Grants: cradle to grave alumni Center ballroom May 6 , 2014

1. Grants: cradle to gravealumni CenterballroomMay 6, 2014 Post Award Processes & Effort Reporting Roberta McManus Associate Director – Sponsored Research Administration

2. Agenda • Post Award Activities • Principal Investigator's (PI) Responsibilities • Compliance Regulations • Key Financial SR Policies • Budget & Expenditure Monitoring • SRAS Review of Expenditures • Collaboration with Other Researchers • OMNI Overview • PI Resources

3. Post Award Activities • Award documents have been executed • Signed by appropriate institution authority • Award is to FSU, not the PI • Proposal and Award number • Project number assigned – budget activated! • Cost sharing accounting • Research can begin • Adhere to scope of work • Collaboration/subcontracting to other individuals/institutions • Monitoring of activities - documentation • Status reports • Technical reports • Payments will be held if not submitted timely • Hold up future awards!!

4. Post Award Activities • 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 Coordinators review allowability of most (not all) expenditures • Billing/Collecting from agencies (SRA responsibility) • Financial reporting to agencies (SRA responsibility) • Amendments (SOW & Budgetary) • Contracting Officer for grantor and grantee • Starts with Award Administrator

5. Post Award Activities • 90 days prior to award end • New funding increment? • Request extension if needed/allowed • Notify university grants officer in accordance with timelines established

6. Principal Investigator (PI) 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 • Obligations in proposal and/or award documents • 2 months of PI’s effort for academic term • 15% of PI’s time for fall semester • Must be met whether paid from award or not • Monitor subcontractor performance

7. Award Closeout • SOW complete and final reports submitted • Expenditures are complete: • All charges incurred during project period are posted • Avoid late cost transfers • Charges posted allowable • Necessary and benefit the award • Subcontractor • SOW complete • Final invoice processed timely • Effort reported for amount of time expended on project • Commitments met • Funded or not funded by award

8. Compliance Requirements • Federal • New Federal guidance issued December 2013 • Effective for awards/increments issues on/after December 26, 2014 • 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.html#

9. 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”

10. 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

11. SR 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 • Subrecipient Monitoring • Unallowable Costs

12. Advance Policy • 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 SRA (as evidenced by a project budget) • DO NOT charge expenses for pending award to another funding source • Transfers will not be approved

13. Cost Transfer Policy • 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 • Moving overrun on one project to another project • Moving unallowable costs on one project to another project • Circumventing award restrictions • Reimbursing a temporary “loan” of funds from another project

14. Cost Transfer Policy • Proper cost transfers • The transfer represents an adjustment for an erroneous charge • Split purchase • Timeliness • Essential to evidence sound fiscal management • Monthly reconciliations!!!!! • 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 • SRA Cost Transfer Committee • Assistant Director –SRA Accounting Chairs

15. 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

16. 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 administrative and clerical expenses directly to a sponsored project unless there are exceptional circumstances

17. CAS Exception Process • Must be documented for all federally-funded awards • Pertains to direct charge costs that are normally treated as indirect costs • Personnel • Non-personnel • Inclusion in the budget in the award document does not automatically grant the exception • Form at http://www.research.fsu.edu/contractsgrants/forms.html • Justify exceptional circumstance • Submit to Sponsored Research Administration

18. Cost Sharing • Policy at http://www.research.fsu.edu/contractsgrants/costsharing.html • Procedures at http://www.research.fsu.edu/contractsgrants/documents/csprocedures.pdf • Definition = Costs not 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

19. 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 SRA or will hold up being able to spend • Does not include 3rd party • Transfer cash when using these funding sources: • PI Support projects • SRAD projects • FSU Foundation • FSU Research Foundation

20. Effort Certification • Effort = Amount of time expended on a particular activity • Federal government expects Universities to • Meet commitments of time by key personnel (PI/CO-PI) • Provide evidence that commitments have been met • Requires periodic reporting by faculty and other staff working on sponsored projects • Application = Faculty Assignments Effort Certification Tracking (FACET) • After each academic term (Fall, Spring, Summer) for Exempt (PIs) • Monthly for Non-exempt employees (OPS – temporary) • Provide reasonable estimates of time/effort spent on various activities (instruction, advising, projects, etc.)

21. Budget & Expenditure Monitoring • 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 • Expect/Request expenditure reports • Personnel – staff charged/encumbered • Non-personnel

22. SRA Review of Expenditures • Requisitions > $1,000 • Travel and Expense reports > $1,000 • Unencumbered expenses (pay requests/participant requests) >$1,000 • All personnel appointments • Payroll cost transfers (Retroactive Distribution of Funding – RDF) • Cost Transfer Justification Form • All journal entries • Cost Transfer Justification Form • All interdepartmental requisitions • Sales between departments (stockrooms, machine time, etc.)

23. SRA 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 • Available Balance • Direct cost budget check • Budget category line item • FDP/RTC

24. SRA Review of Expenditures • Account or Job Code • Appropriate for nature of expense • Allowable • Remember OMB Circular A-21! • Terms and Conditions support expense

25. Collaboration with Other Researcher • Often included in proposal • Institution approval vs. researcher • Participates in research (sub recipient) vs. provider of goods/services (vendor) • Starts with SRA Subcontract Coordinator • Standard agreement • Incorporates Federal requirements • Encumbered in OMNI as PO • Numbers = RXXXX • PI approves invoices (deliverables met)

26. 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)

27. PI Resources

28. Training Opportunities • CReATE – Compliance and Research Administration Training and Education • Next session Fall 2014 • New Federal guidance • SRA Certificate Series • Curriculum geared toward support staff • Hands on tools • Summer schedule in process • Schedule posted at http://www.research.fsu.edu/contractsgrants/workshops.html

29. 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)

30. 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/) • Matriculation Waiver Information • Purchasing (http://www.purchasing.fsu.edu/) • Human Resources (http://hr.fsu.edu/) • OMNI Resources (http://erp.fsu.edu/OMNI-Training)

31. Contact Information SRA Assignment Sheet http://www.research.fsu.edu/contractsgrants/documents/staff.pdf

32. QUESTIONS