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Post Award Accounting at Caltech. New Grant Manager Training October 28, 2004. Overview. Organization and responsibilities Account structure/types Monitoring accounts Useful expenditure types. PROJECT ACCOUNTING Budget Realignments Billing Cost Transfers Cost sharing

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post award accounting at caltech

Post Award Accounting at Caltech

New Grant Manager Training

October 28, 2004

overview
Overview
  • Organization and responsibilities
  • Account structure/types
  • Monitoring accounts
  • Useful expenditure types
post award accounting responsibilities
PROJECT ACCOUNTING

Budget Realignments

Billing

Cost Transfers

Cost sharing

Financial reporting

Closeouts (financial)

Fabrication accounts

JPL/Caltech accounting interface

NIH Salary cap

Monitoring awards

(in conjunction with campus)

Responding to internal and external audits

COST STUDIES

Payroll Distribution (aka effort reporting)

F&A rate development and negotiation

Service centers

Space surveys

Post Award Accounting Responsibilities
organization
Organization
  • Who is the Accounting Specialist on a particular award?
    • http://www.atc.caltech.edu/support/queries.html
      • POETA-Alias Queries
      • Award Information
        • Type in award number
        • Award Detail summary screen will appear
        • Scroll down to Award Personnel
  • Note: This screen is also useful because it includes all linked awards
account structure type
Account Structure/Type
  • Structure
  • Cost Sharing
  • JPL Research accounts
  • JPL Service accounts
  • Fabrication accounts
account structure what is poeta
Account Structure - What is POETA?
  • Project - Projects are funded by Awards

(Two kinds of Projects, Capital and Non-Capital)

  • Organization in POETA, will default to Caltech
  • Expenditure Type
  • Task - A Project is made up of one or more

tasks. All expenditure occurs at the task or sub- task (i.e., breakdown of a task into a smaller unit of work) level

  • Award - Awards fund Projects
account structure what is work breakdown structure
Account Structure – What Is Work Breakdown Structure?

Organization of an activity into a hierarchy of one project and one or more tasks

cost sharing
Cost Sharing
  • Committed cost sharing on a sponsored project is a binding obligation that must be satisfied in accordance with the sponsor’s requirements
  • Offer cost sharing only when required by the sponsor

http://atc.caltech.edu/Finance/pa_policies.htm

types of cost sharing
Types of Cost Sharing
  • Committed
    • Must be tracked, documented, and in some cases, reported
  • Uncommitted
    • Does not have to be tracked or recorded
cost sharing federal requirements
Cost SharingFederal Requirements
  • Do not use federal funds
  • Use only once
  • Costs must be verifiable, necessary, allowable and reasonable for the award on which they are being claimed
cost sharing procedure
Cost SharingProcedure
  • Establishing a linked account or specific task within a PTA to track cost sharing is not mandatory under the terms of Caltech’s policy
    • Depends on the Division
  • In all cases a manual worksheet, the Committed Cost Sharing Worksheet, will be prepared and distributed by OSR (based on information included in the proposal and the award document)
cost sharing procedure1
Cost SharingProcedure
  • PA will contact the grant manager on an annual basis to obtain an update of the status of cost sharing and to review any supporting documentation
    • Will require account detail of where the cost sharing was charged and require specific costs to be identified within that account
  • PA will submit any financial reports due to agency or prime contractor
jpl interdivisional authorizations
JPL Interdivisional Authorizations
  • What is an Interdivisional Authorization?
    • Authorization for Caltech to incur expenses for providing a service to JPL and a means for billing JPL for those services (i.e., transferring funding from JPL to Caltech)
jpl interdivisional authorizations1
JPL Interdivisional Authorizations
  • There are 2 types of IAs
      • Research IA
      • Service IA
  • Set-up process depends on the type of IA
jpl research ia s
JPL Research IA’s
  • Generally involve a member of the Caltech faculty
  • Set-Up
    • Must prepare a budget and statement of work that is reviewed by Caltech’s Office of Sponsored Research
    • Should conform to all the usual requirements for proposal submission, e.g., Divisional Approval Form
jpl research ia s1
JPL Research IA’s
  • JPL Contract Management Office (CMO) will only issue an IA to authorize payment for the work after the proposal has been submitted and reviewed
  • For more information refer to OSR website
    • http://atc.caltech.edu/OSR
  • Billings and Close-Outs
    • Processed by Project Accounting
      • Divisional teams
jpl service ia s
JPL Service IA’s
  • Generally do not involve, or are not supervised by, a member of the Caltech faculty e.g., services provided directly to JPL by MPS, technicians, shops, service centers, etc.
  • Set-Up
    • Complete template detailing budget and statement of work
    • Submit to Lisa Frenchie in Project Accounting (M/C 211-15)
    • Template and instructions are available on the Project Accounting website under forms
    • http://atc.caltech.edu/Finance/pa_forms.htm
jpl service ia s1
JPL Service IA’s
  • Reviewed by Project Accounting to verify
    • Salary rates (JPL will not accept a different salary rate than Caltech rate)
    • Correct overhead rate
      • Work performed at campus (59.3%)
      • Work performed at JPL (26%)
    • Staff benefit rate
jpl service ia s2
JPL Service IA’s
  • JPL CMO will only issue an IA to authorize payment for the work after this paperwork has been submitted and reviewed
  • Billings and Close-Outs
    • Processed by Project Accounting
      • JPL team
jpl ia s
JPL IA’s
  • Be aware of restrictions on charging to JPL IA’s (both service and research)
    • Equipment
      • Must be preauthorized and specifically identified in the IA
      • Equipment threshold is lower than Caltech’s ($1,000 compared to $5,000)
    • Foreign travel
      • Must obtain prior approval
jpl ia s1
JPL IA’s
  • Deobligations
    • Not uncommon
    • JPL CMO will only de-obligate after obtaining written concurrence from Caltech PI
    • A revised IA will be issued deobligating the funds
fabrication accounts
Fabrication Accounts
  • Fabrication policy http://www.atc.caltech.edu/finance/
  • Fabrication set up form

http://www.atc.caltech.edu/finance/

fabrication accounts1
Fabrication Accounts

Definition

  • “An equipment fabrication is the transformation of materials, supplies, hardware costs and direct labor (including associated fringe benefits) into an item of equipment that:
    • Does not currently exist
    • Meets unique research specifications
    • Has a total estimated cost in excess of $5,000
    • Has an estimated useful life of at least 2 years
    • When completed, will not be affixed permanently to a building or structure”
fabrication accounts fiscal implications
Fabrication AccountsFiscal Implications
  • Costs charged to a fabrication account are not burdened (i.e., overhead rate is not applied), regardless of expenditure type
  • Fabricated equipment that is eventually capitalized in Oracle Fixed Assets will include all costs charged to the fabrication PTA (including labor, travel, etc.)
fabrication accounts chargeable costs
Fabrication AccountsChargeable Costs
  • Costs charged to a fabrication PTA must be integral to the construction of that fabrication (may include labor costs)
  • Must be in compliance with OMB Circular A-21
  • Must not be prohibited in the awarding document
establishing a fabrication pta
Establishing A Fabrication PTA
  • Fabrication PTA’s should be established as far in advance as possible to prevent initial costs being charged to a non-fabrication account
  • Division representative completes an equipment fabrication request form
establishing a fabrication pta1
Establishing A Fabrication PTA
  • Information required on the fabrication set up form includes:
    • Description
    • Ownership (Caltech/Gov’t/Other)*
    • Ultimate destination*
    • Estimated placed in service date (the best judgment of the PI of the point in time at which an equipment fabrication will become operational)
    • Estimated cost
    • Must be signed by the PI or the division representative

*It is extremely important that the issue of ownership and final destination be known and appropriately

identified at the time of account set up as this directly impacts the type of fabrication account that will

be established. If the incorrect type of account is established at set up then all costs charged to that

account will ultimately have to be transferred to the corrected account type.

establishing a fabrication pta2
Establishing A Fabrication PTA
  • Completed forms should be sent to Property Services (Ernest Ngalula at M/C 116-6, ext. 4181)
  • Property Services reviews the form to verify that the proposed fabrication is capable of meeting Caltech’s definition of fabricated equipment then passes the form to Project Accounting
establishing a fabrication pta3
Establishing A Fabrication PTA
  • Project Accounting verifies that the fabrication is allowable under the terms of the grant, contract or co-operative agreement being charged and if prior approval is required
  • Who actually sets up the account?
    • If set up at the same time as the main award – OSR
    • If main award already set up – Project Accounting
establishing a fabrication pta4
Establishing A Fabrication PTA
  • If a significant budget realignment is subsequently requested (more than 20% of the original fabrication budget) PA will work with Property Services and OSR to ensure that the project continues to meet the definition of a fabrication and that it continues to be allowable under the terms of the awarding document
fabrications
Fabrications
  • Equipment expenditure types should not be used on fabrication accounts
    • Technically, a component purchased for a fabrication is not a stand alone asset therefore it doesn’t meet the definition of equipment
    • In practical terms using equipment expenditure types on fabrications impacts Caltech’s reporting to agencies
  • Remember: Charges hitting a fabrication PTA are overhead free therefore no fiscal implications to using ‘supplies – allocable’
monitoring awards
Monitoring Awards
  • Cost transfers
  • NIH NRSA Fellowships
  • Budget realignments
  • NIH salary cap
  • Foreign travel
  • Closeouts
  • Payroll distribution
cost transfers
Cost Transfers
  • Policy on cost transfers to federally funded awards
    • http://atc.caltech.edu/Finance/policies_costtransfers.htm
cost transfers1
Cost Transfers
  • Definition
    • An after-the-fact reallocation of costs, either labor or non-labor, to a federally funded award
    • Federal requirements limit the circumstances under which cost transfers are allowed
cost transfers2
Cost Transfers
  • Procedures for non-labor cost transfers within 90 days
    • Fill out cost transfer and justification form
    • Answer questions 1 through 3 in Section C
    • Signed by PI or cognizant administrator
      • Send form and supporting documentation to Project Accounting
      • Project Accounting will notify if transfer is not approved
cost transfers3
Cost Transfers
  • Procedures for labor cost transfers within 90 days
    • Campus personnel inputs into Labor Distribution Module
    • Must address the following
      • Indicate name of designated/knowledgeable individual who has reviewed and approved the transfer
      • Explain why the labor expense was posted to the incorrect PTA
      • Explain why the labor expense should be transferred to the proposed receiving account. How does the receiving account benefit?
      • Explain why, based on the terms of the receiving award, the charges are allowable and allocable
    • Will be reviewed and approved by LDU at Caltech
    • Depending on the Division, a signed cost transfer and justification form may be required
cost transfers4
Cost Transfers
  • Procedures for transfers after 90 days
    • Fill out cost transfer and justification form
    • Answer questions 1 through 5 in Section C
    • Must be signed by PI, Division Chair and Project Accounting official
      • Send form and supporting documentation to Project Accounting
      • Project Accounting will notify submitter if transfer is not approved
      • If a labor transfer, PA will forward copy of form to LDU for system approval
cost transfers5
Cost Transfers
  • What qualifies as an extenuating circumstance?
    • Late issuance of appropriate documentation for reasons beyond the control of the requestor, such as late issuance of an award by a funding agency
    • Failure of another department to take action when supporting documentation had been properly submitted
    • Transfer of expenditures from an unrestricted account to a federal award that was not in place when the expense was incurred
cost transfers6
Cost Transfers
  • What will not qualify as an extenuating circumstance?
    • Absences of the PI or cognizant administrator
    • Shortage or lack of experience of the staff administering the awards
    • Federally funded sponsored accounts used as a holding account for expenditures
  • If in doubt send PA a draft for review and feedback before obtaining signatures
nih nrsa fellowships
NIH NRSA Fellowships
  • Use the correct expenditure type to prevent overhead being applied
    • “Res/Postdoctoral fellows”
  • Be aware that if a fellow engages in training for less than 6 months of the award year, one half of that years supply allowance must be returned to the NIH
budget re alignments
Budget Re-alignments
  • Why does budget sometimes have to be realigned?
    • Linked awards
      • There must be budget at the PTA level for an invoice to be generated (may need to transfer funding between the main award and the linked award)
    • May wish to re-align budget between categories (subject to the terms and conditions of the award)
nih salary cap
NIH Salary Cap
  • NIH imposes a limitation on the rate of pay individuals may receive as compensation from NIH funds
  • For calendar year 2004, the cap is $175,700 per year
  • NIH also mandates that the portion of the individual’s salary that represents the difference between the capped rate and the actual rate may not be received from federal sources
  • The rate can and usually does change on an annual basis
nih salary cap1
NIH Salary Cap

For example:

  • PI with a salary of $200,000 per year
  • 25% paid by an NSF grant; 25% by an NIH grant; 50% by CIT funds
    • The PI may only be paid $43,920 from NIH funds (he will be paid $50,000 from NSF funds)
    • The difference of $6,080, which exceeds the NIH cap, can be paid from non-federal sources
nih salary cap2
NIH Salary Cap
  • At Caltech an excel spreadsheet is available to assist division/center personnel in calculating the appropriate percent of time needed to input into the payroll system in order to maintain consistency with the NIH salary cap
  • This document also serves the purpose of providing an audit trail

http://atc.caltech.edu/Finance/policies.htm

nih salary cap3
NIH Salary Cap

Procedure:

  • Prior to initiation of any payroll transaction from NIH funds, the division determines which employees are above the salary cap
  • Divisions utilize the NIH salary cap template to determine the percentage of salary that can be charged to relevant NIH grants, and what portion should be charged to non-federal funds
  • Divisions should retain completed NIH salary cap template as partof the record of that payroll transaction
nih salary cap4
NIH Salary Cap

Procedure:

  • On annual basis, and at the end of each NIH award’s competitive cycle, Project Accounting will run a report on that award to verify that all salary payments were consistent with the NIH salary cap in effect at the time of the payment, and work with the Division/Center to make necessary adjustments
foreign travel
Foreign Travel
  • Prior approval for foreign travel may be required on some awards
  • In those circumstances, even if the travel benefited the award, the costs will be unallowable on the award unless prior agency approval was obtained
foreign travel fdp
Foreign Travel - FDP
  • Prior approval for foreign travel is sometimes waived on FDP awards - depends on the agency
  • Prior approval waived for:

AFOSR AMRMC DOE NASA

NIH NSF ONR USDA

  • Prior approval required for:
    • ARO
    • EPA
foreign travel non fdp
Foreign Travel – Non-FDP
  • Look out for :
    • JPL (prior approval is always required)
    • Non-FDP grants & co-operative agreements
    • Contracts
    • There is a high likelihood that prior approval will be required on these type of awards
award close out
Award Close-Out
  • 30 day notice prior to end date
  • NCE required? (best to make request prior to the end date otherwise sponsor approval required)
  • 90 days from end date to close out the award
award close out cont d
Award Close-Out, cont’d
  • Out of period costs
  • Equipment purchased close to the end date
  • Overspends (Don’t wait until the end of the award)
  • Underspends (underspends on fixed price contracts may be transferred to gift awards)
  • Clear commitments
payroll distribution aka effort reporting
Payroll Distribution (aka Effort Reporting)

http://atc.caltech.edu/Finance/coststudies.htm

Policies & Procedures

Payroll Distribution FAQ’s

payroll distribution omb circular a 21
Payroll DistributionOMB Circular A-21
  • Section J.10.b(2)a

The payroll distribution system will … reasonably reflect the activity for which the employee is compensated by the institution…

  • Section J.10.c.(1)(e)

At least annually a statement will be signed by the employee, principal investigator, or responsible official(s) using suitable means of verification that the work was performed, stating that salaries and wages charged to sponsored agreements as direct charges…are reasonable in relation to work performed.

payroll distribution procedures
Payroll DistributionProcedures
  • Report Distribution
    • Every 6 months
      • July and January, for 6 months ending March 31 and September 30, respectively
      • Timing allows for cost transfers to be processed within 90 days
    • Reports distributed to contact person
payroll distribution definition
Payroll DistributionDefinition
  • Payroll confirmation reporting is the formal verification of the reasonableness of payroll charges to sponsored awards
  • In general each faculty/PI will receive 2 reports to sign
    • Faculty Report (detailing his/her own charges)
    • Award Manager Report (detailing the individuals charging to his/her awards)
payroll distribution contact person
Payroll DistributionContact Person
  • Each Faculty and Award Manager Report is associated with a contact person
  • The contact person is responsible for distributing reports to, and receiving from, faculty and/or award managers
  • Contact persons were provided by Division Administrators for the first reporting cycle
  • The Award Set Up Form currently requests that a Payroll Confirmation Contact Person be designated
payroll distribution cognizant signatory
Payroll DistributionCognizant Signatory
  • Responsibility for confirmation may be delegated to a cognizant signatory
  • A cognizant signatory is any individual who:
      • Has suitable means of verification that work was performed, and
      • Has the knowledge to confirm that the payroll charges were reasonable in relation to the work performed
payroll distribution procedures1
Payroll DistributionProcedures
  • Review the information on the report and confirm that it represents a reasonable distribution of payroll charges for the work performed
  • If there is a disagreement that the work was performed and/or that the distribution is reasonable, Cost Studies should be notified immediately
  • Cost Studies will work with the award manager/contact person to determine the appropriate course of action. A cost transfer request may need to be processed by the Division/center through Project Accounting. The Cost Transfer policy will apply to such requests
useful expenditures types
Useful Expenditures Types
  • Caltech currently has 309 active expenditure types
    • Fortunately,119 are for use by Finance only, 16 are for recharge centers, and 4 are for burden expenditures,
    • But, that still leaves 170 to choose from….

For a complete listing go to:

https://fiji.caltech.edu:9013/pls/CNTR/CITWA_EXP.MAIN.PKG.startup

expenditure types
Expenditure Types

* Entertainment should never be charged to a sponsored award

expenditure types supplies
Expenditure Types -Supplies
  • Allocable or unallocable? Is this the type of cost that the Federal Government should be paying for either directly (direct charge to an award) or indirectly (recovered through the F&A rate)?
  • Caltech includes costs categorized as ‘supplies allocable’ in the pool of overhead costs that we, partially, recover from Federal agencies: we exclude costs categorized as ‘supplies unallocable’ from that pool of overhead costs
  • If in doubt use the front page of the newspaper test...
expenditure types determining title
Expenditure Types -Determining Title

Sources of Information:

  • Oracle: https://fiji.caltech.edu:9013/pls/CNTRL/CITWA_POTA_PKG.startup
    • Type in award number
    • Double click on ‘award detail’
    • Scroll down to equipment
  • Award summary
  • Office of Sponsored Research
expenditure types participant support costs
Expenditure TypesParticipant Support Costs
  • Why is it important to use the correct expenditure type? Because participant support costs are overhead free
  • Administrative costs such as room rental, copying, postage, and clerical services do not qualify as Participant Support costs.
  • To rebudget funds from participant support cost category to another category requires Program Officer approval
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