Award Management. NUTS & BOLTS. November 2008. FACILITATORS. Comfort Brownell, Financial Reporting Manager , (SAO) Mark Varley , Senior Financial Accountant , (SAO). Pre-Test/Post-Test Who to contact. Post Award Management 201 Award Process -Topics.
Award Management NUTS & BOLTS November 2008
FACILITATORS • Comfort Brownell, Financial Reporting Manager, (SAO) • Mark Varley, Senior Financial Accountant, (SAO)
Pre-Test/Post-Test Who to contact
Post Award Management 201 Award Process -Topics • Mission and overview of Sponsored Accounting and Cost Compliance Office (SAO) • Players in the Process • Types of Award • Award Life Cycle • Award Management Guides • Managing Spending Activities • SAO Role in the Fiscal Management of the Award
SAO Mission & Purpose • The Cost & Sponsored Accounting Office (“SAO”) is responsible for monitoring and executing the post-award administration of sponsored activity for the University. • To provide the best service possible to the Georgetown faculty and staff in their pursuit and administration of external funding. • We are here for you! Website: http://www9.georgetown.edu/finaff/sao/sao.htm
Cost & Sponsored Accounting Office 2121 Wisconsin Ave; NW • James Reisert, Director • Cost & Compliance • Robert Layser, Manager • Christopher Biggs • Accounting Sector • Marc Peters, Manager • Vacant • Vivian Belleh • Financial Reporting Sector • Comfort Brownell, Manager • Amarjit Singh • Janice Little • Mark Varley • Michel Nau • Pius Kiilu • 687-2313 • 687-5462 • 687-2589 • 687-4126 • 687-3481 • 687-2615 • 687-3941 • 687-7069 • 687-3734 • 687-9231 • 687-0496 • 687-4428
Overview of Research at Georgetown University GU Faculty Academic Department/Center/Institute Sponsored Research Office–SRO, Pre-Award Ofc., Post Award Non-financial(Medical Center) Office of Sponsored Programs--OSP, Pre-Award Ofc., Post Award Non-Financial(Main Campus and Law Center) Internal Review Board (IRB) Office of Technology Licensing (OTL) MedStar (Medical Center) Players at Georgetown
What federal agencies fund research at Georgetown? SPONSORS Federal Other Governmental Agencies Non-Governmental Sponsors
Just in Case You’ve Been Wondering Why We Do What We Do, Here It Is…….. For The Fiscal Year Ended June 30, 2008 Georgetown University Received Approximately $97,328,663 (New Awards $ Amount)
Types of Federal Awards FDP • Recognizes PIs as the person best positioned to manage both programmatic and financial affairs of a research grant. • Gives PIs authority to approve post-award changes NSF • All awards directly from NSF are FDP PHS Non-Research Awards (Public Health Service) • Has standard set of regulations that covers all of its non-research grants (PHS Grants Policy Statement-Postaward Administration, Chp 8)
Types of Federal Awards PHS Expanded Authorities • PHS (including NIH) waived approval of certain actions which had previously required awarding office prior approval • All research grants not covered by FDP USDE Awards • Department of Education-Education Department General Administrative Regulations (EDGAR)
Types of Awards Grant:when the principal purpose is the transfer of money, property, services or anything of value to accomplish a public purpose authorized by federal statute. Cooperative Agreement:used synonymously with “grant” but sponsor has control and oversight of the work being performed. There is substantial involvement of the federal agency.
Types of Awards Contract:legal instrument used when the government is purchasing a supply or service. It is generally based upon submission of deliverables. Subawards:when Georgetown issues a subgrant or sub-agreement to another University or to an organization that is assisting in the performance of work under the grant.
Contracts Often RFP solicitations Need for specific service/product Schedule technical & expenditure reports and/or other deliverables Grants Often standard guidelines/proposal kits Support for Proposed work in general programmatic areas - need to advance knowledge Requires technical progress reports Major Differences between Contracts and Grants
Contracts Payment often tied to deliverables Numerous special terms and conditions Close control on budget Usually audited Can be cancelled for default Grants Payments may be in advance, by schedule, or upon completion General terms and conditions Flexible budget control Some audited Almost never cancelled More Major Differences
Types of Award IPA:Intergovernmental Personnel Act Agreement is when a faculty member is detailed to a federal agency for a finite period of time, generally 12 months. Individual remains a GU employee and GU bills agency for salary and fringe for the period. Gifts:funds given by a foundation or corporation and the only restriction is that they be used for the project.
Types of Awards Clinical Trials: (1) A clinical trial is a controlled study involving human subjects, designed to evaluate prospectively the safety and effectiveness of an investigational drug or device. (2) A type of research study that tests how well new medical treatments or other interventions work in people. The study may be carried out in a clinic or other medical facility.
Award Life Cycle 1. Proposal and Negotiation 5.Final Reporting, Closeout and Disabling 2.Award Receipt and Account Setup 4.Reporting and Cash Management 3.Transacting (Budget and Expenses) • Primarily Department , OSP & OSR • Primarily OSP & OSR • Primarily Department • Primarily SAO and Department • All Areas
Components of a Budget DIRECT COSTS The amount of money that it will cost the faculty member to conduct the project. Costs that can be specifically identified with a particular project or program.
Components of a Budget INDIRECT COSTS Federal Research Rate 53.5% Federal Training Awards 8% Off Campus Rate 26% Other Sponsored Activity 39% Pharmaceutical Agreements 30% Foundations & Corporations 15% **also referred to as “F&A—facilities & administrative” and “overhead.” Cost incurred by the University during a project that cannot be specifically identified with a particular project.
Post-Award PhaseAward Receipt • The NoGA must be reviewed by: • SRO/OSP • The PI • The Budget Manager/Department Administrators
Post-Award PhaseAward Receipt The following questions can be considered when reviewing the NoGA: Do the funds awarded correspond to the budget in the proposal? Has the agency made any unilateral changes in the project scope? Does the award include special terms and conditions? What are the reporting requirements
Award Accepted and Set-Up inPeopleSoft System • Information regarding the proposal and award is entered into PeopleSoft by SRO/OSP • Sponsored Program Action Notice (SPAN) and a copy of the NoGA are forwarded to the PI/dept and SAO (sample SPAN report)
Award Accepted and Set-Up inPeopleSoft System Period of Performance • RX cost center opened for period of performance as specified by agreement terms: – Option to continue – Specified increments – Continuation period
Award Accepted and Set-Up inPeopleSoft System Project Funding Period There are different ways the sponsor can obligate funding: – Entire amount – Option periods (specifies an option to continue funding the research) – Increments (any increment can be specified) – Based on continuation years (eg: one year at a time)
When You Accept Money from the Federal Government • They have the power • They write the rules • They can hurt you bad if you do not play by their rules • Fortunately they give us the rule books
University Code of Ethical Conduct “As we conduct our many University activities, we must always remember that we are responsible for maintaining the highest ethical standards and for complying with relevant laws, regulations and policies.” –John J. DeGioia, President “I’m Listening!”
Award Management Guides • Projects are managed in compliance with the following regulations: • University Policies • Individual award terms and condition • OMB circulars: • A-21 • A-110 • A-133 • Federal Acquisition Regulations • NSF GC-1 • NSF Grants Policy Statement • NIH Grants Policy Manual • NASA Grant & Cooperative Agreement Handbook
OMB Circulars Translated • A-110If you want our money you have to be able to handle it. Is your financial administration good? • A-21If you want to charge us you must do it this way. Allocability and Allowability • A-133If you get our money this is what we are going to do to you. Annual Audit.
A-21 Cost Principles-Fundamentals ALLOWABILITY ALLOCABILITY REASONABLENESS CONSISTENCY Cost must meet ALL FOUR Criteria
A-110-Fundamentals • Establishes uniform administrative requirements for Federal grants and agreements awarded to institutions of higher education. • Federal awarding agencies shall not impose additional or inconsistent requirements, except ( in limited cases where approved by OMB or where in writing in special conditions)
FAR- Working With Contracts Federal • Is a system of uniform policies and procedures governing the acquisition (purchasing) of all federal agencies • Is the procedures manual for federal agencies to acquire goods and services, including research - Universities with federal primes may include FAR or the sponsor’s terms and conditions Non-Federal – may have their own unique terms and conditions.
Effects of Noncompliance Immediate loss of funding for all federally funded human subject Research Damage to an institution’s Reputation Jeopardizes future ability to secure research funding Damage to an investigator’s reputation Adverse effects on graduate research students
Managing Spending Activities FEDERAL AWARDS ARE AUDITED YEARLY- Risk Areas • Effort Reporting (Personnel Activity Reports) • Direct Cost Testing (Allocability and Allowability) • Cost Transfers (Properly Documented) • Cost Sharing/Matching • Overdraft • Subrecipient Monitoring
Managing Spending Activities • Financial access • Complete signature authorization forms • Training (Payroll, Purchasing, A/P, CSR) • CSR generation (PTF’s & charging expenses) • Purchasing—same as for GX cost centers
Managing Spending Activities • Personnel Transaction Forms (PTFs) • Supplies (Boise Cascade/Procurement Card) • Travel • Subawards • Consultant • Cost Transfers (preaward costs) • Track cost sharing/matching
Transfers- What is Required? • Document! • Document! • Document! Auditors want to know WHY you are charging the award! Auditors Also want to know WHY the transfer is being processed 120 days after the fact! Defend the debit! Adequately justify the reason for the transfer NOW! • ALL transfers must be supported by documentation that fully explains how the error occurred and a certification/approval of the correctness of the new charge by PI or someone with knowledge of the project activities
Regulatory Guidance – Circular A-21 (Sections C2-C4, C7) • Cost transfers should NOT be performed: • To shift costs to sponsored awards to meet funding shortfalls from other sources (or cover overruns), • To avoid restrictions imposed by law or by terms of the sponsored award, • For other reasons of convenience: To spend out available balances…. • Costs associated with these transfer actions must: • Meet the Definition of a Direct Cost • Allowable • Allocable • Reasonable
Cost Transfer-important to note Federal agencies do not consider transfer of charges as correction of an error or mistake. Large volume of cost transfer is indicative of an unhealthy financial environment.
QUESTIONS Which are acceptable cost transfer explanations? • To correct an error. • To transfer costs that were held in another federal award that acted as a clearing account. • To transfer overdraft. • To charge appropriate account.
GU Cost Transfer Practices Procedure-Cost transfer Processing: Non payroll cost transfer Payroll cost transfer Procard cost transfer Policy # FA 113-06: Cost Transfers Involving Sponsored Program Accounts • Cost Transfer Form • Payroll Journal
Sub-award or Sub-contact • Prior approval requirements • Is the subcontract or sub award included in the proposal? • If sponsor approves at the proposal review and acceptance stage, no additional documentation or sole source justification is usually required Policy-Policy # FA 143-05
Sub-award Monitoring • Financial • Tracking subrecipient allocations separately • Assessment of correct F&A (e.g., only on first $25,000) • Process for review and approval of subrecipientinvoices- • Obtaining reimbursement for disallowances of unallowable, unallocable or unreasonable costs • Verifying cost sharing commitments