1. Highlights of Post Award Sponsored Project Administration July 11, 2007 Office of Research Training & Compliance

2. Topics Covered  Effort Reporting  Cost Transfers  Subawards  Independent Contractors  Subrecipient Monitoring

3. What is Effort?  Total professional effort is the amount of time spent on ALL activities including both University (instruction, departmentally-funded tasks, funded research) and non- University (i.e., clinical services).  Effort is not based on a 40 hour work week but rather a percentage of effort and must equal 100%.  Effort distributions should be reasonable estimates of activities. Effort includes both direct charged and cost shared effort.

4. Effort Reporting (A-21 requirement)  GW policy requires that the Effort Certification Report be signed by the employee, PI or responsible official using suitable means of verification that the work was performed. Complete semi-annually: Jan-June and July-December.  Effort Certification is not how payroll expense is distributed.  Change in Status (CIS) forms are required to be processed when there is a substantial change in the employee’s effort.  Review monthly labor distribution reports to ensure compliance.

5. What are Cost Transfers? Cost transfers are after-the-fact re-allocations of costs, either labor or non-labor to a sponsored project. Personnel Costs/Non-personnel - CIS/DCF forms that correct a variety of data entry, admin and acct coding errors -CIS/DCF forms that transfer costs between continuations of projects or related project/awards - CIS/DCF forms that transfer pre-award costs

6. Exclusions  Initial allocations of costs from interfaces, service centers and clearing accts, including suspense and failed funds (N.B., these are not cost transfers b/c they do not involve reallocations)  CIS forms that re-distribute salary for a prior period to an award prior to effort cert. (N.B., these are not cost transfers b/c the original allocation is an estimate, so the redistribution of charges is a revision of an estimate)  Credits to awards (N.B….b/c they do not involve allocations of costs to a sponsored project)

7. Why Document?  Reguations specifiy. Every cost transfer must be documented.  Must include info on how the error occurred and approval/certification of the correctness of the transfer by the organizational official.  For standard cost transfers, initiators should use the remarks box on the relevant CIS/DCF forms.

8. Cost Transfers that require a memo to the Comptroller  The correction is initiated 90 days after the error and/or 30 days after the award has been closed;  The cost is being transferred for the second time;  The costs is being transferred to a sponsored project or task to correct a cost overrun on a related sponsored project or task;  Salary costs are being transferred after the certification of effort associated with the costs;  Any other circumstance in which the certifying official needs additional documentation to verify the cost is allowable.

9. Sub-awards  Sub-awards are a formal legal agreement between GW and another legal entity where: -a defined portion of our sponsored project’s scope of work (intellectual activity) is assigned to another entity (“the sub-recipient”) to fulfill; -Work is performed by the sub-recipients personnel, using their resources, usually at their site; -Terms and Conditions from GW’s prime award are flowed down to the third party sub-recipient. -Pass through entity’s F&A rate is only charged to the first $25,000 of each subaward. - Sub-awards can sometimes be referred to as sub-grants, sub- agreements or subcontracts. If the prime award is a contract, then the sub-award is subject to procurement regulations.

10. Independent Contractors  Provide goods/services within normal business operations  Sell to the general public  Operate in a competitive environment  Provide goods and services that are ancillary to GW’s sponsored project.  IP is generally owned by the Company  Non-University Labor or Services (Twenty Factors Test)

11. Documentation Requirements  Subawards Documentation required at proposal submission from PI: OCRO Checklist OCRO Checklist Fair & Reasonable Cost Analysis  Independent Contractors –At proposal submission: Budget and Statement of Services from Contractor - Resume (if individual) Postaward: -Selection of Source form -Supplier registration if new supplier -Twenty Factors

12. Sub-recipient Monitoring A-133 Requirement  Ensure that monies funded to us from a federal awards are used for authorized purposes and are in compliance with laws and regulations of the prime award  Ensure that goals and objectives of the work proposed by the sub-recipient are achieved  Monitor invoices of sub-recipient closely to ensure funds are spent appropriately and work is satisfactory and within time constraints. Communicate deficiencies to sub- recipient in a timely manner! Did the sub-recipient commit to cost-sharing? If so, this must be monitored!

13. Sub-recipient Monitoring (cont.)  GW sub-recipient agreements require the sub- recipient to submit a final report or reports that the PI instructs. These reports will be incorporated into GW’s final report to the sponsoring agency.  Ensure timely closeout! 90 days before end of subaward, confer with sub-recipient. If more time is required, GW may need to request a no-cost extension from our prime sponsor.

14. Policy Sites  http://my.gwu.edu/files/policies/CostTransfersSponsoredAg reementsFINAL.pdf http://my.gwu.edu/files/policies/CostTransfersSponsoredAg reementsFINAL.pdf http://my.gwu.edu/files/policies/CostTransfersSponsoredAg reementsFINAL.pdf  http://my.gwu.edu/files/policies/EffortCertificationFINAL.pdf http://my.gwu.edu/files/policies/EffortCertificationFINAL.pdf  http://my.gwu.edu/files/policies/Bids,Quotes,SoleSourceFI NAL.pdf http://my.gwu.edu/files/policies/Bids,Quotes,SoleSourceFI NAL.pdf http://my.gwu.edu/files/policies/Bids,Quotes,SoleSourceFI NAL.pdf  http://my.gwu.edu/files/policies/SubrecipientPolicyFINAL.p df http://my.gwu.edu/files/policies/SubrecipientPolicyFINAL.p df http://my.gwu.edu/files/policies/SubrecipientPolicyFINAL.p df