NIH Grant Applications – Consideration of Relevant Biological Variables in NIH Grant Applications Consideration of Relevant Biological Variables in NIH Grant Applications – Authentication of Key Biological and/or Chemical Resources in NIH Grant Applications Authentication of Key Biological and/or Chemical Resources in NIH Grant Applications

29. NIH Grant Application Resource Authentication Plan For due dates between now and May 24, 2016 – additional attachment (not part of research strategy) Other Project Information Form, line 12 – Other Attachments – NIH suggests no more than one page For due dates on or after May 25, 2016 – required to use application FORMS-D – PHS 398 Research Plan and Career Development Award Supplemental application packages will have a specific attachment field called “Authentication of Key Biological and/or Chemical Resources”

30. Revised External Contributor Listing Form NOW External Investigator Listing Form One must ONLY list external “Investigators” Column 1: Name of external investigator Column 2: Role on project (e.g. co-PI, consultant etc.) Column 3: External investigator’s institution if applicable (think consultants here) http://academicdepartments.musc.edu/research/orsp/ orsp_coi

31. Tweaked External Investigator Financial Conflict of Interest Certification Form (NON-CORPORATE) NOW External Investigator Financial Conflict of Interest Policy Certification Form Title change only; still ONLY NON-CORPORATE and no other substantial changes (minor edits) http://academicdepartments.musc.edu/research /orsp/orsp_coi http://academicdepartments.musc.edu/research /orsp/orsp_coi

32. NEW ORSP Web Page Resource: “How Do I …?” Section Added – Administrative FAQs – for PI’s and Administrators – Located under “Quick Links” main ORSP web page – Also located under “Policies and Procedures” – List will grow as new FAQs added & Morph as needed – So what do YOU want added ? Please let us know http://academicdepartments.musc.edu/research/o rsp/policies_procedures/how_do_i

33. Sub-award & Subcontracts – MUST make correct determination: Subrecipient or Vendor ? (HOW DO I ? FAQ coming soon) Not sure call ORSP for assistance MISTAKES here COULD BE COSTLY – Timely payment of invoices Approved invoices MUST be paid within 30 days Required by the Uniform Guidance - 2 CFR 200.305 (b) (3) Principal Investigators, departmental staff, etc. MUST work together to meet the 30 day payment deadline

34. Award Closeout – Grants Oversight and New Efficiency (GONE) Public Law No. 114-117 on January 28 th, 2016 Each agency must submit to Congress and HHS by December 31, a report listing EACH federal grant awarded. List MUST contain – Grants awarded by time period of expiration – Number with ZERO dollar balances – Number with undisbursed balances – List challenges leading to delays in closeout – 30 oldest, WHY each has not been closed out

35. “NOT AGAIN” Reminders ! – IMPORTANT we must ALL ADD VALUE; details, details, details – 3 Business Day Deadline (YES even corporate) – YOUR data entered on the ePDS (garbage in….) – Asking ORSP to make changes to the ePDS post routing can cause problems. PLEASE don’t put your Grants Administrator in “the middle” – INCORRECT unit numbers for UDAKs, STILL ? WOW ! ANY Announcements ?

36. Questions or Comments? PLEASE complete a survey & THANK YOU Next ORSP Information Session: April 20, 2016 @ 11:00 am, IOP Auditorium