Tar Heel Certificate Program in Research Administration Level 1 Certification Special Monitoring Requirement & Project Closeout

Transcription

1 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 2

3 Life Cycle of an Award Close-out Award Life Cycle of an Award Generate Payment Requests 3 Monitor Project & Manage Funds

4 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.

5 Special Monitoring Requirement: Cost Sharing 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. 5

6 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 6

7 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 7

8 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 8

9 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 9

10 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 Cash Contribution Sworn statement by financial officer, copy of check or receipt 10 for payment

11 Method of Cost Sharing: In-Kind 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) 11

12 Documenting In-Kind Contributions Equipment Vendor invoice showing total item cost In-Kind Other Letter of support detailing support (time, place, value) 12

13 13 EPAWeb Example

14 Special Monitoring Requirement: Effort Reporting 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 14

15 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 3 rd payroll closes) SPA certified every two payrolls (printed after 2 nd payroll closes) 15

16 FY2009 PAR CYCLES

17 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 17

18 Life Cycle of an Award Close-out Award Life Cycle of an Award Generate Payment Requests

19 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) 19

20 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 20

21 A-110 Post-Award Requirements Reports & Records Monitoring and Reporting Program Performance Prime awardees responsible for monitoring subrecipients Technical, Financial, and Federal Cash Transactions Annual, semi-annual, quarterly, monthly Final Retention for 3 years after last action, government unrestricted access 21

22 OSR Financial Reporting Teams Jenifer Gwaltney, Manager Team Leaders / Reporting Specialists Emily Linz Nancy Armstrong Ellenie Asrat Jane Shaw David Elkins Jessica Charles Matthew Gard Christie Harris Betty Williams Bridget Foust Dewey Green Carolyn Ivey Vacant Marry Harris Financial Reporting Administrator Joan Anderson 22

23 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 23

24 Generate Payment Requests 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 24

25 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 25

26 Close-out Award 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. 26

27 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 27

28 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 28

29 Close-out Reports Report Technical, progress, narrative Financial Patent / Inventions Property **Sub-recipients Principal Investigator Responsibility Office of Sponsored Research (using department NOTR data and FRS data) Office of Sponsored Research & Office of Technology Development Office of Sponsored Research & Asset Management Office of Sponsored Research and PI ** Reports from sub-recipients needed in advance in order to incorporate into reports to sponsor 29

30 Notice of Termination Reply (NOTR) Notice sent as an 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 30

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33 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 33

34 OSR Close-out Checklist 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) 34

35 PI Close out Checklist 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 35

36 After the Termination of an Award What you might encounter: Post-Term Charges Unallowable / Unallocable Costs Final Adjustments / Closing Entries Record Retention 36

37 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 37

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 38

39 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 39

40 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 40

41 Record Retention 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 41

42 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 42

43 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 43

44 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 44

45 Module 5 Competency Test Go to the following web site to complete the Competency Test for Module