Office of Sponsored Programs and Contracts

Transcription

1 Office of Sponsored Programs and Contracts Proposal Process (Part A) Charles E. Patterson, Ph.D. Assistant Director Baylor University Office of Sponsored Programs 4 th Floor, Pat Neff Hall (254)

2 Agenda Part A The Proposal Process What Does the OSP Do Anyway? Grant Seeking Gifts vs. Grants Proposal Submission Proposal Processing Research Compliance Electronic Research Administration Feedback

3 Mission of the Office of Sponsored Programs To foster the development of Baylor University as a distinguished teaching and research university provide research administration support to serve the faculty and to enhance education, research, and other scholarly activities. The OSP provides full service throughout the lifecycle of a project - from preliminary review of funding opportunities to award closeout.

4 Function of the Office of Sponsored Programs The OSP is the University's representative for grants, contracts and other agreements from government agencies and private industry; serves as the centralized point of coordination for the review, approval, submission and management of all sponsored programs; and accepts the responsibility for oversight, compliance management and appropriate conduct of sponsored activities on behalf of the principal investigator or project director.

5 What is a Sponsored Program? Activities, sponsored in whole or in part, by sources external to the University for which there is an expectation (implied or specifically stated) on the part of the sponsor for performance, deliverable or outcome.

6 OSP Facts Director Russell Brewer Assistant Director Charles Patterson 3 Grant & Contract Coordinators Rene Coker Lisa Langlotz Lisa McKethan Manager of Electronic Research Administration (era) James Whiteis 2 Project Coordinators / Grants Accountants TBD Office Manager Pamela Tull

7 OSP Facts FY 2006 FY 2007 (to date) Proposals Submitted Amount Awarded $8.5MM $11.3MM Research Expenditures $10.1MM $8.3MM

8 Expectations from OSP Sponsors Expect guidelines to be followed closely Principal Investigator Expects the freedom to spend on a project as he/she sees fit University Expects that no mistakes will be made on either side!

9 Primary Duties of OSP Advocate for the faculty Review and interpretation of agency guidance for preparing and processing proposals Budget assistance Obtain Institutional approvals required for proposal submission Packaging and submission of proposals to sponsors Negotiations with sponsors

10 Primary Duties of OSP Cont d Award receipt Account set-up Budget transfers Continued compliance Subcontracting Invoicing Financial reporting Closeouts

11 Secondary Duties of OSP Research Compliance Institutional Review Board (IRB) Human Subjects Institution Animal Care & Use Committee (IACUC) animal subjects Conflict of Interest Scientific Misconduct Export Control Certifications and Assurances Develop and maintain policies and procedures for research and scholarship pursuits

12 Responsibilities of the PI Stewardship of sponsored research is vested in the principal investigator Provide sound research or programmatic results Provide overall project management Manage all project activities to ensure compliance with federal, state, University and sponsor laws, rules, regulations and policies

13 Responsibilities of the PI Manage the project budget Balance the books Request Amendments/Modifications Request no-cost extension, through OSP, prior to termination of award Authorize financial transactions of the project Certify Time & Effort Submit technical progress and annual reports

14 Sponsored Projects Lifecycle Pre-award Lifecycle Funding Search Post-award Lifecycle Closeout Proposal Development Reporting Routing / Approval Management Submission Negotiation Start-up

15 Electronic Grant Seeking External Funding Databases COS SPIN (InfoEd) FundSource (Behavioral & Social Sci.) Others: Maintained by the VPR Office

16 Internal Funding Opportunities Faculty Research Investment Program (FRIP) Award: Up to $25,000 Tenured faculty Provides seed money External proposal requirements Deadline: March 23, 2007

17 Internal Funding Opportunities Young Investigator Development Program (YIDP) Award: Up to $25,000 Tenure track faculty w/o external funding Provides seed money External proposal requirements Deadline: March 23, 2007

18 Internal Funding Opportunities Arts & Humanities Faculty Development Program Award: Up to $2,000 Promote development of the arts, fine arts, humanities, and education graduate research programs Deadline: Open

19 Internal Funding Opportunities University Research Committee Award: Up to $6,000 Promote development of all areas of research and scholarship, including the arts, fine arts, humanities, and education graduate research programs Deadline: March 19, 2007

20 Internal Funding Opportunities Other Internal Funding Opportunities Faculty Travel Assistance Program PI Research Investment Program Conference Support Program Postdoctoral Fellowship Program Grant Proposal Matching Program VPR Colloquium

21 Foundation Proposals OSP is involved in the processing and submission of all proposals for sponsored research and funding, including foundations and corporations Must contact FCD to clear foundation/corporation proposals All proposals MUST be reviewed by the Institution for compliance with sponsor and university policies

22 Proposal Submission Most important: Call OSP early in the proposal preparation process! Allows OSP to collect information on the proposal and set a timeline for processing, review, routing, and submission Complete proposal and budget should be received 5 working days prior to sponsor s submission deadline

23 Proposal Routing OSP Directories in BearSpace used for proposal routing Two steps to proposal routing: Academic (initiated by the principal investigator) Dean Chair Administrative (initiated by the OSP) OSP Coordinator OSP Director Vice Provost for Research Provost

24 Proposal Reviews & Approvals Proposal reviews & approvals ensure that the project meets the academic unit s expectations and available resources budgetary approval in cases of cost sharing the sponsor s requirements federal and state requirements research compliance (animals, humans, etc) the mission of Baylor University

25 Facilities and Administrative (F&A) Costs F&A costs (indirect costs) are the cost of doing business that are not readily identified with a particular grant or contract, but are necessary for the general operation of the university. Federally negotiated rate Baylor: 32.5% of modified total direct costs Example: $100,000 direct costs + $32,500 F&A costs $132,500 sponsor costs

26 Facilities and Administrative (F&A) Costs What about sponsors that do not (or do not want to) pay F&A costs? 2 options: 1. Provide adequate documentation of the sponsor s policy on payment of overhead charges on all sponsored projects 2. Request a waiver from the Vice Provost for Research

27 Cost Sharing Costs to the University in support of the project Mandatory The sponsor stipulates that cost sharing is required as a condition for receiving the award Voluntary Committed Sponsor stipulates that cost sharing is encouraged, but not required Voluntary Uncommitted A PI s effort over and above that which was committed and budgeted for in the sponsored agreement

28 Authorized Official Each federal proposal, as well as many nonfederal proposals, require a variety of assurances and certifications to be verified by the Institutional Official signing for the University Hint: Faculty members are not Institutional Officials

29 Certifications and Assurances Restriction on Lobbying Civil rights Act of 1964 Debarment & Suspension Financial Conflicts of Interest Export Controls Research Misconduct

30 Certifications and Assurances Other certifications Drug Free Work Place & Drug Free Schools and Campuses Buy America & Fly America Acknowledgement of Federal Grant Support Clean Air & Clean Water Act Time and Effort Reporting

31 Research Compliance OMB Circulars A-133: Audits of States, Local Governments, and Non- Profit Organizations A-110: Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education A-21: Cost Principles for Educational Institutions FAR/DFAR - Federal Government Subcontract Provisions Cost Accounting Standards (CAS) Cost Sharing Time & Effort Reporting Export Control

32 Research Compliance Financial Conflicts of Interest Research Misconduct Institutional Review Board (IRB - Human Subjects) Institutional Animal Care and Use Committee (IACUC) Radiation Safety Committee Institutional Biosafety Committee Biohazardous Materials

33 What are the Risks? Example: Research Misconduct Debarment and Suspension Fines Imprisonment Example: Noncompliance or misuse of federal funds Northwestern University paid $5.5 million Effort reporting South Florida paid $4.1 million Unallowable charges Effort reporting

34 COEUS Cradle-to-grave software for sponsored programs: Proposal development Proposals Awards Subcontracts Negotiations Conflict of Interest Report Tracking Direct Interface with Grants.gov

35 Grants.gov Single electronic source for finding federal grant opportunities (find) and submitting proposals (apply) Covers 900 grant programs from 26 grantmaking agencies ($350 billion annual awards) Based on standard forms (SF424 R&R) Forms based interface using PureEdge Developing a system-to-system interface

36 Office of Sponsored Programs and Contracts Administering Grants and Contracts (Part B)

37 Agenda Part B Overview of Grant and Contract Administration Origination of Awards Budgets Recordkeeping and Financial Management Cost Sharing Guidelines F&A Costs Closeout of Projects

38 Function of the Office of Sponsored Programs The OSP is the University's representative for grants, contracts and other agreements from government agencies and private industry; serves as the centralized point of coordination for the review, approval, submission and management of all sponsored programs; and accepts the responsibility for oversight, compliance management and appropriate conduct of sponsored activities on behalf of the principal investigator or project director.

39 What is a Sponsored Program? Activities, sponsored in whole or in part, by sources external to the University for which there is an expectation (implied or specifically stated) on the part of the sponsor for performance, deliverable or outcome.

40 OSP Facts Director Russell Brewer Assistant Director Charles Patterson 3 Grant & Contract Coordinators Rene Coker Lisa Langlotz Lisa McKethan Manager of Electronic Research Administration (era) James Whiteis 2 Project Coordinators / Grants Accountants TBD Office Manager Pamela Tull

41 OSP Facts FY 2006 FY 2007 (to date) Proposals Submitted Amount Awarded $8.5MM $11.3MM Research Expenditures $10.1MM $8.3MM

42 Pre-award Administration Grant & Contract Coordinators assigned to individual colleges/schools and their corresponding centers/institutes Work closely with the faculty in Budgeting for proposals Review and routing of all proposals Sponsor correspondence Establishment & management of all awards

43 Post-award Administration Federal, state, and university regulations Sponsor terms and conditions Budget management Allowable & unallowable expenses Billing Closeout

44 Origination of Awards Awards are received by the OSP for institutional review Budget Certifications and assurances Institutional execution

45 Federal Regulations Office of Management and Budget (OMB) Circulars A-21: Cost Principles for Educational Institutions Establishes principles for determining costs applicable to sponsored agreements, contracts, and other agreements with educational institutions. A-110: Financial Management Standards Sufficient Internal Controls Requires complete financial results of each sponsored project Procedures for determining reasonableness, allocability, and allowability of costs Requirements for supporting documentation A-133 Audits (governs statutory audit requirements for all non-profit organizations)

46 Agreement Types Federal There are 26 Federal grant-making agencies and over 900 individual grant programs that award over $350 billion in grants each year ( Federal Pass-Through Federal requirements apply even though the funds provided to the University are flowing through a nonfederal entity Private State Local

47 Agreement Types Contracts Outline specific goals and requirements For goods/services to be provided to the sponsor by the University Procurement relationship Grants For transfer of money, property or services to the recipient To provide support to accomplish a public purpose of support Anticipates no substantial programmatic involvement of the sponsor Assistance relationship Cooperative Agreements Similar to a grant Substantial sponsor involvement Assistance relationship

48 Gift or Grant? Gifts for Research The funds are awarded irrevocably to the institution. There is no commitment of direct project personnel effort (i.e. time and effort of faculty, staff or students) to accomplish project objectives. The donor does not impose restrictive conditional obligations. There is no need for review and approval of compliance issues related to the performance of research.

49 Types of Agreements Cost Reimbursable Reimbursement is based on actual expenses incurred, up to an agreed upon amount Residual funds revert to the sponsor Fixed-Price Payment is not subject to adjustment based on cost incurred Billing(s) are not based on actual expenditures Residual funds should be insignificant Beware of falsification in proposing/estimating costs 25% residual may indicate: Change in scope Shift of expenses to department or other sponsored agreements

50 Agreement Actions Subcontract/Subaward Legal agreement to transfer a portion of the research effort of the prime agreement to another institution/organization Follows the terms of the prime agreement Amendment/Modification Change to an agreement Requires authorized signature Modifies any aspect of the existing award Carryover approval (when required) Changes in funding levels No-cost Extension A common type of modification Extension of the period of performance beyond the original end date without additional funds Purpose is to ensure the successful completion of research goals Request prior to end date

51 Direct Costs Costs easily identified with a specific sponsored project Costs assignable with a high degree of accuracy to a sponsored project Examples: Salaries, lab supplies, travel, equipment, sub-contracts

52 Unallowable Costs Costs which may not be allocated to sponsored projects, either as direct or indirect costs Lobbying, public relations, alcoholic beverages, first-class air travel, fundraising

53 Facilities and Administrative (F&A) Costs F&A costs (indirect costs) are the cost of doing business that are not readily identified with a particular grant or contract, but are necessary for the general operation of the university. Federally negotiated rate Baylor: 32.5% of modified total direct costs Example: $100,000 direct costs + $32,500 F&A costs $132,500 sponsor costs

54 Facilities and Administrative (F&A) Costs What about sponsors that do not (or do not want to) pay F&A costs? 2 options: 1. Provide adequate documentation of the sponsor s policy on payment of overhead charges on all sponsored projects 2. Request a waiver from the Vice Provost for Research

55 Unallowable Costs Yale University had claimed $193,779 of unallowable costs. Yale had received the $1.7 million subaward from the University of Massachusetts Medical School (UMMS) under an NIH grant. The OIG audited the budget period Feb. 1, 2001, through Aug. 31, 2002, which had an award of $572,344. The unallowable costs broke down as follows: $151,252 for labors, related fringe benefits and indirect costs representing unallowable cost transfers, and $42,527 in unsupported direct charges and related indirect costs, including unconfirmed effort reports of $9,534. In addition, the principal investigator failed to provide the 25 percent level of effort proposed in the university's budget justification document and subgrant application and did not obtain prior approval from UMMS for the significant reduction in effort. Because UMMS, not Yale, was the grantee, the OIG is recommending that UMMS reimburse NIH for the unallowable costs.

56 Cost Principles Goal is consistent charging of expenses for all sponsored agreements (federal and nonfederal) throughout all sponsored programs

57 Cost Principles In accordance with OMB A-21, direct costs must be: Allowable: A cost can be charged to a project per the award documentation. Allocable: A cost can be assigned to a project that meets a specific project objective based on the benefits received. Reasonable: The nature of the goods and services acquired and cost involved reflect the action that a prudent person would have taken under the same circumstances.

58 Cost Principles Consistently Treated like expenses must be treated in the same manner Adequate: When incurring expense on a sponsored project, it is essential to keep sufficient documentation, such as: Answer: who, what, when, where, and why Describe any instructions that you received, such as Requested by the PI or This cost was justified in the budget proposal and approved by the sponsor. For purchases that do not appear to directly benefit the project, explain the benefit served.

59 Prior to charging expenses Is the expense allowable per the sponsor and University guidelines? Is the item/expense directly allocable to the project? Does the project have funds available for the expense? Is the expense reasonable? Would a prudent person purchase this item under the same circumstances? What will need to be included in the budget justification for the expense to be adequate?

60 Unacceptable Charging Unacceptable direct charging practices include: Purchasing items simply to exhaust an unobligated balance Rotating charges among projects Charging an arbitrary amount rather than expenses based on actual usage Assigning charges to an award before the cost is incurred Charging an expense to a single award when the expense clearly has supported other activities Transferring an overdraft from one sponsored project to another

61 Cost Transfers After-the-fact-reallocation of costs, either salary or costs other than personnel services (OTPS), to a federally funded award Examples of typical circumstances where costs transfers are allowed: Correction of a clerical error Reallocation of effort and other non-labor expenses where multiple projects benefited Reallocation of shared services Transfer of pre-award costs

62 Cost Transfers OMB Circular A-21 & A-110 cost transfers must be Explained and justified the transfer of charges to federal awards from other federal or non-federal accounts Documented Consistent Timely and appropriate under the circumstances Should be authorized by the PI responsible for the federal project to which the cost is being transferred or by the administrator to whom the PI has delegated responsibility to authorize such transfers

63 Audits Federal awards are subject to A-133 audits All sponsored projects are subject to audit by their respective agencies or Internal Audit. Receiving justification will not guarantee that the expenses may not be questioned at a later date.

64 Audits In the event of a disallowance, the responsibility for covering any disallowance will belong to the academic unit. PI and financial administrators responsible for grant administration may be subject to the following sanctions for noncompliance: fines, penalties, suspension and/or debarment.

65 Cost Sharing Cost sharing refers to funding contributed to a project from some source other than the grantor These commitments cannot be charged to another Federal project Cost sharing should not be included in the proposal budget unless required by the sponsor. Cost sharing will be reviewed thoroughly for sources and approval by chair/dean before proposal submission.

66 Types of Cost Sharing Mandatory The sponsor stipulates that cost sharing is required as a condition for receiving the award. Voluntary Committed Sponsor does not stipulate that cost sharing is required, but the PI includes such costs to enhance the proposal. Voluntary Uncommitted A faculty member s effort over and above that which was committed and budgeted for in the sponsored agreement.

67 Allowable Cost Sharing The costs must be: Allowable and allocable under the principles of OMB Circular A-21 Verifiable from University records Necessary and reasonable in order to meet project objectives Identified in the approved grantor budget

68 Unallowable Cost Sharing Federal to Federal A cost sharing requirement cannot be fulfilled by another federal grant or contract Costs incurred outside of the project period Costs that are not specifically related nor directly benefit the project cannot be cost shared

69 Unallowable Cost Sharing Alcohol, entertainment, advertising, memberships, and sabbatical costs Effort expended that exceeds a mandatory salary cap These expenses have already been factored into the indirect cost calculation

70 There are Promises to Keep An award = legally binding agreement Must fulfill any technical requirements set by the sponsor Note the schedule and due dates of reports, deliverables, etc. Note any restrictions placed by the sponsor Sponsors have held up funds while awaiting technical reports called for in their awards! What happens if we do not meet our terms and conditions?

71 Research Compliance Financial Conflicts of Interest Research Misconduct Institutional Review Board (IRB - Human Subjects) Institutional Animal Care and Use Committee (IACUC) Radiation Safety Committee Institutional Biosafety Committee Biohazardous Materials

72 What are the Risks? Example: Research Misconduct Debarment and Suspension Fines Imprisonment Example: Noncompliance or misuse of federal funds Northwestern University paid $5.5 million Effort reporting South Florida paid $4.1 million Unallowable charges Effort reporting

73 Project Management The PI is responsible for the day-to-day technical and fiscal performance and of the project If the PI has spent 80% of his/her budget, is the PI roughly 80% finished with the project? Spot problems early Overspend?

74 Reporting Requirements Reporting requirements are stipulated by the funding sources and often vary in frequency Types of frequencies include Quarterly, Semi-Annual, Annual, Interim and Final All reports are important, however final reports are especially crucial Finals are the last opportunity to convey spending activity

75 Financial Reporting Financial reporting is the vehicle used for communicating spending activity to the various funding sources Reporting requirements are often stated as part of the terms and conditions agreed upon within the contract

76 Reporting Deadlines All reporting deadlines, often stipulated within the contract, are pertinent and must be met on a timely basis Failure to meet deadlines may impact continued or future funding No Cost Extensions should be requested if more time is needed for project activity completion

77 Project Closeout The project closeout process is an internal reconciliation process It involves finalizing all outstanding receivables/payments due with payments received Overdrafts should not occur with budget control in place Should deficits exist they must be covered by the unit who incurred the expenses

78 Project Closeout Unobligated balances must be cleared Options for clearing the surplus include: Returning the unspent revenue to the sponsors Transfering the excess to an unrestricted account Handling of unobligated balances are usually communicated within the terms and conditions

79 Questions?