Grants: Cradle to Grave

1. Grants: Cradle to Grave Post Award Processes and Effort Reporting

2. Today’s Agenda • What is Post Award? • What are the PI’s Responsibilities? • What are Compliance Requirements? • I am a researcher why do I have to approve expenditures and monitor budgets? • SRAS Review of Expenditures • Advance Policy • Cost Transfer Policy • CAS Exemptions • What is cost sharing? • What is Effort Reporting • OMNI Overview • PI Resources New Fac Post Awd

3. What is Post Award? Activities that occur after award documents have been executed by appropriate institution authority • Award is to the Institution, not the PI • Budget number assigned • Cost sharing expenditure accounting • Research can begin • Adhere to scope of work • Collaboration/subcontracting to other individuals/institutions • Status reports • Technical reports NOTE some invoices require submission prior to payment New Fac Post Awd

4. What is Post Award? • Spending occurs • Plan ahead to meet deadlines • Personnel – Human Resources policies and procedures • Non Personnel – Purchasing/Travel/Subcontract/Non PO policies and procedures • Central Offices have role in reviewing allow ability of expenditures • Billing/Collecting from agencies (central office responsibility) • Financial reporting to agencies (central office responsibility) • Amendments (SOW & Budgetary) • Contracting Officer for grantor and grantee New Fac Post Awd

5. What are the PI’s 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 • Monitor subcontractor performance New Fac Post Awd

6. What are Compliance Requirements? • Federal • OMB Circulars applicable to University • A-21 (more on this later!) • A-110 • A-133 • Available on OMB website at: http://www.whitehouse.gov/omb/circulars/index.html • Agency specific requirements • Terms and Conditions in award • Non Federal • Terms and Conditions rule!! • FSU SR Related Policies and Procedures • http://www.research.fsu.edu/contractsgrants/policypro.html# New Fac Post Awd

7. What are Compliance Requirements? • Hot button issues frequently cited in audits • Cost transfers onto or between projects – do it right the first time! • Expenditures late in the project – using up available balance • Cost share accounting/reporting • Effort reporting processes • Charging costs normally considered overhead directly to projects New Fac Post Awd

8. 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” New Fac Post Awd

9. 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 New Fac Post Awd

10. Sponsored Research 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 • Sub recipient Monitoring • Unallowable Costs • Closeout Authority – Memorandum dated September 24, 2008 New Fac Post Awd

11. How do I collaborate with another researcher? • Often included in proposal • Institution approval vs. researcher • Participates in research (sub recipient) vs. provider of goods/services (vendor) • Starts with SRS Subcontract Coordinator • Standard agreement • Incorporates Federal requirements • Encumbered in OMNI as PO • Numbers = RXXXX • PI approves invoices (deliverables met) New Fac Post Awd

12. Why do I approve expenditures and monitor budgets? • 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 New Fac Post Awd

13. SRAS Review of Expenditures • Transactions SRAS Coordinators evaluate • Requisitions > $1,000 • Travel and Expense reports > $1,000 • Unencumbered expenses (pay requests/stipends) • All personnel appointments • All journal entries • Cost Transfer Justification Form • All interdepartmental requisitions New Fac Post Awd

14. SRAS 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 Dates of Award period • Available Balance • Direct Cost Funds available for Expense by budget category line item • Account or Job Code • Appropriate for nature of expense • Allowable • Terms and Conditions support expense New Fac Post Awd

15. Advance Policy • Purpose: 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 SRS (as evidenced by a project budget) • DO NOT charge expenses for pending award to another funding source • Transfers will not be approved New Fac Post Awd

16. Cost Transfer Policy • Purpose: 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 • Avoiding/alleviating an over expenditure • Moving unallowable costs on one project to another • Circumventing award restrictions • Reimbursing a temporary “loan” of funds from another project New Fac Post Awd

17. Cost Transfer Policy • Examples of proper cost transfers • The transfer represents an adjustment for an erroneous charge • Split purchase • Timeliness of identification and correction of errors is essential to evidence sound fiscal management • Policy • Payroll – within 30 days of end of the month in which error occurred (agrees with RDF Policy) • Non-Payroll – within 90 days of end of month in which error occurred (or within 30 days of the project expiration date. New Fac Post Awd

18. 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 New Fac Post Awd

19. 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 expenses typically treated as an indirect cost directly to a sponsored project unless there are exceptional circumstances New Fac Post Awd

20. CAS Exception Process • Must be documented for all federally-funded awards • Pertains to direct charge costs that are normally treated as indirect costs • Inclusion in the budget in the award document does not automatically grant the exception • Form at http://www.research.fsu.edu/contractsgrants/forms.html • Submit to Director, Sponsored Research Services New Fac Post Awd

21. What is Cost Sharing? • Policy at http://www.research.fsu.edu/contractsgrants/costsharing.html • Definition = Costs 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 • Include in the proposal budget • Cost Share Commitment Form • Signed by Chair/Dean/Director • Cost Share budgets are set up in OMNI • Does not include 3rd party • Transfer the cash for PI, SRAD, Auxiliary, FSU Fdtn, Research Fdtn funding sources New Fac Post Awd

22. What is Effort Reporting? • Federal government expects Universities to • Meet commitments • Provide evidence that commitments have been met • FSU certification cycle • Certify after each academic term • Application = Faculty Assignments effort Certification Tracking (FACET) • Provide reasonable estimate of time spent on various activities (instruction, advising, projects, etc.) New Fac Post Awd

23. 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) New Fac Post Awd

24. PI Resources New Fac Post Awd

25. Training Opportunities • CReATE Compliance and Research Administration Training and Education • Next session in Fall 2010 • SP2089 Proposal Development for Sponsored Programs Training • Lunch & Learn series • 1-2 per month • Wednesdays 11:30am – 12:30pm • Current schedule http://www.research.fsu.edu/contractsgrants/workshops.html) New Fac Post Awd

26. 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) New Fac Post Awd

27. 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/) • Tuition Waiver Information • Purchasing (http://www.purchasing.fsu.edu/) • Human Resources (http://hr.fsu.edu/) • OMNI Resources (http://erp.fsu.edu/OMNI-Training) New Fac Post Awd

28. QUESTIONS New Fac Post Awd OMB A-21