Upload
roy
View
42
Download
0
Tags:
Embed Size (px)
DESCRIPTION
Post Award Primer and Terminology, Management and Reporting Tools, Closeouts and Audits. Sponsored Programs at Penn. The FDP F ederal D emonstration P artnership. - PowerPoint PPT Presentation
Citation preview
The Office of Research Services The Office of Research Support Services
1REVISED April, 2012
Post Award Primer and Terminology,
Management and Reporting Tools, Closeouts and Audits
Sponsored Programs at Penn
The Office of Research Services The Office of Research Support Services
2REVISED April, 2012
The FDPFederal Demonstration Partnership
is a cooperative initiative among federal agencies and institutional recipients of federal funds. It was established to increase research productivity by streamlining the administrative process and minimizing the administrative burden on principal investigators while maintaining effective stewardship of federal funds.
Penn is a participating institution
Many of the recommendations of the FDP have been includedin expanded authorities.
The Office of Research Services The Office of Research Support Services
3REVISED April, 2012
Carryover Authority & SNAP• Carryover Authority
– Generally R’s, K’s and P01’s, but always check the Notice of Grant Award.
• SNAPStreamlined Non-competing Award Process
– Generally R’s, K’s– A grant must have carryover authority if it is
under SNAP
The Office of Research Services The Office of Research Support Services
4REVISED April, 2012
Importance of Expanded Authorities/FDP
Allows some administrative privileges authorized by A-110:
• Automatic carryover of unobligated balances across budget periods and competitive segments (except when noted in the Award)
• Up to one year no cost extension if requested 10 days prior to end of budget period (to complete project & not spend the $)
The Office of Research Services The Office of Research Support Services
5REVISED April, 2012
Importance of Expanded Authorities/FDP
• Waive most cost related and administrative “prior approvals” except:– Change in scope or objective of the project– Change in key personnel– Requests for additional funding– Other exceptions as noted
• Allows for 90 day Pre-award startup costs
The Office of Research Services The Office of Research Support Services
6REVISED April, 2012
Remember!• At Penn, grants with automatic carryover retain
same fund # for the entire segment.– An exception to this rule is subcontracts.
• All grants without automatic carryover receive a new fund # every new budget period.
Understanding this most basic concept helps you understand when a fund # should expire, require a
closeout, or when an advance account may be needed as the project continues.
IT IS VITAL TO UNDERSTAND THIS!!!!
The Office of Research Services The Office of Research Support Services
7REVISED April, 2012
Basic Terms to Know• Revenue
Recognition• PBIL and PBUD• FSRD and FSRI• Operating
Budget• Object Code
1220 Receivable
• Adjustment Period• MTDC• Encumbrance/
Unliquidated Obligation
• Unobligated Balance
• Letter of Credit
The Office of Research Services The Office of Research Support Services
8REVISED April, 2012
Revenue RecognitionRevenue• Our entitlement to be reimbursed by the
sponsor for the allowable expenditures of the grant
• An equal $ of Revenue is recognized for every $ of allowable expense in object code 4600 Grant Revenue
• Unallowable expenses and expenses above the award amount do not recognize revenue
• Revenue does not necessarily reflect the cash received from the sponsor
WHAT’S WRONG WITH CHARGING AN INDIRECT COST
DIRECTLY TO THE GRANT ?
The Office of Research Services The Office of Research Support Services
9REVISED April, 2012
Other Potential Sources of Revenue on a Grant Fund
• University Funded Cost Sharing - Object Code 4822• TIF (Interest) Income - Object Code 4780• Program Income - Object Code 4620
In the end(at closeout and disablement of the fund),
all sources of Revenue must equal Total Expense.
The Office of Research Services The Office of Research Support Services
10REVISED April, 2012
Grant Receivables(Object Code 1220)
• As payments are received from the sponsor, the Receivable decreases (a credit)
• As Revenue is recognized (a credit), the Receivable increases (a debit)
• Positive Receivable: Expenditures > Cash Received
• Negative Receivable: Cash Received > Expenditures
The Office of Research Services The Office of Research Support Services
11REVISED April, 2012
Grant Receivables(Object Code 1220)
LOCLetter of Credit funds have a zero receivable. The actual receivable resides in a special holding fund for all funds under the specific LOC.
The Office of Research Services The Office of Research Support Services
12REVISED April, 2012
Special Object Codes(entered by Research Services)
PBIL - The Maximum Billable AwardPBUD - Authorized Project BudgetFSRD - The Total Direct Costs reported to the
sponsorFSRI - The Total Indirect Costs reported to the
sponsor
The Office of Research Services The Office of Research Support Services
13REVISED April, 2012
More on PBILPBIL• Serves as the control and limits revenue
recognition up to award amount• Gets reduced to reported amount and
guarantees that revenue recognition above reported amount does not occur
• Will always be rounded to nearest dollar. Cents will only show if there has been a carryover of funding from a previous fund (increase) or has been adjusted to the reported amount (decrease)
The Office of Research Services The Office of Research Support Services
14REVISED April, 2012
More on PBUDPBUD
Most often equal to PBIL except on advance accounts
The Office of Research Services The Office of Research Support Services
15REVISED April, 2012
Operating Budget(Entered by Administrator)
The Office of Research Services The Office of Research Support Services
16REVISED April, 2012
Unliquidated Obligations/Unobligated Balance
• Unliquidated Obligations– Commitments of the budget period not yet
paid– When reported funding gets reserved in the
next budget period so they can be paid– Must liquidate within 90 days (A-110)– Can not be reported in the final period
• Unobligated Balance– unspent and uncommitted– may be able to carryover automatically or
with approval
The Office of Research Services The Office of Research Support Services
17REVISED April, 2012
Project Management and Reporting Tools
Sponsored Programs at Penn
The Office of Research Services The Office of Research Support Services
18REVISED April, 2012
Project ManagementAgenda
• Communication• Establishing the Project Environment• Managing Monthly• Monitor Expenditures• Cash Management
The Office of Research Services The Office of Research Support Services
19REVISED April, 2012
Communication• Report monthly to PI
– Establish payroll distribution• Establish level of effort anticipated for each individual on
project – Be mindful of Salary cap limitations – Restrictions on spending
• Special Terms and Conditions within Award Notice – Monitor Subcontracts = Confirm amounts & work done
• Review each invoice (SPP #2131, #2135 Sub-recipient Monitoring policies)
• Communicate regularly with ORS– Extensions / Continuations and other project changes– Financial reports, delinquent sponsor payment– Inform Sponsor via ORS of any Programmatic changes– Assesses allowability of costs
The Office of Research Services The Office of Research Support Services
20REVISED April, 2012
Support the Project• Work with PI on on-going basis• Ensure that interim reports &
proposals are submitted on time• Disclose Inventions and Patents• Prepare for Progress Reports and
Non-Competing Continuations
The Office of Research Services The Office of Research Support Services
21REVISED April, 2012
Establishing the Project EnvironmentPayroll Set-up
• Identify who belongs on distribution• Identify amount of funding and % effort• Distribution Stop Date s/b set to the
Account End Date• Salary Encumbrances are calculated
through the Current Budget End Date or Distribution Stop Date (whichever is earlier)
The Office of Research Services The Office of Research Support Services
22REVISED April, 2012
Procurement• Ben Buys Commodity Matrix
– Methods of Purchasing– When should C-1, C-1A, C368,
Purchase Order, or P-Card be used
• http://www.purchasing.upenn.edu/buyinfo/matrix.php
• Competitive BidsRequired on aggregate purchases > $5,000 unless purchase is with a University Contract Supplier or with a supplier participating in the Penn Marketplace.
The Office of Research Services The Office of Research Support Services
23REVISED April, 2012
Cost Share • Types of Cost Share
– Mandatory – costs required by terms of award that the University must contribute toward project in order for award to be made.
– Voluntary Committed – costs associated with project (identified in proposal or budget justification) for which funding has not been requested from sponsor.
– Voluntary Uncommitted – costs associated with project NOT identified within proposal or budget justification and NOT funded by sponsor.
– In-Kind / Matching - Refers to funds being matched in some proportion with non-sponsored project funds, or that the grantee participate to some extent in the cost of the project. Matching requirements may be in the form of an actual cash expenditure of funds, or may be an “in-kind” match, which is the value of non-cash contributions to the project.
• Tracking Cost Share Commitments– Costs must be expended as proposed and recorded throughout life of
project (separate fund ?)– Same allowability rules apply & same performance period as primary award
The Office of Research Services The Office of Research Support Services
24REVISED April, 2012
Program Income • Definition
– Gross income earned that is directly generated by a sponsored activity or earned as a result of the sponsored activity
• Some examples: Income from fees or services performed from external entities or within University, Revenue from sale of tissue harvested from project.
• Methods of Program Income– Additive = income is added to sponsor commitment.– Deductive = income used to reduce sponsor commitment.– Matching = income used to finance portion of departmental commitment.
• Tracking Program Income– Program income rec’d from external entities must be deposited into o/c
4620– Revenue earned by University dept for fees or selling goods or services to
another Univ. dept is consider internal revenue and must be recorded using o/c 5500.
– Program Income fund is to be set-up to account separately for the costs of collecting and spending the Program Income Awards in which Gross Program income may be off-set by the costs of collecting the income to enable reporting Net Program Income. ($5,000 threshold)
The Office of Research Services The Office of Research Support Services
25REVISED April, 2012
Issues Surrounding Specific Expense Categories
The Office of Research Services The Office of Research Support Services
26REVISED April, 2012
Equipment• Definition – tangible, nonexpendable, personal property having a
useful life of more than one year and an acquisition cost of $5,000 or more per unit
• Must be necessary for project purposes – During the award period
• Is not reasonably available for use elsewhere in the University• Award notice does not constrain equipment purchases• Must obtain necessary bids, unless sole source justification• Document whether Equipment is
– Government owned– Government furnished
• Disposition after the project has ended– Know sponsor regulations
The Office of Research Services The Office of Research Support Services
27REVISED April, 2012
Foreign Travel• Foreign Travel must be included in proposal or otherwise be
allowed by sponsor. Be sure to justify and document changes (approval, if applicable) if not in proposal– Department must maintain documentation in the file that supports the
trip’s purpose
• Foreign air travel paid with federal funds must be on US-flag air carriers– Limited exceptions and they can be found out:
www.access.gpo.gov/nara/cfr/cfr-retrieve.html#page1
• Exceptions, which must be documented, generally include:– US-flag air carrier does not go to destination– Total trip time extended more than 24 hours– Lay-over extended more than 6 hours– Foreign carrier eliminates 2 or more changes
The Office of Research Services The Office of Research Support Services
28REVISED April, 2012
Consultants• Evaluate: Consultant, Employee or Subcontractor?
– Use C-12 Independent Contractor Determination & Certification
http://www.finance.upenn.edu/comptroller/tax/contractor_certif.shtml
• Consulting agreement needs to be completed and forwarded to ORS for approval & signature
• Document role of consultant– Needs to be working towards goals of project to which he/she is
charged• Review sponsor guidelines for consultants
– Ensure approvals are obtained, if applicable– Consultant rates may be limited for some sponsors
The Office of Research Services The Office of Research Support Services
29REVISED April, 2012
Purchases• PI approval process for purchases• Assess allowability, allocability and
reasonableness
• Verify budget and availability of funds• Procure bids• “Buy American” on federal awards when possible • Don’t buy capital equipment at end of project
The Office of Research Services The Office of Research Support Services
30REVISED April, 2012
Service Centers• Definition:
– A department or functional unit within a department, which performs specific service for a fee
– Examples: Cell Sorting facilities, Resonance Imaging facilities, and Animal Care facilities
• ORS responsible for review & approval of rates– Services provided charged based actual use of services– Charges for services allocated monthly
-Financial Policy #2115 University Service Centers
• Make sure Service Centers use correct fund account• PI & BA should review Service Center charges regularly
– The BA may not know what services were provided, or if the amount charged is appropriate
The Office of Research Services The Office of Research Support Services
31REVISED April, 2012
Manage Monthly• Plan expenditures in advance
– This will make the project easier to manage throughout life of project
• Run and analyze appropriate reports– Financial Policy #1402.5 Monthly Closings/Reporting
• Send detailed reports to PI• Remove unallowable and wayward charges• Compare expenditures to projections• Manage changes through full system
– Changes in award value affect payroll– Changes in subcontracts or equipment affect F&A charges
The Office of Research Services The Office of Research Support Services
32REVISED April, 2012
Manage Project Changes Proactively
• Use proposal as “home base”
• Anticipate necessary changes– Contact ORS for approval– Get sponsor approval through ORS– Change of scope or effort
• Plan ahead for extensions
The Office of Research Services The Office of Research Support Services
33REVISED April, 2012
Monitor Expenditure Rates• Sponsors question unusual expenditure
rates• Have we changed scope of work?• Are we still breathing?
• Communicate with Sponsor (cc ORS)
The Office of Research Services The Office of Research Support Services
34REVISED April, 2012
Cost Transfers• The transfer of costs to sponsored projects
where the costs initially had been incorrectly charged to another account. Any cost transfers that occur need to be properly justified and documented.
• University Financial Policy Number 2113 Cost Transfers and Payroll Reallocations states "Cost transfers must be prepared and submitted within 90 days from month end in which the transaction appears on the fund." Failure to adhere to this policy may result in the University disallowing the transfer which would result in a write-off to the administering department.
The Office of Research Services The Office of Research Support Services
35REVISED April, 2012
Cost Transfers• Must be an allocable, allowable
and justified charge to the particular award
• Department must maintain documented justification for transfer
• Must be made within time constraints
The Office of Research Services The Office of Research Support Services
36REVISED April, 2012
New Cost Transfer J/E Categories
• On 7/1/2010, an additional BEN Financials Journal Entry Responsibility titles Journal Entry – G&C Costs Transfers was introduced to improve monitoring, tracking and compliance with the University’s cost transfer Financial Policy # 2113.– Initially added 15 G&C UN90 and 16 G&C OV90
• On 10/4/2010, updates were made BEN Financials Journal Entry Responsibility to add 2 additional Categories.– 17 UPHS Gds/Svs– 18 UPHS Payroll
The Office of Research Services The Office of Research Support Services
37REVISED April, 2012
The Office of Research Services The Office of Research Support Services
38REVISED April, 2012
Cost Transfer Principles• Cost transfers are for correcting legitimate
ERRORS
• Cost transfers should NOT be used as a means of managing cash flow
• Project funds are NOT interchangeable– Integrity of each grant account must be maintained
• Allowability of costs must be maintained
The Office of Research Services The Office of Research Support Services
39REVISED April, 2012
Cost Transfers• Documentation
– Supported by full explanation and justification, as well as a certification of the propriety of the transfer
– Explanations such as “to correct error” or “to transfer to correct project” are not sufficient
– Approval can be documented by• PI signature• Printed e-mail messages from PI
The Office of Research Services The Office of Research Support Services
40REVISED April, 2012
Cost Transfer “Red Flags”• Transfers made in excess of 90 days after the original
charge• Improper J/E Categories (15 G&C UN90, 16 G&C OV90)• Transfers without a full explanation• High volume of transfers • Timing and “route” of transfers• Late transfers to funds with unexpended funds• Transfers from funds with overdrafts to other 5 fund(s)• Transfers between funds with scientific overlap
The Office of Research Services The Office of Research Support Services
41REVISED April, 2012
Advance Accounts for Continuation Awards
• Recommended for non-competing renewals requiring new fund #’s for each period
– Department requesting the advance account bears the risk of having to fund any costs incurred if the funding never materializes
– Med School sets up NIH advances for full budget period– All other Schools set up Advances for 3 month period
The Office of Research Services The Office of Research Support Services
42REVISED April, 2012
Monitoring Accounts Receivable• For Letter of Credit awards, check revenue & cash
received. There should be no cash on hand.
• On Letter of Credit, confirm that PBIL is correct
• Contact ORS to address payment problems with sponsors– Departments should review AR and contact ORS regarding
aged receivables of concern• For awards on payment schedule, contact Bob Speakman• For all other awards, contact Gokila Venkateswaran• For Med School awards, ORSS representative is Danielle DiIanni
The Office of Research Services The Office of Research Support Services
43REVISED April, 2012
Checks, Payments and Project Budget Increases
• Hand carry check to ORS immediately, with project identification – Do not deposit check
• Should AIS be increased because of check?
The Office of Research Services The Office of Research Support Services
44REVISED April, 2012
Run and Review Reports• BEN Reports
– 102.ORG – Summary CNAC-ORG-FUND level– 115.ORG – Fund Summary– 133.ORG – Due to Close– 134.ORG – Summary of Final Expenditure Report
• Data Warehouse– Fund Summary– Org Summary– Corporate Documents
• Payroll• Correct Errors
The Office of Research Services The Office of Research Support Services
45REVISED April, 2012
Reporting Tools“There are so many reports I’m not sure where to look first.”
The Office of Research Services The Office of Research Support Services
46REVISED April, 2012
GRAM / BEN Reports• Reports used primarily by
Principal Investigators
• Reports represent a Current Budget Period perspective
• Not easy to determine PJTD Numbers or amount to close out at (other than Budget Available)
• Critical for Operating Budget to be posted to the Budget Period Start
GRAM – The online PI view
The Office of Research Services The Office of Research Support Services
47REVISED April, 2012
• Actual Spent represents Current Budget Period Only• Further Detail can be clicked on, but none is available for Prior
Budget Periods
The Office of Research Services The Office of Research Support Services
48REVISED April, 2012
Management of All Grants in ORGBUSINESS OBJECTS
ORG Summary by Fund, PI, Acct End, receivables, overdrafts, funds freezing, late/due FSR’s, Analysis of expired funds, Illegal object code charges, possible F&A direct charged to Fed grants, payroll compared to budget.Grantmonitor PBIL/PBUD/Budget, NCC Due, Awards Due, Revenue Check, Overdrafts (active and expired), Federal Cash, CT Cash, Residual Balances, ReceivablesSubbudgets our charges to othersOtherorgschgsORG Wayward Summary.repORGpersonnel. all current distributions of home dept orgAward Analysis- Award DatePT-Requests (all proposals submitted for any time period)JE inquiry (by batch between dates)FY Grant ORG Expense AnalysisEffort Report – Home Dept ORGObject code by fund – posted orgObject code by fund – detailAIS (full search)
Protocols – Org/ Protocols – PI
BEN FINANCIALS
132.ORG List of Terminated G&C Funds133.ORG List of G&C Funds Due to Close138.ORG Frozen Fund List201.SCH PJTD Rev/Exp for G&C/URF202.SCH YTD Rev/Exp Totals for Funds211.SCH PJTD Rev/Exp Outline for G&C/URF212.SCH YTD Rev/Exp Outline for G&C/URF301.BUD Budgetable Amount - Grants/Contracts306.BUD Negative BBA ORG/FUND/CREF PJTD
The Office of Research Services The Office of Research Support Services
49REVISED April, 2012
Fund Level ManagementBUSINESS OBJECTS
fundsummaryfundsummary with BRIMfundsummary (w date range) summary by ORG/CNAC SNAP/NCC estimated unobligated balance
Fund Detail monthly matrix all expense monthly matrix personnel paid
FUNDpersonnel – all current distributions on fund
Effort Report – Fund
GRANT REPORTS (-Resp Org, -PI, -CREF, -PI Awarded) PI friendly & monthly payroll and expense detail
BEN FINANCIALS
102.ORG Summary G&C by CNAC/ORG/FUND103.ORG Summary G&C by CNAC/ORG/FUND/CREF115.ORG Grant Fund Summary Report130.ORG PI Report by CNAC/ORG/FUND134.ORG Summary of Final Expenditure Report (available for grants in adjustment period)137.ORG Grant/Contract Budget Period Summary
The Office of Research Services The Office of Research Support Services
50REVISED April, 2012
Expense DetailBUSINESS OBJECTS
Fund Detail. Payroll by Obj, by Person,Exp Detail by Object, Org, Acct Period, P.O./UserFund Detail – PI monthly matrix of personnel paid on PI grantsPayroll.(any fund any period of time) variations include: All grants of PI All grants of Resp OrgPersonnel.(any person, any period)Personnel-one (any person’s current distrib)Detail. variations include: All grants of PI All grants of Resp ORG subcontracts object special budget operating budget cash depositsEncumbrances(Fund)ORG Wayward Detail
BEN FINANCIALS
150.ORG Detail by CNAC/ORG/FUND151.ORG Detail by CNAC/ORG/FUND/CREF152.ORG Detail by CNAC/ORG/CREF153.ORG Detail by CNAC/ORG/FUND/PROG155.ORG Detail Extract156.ORG Detail by CNAC/ORG/FUND/PROG/CREF160.ORG Account Analysis with payables detail163.ORG Open Encumbrances Report301.BUD Budgetable Amount - Grants/Contracts304.BUD Negative BBA ORG/FUND YTD305.BUD Negative BBA ORG/FUND/CREF YTD306.BUD Negative BBA ORG/FUND/CREF PJTD315.BUD Posted Budget Journal with Exceptions507.GA Posted Journal Activity Report508.GA Unposted Journal Activity Report510.GA Detail Transaction by OBJECT by ORG
The Office of Research Services The Office of Research Support Services
51REVISED April, 2012
Your assignment• Full documentation of the Business Objects Queries
is available at:http://www.upenn.edu/computing/da/dw/financial_queries.html
Select “Grants Management”
• While we will discuss and give samples of some of the more popular reports today, it is essential that you GO BACK TO YOUR OFFICE AND PLAY WITH THE REPORTS!!! Decide what tools/reports work best for you and your investigators.
The Office of Research Services The Office of Research Support Services
52REVISED April, 2012
Award Analysis – Award Date
The Office of Research Services The Office of Research Support Services
53REVISED April, 2012
FY Grant ORG Expense Analysis
The Office of Research Services The Office of Research Support Services
54REVISED April, 2012
ORG Summary
The Office of Research Services The Office of Research Support Services
55REVISED April, 2012
ORG Summary - Analysis of Expired FundsWhy isn’t my fund disabled?
The Office of Research Services The Office of Research Support Services
56REVISED April, 2012
ORG Summary – possible F&A
The Office of Research Services The Office of Research Support Services
57REVISED April, 2012
Grant Reports
PI Summary Tab
The Office of Research Services The Office of Research Support Services
58REVISED April, 2012
Grant Reports
PI Detail Tab
The Office of Research Services The Office of Research Support Services
59REVISED April, 2012
Grant Reports
Payroll Encumbrances Tab
The Office of Research Services The Office of Research Support Services
60REVISED April, 2012
Grant Reports – PI
Taken from the “PI Matrix –all” Tab
The Office of Research Services The Office of Research Support Services
61REVISED April, 2012
Grant Reports – PI.rep
Taken from the “Personnel Matrix” Tab. Note: this covers one period only. Fund Detail –PI.rep could do this for a range of dates
The Office of Research Services The Office of Research Support Services
62REVISED April, 2012
The Office of Research Services The Office of Research Support Services
63REVISED April, 2012
fundsummary – Award History tab
The Office of Research Services The Office of Research Support Services
64REVISED April, 2012
fundsummary - SNAP/NCC Estimated Unobligated Balance
Make sure the formula toolbar is checked under View Toolbar.
The Office of Research Services The Office of Research Support Services
65REVISED April, 2012
fundsummary.rep – Cref Matrix
The Office of Research Services The Office of Research Support Services
66REVISED April, 2012
Fund Detail.rep
This is the “Acct Per. Summary Tab”. There is also a Pay Summary Tab as well as numerous tabs to sort payroll information and expense detail information. Variations of this include: Fund Detail-PI.rep and Fund Detail - cref detail.rep, and fundsummary (w date range)
The Office of Research Services The Office of Research Support Services
67REVISED April, 2012
GrantMonitor
This tab of the GrantMonitor can help identify NIH noncompeting Progress Reports that might be due. There are also separate tabs which can identify when Subcontracts Progress Reports are due and also T32’s based on which Institute the award is with.
The Office of Research Services The Office of Research Support Services
68REVISED April, 2012
JE Inquiry (by batch between dates)
Note the 3 tabs which are specifically designed for grant entries done by Res Svcs (8760) or the Comptroller’s Office (8720)
The Office of Research Services The Office of Research Support Services
69REVISED April, 2012
AIS (full search)
Ability to search on multiple criteria
The Office of Research Services The Office of Research Support Services
70REVISED April, 2012
AIS (full search)
The “New AIS Summary” Tab can give a summary of AIS’s issued in the last 35 days
The Office of Research Services The Office of Research Support Services
71REVISED April, 2012
AIS (full search).rep
The Office of Research Services The Office of Research Support Services
72REVISED April, 2012
Effort Report – Fund.rep
The Office of Research Services The Office of Research Support Services
73REVISED April, 2012
Effort Report – Fund.rep
The Office of Research Services The Office of Research Support Services
74REVISED April, 2012
Protocols – Org.rep
This tab gives a summary of protocols by fund #. There are also separate tabs for Human Protocols by PI, Animal Protocols by PI, Protocols by #, and Expired Protocols.
The Office of Research Services The Office of Research Support Services
75REVISED April, 2012
Identifying Waywards – 115.ORG
The 115 shows a possible wayward charge from ORG 4227 Cardiology. To obtain the detail of the charge a 15X.ORG report can be run entering the ORG making the charge in the Accounting Period the charge was made.
The Office of Research Services The Office of Research Support Services
76REVISED April, 2012
Otherorgschgs.rep & Waywards.rep
The Office of Research Services The Office of Research Support Services
77REVISED April, 2012
In Summary• Award must be reviewed on a
regular basis• Communication is vital to the proper
administration of the award• When you are not sure, investigate
and ask• If an award is properly managed,
the closeout process is very simple
The Office of Research Services The Office of Research Support Services
78REVISED April, 2012
Closeouts and Audits of Sponsored Project Funds
Sponsored Programs at Penn
The Office of Research Services The Office of Research Support Services
79REVISED April, 2012
Closeout of Sponsored Project FundsAgenda
• PI & Department responsibilities– Communication– Pre-closeout review– Adjustment period– Freeze/unfreeze grants– Technical & invention reports
• ORS responsibilities– Unfreeze requests– Financial & non-financial reports– Disabling accounts
SPP # 2126 Interim & Final Financial ReportsSPP # 2128 Account Close-out
The Office of Research Services The Office of Research Support Services
80REVISED April, 2012
What is the Adjustment Period?• Period of up to 60 days after Account end
date– Allows for final review of project activity so adjustments can be made prior to final
reporting• 30/31 days: Account End Date + 15 days• 45 days: Account End + 30 days• 60/61 days: Account End + 30 days• 90/91 days: Account End Date + 60 days
The Office of Research Services The Office of Research Support Services
81REVISED April, 2012
Adjustment Period (cont.)• Run 134.ORG Report in BEN Financials or
Fund Summary in Business Objects
– Review the following areas• PBUD/PBIL should be equal• Revenue vs. Expense
– Should be equal– If not, requires further review– F&A and Employee Benefits (EB) – Were
the correct rates appropriately applied?
The Office of Research Services The Office of Research Support Services
82REVISED April, 2012
Adjustment Period (cont.)– Review the following areas (cont.)
• Payroll – Any adjustments that may be needed must be made by the end of the adjustment period
• Service Centers – Were these handled appropriately
• Cost transfers over 90 days that were done without prior approval
• Other direct costs for allowability
The Office of Research Services The Office of Research Support Services
83REVISED April, 2012
Final Review Prior to End of Adjustment Period
• Review PBIL/PBUD, NOGA and approved carryforward, if applicable
• Review subcontracts and respective closeouts• Communicate with ORS Accountant
– Outstanding reporting/receivable issues • Determine and address
– Unliquidated and unobligated carryovers• All adjustments must be processed by end of
the fund adjustment period – Complete all approved, allowable, allocable and
appropriate adjustments identified during pre-closeout review
The Office of Research Services The Office of Research Support Services
84REVISED April, 2012
Best Practices for Communications
• Emails - the subject line of your email should be informative– “Action Fund#, P.I., Description– Examples:
• “Closeout 538500, Mendel, 5K23MH024680-03” • “Unfreeze 538000, Frankenstein, 5R01HG012345-05
• One email per fund action• Email ORS Accountant and notify them of the
Direct, Indirect, and Total Expenses to report hopefully by the end of the adjustment period but no later than 1 week before report due date.
The Office of Research Services The Office of Research Support Services
85REVISED April, 2012
Freeze/Unfreeze Grant Functionality
The Office of Research Services The Office of Research Support Services
86REVISED April, 2012
Freeze Grants Functionality• Tool that allows authorized research
administrators and ORS to limit activity against an award– Can be used during life of project and
during the adjustment period– Can reduce cost transfers and overruns
after the end of the fund project period– Improve timeliness and accuracy of final
financial reports
The Office of Research Services The Office of Research Support Services
87REVISED April, 2012
Freeze Grants Features• Awards are frozen/unfrozen at fund level
– Payroll can be frozen manually prior to the Account End Date
– Functionality frozen automatically after Account End Date• New Purchase Orders/Requisitions
– Functionalities frozen automatically after Adjustment Period End Date (APED)• Manual Journal Entries• C-forms• Feeder Journal Entries• Payroll
The Office of Research Services The Office of Research Support Services
88REVISED April, 2012
Unfreeze Request (cont.)• Are not necessary to:
– Prepare budget journals– Pay already encumbered amounts on
an existing P.O.– Unfreeze advance accounts (request
an extension of advance account)
The Office of Research Services The Office of Research Support Services
89REVISED April, 2012
Unfreeze Grants (cont.)• Submit your request to:
– School of Medicine departments• Send worksheet and details (including documentation)
to Office of Research Services Support (ORSS) Grant Manager with a cc to ORS Accountant
• ORSS will review and, if approved, will forward to Research Services Accountant and cc Assistant Director
– All other Schools• Send worksheet and details to ORS Accountant and cc
Assistant Director
– Unfreeze requests are normally addressed within two business days
The Office of Research Services The Office of Research Support Services
90REVISED April, 2012
ORS Responsibilities
The Office of Research Services The Office of Research Support Services
91REVISED April, 2012
ORS Reporting Period Tasks• Reviews Due Reports to determine report due date• Email will be sent requesting closeout information• ORS Accountant reviews the following;
-Terms and conditions of award and sponsor reporting requirements
– Review the 734 report in Business Objects (similar to 134.ORG report in Ben Financials)
– Check PBUD/PBIL for accuracy– Reconcile EB’s, F&A and Cash– Review 252 report for stale dated checks
The Office of Research Services The Office of Research Support Services
92REVISED April, 2012
ORS Reporting Period Tasks (cont.)• Review expenses posted to the fund for
allowability– Revenue
• 4600, 4620, 4630, 478X, 4822, TIF, Program Income & Other Revenue
• Review remaining balances or deficits
• ORS will communicate any issues identified and request a response from the BA
• If the ORS Accountant does not receive a
response regarding closeout the report will be issued and an email will be sent stating what was reported to the sponsor.
The Office of Research Services The Office of Research Support Services
93REVISED April, 2012
ORS Reporting Period Tasks (cont.)
• Overdrafts– ORS will contact department regarding
resolution– If no response is received by report due date,
fund will be reported up to award amount and ORS will process journal to transfer resources from departmental fund to grant fund to offset overdraft via object code 4822
SPP # 2129 Chargeback of Overdrafts and Disallowances
The Office of Research Services The Office of Research Support Services
94REVISED April, 2012
ORS Reporting Period Tasks (cont.)
• Unexpended Balance – Will be reported to sponsor– Carryover will be processed and/or requested as
appropriate– Residual cash will be remitted to sponsor according
to agreement– Carryovers and/or unliquidated obligations will be
determined and handled as appropriate
The Office of Research Services The Office of Research Support Services
95REVISED April, 2012
ORS Reporting Period Tasks (cont.)
• Final Financial Status Report (FSR)/(FFR) Submission– Financial report will be issued by ORS no later
than due date – A copy will be sent to department and a copy will
be scanned into our imaging system (Acorde)– ORS will process any closing entries based upon
final reports
The Office of Research Services The Office of Research Support Services
96REVISED April, 2012
Revised FSR/FFR’s• Only done in rare circumstances• When revising to increase total expenses, most
sponsors will only accept revised reports for limited period of time following the end of the award. Some agencies will not accept upward revised FSRs.
• When revising to decrease total expenses, there is no time limit. These should be completed immediately upon identification of the need for a revised FSR.
SPP # 2137 Revised Final Financial Reports
The Office of Research Services The Office of Research Support Services
97REVISED April, 2012
Disabling Funds• How does a fund get Disabled?
– ORS runs 717.RA report in BEN Financial weekly • To identify funds that meet disable
requirements
– If the fund is eligible for disabling ORS checks “Enable” flag • Enters date in BEN Financials
The Office of Research Services The Office of Research Support Services
98REVISED April, 2012
Requirements to Disable Funds1. Financial Report must be submitted if required-
Last FIN Report Filed=Next FIN Report Due2. FSRD and FSRI s/b posted reflecting Direct and
Indirect Costs reported3. PBIL=PBUD=FSRD+FSRI=Total Expenses reported
and on the G/L4. No Encumbrances can remain5. Object Code 1220 Receivable must =06. Equipment in Object Code 183X/187X must be
transferred to School Surrogate Accounts via an Object Code 4826 Equipment Transfer
7. BRIM (ORS billing system) is reconciled (requires ORS action)
8. All stale dated checks have been satisfactorily addressed
The Office of Research Services The Office of Research Support Services
99REVISED April, 2012
Miscellaneous - Cost Sharing (con’t.)• Cost Sharing
– How is it recorded in our system?• Must be separately accounted - a 5 fund must be
established if Cost Share > $10K– What needs to be done at closeout?
• Mandated cost sharing must be reported to the sponsor
• How is it managed?• Expenses should be recorded and monitored on a
timely basis• Revenue entries must be routinely performed
SPP #2119 Cost Sharing/Matching Requirements
The Office of Research Services The Office of Research Support Services
100REVISED April, 2012
Miscellaneous – Interest Bearing Funds
• Interest Bearing Funds– When does an award fund receive interest?
• Monthly basis– How do I know if my fund is interest
bearing?• T&C of award determine
– Can I spend these funds?• T&C of award determine
– At Closeout, what happens to these funds?• T&C of award determine
The Office of Research Services The Office of Research Support Services
101REVISED April, 2012
Miscellaneous – Program Income
• Program Income– What is Program Income?
• Gross income earned & directly attributable to the sponsored activity
– How is Program Income handled? • Additive vs. Deductive
– How is Program Income handled at closeout?SPP #2121 Accounting for Program Income
The Office of Research Services The Office of Research Support Services
102REVISED April, 2012
Miscellaneous –Record Retention
• What do I need to retain?
• How long do I need to keep it?
• SPP #2132 Record Retention
The Office of Research Services The Office of Research Support Services
103REVISED April, 2012
Miscellaneous –Award Transfers
• If a PI is planning to leave the University, ORS staff should be contacted as soon as possible to expedite the process
• “Statement of Relinquishment” or similar document– Required information must be verified– ORS signature must be obtained– Estimated unobligated balance-funds awarded on NOGA
for current year only exclusive of any amounts carried over– Not finalizing costs may delay transfer of funds to the next
University– Any property being transferred must be addressed
The Office of Research Services The Office of Research Support Services
104REVISED April, 2012
Non-Financial Close Out Issues
• Final technical and/or progress report
• Final invention statement• Final property report
The Office of Research Services The Office of Research Support Services
105REVISED April, 2012
Getting Assistance on Closeouts
• For financial matters: – Contact ORS accountant or Post-
Award Assistant Director
• Regarding extensions, requests for budget or other modifications to agreement, or non-financial matters:– Contact your Contract Administrator
The Office of Research Services The Office of Research Support Services
106REVISED April, 2012
Questions???
The Office of Research Services The Office of Research Support Services
107REVISED April, 2012
Audits
Sponsored Programs at Penn
The Office of Research Services The Office of Research Support Services
108REVISED April, 2012
Pre-Award Audits• Performed by agency to verify
– Accuracy of costs on application– Adequacy of University systems and
controls• Usually performed by or at the
request of the sponsor• Federal Awards
– DHHS is Cognizant Agency– Sponsoring Agency
The Office of Research Services The Office of Research Support Services
109REVISED April, 2012
Agency or Programmatic Audits• Performed on Active or Terminated
awards• Federal Awards normally a result of
a request by the Sponsor– Review by Dept of Health & Human
Services (DHHS) – Foundations and Associations– Other
The Office of Research Services The Office of Research Support Services
110REVISED April, 2012
Investigative/Criminal Audits• Usually based on allegations of fraud
– Misuse of funds on awards including:• Purchasing Card charges• Petty Cash abuses
– Audit of how we comply with regulations– If Federal OIG audit
• Subpoena powers
The Office of Research Services The Office of Research Support Services
111REVISED April, 2012
Internal Audits• University audits projects to
– Evaluate system controls– Assess compliance with University and
sponsor policies and applicable OMB circulars
– Investigate reports of fraud
The Office of Research Services The Office of Research Support Services
112REVISED April, 2012
Compliance Audits• Assess compliance with
– Sponsor regulations– University policies
• Human Subject/Animal issues
The Office of Research Services The Office of Research Support Services
113REVISED April, 2012
F&A Cost Proposal Audits• Audit occurs cyclically
– During the F&A negotiation process• F&A recovery rates are affected by
expenditures• Interviews of PI and BA to determine
basis for assigning space to research– Space drives the rate – 32.5 points of 57% rate
The Office of Research Services The Office of Research Support Services
114REVISED April, 2012
OMB Circular A-133 Audit• Required annual audit of federal grants &
contracts
• Performed by independent auditors– Penn: PricewaterhouseCoopers (PwC)
• Audit of systems and transactions• Cost Transfers, Effort Reports, Subcontracts, Service
Centers, Technical & Financial Reports
The Office of Research Services The Office of Research Support Services
115REVISED April, 2012
General Principles for Audits• Good award management is the key
to good (uneventful) audits• Good documentation is essential in
– Department and ORS• Audits are everyone’s responsibility
– PI, BA, School, Pre and Post-award in ORS
– Don’t go in alone
The Office of Research Services The Office of Research Support Services
116REVISED April, 2012
• Audited on compliance with all applicable regulations & policies– Federal– State– Sponsor– Specific award terms– University
General Principles for Audits (cont.)
The Office of Research Services The Office of Research Support Services
117REVISED April, 2012
General Principles for Audits (cont.)• Audited on consistency of policy
application• Audits may provide feedback for
process improvement• Audit results can be expensive• ORS & PI have a responsibility to
educate the auditor about the purposes of the project
The Office of Research Services The Office of Research Support Services
118REVISED April, 2012
Preparing for Audits• Notify ORS as soon as you learn of audit
– SPP #2130 External Audits
• ORS & PI/BA meet to prepare for audit– Anticipate questions – Develop procedures for working with auditors
• File management• Prepare and support the PI
– Work to prevent adversarial relationship
• Don’t panic
The Office of Research Services The Office of Research Support Services
119REVISED April, 2012
Audit Lessons Learned
The Office of Research Services The Office of Research Support Services
120REVISED April, 2012
Critical Audit Concerns• Salary Charges on Awards
– Effort on award must equal or exceed salary charged
– Effort must be documented in Personnel Activity Report form
– Payroll Reallocations• Same as Cost Transfers
– Communicate with PI
The Office of Research Services The Office of Research Support Services
121REVISED April, 2012
Critical Audit Concerns (cont.)• Cost Transfers
– Auditors view them as corrections of errors– Explain why the error occurred– Establish correlation of charge to next grant– Provide documentation– Maintain documentation in file– Cost Transfers must be prompt and justified– “Parking” a charge is illegal
The Office of Research Services The Office of Research Support Services
122REVISED April, 2012
Critical Audit Concerns (cont.)• Documentation
– Costs that deviate from the proposal must be justified in terms of the project
– Maintain all approvals from sponsor– Explain why decisions were made– PI must approve costs incurred on award
The Office of Research Services The Office of Research Support Services
123REVISED April, 2012
Critical Audit Concerns (cont.)• Consultants
– Document relationship with consultants• Do not circumvent IRS employee regulations• Do not engage an employee of sponsor or Penn
employee as a consultant– Consulting agreement (work for hire) must
document scope of work, rate and payment terms
• Proper inventory of equipment– Tag & document transfer, move or disposal
The Office of Research Services The Office of Research Support Services
124REVISED April, 2012
Critical Audit Concerns (cont.)• Service Centers are reviewed (A-133 & F&A
proposal)– Surpluses are problematic
• Are federal awards being overcharged?– Rates must be adjusted to off-set the surplus– At least annually adjust to compensate for
surplus or deficit– Maintain documentation of charges– Maintain records of rate determination
SPP #2115 University Service Centers
The Office of Research Services The Office of Research Support Services
125REVISED April, 2012
Critical Audit Concerns (cont.)• Subcontracts
– PI must monitor subrecipient performance and expenses
– Subrecipient must verify that it is not debarred or suspended
– ORS monitors subrecipient audit reports
• If findings result from expenditures of subcontract, Penn department is responsible for the cost of findings.
The Office of Research Services The Office of Research Support Services
126REVISED April, 2012
Critical Audit Concerns (cont.)
• Close-Out– Penn must submit all required reports
• Programmatic, Financial, Patent, Property– Timeliness of reports
The Office of Research Services The Office of Research Support Services
127REVISED April, 2012
If you are contacted by a sponsor regarding an audit…
…Contact ORS Executive Director
The Office of Research Services The Office of Research Support Services
128REVISED April, 2012
Questions???
The Office of Research Services The Office of Research Support Services
129REVISED April, 2012
Resources
Sponsored Programs at Penn
The Office of Research Services The Office of Research Support Services
130REVISED April, 2012
ORS Website and Resource Tour• http://www.upenn.edu/researchservices/
– Homepage– Left Quick Links– Sponsored Projects Manual– Sponsor Links– Spotlights– ORS Newsletters and listserv– Brown Bags and other Training
Opportunities