Principal Investigator Training

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Principal Investigator Training

• Financial Oversight of Sponsored Programs

New York University School of Medicine Finance
Division October 29, 2003
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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
PURPOSE OF TRAINING
Good fiscal management results from a joint
effort between the Principal Investigators,
Department Administrators and Finance

• To give Principal Investigators (PI) the tools
  with which to exercise oversight by
• Making PIs aware of Federal and School of
  Medicine policies
• Providing PIs with guidance in exercising
  oversight

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
TRAINING LIMITATIONS
It is not possible to present training materials
that cover every situation, or every granting
agencys particular set of regulations. The
materials presented here are intended to aid the
PI in managing sponsored programs. They have
general applicability to most Federal research
grants, and many other Federal and non-Federal
awards.
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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
TRAINING OUTLINE

• Why the Principal Investigator (PI) ?
• NIH Compliance Issues
• What every PI should know
• What every PI should do
• Key points in PI oversight
• Indicators of problems
• Contact Information
• External Resources
• Q A

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
WHY THE PI ???

• The PI has 1st hand knowledge of sponsored
  activity to allow for
• Correlation between application and awarded
  grant activities
• Proper allocation of costs
• Adequate resources applied to programs

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
NIH COMPLIANCE ISSUES

• Allowable/Unallowable Costs
• Misuse of Funds on a particular grant
• Allocation of Costs (especially salary charges)
• Cost Transfers
• Accelerated Expenditures
• Unobligated Balances

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
WHAT EVERY PI SHOULD KNOW

• Program Income
• Rebudgeting
• Roles Responsibilities

• Direct Costs
• Effort Certification
• Allowable/Unallowable costs
• Equipment Purchases
• Travel Expenses
• Cost Transfers
• Cost Sharing

• WHAT EVERY PI SHOULD DO
• Grant status reports/eReports
• Agency Reporting
• Compliance check
• Contact Information

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
WHAT EVERY PI SHOULD KNOW

• Direct Costs
• Costs must be related to the project charged
• Costs must be reasonable the prudent person
  test
• Costs related to multiple programs must be
  allocated base on
• - proportional benefit, where possible
• - any reasonable basis, where necessary
• Costs may not be assigned on fund availability,
  award expiration date or other inappropriate
  criteria

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
WHAT EVERY PI SHOULD KNOW

• Effort Certification
• Each professional employee must review and sign
  their own time and effort report, certifying to
  100 percent of their effort.
• Non-professional employees effort certification
  are signed by either the employee or department
  designee with suitable means of verification of
  the staff members effort.
• Certify how time was actually spent, not how
  payroll was distributed.
• For NIH grants, Federal approval is required for
  changes in effort of 25 or more of the budget.

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
WHAT EVERY PI SHOULD KNOW
Allowable/Unallowable Costs Unallowable costs
is a Federal term denoting costs not reimbursable
under Federal grants contracts. Federal
regulations prohibit certain costs, most common
being - entertainment - alcoholic beverages -
air/rail fare in excess of lowest available -
general office supplies (in most cases) -
clerical administrative salaries (in most cases)
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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
WHAT EVERY PI SHOULD KNOW

• Equipment Purchases
• Definition 3,000 and useful life of 1 years
• Purchases during the last 60 days of terminal
  year may be problematic
• School of Medicine tags, tracks, and capitalizes
  equipment. Dispositions and moves must be
  reported to Finance Property Manager, Joe Martin,
  3-8795

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
WHAT EVERY PI SHOULD KNOW

• Travel Expenses
• Limited to lowest commercial fare economy
• Must use U.S. carriers
• Daily allowance for lodging meals is limited
  to 250

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
WHAT EVERY PI SHOULD KNOW

• Cost Transfers
• Cost transfers are used to correct, reassign, or
  redistribute costs between chartstrings.
• Must comply with the principles of direct costs
• Project funds are NOT interchangeable
• Exception, not routine
• Done on a timely basis
• Justified documented

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
WHAT EVERY PI SHOULD KNOW
Cost Sharing

• Definition specific portion of the project or
  program costs, which are not funded by the
  sponsor cost sharing cannot come from another
  Federal project.
• Cost sharing must be in compliance with the
  institutions cost sharing policy.
• Types
• Committed
• Voluntary
• Mandatory

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Cost Sharing - Functions
Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
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Cost Sharing - Funding
Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
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Cost Sharing - Effort
Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
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Cost Sharing
Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
WHAT EVERY PI SHOULD KNOW

• Program Income
• Definition Gross income earned by the recipient
  of a sponsored award that is directly generated
  by the supported activity or earned as a result
  of the award
• Anticipated program income should be identified
  in the application or subsequent to the award
• In certain cases program income must be reported

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
WHAT EVERY PI SHOULD KNOW

• Rebudgeting
• NYU Rebudgeting Policies include the
  following-Rebudgeting between direct and
  indirect
• Rebudgeting of direct costs
• 12 month extension without additional funds
• Request to carryover
• Issuance of pre-award costs

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
WHAT EVERY PI SHOULD KNOW

• Roles Responsibilities (PI)
• Maintains local oversight including
• Initiating and approval of expenditures
• Budget vs. spending is reasonable
• Avoids cost overruns
• Identifies Program Income

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
WHAT EVERY PI SHOULD DO
Grant Status Reports/eReports

• Review available eReports to ensure expenditures
  are charged to appropriate Sponsored Program
• Review Grant Status Report to aid in making
  personnel and other related decisions regarding
  your Sponsored Programs

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
WHAT EVERY PI SHOULD DO
Agency Reporting

• Financial Status Report (FSR)
• Progress Report
• Invention Statement
• Inventory Equipment

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
COMPLIANCE CHECK

• Questions to consider
• Have I lived up to my fiscal stewardship
  responsibilities through diligent oversight of my
  sponsored research?
• How would this transaction be perceived if it
  were reported in the newspaper?
• NYU SoM
• Code of Ethical Conduct Hotline
• [phone]
• www.med.nyu.edu/compliance

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
KEY POINTS

• Dont park expenses in project chartfield only to
  be transferred at a later date
• Review final grant status report (update) to
  insure concurrence

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
INDICATORS OF PROBLEMS
Watch out for these problem indicators

• Unauthorized or inappropriate charges
• Unallowable costs
• Overdrafts or large balances
• Assignment of costs based on fund availability or
  project expiration
• Cost Transfers (frequent, delinquent, poorly
  justified, etc.)
• Equipment purchases near end of project

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
CONTACT INFORMATION

• If you are not sure about the applicability of a
  particular provision to your project, check with
  your departmental administrator, Sponsored
  Programs Administration, or the Sponsored
  Programs Area of the Controllers Office.

Robert Cohen Senior Director 212-263-6796 Tony
Marsicano Director of Sponsored
Programs 212-263-6671
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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
USEFUL LINKS

• Finance website
• http//www.med.nyu.edu/finance
• Sponsored Programs Administration
• http//www.med.nyu.edu/spa/
• OMB Circulars
• http//www.whitehouse.gov/omb/circulars
• (Includes A-21, A-110, A-133)
• NIH Grants Policy Statement
• http//www.nih.gov/grants/policy/nihgps/nih_gps.pd
  f

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Principal Investigator TrainingFinancial
Oversight of Sponsored Programs
Q A FEEDBACK