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Keys to Successful Sponsored Award Processing. Program for Sponsored Award Faculty and Staff Fall 2008 Neta Fernandez Ancelmo (Sam) Encinias. Agenda. Whose idea? Various Players Proposal cycle Award cycle Basics Cost Accounting Standards (CAS) Cost Share and Other Costing Basics - PowerPoint PPT Presentation
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Keys to Successful Keys to Successful Sponsored Award Sponsored Award
ProcessingProcessing
Program for Sponsored Award Faculty and Staff
Fall 2008
Neta FernandezAncelmo (Sam) Encinias
AgendaAgenda
• Whose idea? • Various Players• Proposal cycle• Award cycle• Basics• Cost Accounting Standards (CAS)• Cost Share and Other Costing
Basics• Audits• Questions
Whose Idea Was This?
Began with various committeerecommendations:
• Grant and Contract Process
• F&A Recovery
• Disclosure Statement
Unanimous Recommendation
• Mandatory (and ongoing) training
• Reduce duplication of CAS justifications in budgets
• Streamline grant and contract process
Other Workshops• Cost Accounting Standards (CAS)
• Cost Sharing
• Export Control
• Others, as requested
Various Players
Who is Research CenterWho is Research Center
• Reports to the college Associate Dean or Director• Available to PI’s for questions and
info• Assist with proposal• Questions on
purchases/expenditures
Who is OGC?
Reports to VPR ~10 research administrators Submits all proposals Negotiates with agencies Provides assistance/training Provides authorized signature
for Board of Regents Responsible for close out
Who is Sponsored Projects Accounting (SPA)? Reports to Senior Vice President for
Business, Finance, and HR
Creates indexes
Invoicing/billing
Review & process financial trans-
actions, ensuring compliance with
federal, agency and NMSU regulations
Proposal Cycle
Sam Encinias
How to do Proposals?How to do Proposals?PI writes proposal
PI works with RC on budget and assembling proposal as required by Sponsor
RC submits proposal to OGC
OGC reviews, approves, submits proposal
Proposal DeadlinesProposal Deadlines 5 Days before deadline to OGC
for all Electronic Proposals that must be submitted through the Grants.gov on-line portal
48 Hours before deadline to OGC for Non-Grrants.gov proposals
Allow extra lead time for Complex Proposals
Complex ProposalsComplex ProposalsKey is the RFPNew Sponsor with Unique
GuidelinesWork is InterdisciplinaryIncludes Partners – SubcontractorsCenter Grants – Multi YearCost Share or In-kindForeign Countries – Export Controls
Keys to a Successful Keys to a Successful ProposalProposal Start Early
Team Effort
Cover all your bases up front
YEA – Received Award
Neta Fernandez
OGC receives award OGC reviews and negotiates OGC prepares award packet OGC sends packet to SPA SPA creates index OGC and RC notified of index#
Finally…PI begins research
Award Cycle
Let’s Discuss the BasicsLet’s Discuss the Basics
Definitions of Agreement
Grant: more flexible than contract; team oriented; deliverables normally consist of report
Contract: issued by external sponsors for detailed statement of work with final or milestone deliverables
Definitions of AgreementDefinitions of Agreement
Cooperative Agreement:
similar to grant but has statutory
criterion that anticipates substantial
agency involvement
Definitions of Agreement
Gift: a donation, no deliverables; all gifts processed through the Office of the Vice President for University Advancement
* Colleges sometimes have one specific person who deals with Advancement
Types of Awards
• Fixed Price
• Cost Reimbursable
Fixed Price
Grant or contract for which one
party pays the other party a pre-
determined price, regardless of
actual costs, for services rendered
* More common on contracts
Cost Reimbursable
Grant or contract where one party
pays other party for full allowable costs
incurred during project. Based on actual
costs incurred including direct and
indirect costs.* Common on grants
Cost Accounting Standards (CAS)
“The
Rule”
Sponsored Award Costs
There are two ways to charge toa sponsored award:
• Direct costs
• Indirect costs
Cost Accounting Standards (CAS)
• Created as act of Congress, 1971
• Applied to universities in 1996
• Promoted greater standardization of costs
• Goal to tighten rules on allowability/ allocation
Direct Costs
OMB Circular A-21 definition:
Those costs that can be specifically
identified to the cost objective
with relative ease and a high degree
of accuracy
Examples of Direct Costs
• Salaries and wages including fringe
• Non-office supplies
• Subcontracts
• Animal use fees
• Travel related to project
OMB Circular A-21 definition:
Costs that are incurred for common or joint objectives and therefore, cannot be identified readily and specifically with particular sponsored project, an instructional activity, or any other institutional activity
Facility and Administrative(F&A or Indirect Costs)
Examples of F&A Costs
• Operation and maintenance of buildings
• Library costs
• Administrative office supplies
Charging Indirect Costs as Direct Costs
• Must be required by scope of work
• Cost can be accurately identified / allocated to project
• Must be unique requirement and be justified
• Evaluated on case-by-case basis
Is it Acceptable?
For example, office supplies are consideredunder F&A costs. If you can show that the office supplies are an unlike circumstance or are excessive for this project, you can write a justification and get approval for charging as a direct cost.
Office Supplies Example
Program is to promote AIDS
Awareness on campus. Requires
unusually large amount of supplies to
prepare brochures and educational
training materials for workshops
Supplemental Compensation
For exempt staff and faculty to be paidsupplemental compensation, the workmust:
• cross departmental lines or be at remote site AND• be performed in addition to regular workload
Supplemental Compensation
• Must have agency approval
• Must have approved CAS justification
• Must comply with NMSU policy and procedures
Questions?
Role of PI
Sam Encinias
Get Started
• Three general phases to funding cycle:
-- Proposal Devel & Submission
-- Project Administration
-- Project Reporting & Closeout
• Hopefully, Reporting & Closeout is not
“forever” but leads to follow-on or
subsequent grant
Proposal Development and Submission
Proposals have 3 general areas:
• Technical Proposal (your ideas)
• Management Proposal (who will do the work, does NMSU have right facilities, are protocols to conduct work in place, do we need subcontractors, etc)
• Cost Proposal (who will pay for what, are costs proper, do they track with technical needs of work, etc)
Provide a copy (ASAP) of Request for Proposal (RFP) to research center
Proposal Award Form (PAF)
Proposal Development and Submission
Management ProposalManagement Proposal
• Develop staffing plan◦ Faculty, students,
professional staff◦ AY and summer loads◦ Subcontractors?
• Ensure that NMSU follows proper protocols for test subjects, laboratories, and research materials (as applicable)
• Ensure everyone involved is eligible to work on the project
Cost ProposalCost Proposal
• Cost Proposal◦ Look for restrictions on
funds, cost share requirements, etc. in RFP
• Budget expenses according to CAS guidelines; justify expenses as needed for NSMU and/or RFP
• Supply documentation for cost sharing or F&A caps
Project Administration
Project Administration Stages:
• account/project setup
• day-to-day administration
• project reporting
Day-to-Day Administration
• Personnel
-- allocate, monitor, track level of effort
-- complete effort certifications (6 mo)
-- record timesheets in timely manner
• Property
-- if property is purchased under
grant, track property as part of
NMSU inventory list
Day-to-Day Administration
Financial Responsibilities:
• ensure cost sharing is documented and met• expend funds per approved budget• initiate, monitor, and approve expenditures
for subawards• review/validate expenditures on BANNER• ensure travel expenses follow agency
requirements and NMSU allowed costs
Day-to-Day Administration
Purchases:• Can use Purchase Order or Procurement
Card• Vendors must be approved and “in system”• Use “account codes” to map purchase items
to budget categories• PI initiates purchase and gets approval at
department/college/unit level for
appropriateness and funds available** PI responsible if purchases are not appropriate
Project Reporting
• Technical Reports -- prepare project Final Report and any Intermediate Reports according to terms and conditions from agency -- disseminate project results according to proposal plan (conference proceedings, journal articles, etc) and acknowledge grant
• Assist research center in final reporting of financial matters, inventions, inventory, etc
More Basics
Cost Sharing
Definition:
Portion of project costs not borne by sponsor
Cost SharingTwo types of cost sharing:
• Mandatory – required by agency or statute as condition of award
• Voluntary – NOT required by agency; cost sharing is not required but university funds part of cost of research
Cost Sharing
• Charge full F&A, unless
capped by agency
• Treated as cost share
Cost Sharing
If not charging full F&A and not
capped – MUST have VPR approval
Voluntary cost share will only be approved
in very rare cases such as when it is
considered a proposal review criteria and
is stated as such in the RFP
Cost Sharing
Terminology may vary among agencies:
• cost sharing
• matching funds
• in-kind
Cost Sharing
National Science Foundation has
policy stating voluntary cost share
cannot and will not be considered
in the granting of the award
Effort Reporting
Federal Government requirement
PI must sign and certify the percentage
of effort twice a year Timesheet personnel (hourly) sign
timesheet as certification
Business Procedures Manual
• Outlines procedures for conducting
business processes at NMSU
• www.nmsu.edu/~boffice (under Resources)
Property Guidelines
• All property (equipment) purchased will be tagged
• Physical inventory conducted annually
PI is responsible for knowing the Location and condition of equipment
Program Income
OMB Circular A-110 definition:
income generated from a project
financed by a grant or contract
Program Income
Can be revenue obtained from:
• conference fees
• sale of videos
• sale of books
Program Income
Federal regulations provide followingguidelines for treatment of program income:
• Use to further program objectives*
• Use to finance non-federal share of project
* Default application for research projects
Compliance and Audits
Neta Fernandez
Special Compliance TopicsSpecial Compliance TopicsMonitored Thru CommitteesMonitored Thru Committees
Compliance Committeesand Issues
• Conflict of Interest
• Institutional Review Board (human subjects)
• Institutional Animal Care and Use Committee (animal subjects)
Compliance Committeesand Issues
• Institutional Biosafety Committee
• Supplemental Compensation
• Export Control
Conflict of Interest Definition
• Research where it appears researcher may have significant financial interest that could directly/indirectly affect the design, conduct, or reporting of research activities
• Or the researcher’s situation could directly and significantly compromise his/her professional commitments to NMSU
Conflict of Interest Examples
• Issuing subaward to spouse/significant other
• Purchasing supplies/equipment from company that relative/close friend owns
• Accepting gratuities or gifts from private organization that may be interpreted as attempt to influence
Conflict of Interest Procedures
• PI required to fill out and submit a Disclosure of Significant Financial Interest at annual evaluation
• PI required to submit new form when new interests are acquired
Conflict of Interest Conflict of Interest CommitteeCommittee
GOAL is to resolve completely or develop a plan to manage
Note: COI problems can cause PI to pay back agency out of personal
funds
Institutional Review Board (IRB)
• NMSU is required by federal regulations to review research involving human subjects
• Must have IRB approval before PI actually begins research
Institutional Animal Care andUse Committee (IACUC)
• NMSU is required by federal regulations to review research involving animal subjects
• PI required to get IACUC approval for any use of vertebrate animals – including research, teaching or testing
• PI must get IACUC review and approval in advance
Institution Biosafety Committee (IBC)
• Provides guidelines for research or academic programs involving biological agents
• Researchers must receive IBC approval before beginning work
Export Control
• Federal laws to protect items, technical data, and information important to U.S.
• More important during times of war or heightened security*
*Protect national security
What is an Export?
• Any oral, written, electronic or visual disclosure, transfer or transmission outside the US to anyone, including a US citizen, of any commodity, technical data, technology, or software
• Transfer of a controlled commodity, technology, or software to a non US entity wherever located
Foreign Students/Scientists
• Large presence of foreign students and scientists at NMSU increases the chance of transferring knowledge to other countries.
Note: Export Control laws can restrict use of foreign students/scientists on research
University Exemption
Exemption for universities:
• fundamental research
• open publication rights
• does not involve satellite
Civil penalties up to $500,000 each violation
Criminal penalties up to $1,000,000 each violation
Imprisonment up to 10 years
OR BOTH
Penalties and Fines
Dr. Horan
Intellectual Property/Tech Transfer
• Patent rights retained by university
• Government receives license to practice
• Universities to share royalties with inventors
Bayh Dole Act
• Signed prior to beginning of research project
Intellectual Property Agreement
Director of Intellectual Property
and Technology Transfer
Maureen Camunez 6-5398
Questions? Contact:
Review of Activity - Audits
Auditors
As recipient of federal funds, NMSU issubject to frequent reviews by various groups of auditors
Purpose of Audits
For sponsored awards:
• ensure compliance • ensure achievement of stated goals of award
Groups of AuditorsGroups of Auditors
External -- federal -- state -- agency auditors
Internal -- Audit Services at NMSU
Consequences of Audit Findings
Unfavorable outcomes can result in:
• Disallowances of claimed costs with refund to sponsor
• Termination of agreement
• NMSU no longer receiving awards from that agency
Notification of Audit Findings
• Board of Regents
• State Auditor’s Office
• Federal Clearinghouse
• Sponsoring Agency
• NMSU Audit Services will follow up on findings
Important Note to PIImportant Note to PI
If contacted by agency or the Inspector
General’s Office for any agency regarding a
Review –
CONTACT CONTROLLER’S OFFICEIMMEDIATELY!! 646-2432
How Can You Protect Yourself,How Can You Protect Yourself,Your Staff, and NMSU?Your Staff, and NMSU?
• Understand the policies and regulations that apply to your project
• If program activities deviate from award, get sponsor approval in writing
• If you or someone close to you will receive money from an award, file appropriate disclosures and get
approval in advance
How Can You Protect Yourself,How Can You Protect Yourself,Your Staff, and NMSU?Your Staff, and NMSU?
• Do not charge a grant or contract for large
amount of supplies and/or equipment toward end of project.
• Be cautious when using funds from one grant to support activities on another grant.
How Can You Protect Yourself,How Can You Protect Yourself,Your Staff, and NMSU?Your Staff, and NMSU?
• Track your time and charge it accordingly
• Monitor financial activity on your account
• When in doubt, ask for help!
OGC Contact InformationOGC Contact InformationPhone: (575) 646-1590
FAX (575) 646-2020
Email: ogc@nmsu.edu
Web:http://research.nmsu.edu/ogc.html
Compliance Requires Compliance Requires TeamworkTeamwork
All those involved must work together as
a team
Questions?
Thank you for all your Thank you for all your attention!attention!
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