Surviving the Post Award Process

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Surviving the Post Award Process

• Susan Campbell, Sr. Accounting Manager
• Grants and Contracts Office
• Office of the Comptroller

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Agenda

• Overview of the Responsibilities of the Post
  Award Office
• Focus on Effort Reporting
• Post Award Administration of Sponsored Projects

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What are our goals?

• Prudent stewardship of external funds
• Effective management of institutional business
• Be a resource to faculty, staff and students
• Compliance, Compliance, Compliance

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What does the Post Award Office do?????

• Account Setup
• Funds Approval
• Financial Reporting/Invoicing
• Special Reporting
• Effort Reporting
• Budget Revisions
• Cost Transfers
• Changes in Project Status
• Account Close Out

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Focus on Effort Reporting

• Why do I have to complete this report?
• OMB Circular A-21, J-10c(2) Compensation for
  personal services, after-the-fact activity
  records to confirm appropriateness of charges

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Who has to complete an effort report?

• Anyone who has effort pledged to or is paid from
  federally sponsored projects or other sponsored
  projects

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Effort Reporting Form
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How do I fill out this form?

• Verify accounts identified as a pay source
• What type of activities are you working on?
• Is there a UMC account number assigned to those
  activities?
• How much effort have you committed to various
  projects?
• Is there someone working on your project that is
  not getting a report?
• What if the employee has left the department or
  UMC during the month?
• Sign and date the report

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Common Problems.

• Invalid account numbers
• Omission of account numbers / activities
• Reporting effort under wrong category
• Reporting effort to faculty research enhancement
  program pay source (28007)
• Returning forms with no effort or incorrect
  percentages written in (Percent effort100)
• Report not signed and dated
• Report not turned in timely

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Note for FY03/04Effort Reports

• All effort reports for the period
• July 1, 2003 through June 30, 2004 are due by
  August 15th

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Questions on Effort Reporting
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Post Award Administration of Sponsored Projects

• What is a Sponsored Project?
• Any financial award (grant, contract or
  agreement) from external sponsors to conduct
  specified research, training or public service
  projects.

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Incurring Allowable CostsJust because it is in
the budget does not always mean it is an
allowable cost to the project
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Incurring Allowable Costs How do I know if a
cost is allowable?

• Reasonable
• Allocable
• Consistent Treatment
• Limitations and Exclusions
• If in doubt, please call us...

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Incurring Allowable Costs

• The primary guidance for allowable costs for our
  Federal programs is OMB Circular A-21. The link
  for the circular is...
• http//www.whitehouse.gov/omb/circulars/index.htm
  l
• This documents provides examples of allowable
  costs and guidance for making the determination.
• The Office of Research website provides links to
  policy statements on most of our sponsors.
• The link to OoR website is http//research.umc.ed
  u/

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Cost Transfers

• What is a cost transfer and what is our policy?
• Transfers of costs to any sponsored project that
  represent corrections of clerical or bookkeeping
  errors must be made within 90 days. All
  transfers must be supported by documentation that
  fully explains how the error occurred and
  certification of the new charge by the principle
  investigator. Transfers of costs from one budget
  period to the next or from one project to another
  to solve funding problems or other reasons of
  convenience are not allowable.

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Cost Transfers

• Are cost transfers a real compliance risk?

YES
Constant audit target for the past 20
years Specifically discussed in the CAS audit
guide, A-21 and A-133
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Which transfers should be of concern?

• Transfers on Federal Project
• Transfers that move charges more than 90 days of
  the original charge
• Transfers to Federal Projects at the end of a
  project

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Which transfers should be of concern?

• Transfers with inadequate explanation (i.e. To
  correct error or to charge correct project)
• Transfers between Federal Projects when an
  overdraft is involved
• Salary transfers (Retroactive PAR)

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Changes in Project Scope
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What constitutes a change in project scope?

• A change in the specific aims approved at the
  time of the award
• Substitution of one animal model for another
• Shifting emphasis of research from one disease to
  another
• Transferring work to a third party
• Change in key personnel
• Significant re-budgeting
• Incurrence of patient care costs not originally
  approved

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Changes in Project Scope

• Requesting a no cost extension for a project
• You can request a one time no cost extension on
  most awards in a final year, provided one of the
  following conditions exist
• Additional time is needed to ensure adequate
  completion of the originally approved project
  Continuity of funding is required while
  completing a continuation application Extension
  is necessary for the orderly phase out of a
  project that will not receive future support.
• What do I need to do 1) Prepare a
  justification letter addressed to the sponsoring
  agency 2) include grant number and requested new
  expiration date 3) leave a place for business
  office to countersign request letter 4) submit to
  Grants and Contracts for review, signature and
  submission to sponsor AT LEAST 30 DAYS BEFORE THE
  CURRENT END DATE

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Changes in Project Scope

• If you have a change in project scope during a
  budget period contact the Grants and Contracts
  Office for instructions
• These changes require
• business office approval prior
• to submission of request
• to sponsor.

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Financial Monitoringof Sponsored Projects

• It is the responsibility of the PI to ensure that
  all charges are appropriate.
• The Grants and Contracts Office prepares
  financial reports and/or invoices for most
  sponsored projects.
• Exception.. Clinical Trial Agreements.. The PI
  / study coordinator prepare invoices.

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Financial Monitoring

• The PI should review all invoices and financial
  reports.
• UMMC requires PI signature on all financial
  documents prepared for sponsored projects.
• Monthly budgets statements are sent to the
  PI/dept. Questions should be discussed with
  Grants and Contracts

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Close Out of Sponsored Projects

• Lets Bring It To An End
• At the end of the budget and/or project period
  the Grants and Contracts Office will prepare a
  final accounting for the sponsor
• Exception. Clinical Trials. We do not know it
  is over until you tell us!

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Things to Consider When Closing Out a Sponsored
Project

• Submit Final Technical Report to Sponsor
• Change Employee Pay Source via PAR
• Clear Out All Outstanding Purchase Orders
• Check Budget Statements for Charges After the End
  of the Project
• Resolve Any Over-expenditures or Unallowable
  Charges

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Close Out of Clinical Trial Accounts

• Please Notify the Appropriate Compliance Office
  AND the Grants and Contracts Office the Study is
  Complete

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Close Out of Clinical Trial Accounts

• To Utilize Residual Funds from Industry Sponsored
  Projects you Must Provide the Grants and
  Contracts Office with
• 1) A copy of the notification letter to/from the
  IRB stating study has been closed
• 2) Documentation from sponsor that study is
  complete
• 3) A memo from the PI certifying that all
  expenditures / obligations related to the project
  have been finalized

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General Information
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Grants and Contracts OfficeOrganizational Chart
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UMMC Grants Policy Manual

• The Accounting manual is on the UMMC Intranet.
  Go to Intranet home page - Support, then
  Comptrollers Office
• The direct link to the Grants Information is
• http//accounting.umc.edu/Departments/depts_Grants
  Contracts.html