Sponsored Program Administration Basics

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Sponsored Program Administration Basics

• Presented by
• Jeff Coleman, Irene Jorgensen, and Jerilyn Hansen

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Sponsored Programs Administration

• Sponsored Programs Office
• Funding Opportunities
• Proposals
• Award Administration
• Coordinate Closeout

• Sponsored Programs
• Accountants
• (Controllers Office)
• Account Set-up
• Financial Reporting
• Invoicing
• Financial Closeout

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Sponsored Programs Office Mission

• Provide quality service to faculty and staff
• Provide assistance to support research
• Assure compliance
• Protect the Universitys assets keep the PI out
  of jail

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Operations of the Sponsored Programs Office

• Funding Opportunities
• Proposal Development/Review
• Award Negotiation and Acceptance
• Project Administration
• Coordinate Administrative Closeouts

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1. Funding Opportunities

• The Foundation Directory
• 10,000 Grant Issuing Foundations
• Annual Register of Grant Support
• 3500 Grant Support Programs
• InfoEd International
• Sponsored Program Information Network (SPINPlus)
• GENIUS
• SMARTS
• Contact Corey Burger (Corey.Burger_at_usu.edu)

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2. Proposal Development / Review

• Solicitation Guidance
• University/Sponsor requirements
• Sponsor Forms
• Overhead (FA) Rates
• FA rates stay the same year to year as
  originally proposed.
• Limited Submission Proposals
• Budget Development/Review
• Benefits Rates
• Allowable, Allocable, Reasonable (OMB A-21)
• Conflict of Interest
• Subcontracts / Collaborations
• Signature Authority for the University

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Budget Development

• Resources for budget development
• Your Sponsored Programs Administrator and
  Accountant
• MTDC vs. TDC for Indirect Costs Rate (FA)
• Extra Compensation
• Subcontracts/Collaborations
• Sponsored Programs Budget Template
• http//spo.usu.edu/files/uploads/Proposal_Budget_T
  emplate.xls
• GAMS
• https//gams.usu.edu/index.html

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Budget Justification
Most sponsors require that a budget justification
accompany the budget. This section of the
proposal gives the rationale for the requests
made in the budget.

• Salary Benefit Rates
• (Multiple year increases - inflation)
• Other Direct Costs
• Lab equipment, computer time, fees, etc.
• Travel (No. of trips, travelers, destination)
• Equipment (Over 5,000 or life expectancy of gt 2
  years)

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Proposal Development Issues

• Indirect Cost (FA) Rate
• What is it? - Actual costs incurred in a
  sponsored project that are not directly charged
  because to do so would be costly and cumbersome
  to determine. Examples space, utilities,
  library, general administrative services,
  compliance, such as IRB, safety personnel, and
  compliance committees.
• How is it Determined? Total anticipated costs for
  all indirect services and facilities are
  computed. The rate is then determined by taking
  (indirect Costs)/(Modified Total Direct Costs) X
  100.
• When to use it? Always use negotiated rate unless
  sponsor does not allow full rate and provides a
  lesser rate or does not allow it at all.

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Indirect Cost (FA) Waiver

• An indirect cost waiver is an institutional
  agreement that indirect costs will be charged at
  a rate lower than the sponsors published rate.
• Verification stating sponsors IDC limitations
  must be attached to the waiver, or signature and
  approval from the Vice President for Research.

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How does Sponsored Programs Review a proposal?

• Review Request for Proposal (RFP) / Request for
  Application (RFA) and Announcements
• Review Budget
• Review Administrative Forms
• Review SP-01

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SP-01 (What is this?)

• Internal Approval Form
• http//spo.usu.edu/files/uploads/SP01.pdf
• SP-01 Proposal Information Form
• Project Information
• Document Indirect Cost (FA) Waiver
• Document Cost Share
• Compliance Issue
• Safety, Human Participants (IRB), Animal Use
  (IACUC), Radioactive Materials, rDNA, Hazardous
  Chemicals.
• Conflict of Interest
• Institutional Approvals

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3. Award Negotiation and Acceptance

• Types of Awards
• Grant
• Most Common Sponsored Agreement
• Financial assistance for research or other
  program as specified in an approved proposal 
• Sponsor anticipates no substantial programmatic
  involvement with the recipient
• Terms and conditions are usually standard for
  particular sponsors
• Cooperative Agreement
• Similar to a grant but substantial programmatic
  involvement by the sponsor is anticipated during
  the project
• Contract
• Principal purpose of the agreement is to provide
  tangible results or other deliverable items or
  to carry out a prescribed service for the direct
  benefit or use of the sponsor
• Usually terms and conditions are strict and
  fiscal management inflexible

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Award Administration

• Review and negotiate terms and conditions
• Publication Restriction
• Confidentiality (GRAMA)
• Indemnification
• Intellectual Property
• Period of Performance
• Budget
• Reporting Requirements
• Signature Authority for the University

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4. Project Administration

• Cost Issues
• Administrative Issues
• No Cost Extensions
• Project Revisions
• Re-budgets
• Sabbatical Leave/Leave of Absence
• PI Leaving University/Award Transfer
• Monitor submission of annual technical reports

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Subaward Administration

• Sponsored Programs Office Responsibilities
• Signature Authority for the University
• Sub Award Information Form
• Sponsor Approval
• A-133 Audit
• Sponsor Terms and Conditions

• Sponsored Programs Accountants Responsibilities
• Financial Monitoring
• Invoices
• (Payment Monitoring)

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5. Administrative Closeouts

• Monitor Technical and Financial Reporting
• Reports or deliverables are required of
  most awards
• Intellectual Property Patent Notifications
• Equipment Reports
• Document Retention

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Financial Administration
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Sponsored Program Accounting Mission

• Provide post-award fiscal and administrative
  support to the campus community
• Ensure regulatory compliance with university,
  state, and federal polices
• Safeguard University assets

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Office of Management and Budget (OMB)

• Office in the Executive Branch of the President
  of the United States
• OMB assists the President in the development and
  implementation of annual national budget, and
  supervise its administration in Executive Branch
  agencies
• Provides ongoing direction in the implementation
  of financial management policies and systems.
• Provide the highest quality regulatory analysis

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OMB Circulars

• Purpose Provide standards for obtaining
  consistency and uniformity among Federal Agencies
• Federal agencies pass the requirements to
  recipients of federal funding
• Effect Set minimum standards for institutions

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Federal Regulations

• OMB Circulars
• A-21 Cost Principles for Educational
  Institutions
• A-110 Administrative Standards
• A-133 Audit Standards

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OMB Circular A-21 Cost Principles for Educational
Institutions

• Purpose Establishes principles for determining
  costs applicable to grants, contracts, and other
  agreements with educational institutions
• A-21 addresses both direct and FA (indirect)
  costs
• Determines what costs can be included in the FA
  calculation

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A-21 Continued

• Defines Allowablility of Costs
• Reasonable
• Allocable
• Treated Consistently
• Conform to limitations in A-21 or sponsored
  agreement

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Time and Effort Certification

• . What is effort reporting
• - Accounting of effort on
  sponsored agreements
• - Must certify to 100 effort
• . Why is effort reporting important?
• - Requirement of OMB circular A-21
• - USUs obligation to exercise good
  stewardship of funds.

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Time and Effort Certification continued

• - Faculty and staff salaries charged to sponsored
  programs shall be commensurate within 5 of the
  direct effort provided to the project.
• - Differences between payroll distribution and
  percent of effort in excess of 5 need to be
  corrected In the payroll system.

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What is a cost transfer? Policy at
http//www.usu.edu/hr/policies/581.htm

• A cost transfer is an after-the-fact
  reallocation of cost from one Index/project to
  another Index/project.
• Excerpt from OMB Circular A-21
• Any costs allocable to a particular sponsored
  agreement under the standards provided in this
  Circular may not be shifted to other sponsored
  agreements in order to meet deficiencies caused
  by overruns or other fund considerations, to
  avoid restrictions imposed by law or by terms of
  the sponsored agreement, or for other reasons of
  convenience.

.
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Unallowable Costs Section J(Cannot be charged
against Federal agreement, used as cost sharing
or placed in the FA cost base)

• Advertising
• Alcoholic beverages
• Entertainment
• Fines penalties
• Moving Costs if employee resigns within twelve
  months
• Certain recruitment costs

• Lobbying
• General public relations alumni activities
• Student Activities
• Commencement
• Social Memberships

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Cost Accounting Standards

• . Created by Congress to establish
  accounting rules and regulations.
• - CAS 501 Consistency in Estimating,
  Accumulating, and reporting Costs
• - CAS 502 Consistency in Allocating Costs
  Incurred for the same Purpose
• - CAS 505 Unallowable Costs
• - CAS 506 Cost Accounting Period

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Cost Sharing

• Portion of university share of expenses related
  to total research projects
• Do not include cost sharing amounts on the
  proposal budget if it is not required by RFP
• Do not exceed the cost sharing level or amount
  specified in the solicitation

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Sources of Cost Share

• MOST PROJECTS
• EG, returned overhead or unrestricted accounts
• EG provides economic advantage
• Benefits paid from pool, but counted as cost
  share
• Waived F A
• If approved by Sponsoring Agency

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A-110 Purpose

• Sets forth standards for obtaining consistency
  and uniformity among Federal agencies in the
  administration of grants to and agreements with
  institutions of higher education

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Aspects of A-110

• Effect on Issues
• No agency can impose rules that are in conflict
  with A-110
• Deviation
• OMB can grant exceptions in unusual circumstances
• Subcontracts
• A-110 applies to any subcontractors performing
  work under an award

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OMB Circular A-110Uniform Administrative
Requirements

• Expanded Authorities under OMB A-110 C.25e
• Agencies can waive cost-related and
  administrative prior approvals
• University Sponsored Project Offices can approve
• Pre-award costs (up to 90 days prior to award
  start date)
• First no-cost extension up to 12 months
• Carry forward of balance

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Project Closeout

• Sponsored Programs Office is responsible for the
  oversight of the closeout of awards.
• Required Reports
• Technical Principal Investigator
• Equipment Central Property Control Office
• Patent/Invention PI in collaboration with
  Technology Commercialization Office (TCO)
• Fiscal Controllers Office
• Sub-awards Sponsored Programs Office with PI
  and Controllers Office
• Reports from sub-recipients needed in advance in
  order to close USUs award.

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Reporting Requirements

• Established by the sponsor and communicated in
  the award instrument. Timely report submission
  is important

• Critical stewardship
• Requirement (part of the terms and conditions)
• Incremental funding or future funding may be
  dependent upon receipt of the report

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Closeout Documents

• Final Invention Statement
• http//spo.usu.edu/files/uploads/USU_Final_Invent
  ion_Statment.pdf

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Audits

• Question When do you start preparing for an
  audit?
• Answer The day the proposal is being prepared

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Who Audits the University?

• Federal Government Office of Naval Research
  (ONR) is USUs cognizant audit agency
• A-133 Auditors USU utilizes the services of
  Deloitte Touche LLP
• USU Internal Auditors

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Key to a Successful Audit

• Organized Files
• Documentation for expenses
• Appropriate Approvals
• Audit Trails (i.e., documentation)
• Knowledge of policies and regulations
• If its not documented, it didnt happen.

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Audits

• Document! Document! Document!
• When transfers are required Defend the Debit
• Auditors want to know why the award was charged
  for the expense

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A Look at Accusations

• George Washington University Engineering
  professor charged with embezzling almost 600,000
  in federal grants by directing the money into his
  own private companies. Also charged with using
  University money to pay his cousins wife for
  work that she never did. The court case is still
  pending. Article taken from the Chronicle of
  Higher Education, 2/4/05

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A Look at Accusations

• University of Connecticut engineering professor
  resigned his tenured position after being accused
  of spending thousands of hours on his private
  consulting practice and neglecting his academic
  work.
• Florida Atlantic University professor resigned
  following accusations that he used state money to
  give an edge to a company that he had created to
  make and sell the same mine-detecting submarine
  that he was studying at the university.

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A Look at Settlements Associated with
Noncompliance

• Northwestern University (5M mischarging
  Federal Grants, fraud, Time Effort issues)
• Yale University - Tenured Professor forced out
  for allegedly padding his business travel
  expenses by approximately 150,000. He has made
  full restitution and resigned. 1/21/05 article
  from the Chronicle of Higher Education.

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A Look at Settlements Associated with
Noncompliance

• Florida International University - 11.5M for
  improperly billing the U.S. Dept. of Energy for
  scientists time, travel and administrative
  expenses. Article taken from the Chronicle of
  Higher Education, 2/15/05
• The Johns Hopkins University - 2.6M to settle
  claim that scientists had overstated the amount
  of time they were spending on projects financed
  by the federal government. Article taken from
  CHE, 3/1/04

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Words to the Wise

• If you dont like being audited by an auditor,
  you will really dislike being audited by an angry
  auditor.
• National Council of University Research
  Administrators (NCURA)

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Current Federal Hot Buttons

• Final Reports
• Cost Transfers
• Cost Sharing
• Effort Reporting
• Departmental Administrative Costs
• Subaward Monitoring
• Program Income

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Additional Resources

• OMB Circulars
• http//www.whitehouse.gov/omb/circulars/a021/a21_2
  004.html
• http//www.whitehouse.gov/omb/circulars/a110/a110.
  html
• http//www.whitehouse.gov/omb/circulars/a133/a133.
  html
• Sponsored Programs Office
• http//spo.usu.edu
• Sponsored Programs Accountants
• http//controller.usu.edu

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• Questions?