Sponsored Projects Post Award Administration - PowerPoint PPT Presentation

Sponsored Projects Post Award Administration

ASD Academy Presentation

May 17, 2004

“For I am mindful that scientific achievement is rooted in the past, is cultivated to full stature by many contemporaries and flourishes only in a favorable environment. No individual is alone responsible for a single stepping stone along the path of progress, and where the path is smooth, progress is most rapid.”

--Ernest Orlando Lawrence

• Sponsored Project Award Administration Environment and Research Team Responsibilities (Phyllis Gale)
• The Sponsored Project Awards and the SPAA Package (Phyllis Gale)
• Post Award Administration – Non Financial (Phyllis Gale)
• Post Award Administration – Financial (Phyllis Gale)
• Project Costs and Billing (Jerry Kekos)
• Cash/Funding Management (Sallie Frainier)
• Closeout (Andre Bell, and Lisa Rebrovich)
• Award Management Report and

E-Notifications,

• FY2003 – 1,158 Funding Actions resulting in $118.2M of funding
• FY2003 - there was 927 active Sponsored Project Awards with 285 different sponsors
• FY2003 - there were 347 new sponsored project awards with 163 different sponsors
• Every Berkeley Lab Scientific Division has at least one active sponsored project award
• Sponsored Project Awards represent about 25% of the Lab’s research funding

• The research is accomplished

by dedicated research

teams typically composed of

• PI
• Divisional Administration
• Sponsored Projects Office
• Finance
• Other Central Functional Administrative Units
• Procurement, Property Management, Patents. Technology Transfer, EH&S, Human and Animals Regulatory Commission, Records and Archives, Human Resources, and Internal Audit

• Sponsored research is conducted in a regulated environment that come from a multitude of different sources
• Federal Government as represented by the U.S. Department of Energy through “Contract 98”
• The University of California
• Berkeley Laboratory
• Terms and conditions of our agreements with the Sponsors

• All members of the research team are responsible for the conduct of research in a prudent and ethical manner through
• understanding relevant laws, regulations, contract and grant requirements pertaining to research administration
• ensuring compliance

• What happens if there are violations of policy or regulation occurs during the course of a sponsored project, what are the consequences?
• More scrutiny by sponsors and audit agencies, corrective action plans, more regulations, potential fines and penalties, potentially disallowed costs, harm to the health and safety of individuals, and harm to Berkeley Lab’s reputation.

UC Contract and Grants Manual defines Principal Investigator as the individual with primary responsibility for

• The scientific integrity and management of the project;
• The financial management of the project funds;
• Adherence to all applicable DOE and University policies; and
• Adherence to externally imposed sponsor terms and conditions including reporting, deliverables, and record keeping requirements contained in the award documents
• UC Contract and Grants Manual
• Chapter 10 – Internal University Administration

Division Directors are accountable for the performance of LBNL PIs under their supervision. Basic responsibilities include:

• Determining an individual’s eligibility for PI status;
• Determining the consistency of the proposed project with the objectives of the organizational unit;

• Determining the appropriateness and acceptability of research personnel, space, equipment, and LBNL financial commitments contained in the proposals for sponsored projects;
• Assuring the project performance is consistent with DOE and UC policies along with externally imposed sponsor terms and conditions.
• UC Contract and Grants Manual
• Chapter 10 – Internal University Administration

• Supports PI in post award administration
• Works with the PI, SPO, Finance and other functional organizations to ensure compliance with award terms and conditions, DOE, University, Laboratory, and Sponsor policies
• Initiate transactions to support research

• UC Contract and Grants Manual divides the responsibility for contracts and grants between their Sponsored Projects Offices and the Principal Investigators:
• The Berkeley Laboratory’s Sponsored Projects Office is the only office responsible for the formal legal obligations related to the solicitation and acceptance/execution of extramural funding as delegated by DOE and the University of California
• UC Contract and Grants Manual
• Chapter 10 – Internal University Administration

• Authorizes Sponsored Project Awards
• Negotiates the award and the required sponsor approvals during the course of post award administration
• Partners with the PI, Division Administration, Finance and other functional organizations to ensure compliance with award terms and conditions, DOE, University, Laboratory, and Sponsor policies

• Partners with the PI, Division Administration, Sponsored Projects Office and other functional organizations to ensure compliance with award terms and conditions, DOE, University, Laboratory, and Sponsor policies
• Bills and receives payments from the Sponsor
• Negotiates and sets Burden Rates and provides guidance for budget formulation
• Interfaces to DOE to assure the Financial Mod to Contract 98 contains sufficient resources for the award expenditures

• Partner with PI, SPO, and Divisional Administration to ensure compliance with award terms and conditions, DOE, University, Laboratory, and Sponsor policies
• Reviews and validates transactions to support research

• All Sponsored Project Awards are part of the DOE Work for Other’s Program
• A Sponsored Project Award is can be defined as
• Externally funded by a Non-DOE HQ Sponsor
• Governed by terms and conditions specified in a written agreement between the sponsor and DOE or UC/Lawrence Berkeley National Lab
• Governed by regulations set out by DOE, the University, and Berkeley Laboratory

• Statement of Work
• Budget
• Deliverables
• Disposition of Property
• Sponsored Project Award Agreement with terms and conditions
• A Finite Period of Performance
• Detailed Fiscal Responsibility with the expectation to return of funds at the end of the period of performance

• Only the Sponsored Projects Office has DOE and University of California delegation to accept Sponsored Project Awards
• If a PI, divisional administration or others receive original award documentation, it should be immediately forwarded to the appropriate SPO Contracts Officer so it can be reviewed, conduct negotiations (if required), and authorize the award.

• When is an award authorized and when can the science begin?
• No Award may be authorized nor expenditures incurred until an award has been fully executed by either DOE or LBNL/SPO, all other requirements are met (i.e. advance payment received) and authorized by SPO.
• What is an Award Package?
• The Award Package consists of a Sponsored Project Award Authorization and a copy of the agreement along with other documentation that SPO may include (i.e. copy of advance check).

What is a Sponsored Project Award Authorization (SPAA)

• It is a report from the RAPID system with specific information highlighted for the administration of the award.
• It is issued by SPO to authorize initial award and post award administrative and funding actions
• Additional funding (including incremental)
• Changes to the Award (including scientific, administrative, financial, and no cost extensions)
• It is issued by Accounts Receivable for deobligations and refunds based on final invoices and financial reports.

• Review the SPAA
• Review the Agreement
• Additional Documentation
• Note if the Sponsor has a separate administrative manual (i.e. NIH) for additional terms and conditions governing the award
• Call your SPO CO if you have

Questions!

• Committed Funding Amount and Payment Method
• Period of Performance
• Property
• Publications
• Intellectual Property and Rights in Data Integrity
• Statement of Work for Deliverables
• Any restrictions or unusual terms that were noted in the SPAA

• The Agreement and/or the sponsor’s administrative manual can contain requirements for
• prior approvals for administrative actions including foreign travel, change in PI, PI absence from the Lab, change in Key Personnel, change in scope of work, addition of Human and/or Animal Subjects to Research, R&D Subcontracts, budget expenditures, purchase of equipment, etc.
• And without prior approval

the costs could become

potentially unallowable costs.

• And balance with the cost

principles of Contract 98

• Deviation from Award Terms and Conditions
• If in the course of research there is any deviation from the terms and condition, consultation with the SPO CO is required to determine if prior approval by the Lab or the Sponsor is necessary and if the award should be amended.
• If it is implemented prior to sponsor approval and amendment of the agreement (if required), the costs may be unallowable.
• Prior approval requests must be in writing and include the endorsement of the SPO CO.
• Sponsor approvals must be in writing (including e-mails) and must be on file in the SPO File

• Human and Animal Subject Approvals: Approvals are required to be current throughout the life cycle of the award. Adding Human and/or Animal Subjects to research is a change in scope of work and must be approved for the research award prior to commencement.
• Some sponsors (i.e. NIH) require prior approval for this type of change in the scope of work
• Lapses in approval, not obtaining approval, or not obtaining prior approval may result in unallowable costs
• Questions? Contact EH&S/HARC

http://www.lbl.gov/ehs/health_services/harc/hsc.shtml

• Conflicts of Interest
• Research and Consultant Agreements:
• When there is evidence of a potential conflict of interest situation between an employee's personal affairs and Laboratory work, policy requires an independent substantive review of all aspects of the matter.
• Questions? Contact the Laboratory COI Coordinator

http://www.lbl.gov/LBL-Work/RPM/R2.20.html#RTFToC8

• Human Subjects:
• Researchers who have an independent role must submit a Checklist for Conflict of Interest for Human Subjects at the time of submitting a protocol
• Questions? Contact EH&S/HARC

http://www.lbl.gov/ehs/health_services/harc/hsc.shtml

• Procurements – PO’s and R&D Subcontracts, and Consultant Agreements
• A purchase order or subcontract (including NIH Consortium Agreement) cannot exceed the current committed funding amount or the expiration period of the parent award.
• Work with Procurement to establish incrementally funded agreements that will mirror the parent award
• Some Sponsors (i.e.) require prior approval before an issuance of a research subcontract or consultant agreement

• Equipment
• Check the agreement and the proposal budget regarding equipment and sponsor administrative manual
• Must have funding for entire purchase price committed in the award prior to making the purchase
• Some Sponsors require prior approval before equipment at a specific threshold can be purchased:
• Example: NIH Grants Title vests with UC/LBNL - Prior approval to purchase equipment over $25K is required
• NonFederal Standard Agreements – equipment over $5,000 vests with the Sponsor (NOT DOE). If the equipment was not budgeted for at the time of proposal and the LBNL PI would prefer to have DOE hold title, then the agreement will have to be amended to reflect the action.
• If not, at the end of the period of performance, the Sponsor can request that the equipment be sent to the Sponsor at the Sponsor’s expense

• Change in Scope of Work
• If there is a substantial change, PI should discuss with Sponsor
• Change in Scope of Work includes changes in research plan, introduction of human subjects, introduction of animal use, application of a new technology, etc.
• Some Sponsors (i.e. NIH) require that written prior approval to be received prior to all instances of change in the scope of work
• The Agreement should be amended to reflect the change in direction and Sponsor’s approval.
• If approval is not received, the costs of the research conducted may be unallowable.

• Change in Principal Investigator or Key Personnel Status
• If the PI plans to leave the Laboratory or will be absent for a considerable period of time, then the Sponsor should be contacted so there is an orderly transition of research both scientifically and administratively.
• Some Sponsors (i.e. NIH) require that written prior approval change in PI or Key Personnel be reviewed and approved prior to the action take place.
• The Agreement should be amended to reflect the change in PI and Sponsor’s approval.
• If approval is not received, the costs of the research conducted may be unallowable.

• Publications: If the PI has been asked by the Sponsor to restrict it may violate LBNL’s ability to publish to an extent that it violates the Laboratory Policy on the Dissemination of Research Results.
• The Laboratory Director’s approval must be obtained prior to agreeing to the requested change.

• Intellectual Property: If the PI has been asked by the Sponsor to handle the disposition of Intellectual property differently that in the agreement, the agreement may need to be amended. Only SPO CO’s can amend an agreement changing IP terms in consultation with DOE and other LBNL departments.
• Rebudgeting: Some Sponsors (i.e. NIH) require prior approval if expenditures deviate from the budget that was approved at the time of the award. Consult with SPO CO if determine if there is a rebudgeting requirement associated with your award.

• Additional Funds: If additional funds are needed and were not approved in the original proposal, a new proposal and amendment of the agreement will be required. LBNL cannot unilaterally spend funds beyond the current contractual limitations. Continuation funding can be requested through the Bridge Funding policy. Only when Bridge Funding is approved and authorized through the issuance of a SPAA can continuation funding be expensed.
• No Cost Extension: If additional time is needed to complete the work as proposed, the agreement will need to be amended formally. LBNL cannot unilaterally work beyond the current contractual period.

• To make the best use of available funds to achieve research outcomes
• To avoid problems of fraud, waste and abuse of sponsor support

All awards are subject to the Cost Principles of Contract 98.

• The sponsor may include more restrictions in the agreement.
• Any cost being charged to a Sponsored Project Award must satisfy the following Criteria:

• ALLOWABLE: All costs must be allowable under Contract 98 and/or the terms of the particular award
• ALLOCABLE: The cost must be allocable, that is, the award which paid the expense must benefit from it.
• REASONABLE: The expense must be reasonable, that is, the cost reflects what a “prudent person” might pay.

• If costs are not allowable, allocable, and reasonable, then they may not be charged to a Sponsored Project Award.
• In addition, all costs should be handled consistently across the Laboratory. If a cost is usually charged to a burden, then it cannot be charged to an award.
• LBNL’s list of Unallowable costs under Contract 98 can be found at:

http://www.lbl.gov/Workplace/FSM/UnallowableCosts.htm

• Sponsors expect to pay only for those portions of employee effort that are actually devoted to their projects.
• Periodically, government and internal auditors review our payroll charges to enforce this expectation.
• In conducting these audits they are assessing whether the salary charged to project accounts is for effort that appropriately benefited those projects. Auditors are checking the accuracy of payroll charges by verifying that the percentage of the employee's salary charged to a sponsored project account reasonably approximates the actual proportion of the employee's FTE effort which was devoted to that project.

• A contractor’s practices used in estimating costs in pricing a proposal shall be consistent with his cost accounting practices used in accumulating and reporting costs.
• A contractor’s cost accounting practices used in accumulating and reporting actual costs for a contract shall be consistent with his practices used in estimating costs in pricing the related proposal
• Excepted from 48 CFR Part 9904

Project Costing and Billing

Jerry M. Kekos

Ultimate Scientific Responsibility

Ultimate Budget Responsibility

Division Analyst, Budget Office, Controller, Accounts Receivable and Sponsored Projects Office

Advisor

Facilitator

Monitor

• Manages award within funding and time limits
• Assures charges are allowable & reasonable
• Responsible for personnel assignments
• Approves the Subcontract requisition
• Agreement
• Payment
• Ensures Sponsor pre-approvals are in place before event execution:
• Re-budgeting
• Key personnel
• Human/Animal
• Exercises responsible fiscal control
• Ensures compliance and reports non-compliance
• Responsible for training:
• Financial
• Administrative

Serves as an Advisor:

• Reviews and understands the Awards Terms and Conditions.
• Assures the that all award costs are treated consistently with regard to direct and indirect allocation and Cost Accounting Standards.
• Transactions are within the award funding (contract value), available cash balances, and period of performance.
• Reasonableness of cost of the transactions
• Reasonable allocation of the cost

Serves as a Facilitator:

• Processes financial transactions (i.e. certifies invoices).
• Reviews and analyzes financial reports for sponsored awards
• Prepares documents and provides information for re-budgeting if required by Sponsor.
• Prepares requests for Resource Adjustments (cost transfers) and validates for posting by Accounting.
• Prepares documents and provides information for compliance with effort reporting (such as "NIH Other Support") on the sponsored award

Serves as a Monitor:

Project Costing:

Ensures the correct burden codes and other attributes are assigned to the proposal and the project.

As project nears closure a greater importance is placed upon monitoring certain costs:

Equipment

Subcontracts

Large supply expenditures

Closely track funds in vs. cost expenditures- request bridge when needed and appropriate

All Costs must be in support of the project.

Billing:

One of the Division Analyst’s most important role is working with the PI and others to get the costs associated with an award right before it is invoiced.

Tools to Manage:

Cost Browser

Award Management

Soft Closes

Pre-audit selected financial transactions

Provide institutional oversight on resource adjustments

Perform risk analysis ensure compliance

Reports instances of financial non-compliance

Controller/Accounts Receivable

Prepare invoices to sponsors in timely basis

Prepare interim financial reports (with Divisions)

Approve or recommend approval of unexpended fund carry-forward

Assists P.I. & Divisions with procedural questions (billing & payments)

Proactively interacts with Sponsor during collection process

Reports instances of Financial non-compliance

• Authorizes Award Funding in RAPID and Distributes a SPAA
• Assists P.I. with procedural management of active research projects
• Reports instances of non-compliance

• Provide a seamless operation
• Everyone clearly knows what their roles are as well as how they fit into the larger picture
• Nothing gets
• passed,
• punted or
• dropped
• Be Proactive
• Take Responsibility
• Partner with other functional groups
• Ignorance is not bliss

• Accounts Receivable (AR) responsibilities
• Billing cycle
• Invoice types
• Final invoice
• Funding and award management
• Unbilled and bridge funds
• Cash management and procedures to alleviate negative cash position on non-federal awards

• Accounts Receivable Responsibilities:
• Billings to sponsors
• Collection activities
• Invoice and advance payment application
• final invoicing sponsors 90 days after project completion
• Refunds of any unused funds to sponsors
• Various financial status reports to sponsors and DOE

• Monthly cutoff for resource adjustments ~ 25th of the month
• Each month on Day 2 of the monthly close, ~29th of the month, the Project Cost (PC) to Billing interface runs
• This process gathers the project costs (up through cutoff) charged to the award and creates invoices
• Invoices are sent five days working days after month-end
• Invoices are due upon receipt

• Most federal agencies are invoiced and make payment via electronic means using the electronic Intra-governmental Payment and Collection (IPAC) system
• National Institutes of Health (NIH) payments are via electronic drawdown
• Certain Department of Army awards payments are made quarterly
• DOE Integrated Contractors (other DOE Labs) payments are via transfer vouchers but shortly invoices will be created and payments submitted via check or electronic funds transfer (EFT)

• At the end of an award AR works with SPO and Divisions to ensure all final costs are in, awards and projects are closed, and final invoices are submitted by the 90 day point (typical time period for final invoices)
• Refunds of unused monies are processed and usually take 90+ days
• The refund amount is requested from Department of Treasury via DOE

• Contract specific closing procedures are found at:

http://www.lbl.gov/Workplace/CFO/SPO/Closeouts/Closeout_Body.htm

• Proper funding management of sponsored research requires close coordination between P.I.,SPO, Divisions, and AR
• Ultimately the P.I. has responsibility for all aspects of award management including funding, budgeting, spending and closeout
• Incurring costs greater than funding or past the award’s period of performance is against federal regulations and results in unbilled costs

• The following is a list of unbilled types
• Costs exceed contract – The contract is within Period of Performance (POP) but total cost is higher than total funding
• Credit costs – The contract is within POP but the invoice payment plus advance paid/or total receipts is higher than total cost
• Past POP with funds – The contract is past POP but there is advance paid/or total receipts available to offset costs
• Past POP, no funds – The contract is past POP

but there is no advance paid/or total receipts available to offset costs

• Review – Requires further research to determine reason for costs in unbilled

• Resolution of unbilled costs should be initiated at the Division level and requires either an additional increment of funding from sponsor, extension of the period of performance, or removal of the costs to the appropriate project
• Bridge funding must be requested in order to work prior to receipt of advance funds or continuation of work in excess of funding
• Bridge funding is provided by UC and the lab has a total allocation of $2.7M
• To request bridge funding, fill out a bridge funding request form and submit to the Budget Office. Contact Budget with procedural questions
• Cash management requires that costs not exceed the cash received to date on the award (advance + invoice payments)

• To request bridge funding, fill out a bridge funding request form and submit to SPO
• The form is located at http://www.lbl.gov/Workplace/FSM/FSMDeptsandCriticalLinks.htm
• The bridge funding policies and procedures are under review by the CFO organization and will be changing. Any changes in procedures will be made known to you shortly

• Cash management requires that costs not exceed the cash received to date on the award (cash = advances + invoice payments)
• Currently DOE is scrutinizing sponsored project work to determine if laboratories are in a financially vulnerable cash position
• In order to ensure the Lab is not in a vulnerable cash position LBNL is stepping up the collection practices by coordinating closely with the P.I., Division, and SPO
• Important Note – Delinquent payments primarily occur on non-federal sponsors. Most federal sponsors payments come either automatically through drawdowns or other electronic means

• 30 days past due – phone call and dunning notice to sponsor by AR. Calls logged into PeopleSoft AR Conversations
• 60 days past due – phone call and second dunning notice to sponsor by AR. Calls logged into conversations. AR will notify SPO CO and Division Analyst if there are issues
• 90 days past due – Third dunning notice sent and notification to SPO CO and Division Analyst. SPO issues a notice (via fax) to sponsor that payment must be received by end of month or work will be suspended

• Division Analyst will let P.I.know that SPO will contact sponsor regarding possible suspension of work. All calls logged into Conversations
• 120 days – AR notifies SPO CO and Division Analyst that work should be suspended and the projects closed effective first day of the following month if payment not received
• SPO issues written notice via fax to sponsor that work has been suspended and a termination notice will be sent in 30 days if the payments have not been received

• Division Analyst informs P.I. That SPO will contact sponsor regarding termination and suspension of work. Calls logged into Conversations.
• 150 days – AR manager follows up with the sponsor to collect payment and notifies SPO CO and Division Analyst if sponsor has not paid
• SPO issues a termination notice via fax to sponsor on 150th day that the award is terminated on the 165th day

• 180 days - AR supervisor notifies SPO CO and Division Analyst that the award is being submitted to DOE/Treasury for collection
• AR will notify all parties if payment received. It would have to be decided on a case by case basis to continue research with the sponsor and under what conditions to minimize the financial risk to LBNL.

• Some tools to assist you:
• Award Management Report
• Monthly 737 report located on \\Issnov7\fsdata\Public\777rpt\FY04
• Monthly Invoice Aging Report located on
• \\Issnov7\fsdata\Public\Aging_Report
• Roles & Responsibilities Matrix located on SPO website
• PeopleSoft AR Conversations (Go/Manage Sales Activity/Collect Receivables/Use/Conversations. Input Customer ID. Notes section available for read/write)

• Managing Award expiration and closeout was reviewed at the RAPID Meeting on 3/19/04.
• Closeout usually entails the following:
• Financial Reporting and/or Final Invoice
• Scientific Reports and Deliverables
• Intellectual Property Reporting
• The roles and responsibilities and procedures can be accessed at:

http://www.lbl.gov/Workplace/CFO/SPO/Closeouts/Closeout_Body.htm

• Update on the “Internal LBNL WFO/CRADA Closeout Checklist”

• Tools to manage award expiration includes
• Award Management Report
• Monthly 737 report located on G:Public/777rpt
• E-Notifications for Award Expiration and Closeout

• Costs Exceed Award Funding (Contract Value) or Occur After the Period of Performance
• 25% of Funding Remaining.
• Costs have Exceeded Funding.
• Costs have Exceeded Funding thru a complete accounting cycle and Award and Projects close.
• Award Expiration and Closeout
• Award Expiration e-notices sent 90, 60, and 30 days prior to end of the period of performance.
• Email Notification for Award Closeout sent one day after the expiration date.

• When will the E-Notifications start?
• May, 2004
• Initial e-mails will be captured on a spreadsheet and sent to Division Analysts for review, comments and action.
• Who will receive E-Notifications?
• PIs
• Division Analysts (Managed through Smartlists)
• SPO CO assigned to the award
• AR at the time of Award and Project Closeout

• If the award remains in a negative funding position, the award and project will close on the first of the month following 30 continuous days in a negative position within a one month accounting period.

4/1/04

5/1/04

6/1/04

Award goes negative 4/15/04

Award remains negative through 5/31/04

Award and Projects Close effective 6/1/04