PowerPoint PresentationResearch Administration Network
November 14, 2014
Mark Your Calendars!
• RAN Family Feud! Date: Friday, December 12, 2014 Location: McGill Faculty Club, Ballroom, 3450 McTavish Street Time: 9am to 11am Continental breakfast will be provided RSVP online (link will be provided shortly)
• 2015 RAN sessions
History: Tri-Agency Monitoring Visit 2010 • Tri-Agency performs monitoring visits every 5 years at all institutions
to review policies and financial control framework associated with the administration of Tri-Agency funding
• Objectives of the 2010 Monitoring Visit: • To assess the effectiveness of the administrative and
financial control framework in place at the University for the administration of grants and awards
• Ensure the grant holders use their grants in accordance with Agencies’ guidelines
• Verify that the grantees are properly supported by the University in the administration of their grants
History: Tri-Agency Monitoring Visit 2010
• The monitoring visit was deemed “Not Satisfactory”
• Key Findings: • Issues related to signing authority delegation and
authorization of expenditures • Lack of supporting documentation • Weakness in financial compliance and monitoring of
expenditures
These findings must be addressed and corrected before the next monitoring visit scheduled for 2016
The Monitoring & Compliance Team (M&C) joined RFMS in July 2012 with the mandate to develop risk based review programs to monitor expense eligibility against Granting Agency Guidelines
Findings from 2010 Visit • Researchers are not authorizing every transaction
• The University had difficulty providing supporting documentation showing that PIs or their authorized delegates had approved/authorized all expenses charged to the grants.
• All expenditures must be supported by the required documents including an appropriate justification • Documentation was not readily available from the departments • Written justification was not provided on how the expenditure
directly relates to the research grant
• Improve financial compliance and monitoring of expenditures • The University was unable to demonstrate that some transactions
were reviewed for compliance and eligibility by an appointed institutional official other than the Grantee or their delegate.
Monitoring & Compliance Team Monitoring and
Compliance Team
• Develops and executes compliance programs by transaction type (Pcard, Expense Reports, Payroll, Feeds, etc)
• Simulates Tri-Agency audits
Elvie Coletta Director, RFMS
• Develop and implement new risk-based monitoring programs to ensure compliance and eligibility vis-à-vis sponsor regulations
• Assess the University’s readiness for the upcoming Tri-Agency Monitoring Visit (2016)
• Recommend policy or process changes to ensure effective controls are in place
• Partner with the Faculties to ensure guidelines are well interpreted and assist the Faculties by providing tools to help them in administering their research grants
• Communicate compliance findings to advise the University of potential areas for improvement
• Facilitate external audits • RFMS control reports
Review Programs In FY14, the following transaction streams were tested: PCard Expense Reimbursement Claims POPs (Casual Payroll) BSA (Banner Student Aid)
New programs to be introduced in FY15 & FY16: Payment Requests Minerva Appointment Forms Journal Vouchers Tri Agency Audit Simulation (scheduled for August 2015)
Transaction Review Criteria • The Monitoring & Compliance Team completes quarterly
reviews of research financial transactions. The aim of these reviews is to ensure that expense transactions charged to research funds are: • Eligible expenses with respect to sponsor agency guidelines • Authorized by the PI or an appropriate delegated signing
authority and • Supported by appropriate back up documentation
• In each review, a random sample of transactions is selected. Source documentation is then reviewed for each transaction selected and will be used to verify eligibility and authorization.
• Has the transaction been authorized and approved
by the PI/Delegate?
Transaction Review Criteria
DOCUMENT AVAILABILITY
PROPER APPROVAL
ELIGIBLITYSUBSTANTIVE ERROR
• Is the amount legitimate & appropriate? • Is there any duplication in payment?
• Is transaction eligible on the fund?
• Is it an economical use of funds?
• Has justification been provided on how it relates to research?
Transaction Review Criteria DOCUMENT AVAILABILITY
PROPER APPROVAL
• Is the transaction eligible on the fund? • Is it an economical use of funds? • Has justification been provided on how it relates to
research? ELIGIBILITY
• Is the payment legitimate and appropriate? • Are there any errors? • Was the transaction underpaid/overpaid?
SUBSTANTIVE ERROR
EXR • Is the claim
countersigned by the chair/dean?
POPS •Is the offer letter signed by the PI?
•Is the time sheet approved by authorized person?
• Is the supporting documentation available to support the expense? • Is the supporting documentation readily available?
Transaction Review Criteria
DOCUMENT AVAILABILITY
PROPER APPROVAL
•Is the transaction eligible on the fund? •Is it an economical use of funds? •Has justification been provided on how it relates to research?
ELIGIBILITY
• Is the payment legitimate and appropriate? • Are there any errors? • Was the transaction underpaid/overpaid?
SUBSTANTIVE ERROR
APPOINTMENT FORM
PAYMENT REQUEST
signed by the PI? • Is the change in
labour distribution approved by the PI?
PAYMENT REQUEST • Is the transaction
approved by the PI/authorized delegate?
JOURNALS • Is the
transaction/transfer authorized and approved by the PI?
• Is the supporting documentation available to support the expense? • Is the supporting documentation readily available?
Special Reviews: Duplicate Payments
• PCard/Expense Reimbursement Claim • Transaction initially paid by Pcard and then submitted on an
Expense Report
• Same receipt attached to two separate claims (electronic receipts)
• POPs Transactions • Same timesheets submitted for the same individual for the same time
period.
Tips to Prevent Duplicates • PCard/Expense Reimbursement Claim
• Encourage a document retention center. This will prevent Pcard receipts from being submitted on EXR claims
• Reimbursement on Two Separate Expense Reimbursement Claims • Be mindful of electronic receipts or credit card chits • Ask questions if EXR claims are incomplete
• POPs Transactions • Process original timesheets • If multiple POPs submitters in unit, ensure process exists to
prevent both submitters from processing same timesheets (ie vacation, time off)
Annual Compliance Results FY14
PROGRAM FY14 FY13
PCard 19% 17%
PROGRAM FY14 FY13
Expense Reports & POPS
remain high
Results communicated to VPA&F, VPRIR, TRIG Executive Steer Co & FFOs Financial Services will continue to work with the Faculties that require further
improvements
Issues M&C Observations Requirements
No affiliation of claimant to grantee
No affiliation stated when traveller is not the grantee OR only the ID of the traveller is indicated
Affiliation to the researcher must be specified – e.g. Post Doc, Grad Student, etc.
No conference program/prospectus
Official supporting documentation (e.g. prospectus or program, indicating the dates of conferences and workshops);
No meeting agenda No supporting documentation is attached to claims when travelling to attend meetings
If the traveller is attending meetings - the meeting agenda, invite letter or email correspondence must be attached to the claim
Missing original receipt(s) Credit card chits are attached in lieu of original receipts
Original receipts are required - credit cards slips are not valid receipts
Missing detailed meal receipt(s) Credit card chits for meals OR Meals on hotel bills
Tri Agency requires detailed meal receipts for all meals charged to the grants
Recurring Findings – by Program POPS (Casual Payroll)
Issues M&C Observations Requirements Missing time sheet/Missing offer letter
No supporting documentation retained at the Faculty
Timesheets and offer letters must be retained at the Faculty
Time sheet not signed by PI/delegate
No signature or incorrect signature on POPS timesheets
Timesheets must be signed prior to payment by the PI and/or his delegate
Offer letter not signed by authorized person
Offer Letters are signed by Department Chairs or Supervisors
Offer Letters must be signed by the Principal Investigators
Duplicate Payments Timesheets are being submitted for the same period resulting in overpayments
Ensure timesheet for the same period has not previously been submitted
No reply to monitoring request No documentation was received from POPS submitter
A response including documents requested must be addressed within 10 days of email receipt
Replies received after 10 day deadline
Documentation received after 10 day deadline
Documentation must be readily available for all audits within specified timeframe
* Duplicate Payments – Faculties need to ensure that proper controls are in place to prevent duplicates from occurring.
Compliance Best Practices • Expense Reports
• Expedia invoices must show proof of payment: either credit card statement, credit card info on receipt to show method of payment OR must show “Collected by Expedia”
• POPS • New timesheets must be used POPS Timesheets • POPS delegates must be set up in Minerva • Proper completion of timesheet – Time in/Time Out • Email approvals from PI must include the POPS payment details (ie $ value,
student name, period paid)
• BSA • The Student Stipend Authorization Form is the only acceptable supporting
documentation • Reassignments – PI approval must be obtained
Communication of Results
• RFMS communicates compliance results on a quarterly basis to each Faculty via both email and face to face meetings with the Faculty Financial Officers (FFO) • Issues and concerns are addressed and recommendations are
made to assist the Faculty
• Results and recurring findings are shared with the FSTs
• Director, RFMS communicates University results to the Executive TRIG SteerCo Committee (quarterly/annually)
• VP-RIR reviews compliance results with the Deans
Typical Sponsor Audit Cycle Initial request for
Information
Procedures
Recent audits • RFMS has been involved in many audits this year:
• Genome Quebec • Health Canada • Agriculture and Agri-Food Canada • CIDA • CFI
Put yourself in the shoes of an external auditor who is not familiar with the research project, the PI or McGill. • How can we justify the costs being charged are
in relation to the research that was awarded? • How can we demonstrate compliance with
agency and institution rules/regulations?
Tri-Agency Monitoring Visit 2016
• Initial Request for Information • Tri-Agency will provide McGill with a Collaborative Information
Gathering Tool (CIGT) to complete • This document contains 100 questions aimed at assessing the
University’s overall controls • Completed jointly by RFMS and OSR • Based on the University’s responses, the auditors will assess each
item and focus their reviews on items where weaker controls exist
• General Ledger Details and sample selection • G/L details are provided to the auditor for the grants selected for
review
sample selections
issued
Monitoring Visit 2016 • Transaction Testing Phase
• The sample of transactions selected is based on risk and volume • The agencies test the various control elements (i.e.
authorizations, documentation, and review for compliance and eligibility)
• The testing is based on the transaction as a whole (i.e. entire travel claim, salary payment including benefits)
• The level of detail and information provided must be identical to the level of detail and information available at the time the institution reviewed the expense
Results of the 2016 monitoring visit must be “ “ as to not jeopardize future research funding.
Ensuring Successful Audits • Seek Training
• Standard Administrative Procedures (SAPs) • Sponsor and/or McGill University policies and guidelines • InfoEd Terms and Conditions • Checklists • Research Administration Network (RAN) • Financial Services Teams (FST) • Internal Meetings
• Ensure accuracy and compliance every time • Ensure expenditure eligibility • Ensure document(s) completeness
• Expenses must be clearly explained as to avoid further questions • Charge direct costs correctly • Use appropriate account codes for all expenses • Avoid expenditure transfers from one fund to another
• Plan salary distribution and other expenses based on fund termination dates
• Be mindful of large purchases in the last six months of the grant
Ensuring Successful Audits • Document, Document, Document
• If a document is related to the research grant/contract – KEEP IT • Ensure all documents are consistently saved in a central local
repository (dept./faculty; NOT in individual Inbox) for 7 years at a minimum
• Ensure PI (or delegate) approval is obtained and kept in central local repository (dept./faculty; NOT in individual Inbox)
A Record Retention Document was created by Financial Services to inform departments of the documentary requirements:
http://www.mcgill.ca/financialservices/sites/mcgill.ca.financialservices/files/reco rd_retention_of_supporting_documentation_20140325_0.pdf
Role Phone Email
Stella Sotocinal Compliance Supervisor (514) 398-1672 stella.sotocinal@mcgill.ca
Cila Correia Compliance Administrator (514) 398-7315 lucilia.correia@mcgill.ca
Nancy Costa Compliance Administrator (514) 398-3011 nancy.costa@mcgill.ca
Kimberly Christmas Compliance Coordinator (514) 398-8894 kimberly.christmas@mcgill.ca
Tina Marzilli Training and Support (514) 398-5488 tina.marzill@mcgill.ca
Kara Watkins Administrator (514) 398-4455 Ext 0346
kara.watkins@mcgill.ca
All eligibility queries should be sent to: RFMS Expense Eligibility rfmsexpense-eligibility.finserv@mcgill.ca
• http://www.mcgill.ca/financialservices/sites/mcgill.ca.financialservices/fi les/record_retention_of_supporting_documentation_20140325_0.pdf
Findings from 2010 Visit