ASPIRE Fundamentals: Basics of Financial Grants Administration Session II

1
ASPIRE FundamentalsBasics of Financial Grants
Administration Session II

• May 4, 2006

2
Introductions
Sarah T. Axelrod Director of Cost Analysis
Financial Operations and Analysis Judy
McSweeney Associate Director, Financial
Services Office for Sponsored Programs Min
Xiao HMS Team Manager Office for Sponsored
Programs
3
Agenda

• Cash Management Judy (from previous session)
• Closeout and Disabling Min (from previous
  session)
• Federal Policies and Guidelines Sarah
• HMS/Harvard Policies Sarah
• HMS Sponsored Expenditure Policy Sarah
• Cost Sharing Sarah
• Cost Transfer Policy Sarah

4
Agenda cont

• Financial Reporting Policy Min
• Unreconciled Account Policy Min
• Effort Reporting Sarah
• Interest Earned Judy
• Interest Charged Judy
• Advance Account Policy - Min
• Roles and Responsibilities Min

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Cash Management

• Judy McSweeney
• OSP

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Cash Management Roles

• OSP performs many functions related to accounts
  receivable management
• Scheduling payments
• Invoicing and applying cash
• Collection follow-up
• Identifying issues of non-payment
• Department also performs cash related functions
• Reconciliation, management of award, submission
  of deliverables

7
Causes of Cash Management Issues

• Original negotiated terms
• Renegotiation of continued funding amendments and
  spending in excess of authorization
• Coding errors
• Timely billings
• Deliverables delayed or not accepted by the
  sponsor

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Strategies to Improve Cash Management

• A/R Oversight Committee meets regularly to
  analyze trends, address issues with specific
  sponsors, and identify ways to correct
  inefficiencies
• Many areas (OSP, SPA, FOA, RMAS, Dept.) involved
  in efforts to reduce sponsored receivable amounts
• Monthly follow-up on large Federal balances

9
Closeout Disabling

• Min Xiao
• OSP

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Closeout and Disabling

• GMAS monthly automatic disabling process
• Activity-Subactivity Disabling GL expenses GL
  income Final Figure
• Segments Close-out in GMAS ( manually )
• Funds Disabling automatically
• If problems arise, OSP team member will work with
  department administrators to resolve issues

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Potential Problems with Disabling

• Expenses posted in the current month
• Invalid codings
• Charges to non-sponsored funds and sponsored
  activity
• Cost sharing
• Work study
• Travel advances

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Post Award Roles and Responsibilities

• Principal Investigator
• Department Administration
• Financial Operations and Analysis (FOA)
• www.hms.harvard.edu/foa/
• Sponsored Programs Administration (SPA)
• www.hms.harvard.edu/spa/
• Office for Sponsored Programs (OSP)
• http//vpf-web.harvard.edu/OSP/

RR Matrix www.hms.harvard.edu/spa/responsibiliti
es.htm
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Federal Policies and Guidelines

• Sarah T. Axelrod
• FOA

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Federal Policies and Guidelines

• A-21
• CAS
• DS-2
• A-110
• A133

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OMB Circular A-21

• Cost Principles for Educational Institutions
• Issued by OMB (Office for Management Budget)
• http//www.whitehouse.gov/omb/circulars/

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OMB A-21

• Costs must be classified as DIRECT COSTS or
  INDIRECT COSTS (FA Costs)
• Direct Costs can be associated with a specific
  activity with a high degree of accuracy
• Indirect costs are costs that are incurred for
  common or joint objectives and therefore cannot
  be readily associated with a particular activity

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A-21 Activities
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Sections of Circular A-21

• The Circular, which is approximately 63 pages
  long, provides detailed guidance on
  classification of expenses as well as how FA
  costs should be allocated
• The Circular has one section devoted to guidance
  on specific selected cost items. Section J
  addresses many of the items in the HMS Sponsored
  Expenditure Policy

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CAS Cost Accounting Standards

• Educational CAS requirements include four
  Standards and a Disclosure Statement
• 501 Consistency in estimating, accumulating and
  reporting costs
• 502 Consistency in allocating costs incurred for
  the same purpose
• 505 Accounting for unallowable costs
• 506 Consistency in using the same cost
  accounting period
• DS-2 CASB Disclosure Statement

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CAS 501

• Requires consistency in the way costs are
• proposed
• accumulated
• reported
• Requires that the practices for estimating costs
  must be consistent with those practices used in
  accumulating and reporting costs
• States the proposed estimated costs should be
  comparable with actual costs for each cost item

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CAS 502

• All costs incurred for the same purpose, and
  under similar circumstances, are either direct
  costs only or FA costs only
• Each type of cost must be allocated once and on
  only one basis to any contract or other cost
  objective

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CAS and Consistency

• A summary of the direct cost consistency rules in
  A-21
• DIRECT COSTS
• Are specifically identifiable on a particular
  project
• With a relative degree of accuracy
• Incurred for same purposes, under like
  circumstances
• Treated consistently as a direct cost (or
  consistently as an indirect cost)

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The CAS Consistency Rules and Unacceptable
Practices

• Unacceptable costing practices for federal
  projects under CAS 502
• Rotation of charges among projects
• Charging projects with largest remaining balance
• Charging budgeted amount, not actual cost
• Charging projects in advance of when cost is
  incurred
• Describing a cost as something other than what it
  is examples
• office supplies as lab supplies
• adding a tax to direct costs
• Charging costs that benefit multiple activities
  (sponsored and nonsponsored) exclusively to
  sponsored projects
• Charging costs that are part of normal
  administration

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CAS Consistency Can Result in Disallowed Charges

• Note that due to the CAS Consistency rules
• Circumstances occur when costs that are
  specifically allowed in a Federal project budget
  may not be allowed to be charged to that award

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CAS Consistency - Exceptions

• The CAS standards indicate that costs should be
  treated as direct or indirect in like
  circumstances. Therefore, if the cost is
  incurred for different purpose and
  circumstance, then specific costs generally
  treated as indirect, can be charged directly.
• HMS treats all non-federal awards as different
  purpose and circumstance

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DS-2

• DS-2 stands for Disclosure Statement
• The DS-2 is a road map for auditors to audit the
  FA rates
• The DS-2 documents the HMS policies and practices
  relating to expenditures and cost allocation

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HMS/Harvard Policies

• Sarah T. Axelrod
• FOA

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HMS/Harvard Policies

• Sponsored Expenditure Policy
• Financial Management Guide to Policies,
  Procedures and Best Practices
• Cost Transfer Policy
• Cost Sharing Guidelines
• Service Center Policy
• Effort Reporting/Salary Certification Guidelines
• Interest Charges on Deficit Sponsored Fund
  Balances
• Unreconciled Account Policy
• Equipment Policies

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HMS Sponsored Expenditure Policy

• Sarah T. Axelrod
• FOA

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HMS Sponsored Expenditure Policy

• HMS Sponsored Expenditure Policy provides
  guidance on appropriate expenditure of sponsored
  funds
• Issued in March 2001
• Policy was written as a joint venture of FOA, OSP
  and Department representatives
• Currently convening a group to update this policy

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HMS Sponsored Expenditure Policy
Who should use this policy?

• Principal Investigators
• Grant administrators
• SPA
• OSP
• External Auditors

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HMS Sponsored Expenditure Policy
Specific types of costs addressed

• Administrative Salaries
• Allocation of general supplies
• Books, Subscriptions
• Copier Charges, copy cards
• Dues and memberships
• Local travel costs
• Telecommunications, cellular phones, internet
• Postage

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HMS Sponsored Expenditure Policy
General Cost Allowability all costs must be

• Allowable
• Allocable
• Reasonable

For unlike purpose and circumstances to exist all
three of the following criteria must be met

• Award is different from typical sponsored awards
• Cost can be associated with award with high
  degree of accuracy
• Sponsor has approved the cost in the award budget

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HMS Sponsored Expenditure PolicyAdministrative
Salaries

• Only allowable if administrative responsibilities
  are more extensive than a normal research
  project may include extensive data collection,
  analysis, travel arrangements
• Policy includes types of awards typically
  allowing administrative salaries and the
  positions that would qualify
• Normally 25 of an individuals effort should be
  charged to a single project

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HMS Sponsored Expenditure PolicyAllocation of
Direct Costs
Cost allocations must

• provide a reasonable linkage between the cost and
  the individual sponsored award
• be identified in advance and documented
• be applied uniformly to the entire population of
  sponsored agreements among which similar costs
  are incurred

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HMS Sponsored Expenditure PolicyAllocation of
Direct Costs
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HMS Sponsored Expenditure PolicyDirect Cost
Treatment of Specific Items

• Books
• Generally part of library costs
• Only allowable if 3 criteria are met
• Unlike circumstances
• Book cost can be associated with project with a
  high degree of accuracy
• Awarding agency has approved the cost as a direct
  cost
• Subscriptions
• Generally not allowable
• Copier Charges
• Generally not allowable
• Same criteria for exceptions as for books
• Dues and Memberships
• Generally not allowable

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HMS Sponsored Expenditure PolicyDirect Cost
Treatment of Specific Items

• Travel (see Harvard travel policy on VPF website)
• Be aware of Fly America and preferred vendor
  requirements Local Travel, Meals and Parking
• For meals to be charged to grants the PI must
  provide written justification of the business
  purpose and meet the 3 criteria
• Cost must be allowable under A-21and terms of the
  award
• Cost must be allocable to the project
• Cost must be reasonable
• Parking is generally not paid in the local
  environs as individual is not traveling and there
  are low/no cost options
• Exceptions are similar to those for meals
• Generally if mileage is reimbursable than the
  related parking is also reimbursable

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HMS Sponsored Expenditure PolicyDirect Cost
Treatment of Specific Items

• Telephones, cell phones internet access
• Normally an FA cost
• Criteria for direct charging
• Long distance calls
• Itemized cell phone calls
• Specific unlike purpose circumstances
• To charge directly, they must meet the
  allowability, allocability and reasonableness
  criteria
• Postage
• A-21 F6b(3) states that postage costs shall
  normally be treated as FA costs
• Express Delivery
• Can be charged to a grant when the expenses meets
  the 3 criteria (allowability, allocability,
  reasonableness)

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HMS Sponsored Expenditure PolicyCase Studies

• Professor Caller has a large survey grant and
  charges a dedicated telephone line to this grant.
  Is this allowable?
• Professor Traveler is working on a federally
  funded project in collaboration with several
  local hospitals. When he travels during the day
  to MGH he charges his parking. Is this
  allowable?
• What about when Professor Traveler periodically
  has to spend entire days at BWH and he parks
  there. Can he charge this to the grant?

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HMS Sponsored Expenditure PolicyCase Studies

• A research group has just finished a significant
  piece of work on their grant and the PI,
  Professor Generous takes them out to dinner. Can
  she charge this to the grant?
• Professor Bookworm buys a book on a new research
  technique that is specific to his primary NIH
  project. Can he charge this to that grant?
• Professor Teckie goes to MicroCenter and buys a
  statistical software package and allocates the
  charge to her 3 grants. Is this okay?

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HMS Sponsored Expenditure PolicyCase Studies

• Your department has a glass washing facility and
  the department administrator has proposed 3
  options for charging the grants. Which one do
  you recommend to her?
• Allocate to each PI based on the number of grants
  he or she has
• Allocate based on number of workstations assigned
  to each grant
• Allocate based on the number of experiments done
  in each period
• Professor Tightwad has funds remaining on his
  primary NIH grant that ends in 2 weeks. What can
  he do with the unspent funds?
• Professor Success received funding from the Big
  Heart Foundation and wants to charge his
  membership dues to 2 organizations to this award.
  Can she do this?

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Cost Sharing

• Sarah T. Axelrod
• FOA

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Cost Sharing

• What is Cost Sharing?
• Cost sharing is defined as any project cost not
  borne by the sponsor!
• Could be anything identified in the narrative or
  the budget that will support the project, but is
  not paid for by the sponsor
• Cost sharing on research projects is a direct
  cost and is included in the Organized Research
  Base for the School (thus decreasing the FA
  rate)

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Types of Cost Sharing

• Mandatory required by sponsor
• Voluntary offered by grantee in the proposal
• Salary cap salaries in excess of the NIH salary
  cap levels (183,500 effective 1/1/06)
• Grant or contract over-expenditures identified at
  the end of the project

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Cost Sharing Issues

• Since Cost Sharing decreases the FA rate, what
  can we do to minimize it?
• Do not offer unrequired Cost Sharing in proposals
• Do not quantify the Cost Sharing commitment for
  non-key personnel,
• e.g. Dr. Smith will provide expert advice to
  this project,
• instead of Dr. Smith will spend 5 of her time
  on the project.
• Sound management of awards to reduce
  overexpenditures

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Recording Cost Sharing

• If a proposal contains cost sharing, it must be
  noted on the Proposal Routing Form
• Cost sharing form is required at the time of
  award
• Form is prepared by department
• Signed by PI
• Signed by Director of Cost Analysis
• Recording/tracking cost sharing is the
  responsibility of the department
• Applicable expenses should be charged to the cost
  sharing account string
• E-tads should be updated to reflect any cost
  sharing of payroll

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Recording Cost Sharing

• Cost Sharing is tracked by a mismatch between the
  G/L FUND segment and the ACTIVITY segment
• The FUND segment indicates the source of funds
  (in the case of cost sharing the source is HMS,
  ie unrestricted funds)
• The ACTIVITY segment indicates the use of funds
  (the funds are used to support the grant,
  therefore the grants activity/subactivity
  account string is used)

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Cost Sharing - Case Studies

• Is This Cost Sharing?
• Professor Busy has committed 50 effort to an NIH
  grant but actually spends 70 of his time on the
  project. Do you record cost sharing?
• Professor Lucky receives a 20 salary increase
  which puts her over the NIH cap. She charges 75
  of her time to federal awards. Do you need to
  record cost sharing for her salary?

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Cost Sharing - Case Studies

• Is This Cost Sharing?
• The chairman of your department buys an expensive
  piece of equipment for Professor Superstars lab.
  Is this cost sharing?
• Professor Poor just received his NIH award but
  was granted only 50 of his requested funding.
  His effort commitment was not reduced from the
  proposed 40. There will not be enough funds to
  cover his salary which will be charged to the
  departmental budget. Will you need to record
  cost sharing?

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Cost Transfer Policy

• Sarah T. Axelrod
• FOA

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Cost Transfer Policy

• Cost Transfer Policy ensures compliance with A-21
  requirements for transfers of charges to federal
  awards
• Policy revised effective January 2002
• Policy clarified October 2004
• A cost transfer is any transfer to a federally
  sponsored account of a charge previously recorded
  elsewhere

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Cost Transfer Policy

• Federal regulations require that transfers to
  federally funded sponsored accounts be timely and
  properly documented
• To demonstrate that adequate financial controls
  are in place, cost transfers should be kept to a
  reasonable minimum
• Monthly monitoring of accounts using the Period
  Expense Report and Detail Listing is encouraged
  to identify incorrectly allocated expenses

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Cost Transfer Policy
COST TRANSFER POLICY TRAINING SESSION
May 18th, 2006 MEC 250 930 11
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Financial Reporting Policy

• Min Xiao
• OSP

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Sponsored Financial Reporting Policy

• Policy Objectives
• Clarify reporting roles and responsibilities
• Identify which expenses will be included on
  financial reports
• Reduce number of unreconciled accounts and
  revised Financial Reports
• Develop consistent reporting practices across
  departments

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Financial Reporting Policy (OSP)

• Each month, the OSP Financial Analyst should run
  the Scheduled Report in CREW identifying which
  financial reports and invoices are due within
  next 30-60 days
• Review and prioritize outstanding financial
  reports list and communicate with departments for
  upcoming reporting deadlines, including annual
  reports or final invoices for the budget periods
• Draft a FSR or a final invoice based on latest
  PER figures and send to department for review
• Work with department to resolve various issues
  and prepare necessary adjustments ( remove
  unallowable transactions, over spent or under
  spent, carry forward, overhead etc. )
• Submit FSR to sponsor before deadline

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Financial Reporting Policy (Dept.)

• Each month, the departmental administrators
  should run the Segments report in CREW
  identifying those awards with anticipated end
  dates within next 120 days
• Ensure all outstanding expenses have posted (e.g.
  web vouchers from affiliates, salaries,
  subcontract final invoices etc.)
• Review expenses for cost compliance - remove any
  unallowable/non-allocable charges (contact OSP
  for cost transfer issues)
• Remove any over-expenditures and reconcile to
  budget
• Review and approve draft FSR ( 5 business days)

59
Financial Reporting Policy Case Studies

• Julie, a grants manager for Professor Smith run
  the Segment report in CREW, and has identified
  five awards will ended within next 120 days, what
  should she do if
• -the award is significantly underspent?
• -the award is significantly overspent?
• -no subcontract invoices have been received?

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Financial Reporting Policy Case Studies

• 2. Professor McCarthy receives a final invoice
  from a subcontractor 2 weeks after agreeing to a
  final figure with OSP. Should the department pay
  the invoice? Can the charge now be added to the
  financial report?
• 3. Professor Davis receives a draft FSR for his
  R01 award that has a financial report due at the
  end of the week. The FSR shows the award under
  spent by 10k. He is certain all funds should be
  spent but he doesnt have time to spend on it
  now. He advises his administrator to have OSP
  report the award as fully spent. Are there any
  issues with this approach?

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Unreconciled Account Policy

• Min Xiao
• OSP

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Unreconciled Accounts Policy

• Policy Overview
• All sponsored accounts must be reconciled
  promptly and no later than 6 months after the
  termination date. (training grants with obligated
  stipends and tuition/fees no later than 15
  months )
• http//vpf-web.harvard.edu/OSP/closing/clos_unr_ac
  counts.shtml
• Policy Objectives
• Streamline the closeout process
• Reduce audit disallowance exposure
• Reduce delay/withholding of funding by sponsors

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Unreconciled Accounts Policy

• Policy Processes and Procedures
• Identify unreconciled accounts by running and
  reviewing theUnreconciled Accounts in CREW
• Review PERs and detail listings all unreported
  expenses should be removed
• Overspent accounts charges need to be removed
• Underspent accounts revisions may be required
• Departments should contact OSP representative
  with any questions

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Unreconciled Accounts Policy

• Unreconciled Accounts ( after six months from the
  termination date)
• Overspent Accounts to be written off by OSP
  against an unrestricted account provided by the
  tub Financial Dean
• Underspent Accounts the FSR will be revised by
  OSP to accurately reflect the expenditures on the
  Universitys general ledger ( PER)
• Remaining funds to be returned to the sponsors
  after the revised final reports are submitted.

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Effort Reporting

• Sarah T. Axelrod
• FOA

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Monthly Effort Reporting Policy Non-Faculty
Effort

• Policy Overview
• Review and certification of non-faculty salary
  charged to sponsored awards must be made monthly
  and within one months time.
• The person who signs effort certifications forms
  must have direct knowledge of lab activities and
  the efforts of all individuals associated with a
  specific research grant.
• http//www.hms.harvard.edu/foa/docs/effortpol.pdf

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Monthly Effort Reporting Policy Non-Faculty
Effort

• Policy Objectives
• Ensure that we are in compliance with federal
  regulations.
• Reduce our exposure to possible audit findings.
• Ensure that salaries charged are commensurate
  with effort expended.
• Maintain our ability to secure funding.

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Monthly Effort Reporting Policy Non-Faculty
Effort

• Policy Procedures
• One person in each department should run,
  distribute, and collect the salary certifications
  
• PIs should sign the certifications (Department
  administrators or grants managers take on
  personal responsibility and risk if they sign the
  forms)
• The process should be completed each month after
  the month-end closing
• If actual effort differs from salary charged,
  correct the salary coding. Use cost sharing
  coding if appropriate.
• Return signed forms to FOA monthly.

69
Monthly Effort Reporting Case Study Non-Faculty
Effort

• As your Departments Effort Coordinator, it is
  your job to collect and review the certified
  effort reports that come to you every month.
  This month you observe that Dr. Busy has
  certified 50 effort against his R01 for a
  Research Assistant whom you know has switched
  full-time to another project during the last
  month.
• What are the issues here?
• What do you do?

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Faculty Salary and Effort Certification

• Process Overview
• HMS is required by Federal regulations to certify
  all salary and wages charged to Federal Grants
• Faculty/PI salaries are certified on an annual
  basis, at the end of the fiscal year
• The Form, sent out by FOA, summarizes all Harvard
  University salary and wages paid to a PI,
  regardless of the Tub or Org
• Forms are sent along with detailed instructions
• Forms should be signed by the faculty member
• Any change /- 5 must be noted, with appropriate
  action taken (e.g., remove costs from award
  and/or transfer costs to an award).

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Faculty Salary and Effort Certification Case
Study

• This years effort certification form for Dr.
  Smart reflected Salary as follows
• Project 1 (NIH 1) 20
• Project 2 (NIH 2) 15
• Project 3 (NSF) 15
• Project 4 (AHA) 5
• Non-sponsored 45
• In completing this years effort certification,
  Dr. Smart indicated that her time on Project 2
  had increased to 20, and her time on Project 1
  had decreased to 15 .
• What are the issues here? What needs to be done?

72
Faculty Salary and Effort Certification Case
Study

• What if Dr. Smart had indicated that her time on
  Project 2 had increased to 25, her time on
  Project 1 had decreased to 15 and her time on
  Project 3 had decreased to 10?
• What if Dr. Smarts annual base salary is
  185,000? What issues are involved now? How
  should this be reflected on the form if this was
  accounted for correctly?
• What if Dr. Smart also receives 25,000 year in
  clinical income from BIDMC?

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Interest

• Judy McSweeney
• OSP

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Interest Income On Non-Sponsored Awards Policy

• Policy Overview
• All non federal sponsored funds with credit
  balance in the prior month, net of year-to-date
  interest, will receive interest income.
• http//vpf-web.harvard.edu/OSP/setup/set_ngne_inte
  rest.shtml
• Policy Objectives
• To provide interest income on non federal awards
  with credit balances.

75
Interest Income On Non-Sponsored Awards Policy

• Policy Processes and Procedures
• Federal guidelines do not allow interest to be
  retained on federal awards.
• Eligible funds will earn interest at the annual
  simple interest rate set annually by the
  University (currently 2.8, changing to 4 July
  1, 2006).
• On a monthly basis OSP/general accounting will
  post interest income to the main account of each
  award.
• Interest income will be posted to object code
  4530

76
Interest Income on Non-Sponsored Awards Policy

• Policy Processes and Procedures, cont.
• The use of a funds interest income must follow
  the terms and conditions of the award
• If the sponsor has no restriction on interest
  income, tub may use it for project related
  expenses or transfer to a non sponsored fund
  using object code 5920
• In the event of an improper income entry, contact
  your OSP representative

77
Interest Charges on Deficit Sponsored Fund
Balances

• Policy Objectives
• To mitigate costs to the Central Bank
• To ensure strong financial accountability at the
  local level.

78
Interest Charges on Deficit Sponsored Fund
Balances

• Policy Overview
• Interest will be assessed against for types of
  deficit fund balances, each of which results in
  costs to the Central Bank
• Dead accounts any fund with anticipated and
  obligated end dates three months old or greater,
  where expenses exceed obligation or income by
  1,000 or more. (Effective 3/1/04)
• Overspent accounts active awards with
  anticipated and obligated end dates more than 90
  days in the future, where expenses exceed
  obligation or income by 10,000 or more. (Likely
  to be implemented 6/1/04).
• Advance accounts likely to assess advance
  accounts that are 120 days or older (still in
  development)
• Late reimbursements (still in development
• http//vpf-web.harvard.edu/OSP/support/sup_def_int
  erest.shtml

79
Interest Charges on Deficit Sponsored Fund
Balances

• Policy Processes and Procedures
• Overexpenditures calculated at the account group
  level.
• Overexpenditures exist when expenses exceed
  available funds (the greater of the total
  obligated amount plus carry-forward, and income
  plus adjustments).
• Reports listing deficit balances sent to the tubs
  at the beginning of every month. Journals to
  clear overexpenditures must post no later than
  the last day of the month to avoid an interest
  charge (assessed after month-end close)
• Charges assessed monthly at the annual simple
  interest rate set annually by the University
  (currently 2.8, changing to 4 July 1, 2006).

80
Interest Charges on Deficit Sponsored Fund
Balances

• Policy Processes and Procedures, cont.
• Charges are calculated monthly by OSP and posted
  monthly via ADI journal entry.
• Interest charges are levied against unrestricted
  School/Dept. funds interest charges may not be
  levied against any sponsored awards.
• Financial aid awards are excluded from interest
  charges.
• Interest charges may be viewed by using either a
  Detail Listing report or a Summary Actuals report
  and searching on object code 7630.
• You can run the Interest Policy report for your
  area in CREW

81
Advance Account Policy

• Min Xiao
• OSP

82
Advance Account Policy

• Policy Overview
• Advance accounts are established at departmental
  risk to allow PIs to begin incurring expenses
  prior to institutional acceptance of an award
• Departments are responsible for covering expenses
  incurred if an award is not made
• Policy updated effective 2/26/04

83
Advance Account Policy

• Policy Objectives
• Allow PIs and departments to track expenditures
  using the same account coding that will be used
  when the award is made
• Eliminate the need for cost transfers
• Establish a 120 day limit for keeping an account
  in advance status
• Provide guidelines for monitoring advance
  accounts and removing charges from advance
  accounts that will not be awarded

84
Post Award Roles and Responsibilities

• Min Xiao
• OSP

85
Post Award Roles and Responsibilities

• Principal Investigator
• Department Administration
• Financial Operations and Analysis (FOA)
• Sponsored Programs Administration (SPA)
• Office for Sponsored Programs (OSP)

Roles and Responsibilities Matrix
www.hms.harvard.edu/spa/responsibilities.htm
Financial Management Guide to Policies,
Procedures and Best Practices http//www.hms.harva
rd.edu/foa/docs/finmgmtguide.pdf
86
Principal Investigator

• Ensure that programmatic objectives of research
  are accomplished
• Monitor Subrecipients
• Signoff on final expense figures and final
  financial reports
• Ensure accuracy of effort reports
• Make sure technical, invention, and patent
  reports submitted

87
Department Administration

• Reconcile accounts on a monthly basis
• Upload GL budget
• Transact to sponsored accounts and ensure that
  expenses are allowable and allocable
• Distribute monthly effort certification reports
• Process cost transfers in a timely manner
• Resolves issues identified on the unreconciled
  accounts report and invalid coding report (CREW)

88
Office for Sponsored Programs

• Serves as a resource for departments on all
  aspects of post award management
• Post audit expenses
• Track the need for and prepare financial reports
  and invoices
• Manage cash (LOC, checks, wires, collections)
• Closeout and disabling of sponsored accounts
• Coordinate the A-133 audit
• Work with FOA and SPA to coordinate issue
  resolution with departments and sponsors

89
Financial Operations and Analysis

• Review, approve, and track cost sharing
• Give users access to financial systems
• Distribute annual effort reports and work with
  departments to resolve effort reporting issues
• Collect and monitor monthly effort certifications
• Monitor invalid coding report status
• Manage the unreconciled accounts report clean-up
• Review and approve 90 day cost transfers
• Deal with issues relating to the HMS FA rates
• Work with OSP and SPA to coordinate issue
  resolution with departments and sponsors

90
Sponsored Programs Administration

• Assign sponsored chart of account numbers
• Negotiate subcontracts
• Approve rebudgeting requests
• Approve no cost extensions
• Process award changes
• Work with FOA and OSP to coordinate issue
  resolution with departments and sponsors

91
Conclusion
92
Basics of Financial Grants Administration
Session II Wrap up

• Any Questions?
• If you are not sure who to contact with a post
  award question call
• Sarah Axelrod 432-3284
• Min Xiao 432-6281
• Next Session
• Cost Transfer Training
• May 18, 2006
• Register on eCommons - www.ecommons.med.harvard.e
  du
• (navigate to SPAs Events calendar)