1. Matty Gilreath Professional Services Consultant Evisions
Best Practices to Stay Ahead of the Game and in Compliance with Regulations, Policies, and Audits using the Research Suite
Matty Gilreath
Professional Services Consultant
Evisions
Stephanie Lezotte
Director, Office of Sponsored Programs
Rowan University

2. Welcome! Rowan University overview COSO internal audit
Rowan OSP best practices
Evisions suggests
Open Discussion/Q&A
Welcome!

3. Rowan University overview
A leading public institution founded in 1923, Rowan has grown in recent years

4. University of Evisions
Case Study
University of Evisions

6. Rowan by the Numbers today

7. Growing pains in 2013:
New Jersey legislature dismantled UMDNJ in 2013 and Rowan acquired the southern campus, a DO-granting School of Osteopathic Medicine
UMDNJ was wrapping up a 5-year Corporate Integrity Agreement (CIA) with the Federal government as a result of fraudulent billing

8. Growing pains in 2013:
During that time, UMDNJ/RUSOM was subject to higher compliance monitoring
This acquisition happened only one year after Rowan finished building its own MD-granting medical school!

9. What the state saw:

10. How University workers felt:

11. Rowan’s new centralized operations
Office of Research
VP, Director, Admin
Office of Sponsored Programs
Director, Pre-Award (2)
Contracts (1), Post-Award (2), Admin (1)
Office of Sponsored Programs - RUSOM
Director, Pre-Award (1.5), Post-Award (3), Admin (1)
Research Compliance
Director, Staff (3), Admin (.5)
Technology Commercialization
Director, Admin (1.5)
Proposal Development
Manager

12. Rowan and Cayuse Research Suite
Rowan was awarded a Robert Wood Johnson Foundation grant in to strengthen healthcare education in Southern New Jersey; small portion was budgeted for the Cayuse Research Suite (424, SP, Data Connect, HR Connect & Finance Connect for Banner)
Cayuse 424 and SP went live in Spring of 2015

13. internal COSO audit
In the Fall of 2015, Rowan tested two units to prepare for future audits: OSP and Financial Aid

14. Q: What is COSO?
A: Committee of Sponsored Organizations of the Treadway Commission. COSO is joint initiative of five private sector organizations that provides guidance on risk management, internal controls, and fraud deterrent.

15. Q: What is COSO?
COSO best practices are recommended by the Federal government, but are not required.

16. Rowan’s internal COSO audit
Internal auditors used COSO best practices to check for OSP internal controls in Fall 2015
Focus was on OSP’s ability to document adherence to internal controls, not just to have internal controls in place

17. Key internal controls audited
Pre-Award
Post-Award
Internal Approvals
Budget development
Subaward Coordination
Application assembly
Journal entries
Budget setup
Cost transfers
Award setup
Closeouts
Financial reporting
Drawdowns
Award modifications
Grant reconciliations
Indirect distribution
Database maintenance

18. Key internal controls audited
Compliance
Technology Transfer
Responsible Conduct of Research
Conflict of Interest
Export Controls
IRB
Effort Reporting
IACUC
Biosafety
Invention Disclosures
Patenting
Royalty Payments

19. 25 Process Narratives

20. COSO audit findings Pre-Award
Proposal Review - No evidence that a PS/CS performed a proposal review before Director approves Cayuse SP proposal
Budget Development - No evidence that a PS/CS reviewed the budget

21. COSO audit findings Pre-Award
Subaward Risk Assessment - Inadequate documentation
Internal Approvals - How can we be sure the internal approval chain is correct and untampered?

22. COSO audit findings Post-Award
Account Review - No evidence of OSP Director checking account information set up in financial system

23. Rowan OSP best practices
What they learned from the COSO audit changed their business processes

24. Rowan OSP Best Practices in Cayuse SP
Pre-Award Proposal Review
Proposal Review – PS/CS now writes a note (non-deletable!) in SP to document their review of the entry/budget

25. Rowan OSP Best Practices in Cayuse SP
Pre-Award Proposal Review
Proposal and Contract Specialists complete and upload to Cayuse SP entry an internal Proposal checklist before OSP Director review/approval

26. Rowan OSP Best Practices in Cayuse SP
Pre-Award Proposal Review

27. Rowan OSP Best Practices in Cayuse SP
Pre-Award Proposal Review
Uploaded to “Checklist” attachment type. Director reviews this document, then approves entry

28. Rowan OSP Best Practices in Cayuse SP
Pre-Award Budget Development
Budget development – We used to delete all attached budgets except the “most final.” Now, we leave the versions in SP to show changes.

29. Rowan OSP Best Practices in Cayuse SP
Pre-Award Subaward Risk Assessment
Uploaded Items include:
Created a proposal attachment type in SP: “Subaward Compliance”
Risk assessment checklist (internal)
Screenshot of SAM.gov clearance
A-133 audits and management plans
F&A Rate agreement
Subrecipient questionnaire
Annual FFATA letters and reports
Budget/LOIs/SOW

30. Rowan OSP Best Practices in Cayuse SP
Pre-Award
Subaward Risk Assessment items include:

31. Rowan OSP Best Practices in Cayuse SP
Pre-Award Internal Approvals
Internal Approvals – Q: How can we be sure the internal approval chain is correct and untampered?
Our response: Cayuse SP routing chain cannot be altered (as much as we’d like to some times!) once the entry has been routed, even if the Research Team is changed. The entry would have to be rejected first and the institutional hierarchy changed before re-routing.
There is almost no possibility to be sneaky with internal approvals without it being documented.

32. Rowan OSP Best Practices in Cayuse SP
OSP forwards the “Proposal Approved by OSP” to VP of Research with additional info (in red) so he can review for high-level campus and/or regulatory issues as part of internal approvals.

33. Rowan OSP Best Practices in Cayuse SP
Post-Award Account Review
Award Checklist - Proposal Specialist completes an internal Award Checklist and uploads it into the newly created SP award record (with updated award amount, as necessary)
Documentation Review - Proposal Specialists ensure the final, approved documents are uploaded and clearly marked in Cayuse SP for post-award staff
Handoff: Post-award goes into Cayuse for needed information. They match budget in Cayuse to NOA before creating a fund. (Eventually, Finance Connect for Banner can be used to feed basic SP award data into the financial system)

34. Rowan OSP Best Practices in Cayuse SP
Post-Award Account Review

35. Rowan OSP Best Practices in Cayuse SP
Based on these changes, Rowan’s internal audit staff said the Division of Research was the most prepared, helpful, and productive unit they worked with. Rowan’s federal auditors said Rowan’s effort to strengthen internal controls was “ahead of the rest of the state.”

36. What work remains?
Pre-Award Internal Approvals
More automated alerts to VP of Research to ensure no high-level campus/regulatory conflicts exist prior to submitting a proposal:
OSP Director currently forwards the automated Cayuse “Proposal Approved by OSP” after modifying it with additional information (amount requested, F&A Rate, Co-PIs and their departments). Abstract would be preferred.
This is a manual task that can be ignored, forgotten, or mistyped; risk: could result in competing priorities (research programs on campus).
We have requested these template tags from Evisions

37. What work remains?
Post-Award Subrecipient Monitoring
Review attachment types in the Award side of Cayuse SP to determine how to appropriately categorize and document ongoing subrecipient monitoring.

38. What work remains?
Post-Award Account Review
Complete the implementation of Finance Connect for Banner to map account setup into our financial system. This will eventually create a secondary check point in our account review process.

39. What work remains? Pre/Post Handoff
Pre-Award previously sent post-award the Award Coversheet PDF as account setup documentation. This listed the pertinent account setup info:
F&A Rate
Budget Period
Responsible ORG
Latest SP version update removed this PDF. We have sent our feedback to the Support team and now send s with this information compiled.

40. Evisions suggests
As Professional Service Consultants, we have some best practice ideas to add

41. Evisions suggests
Get those project docs into SP!
Before Rowan got SP, they had separate Access databases acting as primary records, which made auditing difficult.
One of the key benefits of SP is that it helps you organize your sponsored projects world. So it should be used to store all relevant project documents, for ease of reference/retrieval.

42. Evisions suggests
Thinking ahead with SP
Compliance issues are high on our clients’ agenda right from the start, during implementation.
But even if you’re a longtime SP client, it’s never too late to update your SP environment to keep in step with changing processes, regulations, and policies!

43. Evisions suggests
Helpful configurations in SP
I strongly suggest reviewing your Attachment Type dropdown menu choices in these SP areas:
Proposals
Projects
Awards
Subcontracts
And also decide where to upload your docs? Which level?

44. Evisions suggests
Helpful configurations in SP
Some of our clients (like Rowan) are using the term of “Subaward Compliance”, to capture a variety of possible docs.
Other clients are choosing to be very specific, naming certain documents like “Subrecipient A-133 compliance letters”

45. Why?
To offer your users a better attachment type than just “Other”, so you aren’t scrambling to find certain docs, especially during an audit.

46. Evisions suggests
Proposal attachment types

47. Evisions suggests
Project attachment types

48. Evisions suggests
Award attachment types

49. Evisions suggests
Subcontract attachment types

50. Evisions suggests
At the project level, you can look down into all attachments from the various sections, and mark docs as “Final”, as needed.

51. Questions & Answers Q
& A
We want to hear from you!

52. Thank You!
Please contact the Evisions marketing team if you have any questions.