Title: Faculty Grants Management Program
1Faculty Grants ManagementProgram
2Office of Sponsored Programs
- Lynne ChronisterAssociate Vice Provost of
Research / Director - 206-543-4043
- lchronis_at_u.washington.edu
3Office of Sponsored Programs
- Function Facilitate faculty in the development,
submission and management of externally sponsored
programs. - OSP is the Office of Record and facilitates the
business and administrative components of the
proposals and awards.
4Office of Sponsored Programs
- Life cycle of the administration of research
- Pre-award stage through submission
- Award stage Negotiation and acceptance
- Post-award stage Expenditures and reporting (and
potentially auditing)
5Office of Sponsored Programs
- OSP administrators organized by college and
department - Industry-sponsored clinical trials
- Sub-contracts
- Export control
6Office of Sponsored Programs
- What do we do?
- Review and approve proposals
- Submit electronic proposals
- Negotiate and sign awards and subcontracts
- Liaison with sponsor for award life
- Coordinate close-out of awards
- Implement Grant Contract policies (financial,
legal, and regulatory)
7Office of Sponsored Programs
- Submitting proposals
- eGC-1 form, on-line SAGE system for routing and
approval. - Budgeting
- Direct costs OMB Circular A-21 Revision (May
1996) OMB Circular A-21 Revision (May 1996) Cost
Accounting Standards (See page 30.) - Cost Sharing
- Indirect costs/facilities and administrative
costs/overhead 56 for on-campus research
8Office of Sponsored Programs
- What do we review on proposals?
- Budget details
- Compliance issues (regulatory, legal)
- Forms completed
- All requisite components included and compliant
-
9Office of Sponsored Programs
- Indirect Costs
- Research rate 56
- On-campus vs. off-campus
- Waivers of indirect costs
- Bottom line You cannot charge the government
twice for the same thing. They just dont like
it. -
10OMB A-21, Appendix C May 1998
- Examples where indirect costs may be charged as
direct costs - Large Complex Programs
- Extensive Data Accumulation
- Extensive Travel
- Manuals and Large Reports
- Geographically Inaccessible
- Project-Specific Database Management
- Graphics
- Human or Animal Protocol
11Compliance Issues
- Does the proposal involve the use of animals?
Human subjects? - Just in time procedure.
- Significant financial interest (conflict of
interest) - Export controls
- Use of unapproved stem cell lines
- Environmental Health and Safety
12Conflict of Interest
- Significant Financial Interest Disclosure Form
Statement - The PI affirms that all investigators on the
project have read the UW Investigator Significant
Financial Interest Disclosure Policy for
Sponsored Projects and that the proposed project
does or does not require investigators to
complete the UW Significant Financial Interest
Disclosure Form. (Attach the completed form if
applicable).
13Export Controls Red Flags
- Shipping equipment to a foreign country?
- Collaborating with foreign colleagues in foreign
countries? - Working with a company or individual located in
an embargoed country? - Training foreign nationals in using equipment?
- Using another parties proprietary information?
- Sponsor approval rights over publications or
foreign national participation?
14Office of Sponsored Programs
- What does the PI sign?
- Nothing that will create liability or commitment
- What does OSP sign?
- Anything that commits the institution
15Office of Sponsored Programs
- Reminder
- For NIH awards PUB MED CENTRAL
- NSF Change in the 2/9s salary policy
- Grants.gov challenges
16Office of Sponsored Programs
- Resources
- Grants Information Memoranda (GIM)
- OSP Web Page
- Researchers Guide
17www.washington.edu/research/osp/index.php
18 Grant and Contract Accounting
- Michael Anthony
- Executive Director, Management Accounting
Analysis
19Grant and Contract Accounting
- GCA post-award process
- Direct costs
- Indirect costs
- Program income agreements
- Cost sharing overview/Faculty effort reporting
- Change in level of effort
- Compliance
- Departmental/PI responsibilities
- Resources
20I. Grant and Contract AccountingPost Award
Process
Proposal Award Process
Assignment of Budget Numbers Receipt and
processing of Notice to Establish Account
Active Grant Period Expenditure Allowability
Payment requests to sponsors
Academic Dept/Office of Sponsored Programs
External to Grant and Contract Accounting
Audits
Closing Fiscal Reporting
21What is CAS?
?
?
?
?
?
?
22II. Direct Costs
- (From GIM 23, Costing Policy beginning on Section
4, page 33) - Costs that should be directly charged to
sponsored agreements when they can be
specifically identified to the work performed
under those agreements.
- Salaries, Wages, and Fringe Benefits
- Supplies and Materials
- Other Direct Costs
- Off-Campus Projects Only
23II. Direct Costs
Salaries, Wages and Fringe Benefits
- Faculty
- Research associates
- Predoctoral and postdoctoral fellows
- Technicians, lab assistants, graduate students
- Tuition remission for graduate students
24II. Direct Costs
- (From GIM 23, Costing Policy beginning on Section
4, page 33) - Costs that should be directly charged to
sponsored - agreements when they can be specifically
identified - to the work performed under those agreements.
- Salaries, Wages, and Fringe Benefits
- Supplies and Materials
- Other Direct Costs
- Off-Campus Projects Only
25II. Direct Costs
Supplies and Materials
- Minor equipment
- Uniforms
- Photographic supplies
- Tools
- Animals
- Chemicals
- Laboratory supplies
- Computer software
- Drugs
- Books
26II. Direct Costs
- (From GIM 23, Costing Policy beginning on Section
4, page 33) - Costs that should be directly charged to
sponsored - agreements when they can be specifically
identified - to the work performed under those agreements.
- Salaries, Wages, and Fringe Benefits
- Supplies and Materials
- Other Direct Costs
- Off-Campus Projects Only
27II. Direct Costs
Other Direct Costs
- Travel
- Postage
- Subcontracts
- Radioactive waste disposal
- Animal care
- Motor pool
- Equipment
- Consulting services
- Other costs specifically identified and
justified in funded proposals (where normal
indirect costs are unlike)
28II. Direct Costs
Other Direct Costs
- Long distance telephone costs
- Freight
- Patient care and subject cost
- Costs that are normally indirect may be charged
to non-federally sponsored agreements if
permitted by the sponsors policies/practices
or are otherwise approved by the sponsor
29II. Direct Costs
- (From GIM 23, Costing Policy beginning on Section
4, page 33) - Costs that should be directly charged to
sponsored - agreements when they can be specifically
identified - to the work performed under those agreements.
- Salaries, Wages, and Fringe Benefits
- Supplies and Materials
- Other Direct Costs
- Off-Campus Projects Only
30 II. Direct Costs
Off-Campus Projects Only
- Basic telephone services (such as phone
installation, monthly line charges, basic
instruments)
- Office supplies
- Facilities costs (such as rent, maintenance,
security, utilities)
31III. Indirect Costs
(From GIM 23, Costing Policy beginning on Section
4, page 33) The following costs are normally
considered administrative, infrastructure, or
costs that benefit multiple projects and/or
activities. Where unlike circumstances can be
justified, documented and approved by the
sponsoring agency, these costs may be incurred as
direct costs.
32III. Indirect Costs
- Cellular phones, pagers and related service
charges - Routine / administrative copying charges
- Memberships
- Journals and subscriptions
- Administrative and clerical salaries
- Office supplies
- Toner cartridges, Diskettes
- Basic local telephone services on campus
These costs are allowable and should be
incurred as direct costs for off-campus, APL, and
Regional Primate Center awards. These costs will
not require prior approval from the funding
agency.
33OMB Interpretive Statementof July 13, 1994
Examples Where Direct Charging May Be Appropriate
- Large complex programs
- Extensive data accumulation
- Extensive travel
- Manuals and large reports
- Geographically inaccessible
- Project-specific database management
- Graphics
- Human or animal protocol
34IV. Program Income
- Definition
- Gross income earned by the University that is
directly generated by a sponsored activity or
earned as a result of an award - (OMB Circular A-110)
35IV. PI Responsibilities
- Identify sources of actual or potential program
income at proposal stage. - Develop a plan to use program income.
- Use income in compliance with sponsor regulations.
36IV. Process
- Separate program income budget established
(initiated by PI/department). - Forward income during the life of the project to
GCA (PI/department). - GCA will report income to sponsor if required.
- GCA will return unexpended program income at
expiration.
37V. Cost Sharing Overview
- When effort or non-salary items such as supplies
and equipment are funded by non-federal sources
and contributed to a sponsored project.
38V. Types of Cost Sharing
- Mandatory
- Required by statute or program provision as a
condition of the award. - Committed (formerly known as budgeted voluntary
and voluntary committed) - Cost sharing quantified (often as a percentage of
effort) in the sponsored proposal budget or
budget justification without corresponding
funding requested or awarded.
39V. Types of Cost Sharing (cont.)
- Salary cap
- Required by National Institute of Health (NIH),
Substance Abuse and Mental Health Services
Administration (SAMHSA), and Agency for
Healthcare Research and Quality (AHRQ) when total
faculty salary exceeds the salary cap set by
these sponsors. - Aggregate (phasing out)
- Percentage of cost sharing required on all
research projects for a given sponsor, such as
NSF.
40V. Faculty Effort Certification
- Effort Certification Certification of faculty
effort on all sponsored activities. Effort is
viewed in conjunction with the various activities
the person engages in (e.g. instruction,
administration, service and clinical activity).
41V. Faculty Effort Certification
- Average Work Week The average number of hours a
faculty member normally works during a week.
Hours are to be averaged over the effort
reporting period.
42V. Faculty Effort Certification
- Institutional Base Salary (IBS)
- All compensation received from the institution.
At the UW, IBS is the X and Y salaries from UW,
UWP, and CUMG and the A and B salaries from the
University of Washington. Salary components
include regular salary, summer salary, paid
professional leave, salary for retired faculty,
administrative supplements, and endowed
supplements.
43V. Faculty Effort Certification
- Salary Distribution
- Salary should be distributed appropriately to
individual sponsored projects at a percentage no
higher than the total effort on those projects. - The remainder of University activity can be
funded by one or many funding sources (e.g. if
20 of University activity is teaching and 5 is
administration, it can be funded entirely by one
departmental budget or by a series of
departmental budgets, including but not limited
to state budgets, budgets for indirect cost
recovery, gifts, and endowments).
44VI. Change in Level of Effort
- Most federal sponsors have requirements regarding
change in status and level of effort of the PI
and key personnel. - Typically, the grantee is required to notify the
sponsor in writing if the PI or key personnel
specifically named in the award will - withdraw from the project entirely,
- be absent from the project during any continuous
period of 3 months or more, - or reduce time devoted to the project by 25
percent or more from the level that was approved
at the time of award - The sponsor must approve any alternate
arrangement proposed by the grantee, including
any replacement of the PI or key personnel named
in the award.
45VI. Change in Level of Effort Examples
- 1. Proposal 10 effort
- Changed to 5 effort
- Change in level of effort is 50 and needs prior
approval. - 2. Proposal 50 effort
- Changed to 40 effort
- Change in level of effort is 20 so prior
approval is not needed. - 3. Proposal 50 effort
- (25 paid from grant budget 25 committed
cost sharing) - Changed to 40 effort
- Change in level of effort is 20 so prior
approval is not needed.
46VII. Compliance Salaries/Personnel
Incorrect Practice
Correct Practice
A
Charging of salaries based on funding instead of
actual effort
Salaries charged based upon actual effort Payment
made in corresponding pay period
47VII. Compliance Salaries/Personnel
Incorrect Practice
Correct Practice
B
Payment based on actual hours worked. Payment and
hours properly documented and approved.
Hourly wages paid with no documentation of hours
worked and payment for hours not worked.
48VII. Compliance Salaries/Personnel
Incorrect Practice
Correct Practice
C
Grant was cross-charged (based on funding,
convenience, or as a payback for departmental
accounts to cover deficits.)
Proper accounting and payroll forms used.
49VII. Compliance Salaries/Personnel
Incorrect Practice
Correct Practice
D
Non-research activities performed while salary
charged to grants.
Charge costs that are direct benefit. (No
preparation of new and competing proposals.)
50VII. Compliance Salaries/Personnel
Incorrect Practice
Correct Practice
E
Inconsistent treatment of grant support services.
Reasonable, consistent method in charging dept.
services. Based on actual services or units used.
51VII. Compliance Salaries/Personnel
Incorrect Practice
Correct Practice
F
Signed within 60 days by PI or person with
suitable means of verification that the work was
performed. Retain records in the department.
Salary Certification Report not signed, or not
signed by PI or person with suitable means of
verification that the work was performed.
52VII. Compliance Purchase of Goods and Services
Incorrect Practice
Correct Practice
A
Goods and services purchased did not directly
benefit the research project, or were received
outside the project period.
All goods and services charged as direct costs
have direct benefit to research project and were
received during the project period.
53VII. Compliance Purchase of Goods and Services
Incorrect Practice
Correct Practice
B
Office supplies, basic telephone, subscriptions
and memberships charged directly without proper
justification and approval
Normal indirect costs charged in unlike
circumstances have been properly justified and
documented. (Refer to GIM 23)
54VII. Compliance Purchase of Goods and Services
Incorrect Practice
Correct Practice
C
Inadequate documentation of approval
PI or designee indicates approval for goods and
services. (Refer to GIM 14) PI reviews and signs
BARs/BSRs monthly.
55VII. Compliance Purchase of Goods and Services
Incorrect Practice
Correct Practice
D
Improper or unreasonable basis used to allocate
shared direct costs.
Costs distributed between two or more projects
based on proportional benefit or
interrelationship.
56VII. Compliance Purchase of Goods and Services
Incorrect Practice
Correct Practice
E
Failure to obtain required sponsor approvals
Written, prior approval obtained (where required)
to incur any costs as per sponsors regulations
and/or grant terms and conditions
57VII. Compliance Purchase of Goods and Services
Incorrect Practice
Correct Practice
F
Improper use of Cost Transfer Invoices (CTIs) and
Internal Sales Documents (ISDs)
CTIs and ISDs used to purchase goods and services
that directly support the project.
58VIII. Department / PI Responsibilities
- A) Assistance in grant and contract
reporting/closings - B) Separation of (high risk) duties, such as
payroll or petty cash - Deficit resolution
- Program Income
- Cost Sharing/Faculty Effort Reporting
- Unexpended balances
- G) Records retention
- H) Faculty Effort Certifications (FECs)
- I) Change in PI level of effort
- J) Address problems related to fiscal activities
promptly
59IX. Resources
- A) On-line financial accounting system
- B) Grants information memoranda
- C) GCA on Webhttp//www.washington.edu/research
/gca/office/ - D) OMB Circular A-21 Cost Principles for
Education Institutions - E) Sponsoring agency rules and regulations
60IX. Resources
- F) Quarterly research administrator meetings
- G) Targeted GCA assistance
- H) Departmental administrators and fiscal staff
- I) Advanced costing course
- J) GCA/OSP class
61Audits
- Zenaida Shattuck
- Associate Director
62General Workshop
- Audit Focus
- Tips for Dealing with Auditors
63Who Audits You?
- Federal and state Auditors
- Private/non-government sponsors
- Local government auditors
- Financial statement auditors
- Internal Audit
64State Audit Results
65State Audit Results
- 2007 finding
- Insufficient evidence to support adequate
subrecipient monitoring - No documentation to support the accuracy of
annual performance report
66State Audit Results
- 2005 findings
- FECs and GCCRs not submitted on time
- Federal financial reports not submitted on time
67State Audit Results
- 2004 finding
- Salary benefits charged to grant were not
based on actual effort - 20,000 questioned costs
68State Auditors Office2007 Units Audited
Federal Funds
- Center on Human Development Disability
- College of Ocean Fishery Sciences
- Department of Health Services
- Office of Minority Affairs
69Clashing Philosophies
- University faculty tend to treat the grant funds
as their own to support their research group. - Auditors view the grant funds as earmarked for
support of a very specific research project.
70Federal Audit Focus
- University-wide
- Payroll
- Purchasing
- Procard
- Petty cash
- Travel
- Adjustments/expenditure transfers
71Federal Audit Focus
- Program-specific
- Risk-based selection
- Size of the award?
- Department or program audited before?
- Good internal controls?
- Previous findings?
- Recommendations implemented?
72Compliance Requirements
- Allowability of activities
- Allowability of costs/Allocation of shared costs
- Eligibility
- Cost sharing
- Spend award within budget period
- Program income
- Reporting financial and technical
- Subrecipient monitoring
- Special tests and provisions
73Audit Focus on Internal Controls
- Evidence of PI authorization or review -
may be delegated - Adequate support for transactions
- System of checks and balances (separation of
duties)
74Transaction Selection
- High risk transactions
- High value transactions
- Normally treated as indirect costs
- Expenditure transfers
- Salaries
75Transaction Testing
- Review of payroll certifications (GCCRs, FECs)
- Review documentation to support
- PI/designee approval
- Accurate payment or processing of transaction
- Evidence of receipt
- Review of progress reports
- Review for compliance with
- Special terms and conditions
- State and University policies
76When the Auditor Arrives
- You may have a University representative present
when meeting with an auditor. - School/Department Administrator
- Internal Audit Liaison
77When the Auditor Arrives
During the audit meeting
- Make sure both you and the auditor understand the
audit objective. - Make sure you understand the question.
- Answer honestly and openly.
78Why are you questioning me when everyone does it
this way?
79I dont know.
80I dont understand what the fuss is all about.
81When the Auditor Arrives
Limit conversation to internal controls and
transaction in question, and explain
- How you are directly involved in managing or
overseeing your grant - How expense benefited the grant
- Do not bring in funding issues or departmental
politics
82The Chair did not give me back my indirect cost.
83The auditor seems to expect me to have kept
records. I am not an administrator. I am a
professor. All my life I avoided administrative
duties. This report seeks to penalize me in many
ways for not having accounting and record-keeping
skills.
84Common Audit Findings
- Payroll
- Payment of salaries based upon funding instead of
actual effort. - Hourly employees were paid with no documentation
of hours worked. - Grant was cross charged rather than proper
payroll or accounting paper work submitted.
85Suggestions for PIs
- Understand state and federal guidelines
- Know who is tracking your grant activity
- Review and initial paperwork on a regular basis
- Know the Internal Auditor and ask for help
- Remember, you can ask for time to consult with
the staff responsible for the work
86A High Percentage of Grant Investigations are
Triggered by Whistleblower Complaints
- To avoid this, the department should
- Have a system in place for reporting and
investigating suspected improper governmental
actions within the department - Investigate complaints promptly and openly
- Communicate results
87Internal Audit Contact
- Peter Harris
- ph3_at_u.washington.edu
- Zenaida Shattuck
- zshatt_at_u.washington.edu
- Internal Audit
- iaudit_at_u.washington.edu
88Faculty Grants ManagementProgram