What Every P.I./Administrator Should Know

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What Every P.I./AdministratorShould Know

• Session will attempt to answer
• What are the General Rules or Truisms?
• Cut across job responsibilities
• Set of principles that guide sponsored project
  enterprise
• What is the Basic Vocabulary?
• Cross cutting and shared

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What Every P.I./AdministratorShould Know (Cont)

• A different way of looking at SPA
• Different cut on information than Roles and
  Responsibilities
• Different cut on information than life cycle
  workshops
• Format
• 21 topical areas

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What Every P.I./AdministratorShould Know (Cont)

• General Rules
• Major Federal Regulations
• Cost Sharing/Matching
• Salary/Effort Commitments and Reporting
• Travel and Business Expenses
• Equipment Purchases

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What Every P.I./AdministratorShould Know (Cont)

• Indirect Costs
• Consultant/Subcontract Expense
• Budgeting/Rebudgeting
• Performance Periods
• Unallowable Costs
• Cost Transfers
• Program Income

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What Every P.I./AdministratorShould Know (Cont)

• Monthly Financial Reviews
• Agency Reporting
• Invoicing
• Recharge(Service) Centers
• Regulatory Compliance
• Other Research Related Policies
• Problem Indicators
• Know Your Resources

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What Every P.I./Administrator Should Know General
Rules

• Read the Guidelines
• Talk to a program officer
• Follow all instructions
• Share proposal drafts with colleagues
• Get to know institutional rules
• Get to know institutional processes

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What Every P.I./Administrator Should Know General
Rules (Cont)

• Understand who the key players are and their
  roles
• Ensure PI status and obtain institutional
  approval, if necessary
• Cost must be related to the project charge
• Cost must be reasonable prudent person test

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What Every P.I./Administrator Should Know General
Rules (Cont)

• Allocate cost benefiting multiple projects
• Based on proportionate benefit received, where
  possible
• Based on any reasonable basis, where necessary
• Cost may not be assigned base on fund
  availability, award expiration date or other
  inappropriate criteria
• Charges may not exceed project award

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What Every P.I./Administrator Should Know General
Rules (Cont)

• Pre-award costs, where permitted, limited to 90
  days
• Unexpended funds may often, but not always, be
  carried forward
• Read and follow terms and conditions

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What Every P.I./Administrator Should Know Major
Federal Regulations

• Office of Management and Budget Circulars
  http//www.whitehouse.gov/omb/
• A 21 Cost Principles for Educational Institutions
  http//www.whitehouse.gov/omb/circulars/a021/print
  /a21_2004.html
• A 110 Uniform Administrative Requirements for
  Grants and Agreements with Institutions of Higher
  Education, Hospitals and Other Nonprofit
  Organizations http//www.whitehouse.gov/omb/circul
  ars/a110/a110.html

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What Every P.I./Administrator Should Know Major
Federal Regulations (Cont)

• Office of Management and Budget Circulars (Cont)
• A 133 Audits of Institutions of Higher Education
  and Other Nonprofit Institutions
  http//www.whitehouse.gov/omb/circulars/a133/a133.
  html
• Federal Acquisition Regulations (FAR)
  http//farsite.hill.af.mil/
• Code of Federal Regulations (CFR)
  http//www.access.gpo.gov/nara/cfr/cfr-table-searc
  h.html

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What Every P.I./Administrator Should Know Major
Federal Regulations (Cont)

• Federal Demonstration Partnership (FDP) Terms and
  Conditions http//thefdp.org/
• Agency Specific FDP Terms and Conditions
• Agency Specific Regulations
• NIH (PHS) Grants Policy Statement
  http//grants1.nih.gov/grants/policy/policy.htm
• NSF Grant Policy Manual http//www.nsf.gov/publ
  ications/pub_summ.jsp?ods_keygpm

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What Every P.I./Administrator Should Know Major
Federal Regulations (Cont)

• Agency Specific Regulations (Cont)
• NASA Grant and Cooperative Agreement Handbook
  http//ec.msfc.nasa.gov/hq/grcover.htm
• Department of Defense Grant and Agreement
  Regulations http//www.dtic.mil/whs/directives/cor
  res/html/32106r.htm
• Education Department Grants Administrative
  Regulations (EDGAR) http//www.ed.gov/policy/fund/
  reg/edgarReg/edgar.html

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What Every P.I./Administrator Should Know Major
Federal Regulations (Cont)

• Other Federal and Non-Federal Regulations
  http//researchadmin.uchicago.edu/regulations/

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What Every P.I./Administrator Should Know Cost
Sharing/Matching

• Cost sharing/matching represents costs of
  carrying out a project not charged to the
  project/award.
• Types of cost sharing
• Required cost sharing or matching is a
  programmatic requirement often expressed as a
  percent of budget request or by requirement of
  faculty effort without compensation

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What Every P.I./Administrator Should Know Cost
Sharing/Matching (Cont)

• Types of cost sharing (Cont)
• Voluntary committed cost sharing is not required,
  but is offered to enhance a proposals
  competitiveness
• Voluntary uncommitted cost sharing occurs when
  investigator chooses to devote additional time
  (not promised/not accounted for)
• Voluntary cost sharing, including effort without
  salary, must be prudently allocated

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What Every P.I./Administrator Should Know Cost
Sharing/Matching (Cont)

• Required cost sharing should not generally exceed
  amount required
• Commitments to cost share must be approved by the
  institution
• Source of cost sharing must be secured prior to
  submission of proposal
• Cost sharing commitments on Federal projects
  cannot be satisfied from other Federal projects

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What Every P.I./Administrator Should Know Cost
Sharing/Matching (Cont)

• Salary requests (BSD and off-quarter) and charges
  to projects should reflect effort committed
• Cost sharing must be readily verifiable from
  University records
• Cost sharing commitments over 100,000 require
  approval of University Budget Office and Provost
  (all units but BSD)

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What Every P.I./Administrator Should Know
Salary/Effort Commitments and Reporting

• P.I. determines level of effort to be committed
  by personnel
• Personnel effort shown on budgets should be in
  accordance with agency guidelines
• Salary caps apply only to relevant agency
• Salaries charged should be consistent with effort
• Significant variances in effort require
  redistribution

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What Every P.I./Administrator Should Know
Salary/Effort Commitments and Reporting (Cont)

• No redistribution required for short-term
  fluctuations
• Monthly effort monitoring reports provide
  guidance to departments
• Annual October effort certification by exempt
  employees and academic staff confirms effort
• Time card system constitutes effort certification
  for non-exempt employees

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What Every P.I./Administrator Should Know Travel
and Business Expenses

• Generally limited to commercial coach fare and
  U.S. carriers
• Meals other than the traveler's are unallowable
  Business meals
• Entertainment expenses are unallowable

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What Every P.I./Administrator Should Know Travel
and Business Expenses (Cont)

• Expenses must conform with University Financial
  Policy No. 1202 http//adminet.uchicago.edu/adminc
  ompt/finpolic/1202.shtml
• Must conform with University guidelines for
  Buying and Paying for Goods and Services
  
  http//cps.uchicago.e
  du/uchicago/

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What Every P.I./Administrator Should Know
Equipment Purchases

• Definition of equipment has changed to 5,000
• Justify equipment needs at budget stage, include
  make and model
• General purpose, as opposed to specialized
  scientific, equipment requires special
  justification

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What Every P.I./Administrator Should Know
Equipment Purchases (Cont)

• If equipment cost allocated to sponsored award,
  principal purpose must be project-related
• Equipment purchases during the last 60 days of
  terminal year may be problematic
• Rebudgeting into or out of equipment impacts
  indirect cost recovery

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What Every P.I./Administrator Should Know
Equipment Purchases (Cont)

• Equipment items are added to Universitys
  inventory
• University has title to most equipment, but
  Sponsor may choose to retain title
• Sponsors require reporting of equipment they
  retain title to and may require reporting of
  other equipment

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What Every P.I./Administrator Should Know
Indirect Costs

• Also known as overhead, facilities and
  administrative (F A), indirect cost allowance
  (ICA)
• Includes costs which are necessary to support
  projects, but which cannot be precisely allocated
  to individual projects

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What Every P.I./Administrator Should Know
Indirect Costs (Cont)

• Includes costs such as
• Facilities (utilities, maintenance, security,
  etc.)
• Libraries
• Departmental administration (school/division/depar
  tment)
• General administration (President, Provost,
  Legal, URA, Comptroller, Purchasing, etc)

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What Every P.I./Administrator Should Know
Indirect Costs (Cont)

• Indirect costs are charged by multiplying a
  defined based of expenditures by a rate
• Most federal awards have rates applied to MTDC
  modified total direct costs
• Most non-federal awards (industry, non-profit and
  clinical trials) have rates applied to TDC
  total direct costs

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What Every P.I./Administrator Should Know
Indirect Costs (Cont)

• Federal rates are fixed by a negotiated agreement
  between the University and its cognizant agency
• Separate federal rates for on-campus and
  off-campus activities
• University policy provides for full indirect
  costs unless funding agency policy requires a
  lower rate

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What Every P.I./Administrator Should Know
Indirect Costs (Cont)

• Waiver of indirect costs requires institutional
  approval and is discouraged
• When lower rate is applied, the institution loses
  real dollars
• Only URA (or in BSD, ORS) should contact sponsor
  to verify policy and rates

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What Every P.I./Administrator Should Know
Consultants/Subawards

• University personnel cannot be compensated as
  consultants on University administered projects
• Some agencies have limits to what a consultant
  may charge per day

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What Every P.I./Administrator Should Know
Consultants/Subawards (Cont)

• To hire a consultant on a sponsored project
  requires completion of Sponsored Consultant
  Agreement
• The Sponsored Consultant Invoice should be used
  to request payment
• Consultants must be independent contractors in
  keeping with IRS requirements

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What Every P.I./Administrator Should Know
Consultants/Subawards (Cont)

• Agency approval is required to issue a subaward
• Subrecipients included in a proposal must submit
  a budget, statement of work, copy of indirect
  cost agreement, letter/cover sheet indicating
  institutional approval
• Subaward agreements are negotiated by URA

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What Every P.I./Administrator Should Know
Budgeting/Rebudgeting

• Budgeting should reflect program needs within
  confines of agency policy
• Budget should meet test for allowability and
  reasonableness

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What Every P.I./Administrator Should Know
Budgeting/Rebudgeting (Cont)

• Justification of all costs required, but certain
  categories are especially sensitive
• Non-project specific general office supplies
• Clerical and administrative salaries
• Rebudgeting occurs when spending differs from
  budget

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What Every P.I./Administrator Should Know
Budgeting/Rebudgeting (Cont)

• Modest rebudgeting generally allowed without
  agency approval
• Rebudgeting of 25 or more may be problematic
  (e.g. signal change in scope)
• Significant rebudgeting of key personnel time
  indicates a scope change

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What Every P.I./Administrator Should Know
Budgeting/Rebudgeting (Cont)

• Rebudgeting may affect indirect cost recovery and
  amount of funds available for direct costs
• Obtain agency approval where required

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What Every P.I./Administrator Should Know
Performance Periods

• Necessary to incur cost within performance and
  pre-award period
• May generally extend performance period through
  no-cost extension
• Unused funds not sufficient reason for no-cost
  extension

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What Every P.I./Administrator Should Know
Unallowable Costs (Cont)

• Unallowable cost is a federal term denoting a
  cost not reimbursable under federal grants and
  contracts.
• Federal regulations prohibit certain costs, most
  common
• Alcoholic beverages
• Entertainment
• Fines and penalties

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What Every P.I./Administrator Should Know
Unallowable Costs (Cont)

• Federal regulations prohibit certain costs, most
  common (cont)
• Fundraising/alumni activities
• Internal interest charges
• Meals
• Student aid, except in the case of training
  awards
• Travel tickets in excess of coach

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What Every P.I./Administrator Should Know
Unallowable Costs (Cont)

• Individual awards may designate additional costs
  as unallowable
• University Financial Policy No. 1013 addresses
  unallowable costs
• Unallowable costs may be charged to other sources
  when appropriate

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What Every P.I./Administrator Should Know
Unallowable Costs (Cont)

• Unallowable costs are charged to unique
  subaccounts or 6-digit accounts
• Any costs not reimbursable by the sponsoring
  agency will become the responsibility of the
  PI/department

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What Every P.I./Administrator Should Know Cost
Transfers

• A cost transfer moves expenses from one 10-digit
  account to another.
• Cost transfers are needed to distribute clearing
  account expenses, correct salary distribution
  estimates, correct clerical and bookkeeping
  errors, transfer pre-award costs, etc.
• Federal regulations address cost transfers

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What Every P.I./Administrator Should Know Cost
Transfers (Cont)

• University Financial Policy No. 2111 addresses
  cost transfers
• Guidelines for processing cost transfers are on
  the Web
  http//adminet.uchicago.edu/admincompt/costtran/in
  tro_policy.html
• Transfers should be the exception, not the
  routine
• Transfers should be done on a timely basis

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What Every P.I./Administrator Should Know Cost
Transfers (Cont)

• Transfers must explain why the transfer is
  necessary
• Explanation that simply states to correct error
  is not sufficient how error occurred must be
  explained

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What Every P.I./Administrator Should Know Program
Income (Cont)

• Program income is income directly generated from
  a sponsored project award
• Federal regulations address how income may be
  used to
• increase award funds
• fund required cost sharing/matching
• decrease award funds

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What Every P.I./Administrator Should Know Program
Income (Cont)

• Program Income (Cont)
• University Financial Policy No. 2107 addresses
  program income

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What Every P.I./Administrator Should Know Monthly
Acct./Financial Reviews

• P.I.s and their administrators should review
  accounts monthly
• Use of administrative staff encouraged but P.I.
  must be active in monthly review

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What Every P.I./Administrator Should Know Monthly
Acct./Financial Reviews (Cont)

• University provides standard accounting reports
• Monthly AMO 90, Account Statement in Whole
  Dollars
• Monthly AMO 91, Report of Transactions
• Monthly and Biweekly Payroll Registers
• Business Objects reporting

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What Every P.I./Administrator Should Know Monthly
Acct./Financial Reviews (Cont)

• Review reports to ensure that
• Costs are allowable
• Cost allocations comply with University Financial
  Policy No. 2109
• Costs, which should have been charged, are
  reflected
• Charges are consistent with P.I.s expectations

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What Every P.I./Administrator Should Know Monthly
Acct./Financial Reviews (Cont)

• Review reports to ensure that (cont)
• Reports reconcile to other financial reports
  given to the P.I.
• Significant variances from the budget are
  identified
• Process corrections and reallocations promptly
• Cost transfers should be made within 90 days

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What Every P.I./Administrator Should Know Agency
Reporting

• Terms and conditions outline programmatic,
  financial and other required reporting

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What Every P.I./Administrator Should Know Agency
Reporting (Cont)

• Programmatic reporting
• May be required annually in advance of next
  budget period award
• Responsibility of P.I. to complete
• Some reports require institutional review and
  approval
• Final program report required
• PI must confirm reporting to URA

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What Every P.I./Administrator Should Know Agency
Reporting (Cont)

• Financial Reporting
• P.I./Administrator should make final review of
  expenditures for allowability
• Department/Comptrollers Office are responsible
  for financial reporting

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What Every P.I./Administrator Should Know Agency
Reporting (Cont)

• Financial Reporting (Cont)
• Reporting is based on
• Expenditures in FAS
• Closing Memo prepared by P.I. and/or
  administrator
• P.I. should review to ensure concurrence

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What Every P.I./Administrator Should Know
Invoicing

• Generally done by the Comptrollers office
• Some invoices require special reports, which
  would require departments assistance to complete

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What Every P.I./Administrator Should Know
Recharge Centers

• Charges from recharge centers must be in
  compliance with University Financial Policy No.
  1005
• Prices must be based upon actual costs and
  applied consistently

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What Every P.I./Administrator Should Know
Regulatory Compliance

• Projects involving radioactivity, animals, human
  subjects, biohazardous materials require special
  approvals by University oversight committees
• Agencies require evidence of oversight approval
  (timing requirement varies)

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What Every P.I./Administrator Should Know
Regulatory Compliance (Cont)

• Projects may not be initiated nor FAS accounts
  set up without regulatory approvals
• University complies with federal, state and local
  regulations
• University applies policies to projects
  regardless of funding source

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What Every P.I./Administrator Should Know Other
Research Related Policies

• Administered through the Provost Office
  
  http//www.uchicago.edu/uchi/policies.html
• Academic Fraud
• Conflict of interest
• Patent Policy
• Information Technology Resources

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What Every P.I./Administrator Should Know
Indicators of Problems

• Unauthorized or inappropriate charges
• Unallowable costs
• Improper cost allocations
• Overdrafts
• Assignments of costs based on fund availability
  or project expiration

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What Every P.I./Administrator Should Know
Indicators of Problems (Cont)

• Frequent delinquent cost transfers
• Equipment purchases near end of project

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What Every P.I./Administrator Should Know Check
Your Resources (Cont)

• UC Adminet Web Site http//adminet.uchicago.edu/in
  dex.shtml
• URA Web Site http//researchadmin.uchicago.edu/ind
  ex.shtml
• Office of Foundation Relations http//foundationre
  lations.uchicago.edu/

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