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Post-Award Issues for the Pre-Award Administrator Panelists: Tim Leung Senior Research Accountant Stanford University Craig Johnson Compliance Analyst University of Washington Csilla M. Csaplár Contract & Grant Officer Stanford University
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Agenda Discussion of common issues (and solutions) that arise during proposal development and award stage that impact post-awardDiscussion of common issues (and solutions) that arise during proposal development and award stage that impact post-award Terms and conditions to avoidTerms and conditions to avoid Ways to be proactive!Ways to be proactive! Building the bridge between pre-award and post- award to facilitate effective project managementBuilding the bridge between pre-award and post- award to facilitate effective project management
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Budgets Identify Cost CategoriesIdentify Cost Categories –Unidentified costs –May require sponsor approval for rebudgeting –Bottom line: Not in the budget? Ask. Personnel Costs: Proposal vs. ExpendituresPersonnel Costs: Proposal vs. Expenditures Materials/Supplies vs. EquipmentMaterials/Supplies vs. Equipment Subawards vs. subcontractsSubawards vs. subcontracts Correct rates appliedCorrect rates applied
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Budgets, continued Budget projectionsBudget projections Impacts of poor planning:Impacts of poor planning: –Loss of direct cost funding available to the project –Loss of F&A/indirect cost recovery –Disallowances Open communication reduces potential for:Open communication reduces potential for: –Excessive, inappropriate, or late cost transfers –Manual adjustments –Disallowances –Revised invoices/financial reports –Audit findings –Loss of expanded authorities or letter of credit drawdown eligibility
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Awards Award classification – award type, award instrument, sponsor typeAward classification – award type, award instrument, sponsor type Single PI vs. Multiple PIsSingle PI vs. Multiple PIs –One shared account or separate accounts for each? –PIs from different departments/divisions –Access? Controls? Budget years vs. cumulative project periodBudget years vs. cumulative project period –Separate accounts? –Is carryforward automatic or is prior approval required?
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Award Notices Identify important information that post-award will needIdentify important information that post-award will need –Payment terms or schedule –Financial reporting requirements and timelines –PO or award number to be included on invoice –Restrictions –Milestones
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Award Set-up Interest earnedInterest earned –Return to sponsor? –Use toward the project? –For use at institution’s discretion? TrackingTracking ReportingReporting Interest IncomeInterest Income –Tracked separately from revenue –Recorded as income, not expense Cost sharingCost sharing
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Award Set-up, continued Period of Performance datesPeriod of Performance dates –Effective date vs. execution date –Funding authorizations Budget periodsBudget periods Incremental fundingIncremental funding Supplemental fundingSupplemental funding –Impacts allowability of expenditures RebudgetingRebudgeting –Institutional policy –Sponsor policy/prior approval requirements –Impacts ability to get reimbursed and project planning
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Billing/Invoicing InvoicingInvoicing –Format and documentation Standard or Sponsor-specific?Standard or Sponsor-specific? Back up documentation required (negotiate!)Back up documentation required (negotiate!) –Tied to award type - Cost reimbursement or fixed price –Frequency CR: in arrears monthly, quarterly, semi-annually, annually?CR: in arrears monthly, quarterly, semi-annually, annually? FP: up-front, per milestones reached, at completion?FP: up-front, per milestones reached, at completion? Combination: tied to progress or deliverables?Combination: tied to progress or deliverables?
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Payment Terms Upon execution/initiationUpon execution/initiation Fixed schedule of installmentsFixed schedule of installments Milestone paymentsMilestone payments Upon completion/terminationUpon completion/termination Withholding of percentage or amountWithholding of percentage or amount Net 30 standardNet 30 standard Non-standard can impact institution’s cash flowNon-standard can impact institution’s cash flow Advances/refundsAdvances/refunds
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Reporting Requirements TechnicalTechnical Progress/interimProgress/interim FinalFinal FinancialFinancial SF 269 and SF 270 for federal awardsSF 269 and SF 270 for federal awards Sponsor-specific forms for othersSponsor-specific forms for others Timeframe for submission – at least 60 days preferableTimeframe for submission – at least 60 days preferable Who is responsible – department? Central post-award?Who is responsible – department? Central post-award? Be timely!Be timely! Timely report submission impacts A/R, relationship between central offices with responsibility/oversight, and PI/institution’s reputation with sponsor Delinquent reports may cause sponsors to withhold funding on all awardsDelinquent reports may cause sponsors to withhold funding on all awards Your institution may be identified as “not responsible”; can impact future competitionsYour institution may be identified as “not responsible”; can impact future competitions
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Sponsor Approvals RebudgetingRebudgeting CarryforwardCarryforward Change of PI or level of effortChange of PI or level of effort Pre-award spendingPre-award spending Flowdowns – additional oversightFlowdowns – additional oversight
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Compliance Requirements Waivers (PI effort, indirect costs)Waivers (PI effort, indirect costs) Human/animals subjects approvalsHuman/animals subjects approvals Cost-sharingCost-sharing Conflict of InterestConflict of Interest Impacts level of risk to PI, department, and institutionImpacts level of risk to PI, department, and institution
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Sticky Award Terms PublicationPublication –Restrictions –Impacts: restriction on ability to disseminate research results Export controlsExport controls –Acceptance of controlled or proprietary technology, items covered by EAR/ITAR –Impact: loss of fundamental research exclusion Intellectual propertyIntellectual property –Disclosure internally and to sponsor –Ownership –Impacts: loss of ability to file provisional patents, legal battles over inventorship if proper disclosures not made Legal terms (indemnification, venue, governing law, etc.)Legal terms (indemnification, venue, governing law, etc.)
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Closeout Meet with PIs before the grant period is overMeet with PIs before the grant period is over Develop a processDevelop a process Use checklists to track items of special concernUse checklists to track items of special concern (i.e. cost-sharing, unliquidated encumbrances, (i.e. cost-sharing, unliquidated encumbrances, final invention statements, etc.) final invention statements, etc.) Contact your grant accounting team in advanceContact your grant accounting team in advance Avoid “first among equals” thinkingAvoid “first among equals” thinking
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Terms to Avoid Detailed financial reporting and back-up documentationDetailed financial reporting and back-up documentation Payments or reporting in non-U.S. dollarsPayments or reporting in non-U.S. dollars Reporting deadlines on end date of award (60 days after end date preferred)Reporting deadlines on end date of award (60 days after end date preferred) Final invoicing deadline less than 45 days after end dateFinal invoicing deadline less than 45 days after end date Monthly interim financial reportingMonthly interim financial reporting Return of all award funds if project is terminated earlyReturn of all award funds if project is terminated early Any restrictions on publicationAny restrictions on publication Others?Others?
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Be Proactive! TrainingTraining –PIs: Explain the process and your expectations, answer questions –Department administrators: Understand their role and the relationship with the PI, help facilitate the process with both –Encourage them to take advantage of training opportunities Acting on behalf of the InstitutionActing on behalf of the Institution –Explain the impacts of a poorly planned budget or a rushed proposal –Remind your team and your departments that you have their interests and those of the institution in mind Get to know your neighborhoodGet to know your neighborhood –Meet your customers! –Know who does what and who can help during a crisis Be patient – and be a resource!Be patient – and be a resource!
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Collaborative Solutions What Pre-award can do: Serve as the primary point of contact for the PI, department, and sponsorServe as the primary point of contact for the PI, department, and sponsor Learn about and anticipate the needs of your post-award counterpartsLearn about and anticipate the needs of your post-award counterparts Understand impacts of award terms and conditions so you can negotiate the best deal for all the playersUnderstand impacts of award terms and conditions so you can negotiate the best deal for all the players Educate your post-award counterpart on project specificsEducate your post-award counterpart on project specifics Communicate often, and keep people apprised of your expectationsCommunicate often, and keep people apprised of your expectations Recognize sponsor restrictions and special requirements, negotiate to standardize when it makes sense and is possibleRecognize sponsor restrictions and special requirements, negotiate to standardize when it makes sense and is possible Realize restrictions of institution’s systems, work to accommodate whenever possibleRealize restrictions of institution’s systems, work to accommodate whenever possible
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Collaborative Solutions What Post-award can do: Understand award terms and conditions, and how to adhere to themUnderstand award terms and conditions, and how to adhere to them Interact regularly, not just when there are fires to be put outInteract regularly, not just when there are fires to be put out Ask questions – communication is keyAsk questions – communication is key Be flexible! Not all sponsors and awards are created equal.Be flexible! Not all sponsors and awards are created equal.
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Questions? Tim Leung Senior Research Accountant, Stanford University tnleung@stanford.edu Craig Johnson Compliance Analyst, University of Washington erfalas@u.washington.edu Csilla M. Csaplár Contract & Grant Officer, Stanford University csaplar@stanford.edu With thanks to Marti Dunne, New York University, and Diane Barrett, University of Wisconsin.
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