Tar Heel Certificate Program

in Research Administration

Level 1 Certification

Special Monitoring

Requirement

&

Project Closeout

2

Agenda

• A-110 Post-Award & After-the-Award Requirements

• Special Monitoring Requirements– Cost Sharing

– Effort Reporting

• Generating Payment Requests

• Award Close-out

• After-the-Award– Record Retention

– Audit Survival Tips

• Certificates of Completion

3

Close-out Award

Generate Payment Requests

Monitor Project & Manage

Funds

Life Cycle

of an Award

Life Cycle of an Award

4

Meet the OSR

Cost Sharing &

Effort Reporting Team

Becky Hinshaw, Administrator

Kay Hendricks, Personnel Activity Reporting Technician

Kelly Spivey, Personnel Activity Reporting Technician

Responsible for distribution, collection, review and maintenance of the official file of time and effort reports in compliance with the Office of Management and Budget Circular A-21.

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Cost Sharing definition from OBM Circular

A-110 A.2(i):

“Cost Sharing or matching is the portion

of project or program costs not borne by

the Federal Government.”

Special Monitoring Requirement: Cost Sharing

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Types of Cost Sharing

Mandatory• Specifically required in the

award

• Identified in the proposal budget

• Reporting Requirements:

– Effort Reporting - PAR

– Financial System - FSR 269

Voluntary Committed• Specifically pledged in proposal

budget or budget justification

• Identified in the proposal narrative

• Reporting Requirements:

– Effort Reporting - PAR

– Financial System - FSR 269

Voluntary Uncommitted• Not promised

• Not budgeted

• No reporting requirements

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OMB A-110 Requirements

• Be necessary and reasonable for proper and

efficient accomplishment of the project

• Be verifiable from the official University

records

• Be incurred during the effective dates of grant

• In the approved budget when required by the

Federal awarding agency

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OMB A-110 Requirements

• Not be used as cost sharing for any other

Federal sponsored program or project

• Not be paid by Feds under another award

(except where authorized by Federal statute to

be used for cost sharing or matching)

• Allowable under A-21, the agreement, and

public laws

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Method of Cost Sharing: Cash

The recipient’s cash outlay; contributions under the direct control of the recipient

– Salaries and benefits of University employees

– University purchased equipment/supplies/travel or other allowable expense

– Facility & Administrative (F&A) costs

• Un-recovered from above costs

• Waived F&A costs (with permission of the sponsor)

– University unrestricted funds contributed to project:

• State / Gift / Endowment Funds

• F&A recovered and returned to departments

• Program income

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Documenting Cash Contributions

• Salaries & benefits of University employees – Payroll Records

– Effort Reporting in PARS

• University purchased equipment, supplies, travel or other

allowable expense– PO#, Check #, AJ-1#,

– FRS report with object code, date of expenditure

– Documentation - OSR Form “Documentation of Non-

Personnel Cost Sharing”

http://research.unc.edu/services/forms.php#post

• Cash Contribution – Sworn statement by financial officer, copy of check or receipt

for payment

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Value of non-cash contributions provided by non-

Federal third parties

– Donated Equipment & Supplies:

• At current fair market value

– Volunteer Services:

• Based on rates paid for similar work

• Includes associated Benefits

• * can not include F&A see A-110 c23(e)

Method of Cost Sharing: In-Kind

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Documenting In-Kind Contributions

• Equipment

– Vendor invoice showing total item cost

• In-Kind Other

– Letter of support detailing support (time, place,

value)

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EPAWeb Example

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• Federal sponsors require the University to track and certify how employees are compensated for work performed on sponsored agreements.

• At UNC-CH the Personnel Activity Reporting System (PARS) is used to certify effort

– Provides support for salary & benefits charges to grants & contracts

– Documents that effort commitments have been met

– Documents cost share

Special Monitoring Requirement: Effort Reporting

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Effort Reports Process

• Effort Reports are generated based on most

recent payroll information

• Effort Reports are printed after payroll closes

• EPA – certified quarterly (printed after 3rd

payroll closes)

• SPA –certified every two payrolls (printed

after 2nd payroll closes)

FY2009 PAR CYCLES

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Increased Federal Attention

• Effort Reporting under intense scrutiny

– Signature by person with “first hand knowledge”

– Timely certification (delinquent PAR an area of

audit concern)

– Validity of certifications (frequent cost transfers an

area of audit concern)

– Avoid the appearance or reality of manipulation of

salary for budgetary purposes

Close-out Award

Generate Payment Requests

Life Cycle

of an Award

Life Cycle of an Award

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Meet the OSR

Financial Reporting and

Cash Management Team

Hilda Durham, Director

Responsible for preparing financial reports to

sponsor agencies, preparing invoices, and

managing cash flow for all sponsored research

accounts (excluding accounts involving clinical

trials, per patient or per sample)

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OSR Cash Management Functions

Amy Buchanan, Cash Management Accountant

• Letters of Credit draws and reconciliations

• Deposit of all checks for all sponsored research accounts (including clinical trials)

• Maintain accounts receivable and collection on delinquent receivables

• OSR may contact the department if funds have not been received due to a problem with the PI’s progress report or deliverables

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A-110 Post-Award Requirements

Reports & Records – Monitoring and Reporting Program Performance

• Prime awardees responsible for monitoring sub-recipients

• Technical, Financial, and Federal Cash Transactions

• Annual, semi-annual, quarterly, monthly

• Final

• Retention for 3 years after last action, government unrestricted access

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OSR Financial Reporting Teams

Team Leaders / Reporting Specialists

• Emily Linz

– Nancy Armstrong

– Ellenie Asrat

– Jane Shaw

• David Elkins

– Jessica Charles

– Matthew Gard

– Christie Harris

Jenifer Gwaltney, Manager

• Betty Williams

– Bridget Foust

– Dewey Green

– Carolyn Ivey

– Vacant

• Marry Harris

• Financial Reporting Administrator

– Joan Anderson

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OSR Financial Reporting Functions

• Award Monitoring

– Due dates for progress reports

– Sub recipients

• Liaison on financial matters with

– Funding agencies

– Auditors

• Generate invoices and report of expenditures

• Award Close out

– Final Financial Report to funding agency

– Final account/fund closing

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Under OMB requirements, there are three

methods of payment that are based on the

university’s ability to manage cash:

– Advanced Payment Method

– Reimbursement Method

– Working Capital Advance Method

Generate Payment Requests

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Generating a Payment Request

• Determined by expenditures on latest FBM090

• Resolves issues; makes adjustments

• Monitor cost sharing

• Prepares and submits invoices

• Records submission of invoices and receipt of

payment

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When do you start planning for the close-out process?

a. At the time the proposal is developed.

b. At the time the award is accepted.

c. At the time modifications, extensions or supplements are approved.

d. Just prior to the expiration of an award.

e. At the time of expiration of an award.

f. All of the above.

Close-out Award

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Planning for Close-out

Proposal Stage• Address problematic closeout

issues with justifications and negotiations

– When proposal being developed

– At the time of the award

– When issuing a sub-agreement

– With every modification

• Invoicing and financial reporting

– Flexibility

– Restrictions

Award Stage• Monitor and notify PI and

department administrators

Close-out Stage• Special closeout requirements

• Due dates

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OMB A-110 After-the-Award Requirements

Close-out procedures • Submit all reports within 90 days of expiration

• Pay all obligations within 90 of expiration

• Refund un-obligated funds promptly

• Account for property

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Close-out Reports

Report Responsibility

Technical, progress,

narrative

Principal Investigator

Financial Office of Sponsored Research (using

department NOTR data and FRS data)

Patent / Inventions Office of Sponsored Research & Office of

Technology Development

Property Office of Sponsored Research & Asset

Management

**Sub-recipients Office of Sponsored Research and PI

** Reports from sub-recipients needed in advance in order to incorporate into

reports to sponsor

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Notice of Termination Reply (NOTR)

• Notice sent as an email to business office manager within one week of budget period ending

• Serves as notification that budget has ended for the award account

• Includes request for PI to provide financial data of– Outstanding obligations

– Pending adjustments not shown on FMB 090/091

• Enter NOTR information through RAMSeS

• Always use latest FBM090

• OSR may prepare report without NOTR if it is not received in a timely manner from the department

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Departmental Award Close-out

Checklist• Report Preparation

– PI Final Technical Report

– Notice of Termination Reply

– Final Cost Sharing Report

– Retain Administrative Records

• Final Transactions– Stop all cost sharing

– Cancel or change account for open orders

– Clear cash advances

– Record and reconcile study subject costs from Imprest Account

– Record program income

– Prepare personnel actions to transfer to new source

• Final Monitoring

– Assure sub-contactors have submitted ‘FINAL’ invoice

– Assist with closing sub-awards

– Resolve outstanding encumbrances and charges

– Review costs and reconcile with FRS

– Make adjustments to FRS for unallowable expenses, post-term charges, overdrafts or deficits

– Monitor FRS until Budget Balance Available (BBL) and encumbrances equal ZERO

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• Submits Final Financial Status Report

• Coordinates close-out of sub-awards

• Coordinates the reporting of Patents / Inventions

• Ensures closeout of the award

• Closes out account/fund

• Returns unexpended funds

• Retains files (office of record)

OSR Close-out Checklist

35

• Completes research project

• Submits deliverables/reports (including subrecipients)

• Assists with resolution of issues related to subrecipients

• Assists with preparation of Notice of Termination Reply (NOTR) and certifies in RAMSeS

• Certifies cost sharing

• Retains research records

PI Close out Checklist

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After the Termination of an Award

What you might encounter:

– Post-Term Charges

– Unallowable / Unallocable Costs

– Final Adjustments / Closing Entries

– Record Retention

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Post-Term Charges

Costs incurred after termination date of the project/award

– Common post-term charges

• Payroll expenses

• Procurement card charges

• Telephone costs

• Copy services

• Service center charge

– Should be completed by the department within 90 days after termination date

– Must be explained and justified for allowability

38

Unallowable / Unallocable Costs

Project expenditures that are not in compliance with

– University policy

– Sponsor terms and conditions

– OMB Circular A-21

• Should be completed by the department within 90 days after termination date

• University cannot request reimbursement or payment from the sponsor

• Auditor may question

– Financial controls

– Stewardship of sponsored funds

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Potential Unallowable/Unallocable Costs

• Post-Term charges

• Restricted purchases without proper sponsor

authorization

• Unauthorized foreign travel not in accordance with

US Flag Carrier Regulations

• Costs normally indirect but charged as direct without

proper justification

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Final Adjustments/Closing Entries

• Deficits or overdrafts - when cumulative expenses exceed amount awarded– May be considered voluntary uncommitted cost sharing

– Deficits must be transferred out of sponsored award no later than 90 days after termination date

– OSR notifies department after termination that expenses will be transferred to overhead or residual account

• Positive balance returned to sponsor

• Department must reconcile accounts timely– Keeps monitoring FRS until Budget Balance Available

(BBL) and encumbrances are ZERO

• OSR freezes account once FRS is ZERO

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• Financial records, supporting documents, statistical records and all other records shall be retained for a period of THREE years

• Litigation requires retention until all matters have resolved

• With agency approval, copies can be substituted for original records

• Access to records by agency, inspector, general, or comptroller generally is allowable

Record Retention

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Audit Survival Tips

The most common types• System - conducted by

– UNC-CH Internal Audit

– N.C. Office of the State Auditors

• A-133 – conducted by– N.C. Office of the State Auditors

• Contact OSR - serves as liaison for working with auditors

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What the Auditors Look At

• System Audit

– Budgeting process, recharge center, purchasing

procedures, time and effort/cost sharing

• A-133 Audit

– Compliance and internal controls

– Review financial transactions, payroll, effort

reporting

– Looking at how we have used the research dollars

and how we have allocated costs to specific projects

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What Auditors Test For

• Compliance to program guidelines

• Unallowable costs (cost transfers)

• F&A rate and calculation

• Timeliness and accuracy of reports

– Progress, Financial, Patent and Invention, and Special reports

• Program Income

• Sub-recipient monitoring

• Time and Effort Reporting (compensation and certification)

• Cost Sharing

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Module 5 Competency Test

• Go to the following web site to complete the

Competency Test for Module 5

https://apps.research.unc.edu//THCP_Mod5/THCP_Mod5.htm