Keys to successful sponsored award processing
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Keys to Successful Sponsored Award Processing. Program for Sponsored Award Faculty and Staff Fall 2008 Neta Fernandez Ancelmo (Sam) Encinias. Agenda. Whose idea? Various Players Proposal cycle Award cycle Basics Cost Accounting Standards (CAS) Cost Share and Other Costing Basics

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Keys to Successful Sponsored Award Processing

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Keys to Successful Sponsored Award Processing

Program for Sponsored Award Faculty and Staff

Fall 2008

Neta Fernandez

Ancelmo (Sam) Encinias


Agenda

  • Whose idea?

  • Various Players

  • Proposal cycle

  • Award cycle

  • Basics

  • Cost Accounting Standards (CAS)

  • Cost Share and Other Costing Basics

  • Audits

  • Questions


Whose Idea Was This?

Began with various committee

recommendations:

  • Grant and Contract Process

  • F&A Recovery

  • Disclosure Statement


Unanimous Recommendation

  • Mandatory (and ongoing) training

  • Reduce duplication of CAS

    justifications in budgets

  • Streamline grant and contract process


Other Workshops

  • Cost Accounting Standards (CAS)

  • Cost Sharing

  • Export Control

  • Others, as requested


Various Players


Who is Research Center

  • Reports to the college

    Associate Dean or Director

  • Available to PI’s for questions and info

  • Assist with proposal

  • Questions on purchases/expenditures


Who is OGC?

  • Reports to VPR

  • ~10 research administrators

  • Submits all proposals

  • Negotiates with agencies

  • Provides assistance/training

  • Provides authorized signature

    for Board of Regents

  • Responsible for close out


Who is Sponsored Projects Accounting (SPA)?

  • Reports to Senior Vice President for

    Business, Finance, and HR

  • Creates indexes

  • Invoicing/billing

  • Review & process financial trans-

    actions, ensuring compliance with

    federal, agency and NMSU regulations


Proposal Cycle

Sam Encinias


How to do Proposals?

PI writes proposal

PI works with RC on budget and assembling proposal as required by Sponsor

RC submits proposal to OGC

OGC reviews, approves, submits proposal


Proposal Deadlines

  • 5 Days before deadline to OGC for all Electronic Proposals that must be submitted through the Grants.gov on-line portal

  • 48 Hours before deadline to OGC for Non-Grrants.gov proposals

  • Allow extra lead time for Complex Proposals


Complex Proposals

  • Key is the RFP

  • New Sponsor with Unique Guidelines

  • Work is Interdisciplinary

  • Includes Partners – Subcontractors

  • Center Grants – Multi Year

  • Cost Share or In-kind

  • Foreign Countries – Export Controls


Keys to a Successful Proposal

  • Start Early

  • Team Effort

  • Cover all your bases up front


YEA – Received Award

Neta Fernandez


Award Cycle

  • OGC receives award

  • OGC reviews and negotiates

  • OGC prepares award packet

  • OGC sends packet to SPA

  • SPA creates index

  • OGC and RC notified of index#

  • Finally…PI begins research


Let’s Discuss the Basics

Basics


Definitions of Agreement

Grant:

more flexible than contract; team

oriented; deliverables normally

consist of report

Contract:

issued by external sponsors for

detailed statement of work with

final or milestone deliverables


Definitions of Agreement

Cooperative Agreement:

similar to grant but has statutory

criterion that anticipates substantial

agency involvement


Definitions of Agreement

Gift: a donation, no deliverables; all

gifts processed through the Office of

the Vice President for University

Advancement

* Colleges sometimes have

one specific person who

deals with Advancement


Types of Awards

  • Fixed Price

  • Cost Reimbursable


Fixed Price

Grant or contract for which one

party pays the other party a pre-

determined price, regardless of

actual costs, for services rendered

* More common on contracts


Cost Reimbursable

Grant or contract where one party

pays other party for full allowable costs

incurred during project. Based on actual

costs incurred including direct and

indirect costs.

* Common on grants


Cost Accounting Standards (CAS)

“The

Rule”


Sponsored Award Costs

There are two ways to charge to

a sponsored award:

  • Direct costs

  • Indirect costs


Cost Accounting Standards

(CAS)

  • Created as act of Congress, 1971

  • Applied to universities in 1996

  • Promoted greater standardization

    of costs

  • Goal to tighten rules on allowability/

    allocation


Direct Costs

OMB Circular A-21 definition:

Those costs that can be specifically

identified to the cost objective

with relative ease and a high degree

of accuracy


Examples of Direct Costs

  • Salaries and wages including fringe

  • Non-office supplies

  • Subcontracts

  • Animal use fees

  • Travel related to project


Facility and Administrative

(F&A or Indirect Costs)

OMB Circular A-21 definition:

Costs that are incurred for common

or joint objectives and therefore,

cannot be identified readily and

specifically with particular

sponsored project, an instructional

activity, or any other institutional

activity


Examples of F&A Costs

  • Operation and maintenance of

    buildings

  • Library costs

  • Administrative office supplies


Charging Indirect Costs as Direct Costs

  • Must be required by scope of work

  • Cost can be accurately identified /

    allocated to project

  • Must be unique requirement and be

    justified

  • Evaluated on case-by-case basis


Is it Acceptable?

For example, office supplies are considered

under F&A costs. If you can show that

the office supplies are an unlike

circumstance or are excessive for this

project, you can write a justification and

get approval for charging as a direct cost.


Office Supplies Example

Program is to promote AIDS

Awareness on campus. Requires

unusually large amount of supplies to

prepare brochures and educational

training materials for workshops


Supplemental Compensation

For exempt staff and faculty to be paid

supplemental compensation, the work

must:

  • cross departmental lines or be at remote

    site

    AND

  • be performed in addition to regular

    workload


Supplemental Compensation

  • Must have agency approval

  • Must have approved CAS justification

  • Must comply with NMSU policy

    and procedures


Questions?


Role of PI

SamEncinias


Get Started

  • Three general phases to funding cycle:

    -- Proposal Devel & Submission

    -- Project Administration

    -- Project Reporting & Closeout

  • Hopefully, Reporting & Closeout is not

    “forever” but leads to follow-on or

    subsequent grant


Proposal Development and Submission

Proposals have 3 general areas:

  • Technical Proposal (your ideas)

  • Management Proposal (who will do the

    work, does NMSU have right facilities,

    are protocols to conduct work in place,

    do we need subcontractors, etc)

  • Cost Proposal (who will pay for what,

    are costs proper, do they track with

    technical needs of work, etc)


Proposal Development and Submission

Provide a copy (ASAP) of Request for

Proposal (RFP) to research center

Proposal Award Form (PAF)


Management Proposal

  • Develop staffing plan

    • Faculty, students, professional staff

    • AY and summer loads

    • Subcontractors?

  • Ensure that NMSU follows proper protocols for test subjects, laboratories, and research materials (as applicable)

  • Ensure everyone involved is eligible to work on the project


Cost Proposal

  • Cost Proposal

    • Look for restrictions on funds, cost share requirements, etc. in RFP

  • Budget expenses according to CAS guidelines; justify expenses as needed for NSMU and/or RFP

  • Supply documentation for cost sharing or F&A caps


Project Administration

Project Administration Stages:

  • account/project setup

  • day-to-day administration

  • project reporting


Day-to-Day Administration

  • Personnel

    -- allocate, monitor, track level of effort

    -- complete effort certifications (6 mo)

    -- record timesheets in timely manner

  • Property

    -- if property is purchased under

    grant, track property as part of

    NMSU inventory list


Day-to-Day Administration

Financial Responsibilities:

  • ensure cost sharing is documented and met

  • expend funds per approved budget

  • initiate, monitor, and approve expenditures

    for subawards

  • review/validate expenditures on BANNER

  • ensure travel expenses follow agency

    requirements and NMSU allowed costs


Day-to-Day Administration

Purchases:

  • Can use Purchase Order or Procurement

    Card

  • Vendors must be approved and “in system”

  • Use “account codes” to map purchase items

    to budget categories

  • PI initiates purchase and gets approval at

    department/college/unit level for

    appropriateness and funds available*

    *PI responsible if purchases are not appropriate


Project Reporting

  • Technical Reports

    -- prepare project Final Report and

    any Intermediate Reports according

    to terms and conditions from agency

    -- disseminate project results according

    to proposal plan (conference

    proceedings, journal articles, etc)

    and acknowledge grant

  • Assist research center in final reporting

    of financial matters, inventions,

    inventory, etc


More Basics


Cost Sharing

Definition:

Portion of project costs not borne

by sponsor


Cost Sharing

Two types of cost sharing:

  • Mandatory – required by agency

    or statute as condition of award

  • Voluntary – NOT required by

    agency; cost sharing

    is not required but university

    funds part of cost of research


Cost Sharing

  • Charge full F&A, unless

    capped by agency

  • Treated as cost share


Cost Sharing

If not charging full F&A and not

capped – MUST have VPR approval

Voluntary cost share will only be approved

in very rare cases such as when it is

considered a proposal review criteria and

is stated as such in the RFP


Cost Sharing

Terminology may vary among agencies:

  • cost sharing

  • matching funds

  • in-kind


Cost Sharing

National Science Foundation has

policy stating voluntary cost share

cannot and will not be considered

in the granting of the award


Effort Reporting

Federal Government requirement

  • PI must sign and certify the percentage

    of effort twice a year

  • Timesheet personnel (hourly) sign

    timesheet as certification


Business Procedures Manual

  • Outlines procedures for conducting

    business processes at NMSU

  • www.nmsu.edu/~boffice (under Resources)


Property Guidelines

  • All property (equipment) purchased

    will be tagged

  • Physical inventory conducted

    annually

    PI is responsible for knowing the

    Location and condition of equipment


Program Income

OMB Circular A-110 definition:

income generated from a project

financed by a grant or contract


Program Income

Can be revenue obtained from:

  • conference fees

  • sale of videos

  • sale of books


Program Income

Federal regulations provide following

guidelines for treatment of program income:

  • Use to further program objectives*

  • Use to finance non-federal share of project

    * Default application for research projects


Compliance and Audits

Neta Fernandez


Special Compliance TopicsMonitored Thru Committees

Compliance Comm


Compliance Committees

and Issues

  • Conflict of Interest

  • Institutional Review Board

    (human subjects)

  • Institutional Animal Care and Use

    Committee (animal subjects)


Compliance Committees

and Issues

  • Institutional Biosafety Committee

  • Supplemental Compensation

  • Export Control


Conflict of Interest Definition

  • Research where it appears researcher

    may have significant financial interest that

    could directly/indirectly affect the design,

    conduct, or reporting of research activities

  • Or the researcher’s situation could

    directly and significantly compromise

    his/her professional commitments to NMSU


Conflict of Interest Examples

  • Issuing subaward to spouse/significant

    other

  • Purchasing supplies/equipment from

    company that relative/close friend owns

  • Accepting gratuities or gifts from

    private organization that may be

    interpreted as attempt to influence


Conflict of Interest Procedures

  • PI required to fill out and submit

    a Disclosure of Significant

    Financial Interest at annual evaluation

  • PI required to submit new form when

    new interests are acquired


Conflict of Interest Committee

GOAL is to resolve completely or develop a plan to manage

Note: COI problems can cause PI to

pay back agency out of personal funds


Institutional Review Board

(IRB)

  • NMSU is required by federal

    regulations to review research

    involving human subjects

  • Must have IRB approval before

    PI actually begins research


Institutional Animal Care and

Use Committee (IACUC)

  • NMSU is required by federal regulations

    to review research involving animal

    subjects

  • PI required to get IACUC approval

    for any use of vertebrate animals –

    including research, teaching or testing

  • PI must get IACUC review and

    approval in advance


Institution Biosafety Committee

(IBC)

  • Provides guidelines for research or

    academic programs involving

    biological agents

  • Researchers must receive IBC

    approval before beginning work


Export Control

  • Federal laws to protect

    items, technical data, and

    information important to U.S.

  • More important during times of war

    or heightened security*

    *Protect national security


What is an Export?

  • Any oral, written, electronic or visual

    disclosure, transfer or transmission

    outside the US to anyone, including a

    US citizen, of any commodity, technical

    data, technology, or software

  • Transfer of a controlled commodity,

    technology, or software to a non US

    entity wherever located


Foreign Students/Scientists

  • Large presence of foreign students

    and scientists at NMSU increases

    the chance of transferring

    knowledge to other countries.

    Note: Export Control laws can restrict

    use of foreign students/scientists

    on research


University Exemption

Exemption for universities:

  • fundamental research

  • open publication rights

  • does not involve satellite


Penalties and Fines

Civil penalties up to $500,000 each violation

Criminal penalties up to $1,000,000 each

violation

Imprisonment up to 10 years

OR BOTH

Dr. Horan


Intellectual Property/Tech Transfer


Bayh Dole Act

  • Patent rights retained by university

  • Government receives license to

    practice

  • Universities to share royalties with

    inventors


Intellectual Property Agreement

  • Signed prior to beginning of

    research project


Questions? Contact:

Director of Intellectual Property

and Technology Transfer

Maureen Camunez6-5398


Review of Activity - Audits


Auditors

As recipient of federal funds, NMSU is

subject to frequent reviews by various

groups of auditors


Purpose of Audits

For sponsored awards:

  • ensure compliance

  • ensure achievement of stated

    goals of award


Groups of Auditors

External

-- federal

-- state

-- agency auditors

Internal

-- Audit Services at NMSU


Consequences of Audit Findings

Unfavorable outcomes can result in:

  • Disallowances of claimed costs with

    refund to sponsor

  • Termination of agreement

  • NMSU no longer receiving awards from

    that agency


Notification of Audit Findings

  • Board of Regents

  • State Auditor’s Office

  • Federal Clearinghouse

  • Sponsoring Agency

  • NMSU Audit Services will

    follow up on findings


Important Note to PI

If contacted by agency or the Inspector

General’s Office for any agency regarding a

Review –

CONTACT CONTROLLER’S OFFICE

IMMEDIATELY!!

646-2432


How Can You Protect Yourself,Your Staff, and NMSU?

  • Understand the policies and regulations

    that apply to your project

  • If program activities deviate from award,

    get sponsor approval in writing

  • If you or someone close to you will

    receive money from an award, file

    appropriate disclosures and get approval

    in advance


How Can You Protect Yourself,Your Staff, and NMSU?

  • Do not charge a grant or contract for large

    amount of supplies and/or equipment

    toward end of project.

  • Be cautious when using funds from one

    grant to support activities on another

    grant.


How Can You Protect Yourself,Your Staff, and NMSU?

  • Track your time and charge it accordingly

  • Monitor financial activity on your account

  • When in doubt, ask for help!


OGC Contact Information

  • Phone:(575) 646-1590

  • FAX(575) 646-2020

  • Email:ogc@nmsu.edu

  • Web:http://research.nmsu.edu/ogc.html


Compliance Requires Teamwork

All those involved must work together as

a team

PI

Res Cntr

Award

Processing

OGC

SPA


Questions?


Thank you for all your attention!


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