Post Award Processes and Effort Reporting Roberta McManus Director, Sponsored Research Accounting...
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Post Award Processes and Effort Reporting Roberta McManus Director, Sponsored Research Accounting Services (SRAS) [email protected] , 645-2485
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Transcript of Post Award Processes and Effort Reporting Roberta McManus Director, Sponsored Research Accounting...
Post Award Processes and Effort Reporting
Roberta McManusDirector, Sponsored Research Accounting
Services (SRAS)
[email protected] , 645-2485
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Today’s Agenda
What is Post Award? What are the PI’s Responsibilities? What are Compliance Requirements? I am a researcher why do I have to approve expenditures
and monitor budgets? SRAS Review of Expenditures
Advance Policy Cost Transfer Policy CAS Exemptions What is cost sharing? What is Effort Reporting
OMNI Overview PI Resources
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What is Post Award?
Activities that occur after award documents have been executed by appropriate institution authority Award is to FSU, not the PI Project number assigned
Cost sharing accounting Research can begin
Adhere to scope of work Collaboration/subcontracting to other individuals/institutions Status reports Technical reports
NOTE some invoices require submission prior to payment
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What is Post Award? Spending occurs
Plan ahead to meet deadlines Personnel – Human Resources policies and procedures Non Personnel – Purchasing/Travel/Subcontract/Non PO
policies and procedures Sponsored Research Accounting Services (SRAS) review
allowability of most (not all) expenditures Billing/Collecting from agencies (SRAS responsibility) Financial reporting to agencies (SRAS responsibility) Amendments (SOW & Budgetary)
Contracting Officer for grantor and grantee Starts with Pre Award Administrator
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What are the PI’s Responsibilities?
Understand agency rules/guidelines/restrictions Conduct work timely/professionally Comply with terms & conditions of award Ensure expenditures benefit the project and are
in compliance with award Monitor budget vs. expenditure over life of
project Ensuring commitments are met including cost
share requirements Monitor subcontractor performance
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What are Compliance Requirements?
Federal OMB Circulars applicable to University
A-21 (more on this later!) A-110 A-133 Available on SR website at: http://
www.research.fsu.edu/sras/complianceresources.html Agency specific requirements Terms and Conditions of award
Non Federal Terms and Conditions rule!!
FSU SR Related Policies and Procedures http://www.research.fsu.edu/contractsgrants/policypro.htm
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Hot Button Issues
Cost transfers onto or between projects – do it right the first time!
Expenditures late in the project – using up available balance
Cost share accounting/reporting Effort reporting processes Charging costs normally considered overhead
directly to projects
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OMB Circular A-21
SRS/SRAS use this resource daily
Allowable means: Reasonable (prudent person)
Allocable (relative benefits)
Treatment is consistent (direct vs. indirect)
Conforms to limitations or exclusions (e.g. salary caps)
Direct costs “identified specifically with a particular sponsored project”
Facilities & Administrative (F&A) costs “incurred for common or joint objectives and therefore cannot be
identified readily and specifically with a particular sponsored
projects”
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OMB Circular A-21
Cost Accounting Standards (CAS)
Selected Cost Items (Section J) 54 types of expenses and whether allowable vs. unallowable
Any costs allocable to a particular sponsored agreement
may not be shifted to any other sponsored agreements for
the purpose of (Cost Transfer Policy) Convenience – includes charging a project while waiting for
another project/budget to be set up (Advance Policy)
Meeting deficiencies caused by overruns
Avoiding restrictions imposed by law or terms
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Sponsored Research Financial Policies/Procedures
Advances
Cost Accounting Standards (CAS)
Cost Sharing
Cost Transfers
Effort Commitments
Fixed Price Residual Funds
Indirect Cost Recovery
Participant Support Costs
Program Income
Sub recipient Monitoring
Unallowable Costs
Closeout Authority – Memorandum dated September 24, 2008
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How do I collaborate with another researcher? Often included in proposal
Institution approval vs. researcher Participates in research (sub recipient) vs.
provider of goods/services (vendor) Starts with SRS Subcontract Coordinator Standard agreement
Incorporates Federal requirements Encumbered in OMNI as PO
Numbers = RXXXX PI approves invoices (deliverables met)
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Why do I approve expenditures and monitor budgets? Award is to the University…however
PI responsible for ensuring expenditures benefit the project Timing of when personnel need to be appointed
Timing of when supplies will be used
Collaboration with subcontractor in accordance with SOW
Periodic budget vs. actuals reports (OMNI) Ensure anticipated expenditures charged
Review for expenditures that do not belong on project
Rate of expenditures reasonable for pace of research
progress
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SRAS Review of Expenditures
Requisitions > $1,000 Travel and Expense reports > $1,000 Unencumbered expenses (pay
requests/participant requests) >$1,000 All personnel appointments All journal entries
Cost Transfer Justification Form All interdepartmental requisitions
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SRAS Review of Expenditures
Compliance Evaluation Criteria Authorized Signature
Sponsored Project Manager or PI Chartfield Information
DeptID, Fund Code, Project Combination Performance Period
Goods or Services received and consumed within begin/end dates of award
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SRAS Review of Expenditures
Available Balance Direct Cost Funds available for expense by budget
category line item FDP/RTC
Account or Job Code Appropriate for nature of expense
Allowable Remember OMB Circular A-21!
Terms and Conditions support expense
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Advance Policy Purpose: Ensure timely start up or uninterrupted continuation
effort prior to having a fully executed award document Criteria
Written/verbal assurance from sponsor Delays would adversely impact the program or increase costs Department assumes risk by financially backing the direct cost
amount to be advanced
No work is to be initiated until authorized by SRS (as evidenced by a project budget)
DO NOT charge expenses for pending award to another funding source Transfers will not be approved
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Cost Transfer Policy Purpose: Ensure that funds are properly managed Indicators of inadequate fiscal monitoring
Frequent cost transfers Late cost transfers Inadequately documented or justified cost transfers
Examples of improper/unallowable cost transfers Utilizing unexpended funds Avoiding/alleviating an over expenditure Moving unallowable costs on one project to another Circumventing award restrictions Reimbursing a temporary “loan” of funds from another
project
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Cost Transfer Policy Proper cost transfers
The transfer represents an adjustment for an erroneous charge
Split purchase Timeliness of identification and correction of errors is
essential to evidence sound fiscal management Policy
Payroll/Non Payroll Within 90 days of end of the month in which error occurred
OR Within 30 days of the project expiration date
Must complete Cost Transfer Justification Form
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Cost Accounting Standards (CAS)
FSU is required to disclose “costing practices” in a formalized document (Disclosure Statement-2)
Describes how FSU treats Direct F&A costs
Facilities Administration
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CAS – F&A Costs
Examples of Costs that are normally treated as F&A: Administrative and Clerical Salaries Postage Local Telephone Office Supplies Data Processing/Computer Supplies General Purpose Software Memberships Subscriptions
Cannot charge expenses typically treated as an indirect cost directly to a sponsored project unless there are exceptional circumstances
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CAS Exception Process
Must be documented for all federally-funded awards
Pertains to direct charge costs that are normally treated as indirect costs
Inclusion in the budget in the award document does not automatically grant the exception
Form at http://www.research.fsu.edu/contractsgrants/forms.html
Submit to Director, Sponsored Research Services
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What is Cost Sharing?
Policy at http://www.research.fsu.edu/contractsgrants/costsharing.html
Definition = Costs borne by FSU Criteria for tracking/reporting
Committed—Mandatory vs. Voluntary Committed Must account for and report
“Project Enhancement” Do not have to account for and report
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What is Cost Sharing?
Include in the proposal budget Cost Share Commitment Form Signed by Chair/Dean/Director
Cost Share budgets are set up in OMNI Sponsored award/cost share budget set up
same time Important to get cost share info to SRS or will hold
up being able to spend Does not include 3rd party Transfer the cash for PI, SRAD, Auxiliary, FSU
Fdtn, Research Fdtn funding sources
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What is Effort Reporting?
Federal government expects Universities to Meet commitments Provide evidence that commitments have been
met FSU certification cycle
Certify after each academic term Application = Faculty Assignments effort
Certification Tracking (FACET) Provide reasonable estimate of time spent on
various activities (instruction, advising, projects, etc.)
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OMNI Overview
Financial/Human Resource Systems Project financial information
Job Aids on Division of Sponsored Research at http://www.research.fsu.edu/contractsgrants/
Available project balance inquiry Generating project financial report Running query of project expenditure detail Generating HR report of payroll detail
Budget check against direct cost budget Expenditures (costs incurred) Encumbrances (POs, T-Auths, personnel appointments) Not encumbered (future personnel appointments, tuition,
rent, F&A)
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PI Resources
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Training Opportunities
CReATE Compliance and Research Administration Training and Education Next session May 23 & 24
Lunch & Learn series 1-2 per month Wednesdays 11:30am – 12:30pm
Current schedule http://www.research.fsu.edu/contractsgrants/workshops.html)
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Web Resources
Office of Research (http://www.research.fsu.edu/)
Division of Sponsored Research (http://www.research.fsu.edu/contractsgrants/index.html) Staff Contact Information (SRAS assignments
attached) Policies and Procedures Forms Funding Resources OMNI Information Training Information Email/Newsletter Services (recommend getting on
these list serves)
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Web Resources
Controller’s Office (http://www.vpfa.fsu.edu/control/) General Accounting Payroll Services Property Accounting Accounts Payable Travel
Office of Graduate Studies (http://gradstudies.fsu.edu/) Tuition Waiver Information
Purchasing (http://www.purchasing.fsu.edu/)
Human Resources (http://hr.fsu.edu/)
OMNI Resources (http://erp.fsu.edu/OMNI-Training)
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Contact Information
SRS/SRAS Assignment Sheet
At http://www.research.fsu.edu/contractsgrants/documents/staff.pdf
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QUESTIONS
