1. Controller’s Office Research Administration Town Hall Wednesday, October 29, 2014 10:00-12:00 PM HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium at Mission Bay & Room 116 at the Fresno Campus & Live Webcast Contracts and Grants Accounting

2. Controller’s Office  Introduction of New AVC, Research Administration – Marge O’Halloran  Coverage Analysis – Eileen Kahaner and Jacquie Eichhorn  NOT-OD Updates – Joyce Abe  Uniform Guidance Update – Nilo Mia  Final Invoice Preparation – Dan Wikert  Clinical Trial Post Award Topics – Michael Grafton  Post Award Hot Topics – Michael Grafton and Jean DeMartini  Compliance Update – MC Gaisbauer  CGA Survey and Contact Process – MC Gaisbauer 2 Agenda

3. Controller’s Office Introduction of new AVC, Research Administration 3

4. 4 Update: Clinical Trial Coverage Analysis UCSF Clinical Enterprise Compliance Program (CECP)

5. Controller’s Office Agenda  Introductions  What is a Coverage Analysis (CA) and why is it important  Who performs CAs at UCSF  Your role 5

6. Controller’s Office UCSF Clinical Enterprise Compliance Program  Mission  Promote a culture of compliance with applicable laws, rules, regulations  Provide oversight, guidance, and tools to detect, deter, and resolve non-compliant behavior  Establish an environment that empowers and expects individuals to address conduct that does not conform to the applicable standards  Support UCSF Mission by reducing organizational risk  Scope  Clinical activities, including clinical research billing  Tools  Training, address questions, review policies/SOPs  Perform reviews  Oversee corrective actions 6

7. Controller’s Office Process 7

8. Controller’s Office What is a Coverage Analysis?  Focused review of all clinical trial-related documents to determine who is financially responsible for all items and services provided to the research subjects over the course of the study  Process aligns the Protocol, Clinical Trial Agreement, Informed Consent (ICF), Budget  Creates a reference that all subsequent billing and invoicing decisions should use  Study team, post-award, patient billing  ICF costs section  UCSF CA mandate as of June 1, 2013 8

9. Controller’s Office Some Principles of CA Development  Coverage analysis is based on billing rules  Medicare rules typically applied  More well defined  Most commercial payors follow, even for pediatrics  Charging for an item does not necessarily mean that item is reimbursable  FDA approval does not guarantee reimbursement 9

10. Controller’s Office Why is the CA Important?  Respond to government attention re CRB  Industry trials and federal grants  More accurate assessment of trial costs  Improves budgeting  UCSF cost recovery per OP mandate  Allows accurate ICF for expected costs  Accurate billing to sponsor and payors  Single reference for study teams, post-award, billers  Maintain sponsor and participant trust  Reduces need for “back-end” corrections  Demonstrates due diligence to bill accurately reducing fines or penalties if mistakes are made 10

11. Controller’s Office Multiple Groups Perform CAs CA owner depends on type of trial http://hub.ucsf.edu/ca-budget-billing http://hub.ucsf.edu/ca-budget-billing  CTBSC: clinicaltrials@ucsf.educlinicaltrials@ucsf.edu  Cancer Center: ITRFinance@ucsf.eduITRFinance@ucsf.edu  Division of Cardiology: carol.maguire@ucsf.educarol.maguire@ucsf.edu Budgeting also performed by multiple parties  Non-industry Sponsored Clinical Trial - RMS  Industry Sponsored Clinical Trial - ITA  Cancer Center - ITR  Division of Cardiology - Cardiology 11

12. Controller’s Office Your Role  Encourage study team to seek CA early in process – run in parallel with other activities  Do not finalize CTA without a formal CA  Alert CECP to potential issues that cannot be resolved through standard processes 12

13. Controller’s Office Questions?  Jacquie Eichhorn, Manager Clinical Research Billing Compliance  Jacquie.Eichhorn@ucsf.edu Jacquie.Eichhorn@ucsf.edu  415-514-2576  Eileen Kahaner, Director, CECP  Eileen.kahaner@ucsf.edu Eileen.kahaner@ucsf.edu  415-476-8642  CECP – 415-502-2790 13

14. Controller’s Office NOT-OD Updates 14

15. Controller’s Office Notable NIH Updates  NOT-OD-15-014  NOT-OD-13-097  NOT-OD-14-113  NOT-OD-14-090  NOT-OD-14-094  NOT-OD-14-095 15

16. Controller’s Office Reminder: NOT-OD-15-014  http://grants.nih.gov/grants/guide/notice-files/NOT-OD-15- 014.html http://grants.nih.gov/grants/guide/notice-files/NOT-OD-15- 014.html  Guidance about  NIH Type 5 Progress Reports (annual progress reports) Implements  Effective October 17, 2014 NIH requires that all type 5 progress reports be submitted using the Research Performance Progress Report (RPPR) module in eRA Commons 16

17. Controller’s Office Reminder: NOT-OD-13-097  http://grants.nih.gov/grants/guide/notice-files/NOT-OD-13- 097.html http://grants.nih.gov/grants/guide/notice-files/NOT-OD-13- 097.html  Guidance about  Graduate students/undergraduate students roles participating on NIH-funded projects for one person month or more Implements  Effective October 2014 NIH requires eRA Commons IDs for all graduate and undergraduate student roles reported on annual progress reports (RPPRs) 17

18. Controller’s Office Reminder: NOT-OD-14-113  http://grants.nih.gov/grants/guide/notice-files/NOT-OD-14- 113.html http://grants.nih.gov/grants/guide/notice-files/NOT-OD-14- 113.html  Guidance about  Individual Development Plans (IDP) for graduate students and postdoctoral researchers supported by NIH awards Implements  Effective October 1, 2014 Research Performance Progress Report (RPPR) are required to include a report on the Use of IDPs in Section B, Question B.4. 18

19. Controller’s Office REMINDER: NOT-OD-14-113, continued  The Graduate Division has posted information on IDPs and template language for RPPRs on their website:  You can get the information on IDPs at: https://career.ucsf.edu/grad-students- postdocs/myIDP https://career.ucsf.edu/grad-students- postdocs/myIDP  Template language for RPPRs is located at: https://career.ucsf.edu/sites/career.ucsf.edu /files/PDF/Reporting%20Use%20of%20the% 20IDP.pdfhttps://career.ucsf.edu/sites/career.ucsf.edu /files/PDF/Reporting%20Use%20of%20the% 20IDP.pdf 19

20. Controller’s Office NOT-OD-14-090 and NOT-OD-14-133  http://grants.nih.gov/grants/guide/notice-files/NOT-OD-14- 090.html http://grants.nih.gov/grants/guide/notice-files/NOT-OD-14- 090.html  Guidance about  Update to PA-14-150 (F30) NRSA Individual Predoctoral Dual-Doctoral Degree Fellowship Implements  Requirement to upload “Additional Educational Information” under Other Attachments in the Other Project Information section of the application  Applications submitted without this attachment will be considered incomplete and rejected 20

21. Controller’s Office NOT-OD-14-094 and NOT-OD-14-134  http://grants.nih.gov/grants/guide/notice-files/NOT-OD-14- 094.html http://grants.nih.gov/grants/guide/notice-files/NOT-OD-14- 094.html  Guidance about  Update to PA-14-147 (F31) NRSA Individual Predoctoral Fellowship Implements  Requirement to upload “Additional Educational Information” under Other Attachments in the Other Project Information section of the application  Applications submitted without this attachment will be considered incomplete and rejected 21

22. Controller’s Office NOT-OD-14-095 and NOT-OD-14-135  http://grants.nih.gov/grants/guide/notice-files/NOT-OD-14- 095.html http://grants.nih.gov/grants/guide/notice-files/NOT-OD-14- 095.html  Guidance about  Update to PA-14-148 (F31-Diversity) NRSA Individual Predoctoral Fellowship to Promote Diversity in Health- Related Research Implements  Requirement to upload “Additional Educational Information” under Other Attachments in the Other Project Information section of the application  Applications submitted without this attachment will be considered incomplete and rejected 22

23. Controller’s Office OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

24. Controller’s Office Background – When, Why, Who?  Fall 2009, Executive Order 13520 on reducing improper payments and eliminating waste in Federal programs and Presidential memorandum on promoting administrative flexibility  Set in motion the single biggest regulatory change in the last 50 years of research administration  In the documents, President directed OMB to work with Executive Branch agencies and other key stakeholders to evaluate potential reforms to Federal grants policies  The Council on Financial Assistance Reform (COFAR) was established in October 2011 and has led efforts to improve delivery, management, coordination, and accountability of Federal grants and cooperative agreements, which includes the development of the uniform guidance 24

25. Controller’s Office Background – What Did COFAR Do ?  OMB Advance Notice – Spring of 2012  Proposed guidance issued February 1, 2013  Final guidance issued December 26, 2013  Federal agencies had 6 months (to June 26, 2014) to submit THEIR draft(s) of “implementing regulations” to OMB 25

26. Controller’s Office Overview of UCSF Review and Campus Coordination Process  Meet every two/three weeks to review guidance and make initial assessment  Form UCSF position and stay connected with UCOP to share concerns and stay abreast of UCOP review process  Coordinate UCSF concerns with Council on Government Relations (COGR)  Establish and maintain communication plan with campus stakeholders  Vet concerns of Grant Reform Task Force with campus administrators and academic community  With stakeholders, establish campus priorities and develop implementation plans  Execute, track, and communicate status of implementation processes 26

27. Controller’s Office Parts of UG & Who Is Reviewing It 27 Final Rule Section TitleChampionDepartment  Subpart A – Acronyms and DefinitionsAllAll  Subpart B – General Provisions NMBudget & Resource Mgmt.  Subpart C – Pre-Federal Award RequirementsJR& MOOffice of Sponsored Research  Subpart D – Post Federal Award Requirements MCController’s Office  Subpart E – Cost Principles NMBudget & Resource Mgmt.  Subpart F – Audit RequirementsMC/TPController’s Office/Audit  Appendices  Notice of Funding OpportunityAllAll  Contract Provisions ResearchJR& MOOffice of Sponsored  F&A Costs…for Institutions of Higher EducationNMBudget & Resource Mgmt.  F&A Costs…for Nonprofit OrganizationsN/A  State/Local Gov’t and Indian Tribe Service AllocationN/A  Public Assistance Cost Allocation PlansN/A  States and Local Gov’t and Indian Tribe IDCN/A  Nonprofit Orgs Exempted from Subpart EN/A  Hospital Cost PrinciplesN/A  Data Collection Form (Form SF-SAC)MCController’s Office  Compliance SupplementMCController’s Office

28. Controller’s Office Review Timeline 28

29. Controller’s Office UC Approach to Uniform Guidance, Phase One (6 months)  Identify major issues and areas where systemwide guidance or policy will need to be updated  Determine key issues/approaches to inform and engage local campus constituencies  Issue systemwide guidance, where appropriate, and/or begin work to update policies, as needed 29

30. Controller’s Office Uniform Guidance Applicability Applicability and Dates (200.110)  Uniform implementation date of 12/26/14 for all Subparts, except Subpart F  Subpart F, Audit Requirements, will be effective the first FY beginning after 12/26/14; for UCSF, this will be FY 2016 (July 1, 2015 – June 30, 2016)  The UG will be applicable to all NEW AWARDS and extensions / additions to EXISTING AWARDS with award dates on or after 12/26/14 30

31. Controller’s Office Uniform Guidance Applicability  Question: Will the Uniform Guidance changes apply ONLY to awards made after the effective date (December 26, 2014), or do the changes apply to awards made earlier?  Answer: Once the Uniform Guidance goes into effect, it will APPLY TO AWARDS or FUNDING INCREMENTS AFTER THAT DATE (December 26, 2014); it will NOT retroactively change the terms and the conditions for funds (awards) already received  Note: Existing federal awards will continue to be governed by the terms and conditions of that Federal award 31

32. Controller’s Office Some Top Highlights and Key Issues  200.112 Conflict of Interest  200.301 Performance Management  Researchers must relate Financial Data to Performance Accomplishments of the federal award  Researchers MUST provide COST INFORMATION to demonstrate COST EFFECTIVE PRACTICES (e.g. – unit cost data); objective is to improve program outcomes, share lessons learned, and spread adoption of best practices  Higher reporting bar overall for Federal contracts  Stronger certification language reminds signers of statutory penalties for false certifications  NOTE: Alert your PI’s now of these requirements…  200.303 Internal Controls  Strong emphasis on IA as well as understanding “must” versus “should”  Requires recipients to have strong internal controls; should be in compliance with…  Internal Control Integrated Framework (COSO)  The Federal “Green Book” – Protecting Personally Identifiable Information  Federal statutes, regulations and conditions (Comptroller General of the U.S.) 32

33. Controller’s Office Some Top Highlights and Key Issues  200.306 Cost Sharing  Voluntary committed cost-sharing is not expected in Federal research proposals  Cost-sharing obligations must be included in FOA’s (Funding Opportunity Announcements)  Cost-sharing may not be used as a factor in the merit review of applications or proposals  200.307 Program Income  200-313 Equipment  “Conditional Title” is new; not a new concept, but designed to clarify, among other things, Federal equipment should move with the PI if they transfer between Universities; also clarifies that conditional title is calculated using project costs including mandatory cost sharing  “Percentage of Federal participation in the project costs” (A-110 required the “percentage of Federal participation in the cost of the equipment”) and “use and condition” (“use” is not included in A-110) are new; preliminary assessment is that the subtle changes in terminology will NOT require systems changes to the institution’s equipment inventory system 33

34. Controller’s Office Some Top Highlights and Key Issues  200.317-326 Procurement Standards  Effective July 1, 2016 (or FY17), but work ahead  One year grace period before implementation  200.330 Sub-recipient and Contractor Determinations  New option for each Federal agency to require us to document how we decided each transaction is either a Subrecipient versus a Contractor  Characteristics of a Subrecipient / Contractor have not changed  In new agreements with Subrecipients, be certain to reference the terms and conditions found in the new “Uniform Guidance”, effective December 26, 2014  If you want reports from your “subrecipient”, you must include that requirement in your sub-award documentation  The provisions of the prime sponsor usually flow through to the “sub-awardee”; additional provisions may be added by the awardee 34

35. Controller’s Office Some Top Highlights and Key Issues  200.331 Requirements for Pass-through Entities  Subrecipients must be monitored to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward  The Uniform Guidance provides recommendations, but does not specify how the pass-through entity should conduct that monitoring  Any monitoring would need to comply with the overall need for sufficient internal controls to meet the requirements in this section  Pass-through entities must honor subrecipient negotiated F&A rate or use 10% de minimis rate, or negotiate one with the subrecipient 35

36. Controller’s Office Some Top Highlights and Key Issues  200.332 Fixed Amount Subawards  The uniform guidance allows for the use of fixed amount (fixed- price) subawards but: – Only with the prior approval of the Federal awarding agency – Only up to the Simplified Acquisition Threshold ($150,000)  Prior approval may be inferred if the intent is included in a proposal submission and awarded  The $150,000 cap may be problematic for some projects  200.343 Closeouts  Campuses must complete final reporting, invoicing, and cash draws within 90 days of the end of the performance period or risk not being able to recover funds expended  Although this requirement is not new, the Uniform Guidance codifies it and imposes a hard stop to adjustments  This could prove challenging in the management of subawards 36

37. Controller’s Office Some Top Highlights and Key Issues  200.413 Direct Costs – Clerical & Administrative  The Uniform Guidance allows for the direct charging of administrative and clerical salaries, so long as certain conditions are met:  Administrative or clerical services are integral to a project or activity  Individuals involved can be specifically identified with the project or activity  Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency  The costs are not also recovered as indirect costs  A justification should be included in proposals that addresses the criteria above to facilitate the required agency approval for these charges  Any post-award addition of administrative salaries to a budget would require prior written approval of the funding agency 37

38. Controller’s Office Some Top Highlights and Key Issues  200.414 Indirect Costs  4-year extension, 1.3% UCA  200.419 Cost Accounting Standards and DS-2  11th hour push and cautious optimism  200.430 Compensation – personal services  Opportunities and challenges  200.456 Participant Support Costs  Now a federal-wide concept  Are defined as direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training projects  Participant support costs will be an exclusion in the MTDC base 38

39. Controller’s Office Some Top Highlights And Key Issues  200.461 Publication and Printing Costs  The Uniform Guidance provides institutions additional flexibility to charge Federal awards after the performance period for page charges in professional journals  This may require a system/procedure change to allow costs to post to an award after the performance period  Late charges can create issues for meeting 90 day closeout requirement for Federal awards 39

40. Controller’s Office What’s next?  Phase One (Jan – Dec 2014)  Assess & analyze the Uniform Guidance  Inform the campus and discuss approaches  Issue interim guidance, as needed  Issue Assessment document  Phase Two (Jan – June 2015)  Update guidance & policies as needed  Update DS2s (?)  Update training & support, as needed  Phase Three (Jul – ~Dec 2015)  Update support systems, as needed  Other long-horizon actions needed 40

41. Controller’s Office Thoughts on Implementation Planning 41

42. Controller’s Office Primary UCSF Grant Reform Task Force Contacts  Nilo Mia - Budget and Resource Management Office  MC Gaisbauer - Controller’s Office  Marge O’Halloran - Research Management Services, Office of Sponsored Research  John Radkowski - Government and Business Contracts, Office of Sponsored Research 42

43. Controller’s Office Key Websites  Uniform Guidance, Title II CFR Part 200 www.ecfr.gov  Federal Register Notice with Preamble https://federalregister.gov/a/2013-30465  Council on Financial Assistance Reform www.cfo.gov/cofar  Questions and Concerns about the UG cofar@omb.eop.gov 43

44. Controller’s Office OMB Circulars Consolidated Into UG  A–21, ''Cost Principles for Educational Institutions'' (2 CFR Part 220)  A–87, ''Cost Principles for State, Local and Indian Tribal Governments'' (2 CFR Part 225) and also Federal Register notice 51 FR 552 (January 6, 1986)  A–89, ''Federal Domestic Assistance Program Information''  A–102, ''Grant Awards and Cooperative Agreements with State and Local Governments''  A–110, ''Uniform Administrative Requirements for Awards and Other Agreements with Institutions of Higher Education, Hospitals, and Other Nonprofit Organizations'' (codified at 2CFR 215)  A–122, ''Cost Principles for Non-Profit Organizations'' (2 CFR Part 230)  A–133, ''Audits of States, Local Governments and Non-Profit Organizations,''  Those sections of A–50 related to audits performed under Subpart F— Audit Requirements of this Part 44

45. Controller’s Office Final Invoice Preparation 45

46. Controller’s Office CGA Billing Team Responsibilities  Contract & Grants Accounting (CGA) is responsible for billing and payment processes for sponsored projects  Key billing functions:  Prepare timely and accurate invoices in accordance with award documents, University and sponsor policy  Submit invoices to sponsors  Exception: Clinical trials invoicing initiated by departments (copy CGA)  Cost Reimbursable - CGA generates invoices based on actual expenses incurred and posted to the General Ledger up to the authorized spending limit (appropriation)  Exception: approved PETs, submitted / approved journals for a final invoice or a late award set-up 46

47. Controller’s Office Departmental Administrator’s Role in the Final Billing Process  Review and ensure that all appropriate project expenses are reflected in the General Ledger prior to termination date  Submit any pending cost transfer requests so that they can be received and processed prior to the award end date or activity period end date  Review any open requisitions, purchase orders and contact Accounts Payables attempting to close immediately  For subcontracts, including those with other University of California campuses (intercampus), ensure final invoices have been submitted and paid  Determine if a carryover justification is required to move the unexpended balance from one activity period to the next  Determine if a no-cost extension (NCE) is required for the award and submit a request for an extension prior to award or activity period end date 47

48. Controller’s Office Final Invoices Continued…  If UCSF is the subcontractor and another institution is prime, ensure all services provided have been paid in full  If this is the final year, contact all recharge departments to terminate or change chartstring for any toll charges, phone lines and other UCSF Services such as animal care, storage etc  Review and remove unallowable costs per the office of Management and Budget (OMB) Circular A-21 and UCSF charging practices  For additional requirements, refer to the contract/agreement terms and conditions as well as University policies to fully comply with regulation and sponsor requirements for closing out an award 48

49. Controller’s Office Final Invoices Continued…  After the final invoice filed, clear overdraft or deficit within 90 days of the activity period or award end date  Overdraft  Represents the amount that spending exceeds the award budget  Deficit  Represents the amount the total expense exceeds total revenue 49

50. Controller’s Office Clinical Trial Post Award Topics 50

51. Controller’s Office Set Up of Clinical Trials  Private Industry Clinical Trials  Fund number 4400 is used  Award purpose on award profile page is CLIN  Award must be registered in www.clinicaltrials.gov by UCSFwww.clinicaltrials.gov  Facilities and administration (F&A) is assessed on gross receipts, not only an expenditure basis  Base code is M  The assessment is based upon a “substitution” equation 1 – 1/(1+Rate)  The substitution rate is rounded to one decimal point  The rate for clinical trials is negotiated at 33.0% of total direct costs; the “substitution” rate is 24.8% of gross receipts. 51

52. Controller’s Office Set Up of Clinical Trials, continued  Private Industry Clinical Trials  The rate for off-campus clinical trials is negotiated at 26.0% of total direct costs; the “substitution” rate is 20.6% of gross receipts  Department is responsible for sending the invoice to the sponsor; the department must also send a copy of all invoices to the Contracts and Grants Accounting unit, so that the invoice can be tracked for payment in the RAS accounts receivable module  The appropriation is done at the time of invoicing or time of sponsor payment, whichever comes first 52

53. Controller’s Office Set Up of Clinical Trials, continued  Flow-Through Clinical Trials  Fund number 4301 is used  Award purpose on award profile page is CLINO  Award must be registered in www.clinicaltrials.gov by the sponsorwww.clinicaltrials.gov  Facilities and administration (F&A) is assessed on expenditures, not gross receipts  Base code is either C for total direct costs or A for modified total direct costs  The rate for clinical trials is negotiated at 34.0% of total direct costs or modified total direct costs 53

54. Controller’s Office Set Up of Clinical Trials, continued  Flow-Through Clinical Trials  The rate for off-campus clinical trials is negotiated at 26.0% of total direct costs or modified total direct costs  Department is responsible for providing information to the Contracts and Grants Accounting unit, so that it can create an invoice that will be tracked for payment in the RAS accounts receivable module  The appropriation is done at the time of the award activation and subsequent award modifications 54

55. Controller’s Office Set Up of Clinical Trials, continued  Pending Matters  The definition of clinical trial is going through a review, to treat all agreements registered in www.clinicaltrials.gov consistently www.clinicaltrials.gov  We are reviewing whether an intercampus clinical trial falls under CLIN and assigned to fund 4400, or CLINO and assigned to fund 4301  Treatment of pre-clinical administrative costs has not been finalized by the campus Costing Policy Group. This oncludes both start-ups costs for a specific clinical trail, and set-up costs prior to proposal for a specific study, such as CHR protocol. 55

56. Controller’s Office Set Up of Clinical Trials, continued 56

57. Controller’s Office Post Award Hot Topics 57

58. Controller’s Office Post Award Topics  Advances  GAEL  RSA updates  STIP  Record Retention  SAM Registration  T32 Management  Surplus Transfers 58

59. Controller’s Office Advances  Why do we need an advance?  Funding for a subsequent year can be delayed for a number of reasons; an advance allows the Department to spend on the award while the negotiation process is being concluded  What is the benefit of getting an advance?  Ensures that costs can be placed on the correct award/project in the General Ledger  Ensures that cost transfers are minimalized and that late cost transfers are avoided  Documents financial responsibility should the contract not be awarded  Ensures that compliance concerns are addressed prior to the initiation/continuation of work on the project 59

60. Controller’s Office Advance, continued  What is the process to request an advance?  Please consult with your Research Management Services (RMS) contact early to ensure that the fund advance is completed and sent to CGA in a timely manner  The Award Advance Request Form and Award Activity Period Advance Request can be found on the Office of Sponsored Research website http://osr.ucsf.edu/forms http://osr.ucsf.edu/forms 60

61. Controller’s Office GAEL  GAEL refers to the General, Automobile, and Employee Liability (GAEL) assessment  The GAEL assessment is tied to the distribution of payroll expense ledgers for all regular salary lines (HRG, HST), but is NOT an employee benefit  The GAEL assessment posts monthly at the time that the distribution of payroll expense subsidiary ledger is migrated to the general ledger  In the new chart of accounts, the account number is 57400  In the prior chart of accounts, the expenditure NCA code is 437970  The GAEL assessment is exempt from federal or federal flow through funds with a 100% federal share  On sponsored project awards, the GAEL assessment is subject to the facilities and administration (F&A) base and rate of the project that posts the payroll 61

62. Controller’s Office GAEL  If an award is coded as a federal flow through with a 100% share from the federal government, the award will be coded as federal flow through code 3 in the Award Details link  Steps to Exempt GAEL from 100% Federal Flow Through  Secure proof that the award is 100% federal; there might be an overlooked section of the award with a pertinent clause, or perhaps a sponsor e-mail will attest to the 100% flow through status  Once proof of 100% federal funding is available, send a request to the Contracts and Grants Accounting service desk to have the award updated and the general ledger reflect the reversal of GAEL entries to date CGAsvcdesk@ucsf.eduCGAsvcdesk@ucsf.edu  The federal flow through code on the Award Details link will be updated 3, and the prime sponsor agency will be added; any award that is updated to 3 where the prime sponsor is an agency of the Public Health Service will be subject to the federal salary cap  Contracts and Grants Accounting will reverse the cumulative GAEL assessment on the award with a 535 financial journal 62

63. Controller’s Office GAEL SAMPLE PROOF OF 100% FEDERAL FUND FLOW From: Hax, John R@DOR [John.R.Hax@dor.ca.gov] Sent: Tuesday, September 30, 2014 12:10 PM To: Cc: Subject: RE: Contract #28838 (CFDA #84. 126A) Award A121902 Hi : 100% of the funds you receive as payment on your 801B service invoices are ‘federal’ funds. Once your match is received and the federal draw down funds are received from the federal Rehabilitation Services Administration, all funds are to be identified as ‘federal’ funds. Hope this helps. John R. Hax, Program Specialist Collaborative Services Section CA Department of Rehabilitation (916) 558-5438 CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication. 63

64. Controller’s Office GAEL 64

65. Controller’s Office GAEL 65

66. Controller’s Office GAEL  If an award is a non-federal or non-federal flow through, and the sponsor disallows the GAEL assessment, the department will be required to cover the assessment  In the case of non-federal GAEL disallowances, the GAEL will not be reversed  Departments will be required to transfer the cumulative GAEL accrued on account 57400, at the project level, from the sponsored award to a discretionary fund, using a 535 financial journal 66

67. Controller’s Office STIP  The University defines STIP as a general resource available to the department head to invest in strategic plans as he/she best determines. Therefore, the intradepartmental allocation of STIP is not considered necessary, except where an external sponsor requires the allocation of STIP to the award  If the department head determines an intradepartmental allocation of STIP is necessary to meet the department's strategic objectives, the intradepartmental allocation may not cross fund families 67

68. Controller’s Office STIP, continued  When the sponsor mandates that STIP be allocated to the award, the Department is responsible for transferring all reportable STIP onto the award throughout its life  Department must request budget entry through CGASvcDesk@ucsf.edu CGASvcDesk@ucsf.edu  CGA will monitor for compliance with the award terms during the generation of the FSR and at the time of closeout  Information on this policy:  Job Aid – to come  Contact - Denis Nepveu, Director - Resource Planning Denis.Nepveu@ucsf.edu Denis.Nepveu@ucsf.edu 68

69. Controller’s Office Record Retention  A records retention schedule defines the period of time that records should be retained and when they should be destroyed  Various requirements based in law and university policy govern the retention of administrative records  A retention schedule is critical for promoting responsible records management, mitigating risk, and ensuring consistent compliance across UC  Record retention resources are as follows:  Records Retention and Management Policy 050-19 located at http://policies.ucsf.edu/policy/050-19 http://policies.ucsf.edu/policy/050-19  UC Records Retention Schedule located at: http://recordsretention.ucop.edu/ http://recordsretention.ucop.edu/  Campus Records Management Coordinator: Brenda Gee DePeralta 69

70. Controller’s Office System for Award Management (SAM)  SAM, launched in 2012, integrated 8 federal procurement systems (including the old CCR) into a single streamlined system  Provides federal government with details of management, performance, representations, certifications, etc.  Registration is updated annually (next due date 3/5/15)  Awards/subcontracts may request UCSF to provide SAM status or expiration date https://www.sam.gov/portal/SAM/#1 70

71. Controller’s Office System for Award Management (SAM) 71

72. Controller’s Office T32 Management  Appointments  Appointment forms must be submitted through xTrain before the start of the trainee’s appointment or reappointment  Must correlate to the trainees identified and stipend charged to the general ledger  Stipend levels detailed at: http://grants.nih.gov/training/nrsa.htm http://grants.nih.gov/training/nrsa.htm  Generally appointments are for a full-time, 12 month period  Termination Notices  PD/PI is responsible for submitting, via xTrain, within 30 days of the end of period of support  xTrain – Business Officer is Freddie Robinson 72

73. Controller’s Office Surplus Transfers  A surplus may result at the expiration of a fixed priced award/activity period  Sponsor agreements may require that surplus amounts be returned to the sponsor, or may be retained by the University  Surplus transfers, within the University, should be recorded on a 78% account number  The amount transferred should consider the IDC impact  Any questions should be directed to the CGA Award Closeout Team 73

74. Controller’s Office Compliance Update 74

75. Controller’s Office Compliance Update  Transition  Initiated search for Compliance Manager  Rick Blair will serve as interim Compliance Manager  Key Initiatives  Effort Reporting – period closes 10/31/14  T32 Policy Change  Audit Status Updates 75

76. Controller’s Office Effort Reporting Considerations  Roles  ERC role is to facilitate process, organize and communicate with PI  PI role is to review and certify  Function – PI is certifying based on first hand knowledge of effort  If a PI has already certified an entire report for another faculty member, there are two possible solutions  If the effort certification is correct, the faculty member should add a comment to their effort report stating concurrence with the certified percentages; comments may be added after certification by using the Comments tab  If incorrect, the report should be recertified 76

77. Controller’s Office T32 Award Policy Change  The NIH Grants Policy Statement changed the allowability of Training Related Expenses in 2014 – for this to be applicable at UCSF, we must adopt a new charging policy and update our payroll system http://grants.nih.gov/grants/policy/nihgps_2013/nihgps_ch11.htm#_Toc271265131 http://grants.nih.gov/grants/policy/nihgps_2013/nihgps_ch11.htm#_Toc271265131 11.3.8.4 Training-Related Expenses  Our goal is to have the new campus policy in place and the payroll system modified by the end of the year - the final implementation date will be announced in an upcoming newsletter  The new campus policy will allow for the charging of  Health benefits (medical, dental and vision) ▪ Tuition and fee  Leave rights ▪ Travel  Malpractice insurance - if the research training experience involves direct contact with patients or human subjects  The following items will continue not to be chargeable to grant:  Disability insurance ▪ Life insurance  Union dues ▪ Unemployment insurance  Workers’ Compensation ▪ FICA  GAEL (General, Auto, and Employment Liability) 77

78. Controller’s Office Audit Status Updates  Audit status  Annual Financial Statement Audit  A-133 Audit  Compliance Reviews – Administrative Expenses  Thank you for your assistance during the audit process and your diligence during the year 78

79. Controller’s Office QUESTIONS? 79

80. Controller’s Office We Are Here To Serve You  Research Management Services (RMS) for federal grants, fellowships, cooperative agreements and all non-profit sponsors http://osr.ucsf.edu/find-my-osr-staff  Government and Business Contracts (GBC) for federal contracts and all state, city, county, and foreign government/organization sponsors http://osr.ucsf.edu/content/gbc-contact-information  Industry Contracts Division (ICD) for all industry sponsors (industry is the prime sponsor) http://ita.ucsf.edu/about/staff  CGA Service Desk for post-award issues CGASvcDesk@ucsf.edu Also a CGA service quality survey at https://ucsf.co1.qualtrics.com/SE/?SID=SV_cuSKJUDE6sZTnjT 80