The Lifecycle of a Sponsored Project

Transcription

1 The Lifecycle of a Sponsored Project Active Period Spending, Invoicing, Reporting, Monitoring Award Processing And Account Setup Final Reporting Proposal Closeout Funding

2 Funding Sources Where does the Money come from? Congressionally appropriated funds for Basic Research Private Foundations Federal Contracts for specific work Private Industry Contracts for specific work

3 Funding Opportunities Federal Funds for Basic Research Annual Budget Act becomes Public Law Sets funding levels for each agency (NSF, NIH, USDA etc. ) Agencies issue Requests for Proposals (RFP) n on their website: n n n UA Faculty submit applications endorsed by SPS (on behalf of VPR)

4 Funding Opportunities

5 Funding Opportunities

6 Funding Opportunities

7 Funding Opportunities

8 Funding Opportunities back

9 Funding Opportunities Federal Funds for Basic Research Annual Budget Act becomes Public Law Sets funding levels for each agency (NSF, NIH, USDA etc. ) Agencies issue Requests for Proposals (RFP) n on their website: n n n UA Faculty submit applications endorsed by SPS (on behalf of VPR)

10 Proposal Process UA items needed for proposal process Three business day deadline Electronic Proposal as of October 1 st n Replaced Paper PRS (Proposal Routing Sheet) Sponsor Face/Cover Page Project Abstract Budget and Budget Justification Cost Sharing Budget n Including evidence of commitment

11 Proposal Process Proposal Review n n n n n Budget ERE & F&A Rates Budget categories Cost Allowabillity Cost share Compliance with University Policy and Sponsor Regulations Conflict of Interest, Export Control, human/animal subjects, etc Proposal Submission Upon SPS Approval PI, Dept or College may then to submit to Sponsor Electronic Submission by SPS n n Grants.gov Fastlane

12 Agency Review Federal Agencies Receive applications Initial Review of Applications for eligibility and meeting RFP guidelines Peer Review: impartial merit review by peers of applicants Distribution of Applications to Peer Review Committee members

13 Peer Review Peer Review Committee Meeting: Face to face discussion of each application with goal of ranking best applications. Outcome of Peer Review: ranking and recommendations.

14 Selection and Award Notification of Applicants: recommended, not recommended, ranking, etc. (Review Comments) Budget review and negotiation with recommended applicants Recommendation for funding to Grants Office Funding Document Issued

15 Classification of Award Award documents n Unilateral award (does not require signatures) n Bilateral awards (require signatures) n Requires PI approval Types of agreements n Assistance n Grants n Cooperative Agreements n Procurement n Contracts n n n Clinical Trials Cost Reimbursement Fixed Price

16 Sponsor New Award PI Approval Pre- Award Negotiation ORCA (Office of Research and Contract Analysis) Fully executed Agreement Post- Award Dept. UAFinancial Account Award Process

17 Account Setup Review for Special Restrictions (budget, equipment, carryover, etc.) Invoicing Requirements Reporting Requirements Enter into UAFinancials Once Budget is loaded, department can begin spending

18 Terms and Conditions Where to find them: on the award Order of precedence: Award Sponsor T&C (Program T&C and Agency T&C) Circulars A-110; A-21 for federal grants Research Terms & Conditions (RTC); Agency Specific T&C under RTC Federal Acquisition Regulations (FAR) for federal contracts The SuperCircular

19 Monitoring and Reporting Monthly Reconciliations of Financials by Department and PI SPS submits Invoices and Financial Reports Justification and backup from departments may be needed SPS Monitors Aged Accounts Receivable and Cash Balances Deficit Notices New automatic deficit notice Property Reporting Invention / Patent Reporting: PI signature needed

20 Monitoring Accounts Action List SPS Approvals GEC, General Error Correction SET, Salary Expense Transfer Effort Certifications Requisitions Purchase Order Changes with $ Postings to Expired Accounts

21 Spending versus Time ( Burn Rate ) Ideally, spending should be smooth with time, or peaking in middle of active period Late spending (either delays in starting or spending a lot at the end) can raise red flags

22 Modifications & Prior Approvals No cost extensions (different sponsors have different processes) Prior Approval (Administrative Changes) Key Personnel Budget change approval Equipment not in approved budget Foreign Travel Any waiver of Terms and Conditions

23 Modifications & Prior Approvals Amendments and Modifications: Continuation Funding Modifications requiring dual signature n Sponsor issued amendment n UA templates (ORCA site) Research Terms and Conditions Grants From: NSF, NIH, USDA-NIFA, RTC Prior Approval Matrix Prior approvals processed through postaward

24 End of the Project: Concurrence Getting agreement from the PI is the basic requirement for final financial reporting and closeout PI signs concurrence to certify expenses or delegates signature authority to Business Official Uncommunicative PIs/Departments may result in FFR/Final Invoice being late with possible loss of funding Budget is reduced as soon as concurrence is received

25 MEMORANDUM TO: Douglas Loy c/o Rose Evans DUE DATE: October 25, 2013 FROM: Doug Dawson Phone: DATE: October 18, 2013 RE: Account No Tetrazines for Hydrogen Storage The enclosed FINAL WORKSHEET and FINANCIAL STATUS REPORT for the referenced award are forwarded to you for approval. If you concur with this report, please sign the certification below and return this memo to me. If you do not concur, please advise me of the discrepancy for correction. Total award amount: $ 100, Total expenditures: $ 99, Total unexpended balance: $ 0.83 Budget will be reduced $ 0.83 Refund to Sponsor: Unbilled Balance (To Be Invoiced Upon Concurrenc $ - I concur with the expenditure report and certify that all expenditures reported or payment requested are for appropriate purposes and in accordance with the provisions of the application and award documents. I understand that if I fail to return this concurrence by the DUE DATE the University may lose the ability to collect the unbilled balance and my department will be responsible for the uncollected funds. Principal Investigator Date Reasons for non-concurrence (if applicable):

26 /31/2013 Current Valid Total Expenses & FINAL Previously Current Expenses Unliquidated Unliquidated Cumulative FRS Remaining ITD Reported Expenses Adjustments Reported Obligations Obligations Obligations Budget Balance Personnel 41, , , , , , , Tuition Rem. 13, , , , , * Operations 41, , , , , , (24,032.43) Subcontracts Travel 2, , , , , , , Capital Direct 99, , , , , , Indirect TOTAL 99, , , , , , *Tuition Remission rolls up into Personnel I/C ADJUSTMENTS: I/C REPORTED: TDC 99, TDC 99, DATE Less Capital - Less Capital - Concurrence to Department Less Other Non-OH & Tuition Rem. Less Other Non-OH & Tuition Rem. Report Mailed to Sponsor I/C Base 99, I/C Base 99, I/C Adj. Prepared I/C Rate 0.00% I/C Rate 0.00% BL# & Date N/A I/C Earned - I/C Earned - Billing Sent I/C Applied - I/C Applied - Cost Sharing Request Adjustments - Adjustments - Initials ADJUSTMENTS: UNLIQUIDATED TOTAL EXPENSE RECONCILIATION: OBLIGATIONS: as of : 10/18/2013 Month Month INVALID EXPENSES: Posted Posted Month Reference No. To FRS Amount Reference No. To FRS Amount Posted Sept Transactions Sep-13 $ Reference No. To FRS Amount October Transaction Oct-13 $ TOTAL - TOTAL EXP & UNLIQ. OBLIG. 99, TOTAL EXP AS OF 10/18/ , TOTAL TOTAL - DIFFERENCE -

27 Final Financial Report Draft FFR will be sent to department with concurrence. We are certifying that all expenses are appropriate and in accordance with the agreement. Revision is usually not possible. More detail may be required than previously; department may need to provide this information. Cost Category Breakdowns Personnel Classifications Cost Sharing Backup for some or all expenses Expense Justifications

28 Property Reporting Handled by SPS Property Administrator: Jennifer Brown Based on award regulations For contracts that involve an equipment deliverable it s important to work with Jennifer and to have both a D-tag and proof of delivery Possible outcomes depending on the regulations Maintain equipment at the UA Return equipment to sponsor Provide equipment to third party

29 Invention/Patent Reporting PI s have ongoing responsibility to report any inventions to Technology Transfer Office At the end of a project a Final Patent Report is often required. SPS facilitates this reporting. SPS sends form to PI; PI completes and returns to SPS SPS sends to Tech Transfer for signature Back from Tech Transfer, SPS submits to sponsor

30 Other Closeout Documents SPS will complete or coordinate Release and Assignment Forms for Contracts and Subcontracts UA Small Business Utilization Manager - Beth Lopez in Procurement handles Subcontracting Report for Federal Contract > $650K ($750K for new) UA Small Business Utilization Manager - Beth Lopez in Procurement handles EPA Grants need annual MBE/WBE

31 Fixed-Price Contracts Payment for Fixed-Price Contracts depends on deliverables being submitted and accepted by sponsor. SPS will request status of deliverables for invoicing. SPS usually has little reporting at end; non-auditable Dept confirms work is completed and requests conversion to fixed price complete SPS confirms full payment is received and then Charges out IDC budget and Transfers remaining funds to PI s FPC account in appropriate department

32 Closing the Account All reporting should be complete All encumbrance should be removed All disallowed transactions should be removed, deficit should be cleared Accounts and cash must be balanced Account marked closed Records must be kept for 5 years from acceptance of deliverables and Financial Report Consult with College refer to records management Time to find new funding

33 DISCUSSION & COMMENTS

34 Prior Approvals Processing: The old standard: Letter to Grants Officer/Contracts Officer /Grants Management Specialist (NIH) initiated by Dept/College and signed by PI and routed to SPS for endorsement (include signature line for Sherry Esham, Director, Sponsored Projects Services) Dept submits to sponsor and follows up Amendment/Approval is issued by Sponsor and processed (Amendment=preaward; approval= postaward) Prior Approvals Required: A-110 Equipment: Yes required; change of PI effort > 25%: Yes required; Rebudgeting: no if no change in scope; Preaward Costs: Yes required; Foreign Travel: Yes required, Subcontracts (subaward of significant programmatic activity): Yes required. NCE: Yes required Prior Approvals Required: Research Terms & Conditions (RTC): See matrix Equipment: depends; Change of PI effort > 25%: Yes required; Rebudgeting Participant Support (Yes for NSF); Preaward Costs: No, not required; Foreign Travel: depends, Subcontracts (subaward of significant programmatic activity): Yes required. NCE: depends Other sponsors: See T&C of award. Often an request will result in an approval or a contract modification, as appropriate. Contracts have no automatic rebudgeting, especially if they are cost reimbursable. Grants Officer Approval vs. Program Officer Approval: Grants officer approval is usually required when the request concerns prior approvals required. No Cost Extension Processing: NSF: NIH: 1 st NCE Processed through fastlane 10 days + prior to expiration Initiated by PI in fastlane 2 nd NCE: Initiated by PI 45 days + prior to expiration Initiated by PI in fastlane (requires PO approval) 1 st NCE: to fund accountant with justification within 90 days prior to expiration of final segment SPS submits in NIH ERA Commons 2 nd NCE: Letter to GMS through SPS (requires GMS approval) USDA-NIFA: 1 st NCE: to SPS with justification prior to expiration SPS submits letter to NIFA 2 nd NCE: to SPS with justification SPS submits letter to NIFA (requires approval) NASA: 1 st NCE initiated on NASA Shared Services website NOAA: 1 st NCE prior to expiration - Initiated in NOAA grants online by PI (use NCE prior approval waived if available) Other Prior Approval Processing: NSF: fastlane - "Notifications and Requests" section. Other agencies: Letter to Grants/Contracts Officer Other Notes: Fly America Act applies to all federal funds How to find in UAFinancials: Cost Reimbursement vs. Fixed Price: On award doc: Grant Description Federal vs. Non-Federal: On Account doc: SubFund Group Code : FEDSUB vs. NONFED (Account range usually: Fed: ; NONFED: )

35 US NSF - Awards - Federal-Wide Research Terms and Conditions 1 of 2 10/21/ :26 AM FEDERAL-WIDE RESEARCH TERMS AND CONDITIONS Federal Register Notice - Final Notice of Standard Terms and Conditions for Research Grants Research Terms and Conditions Agency Implementation Statements - Updated August 19, 2008 Research Terms and Conditions June 2011 (side by side with A-110) July 2008 (side by side with A-110) Research Terms and Conditions Appendix B Subaward Requirements - June 2011 Research Terms and Conditions Appendix C National Policy Requirements - June 2011 Prior Approval Matrix October 2008 July 2008 Agency Specific Research Terms and Conditions DOC - 2/13, 10/08 DOD/AFOSR - 3/12, 7/08 DOD/AMRAA - 10/11, 7/08 DOD/ARO - 6/09, 7/08 DOD/ONR - 2/11, 10/10, 7/08 DOE - 7/08 EPA - 9/13, 1/13, 10/12, 2/11, 11/10, 6/09, 7/08 HHS/NIH - 12/10, 7/08 NASA - 7/08 NSF - 1/13 Significant Changes in 1/13 02/12 Significant Changes in 02/12 10/10 Significant Changes in 10/10 1/10 Significant Changes in 1/10 1/09 Significant Changes in 1/09, 7/08 USDA/CSREES - 7/08 USDA/NIFA - 4/13, 2/13, 5/12, 4/12, 7/11, 10/10, 7/10, 11/09 RELEVANT LINKS Research Business Models Subcommittee Research.gov National Science and Technology Council The National Science Foundation, 4201 Wilson Boulevard, Arlington, Virginia 22230, USA Tel: (703) , FIRS: (800) TDD: (800)

36 Research Terms and Conditions Prior Approval and Other Requirements Matrix* ** October 2008 AFOSR ARO AMRMC EPA NASA NIH NSF ONR USDA DOC DOE General Requirements Change in Scope Prior approval required R Absence or Change of PI R R R R R 21 R R R R R Need for Additional Funding Prior approval required R R Subaward of "significant part" of programmatic effort R R R R R 2 R R 3 R 1 Pre-award costs (90 days) Prior approval waived W Pre-award costs (more than 90 days) Prior approval required W Initial no-cost extension of up to 12 months (per competitive segment) R R W 4 W W W R 5 W W Subsequent no-cost extension or extention of more than 12 months Prior approval required R Carry-forward of unexpended balances to subsequent funding W W W W 6 7 W W W W 22 Cost-related Requirements Rebudgeting among budget categories W W W W W 8 W W W W 22 Rebudgeting between direct and F&A costs W W W W W 8 W W W W 22 Rebudgeting of funds allotted for training allowances (direct payment to trainees) to other categories of expense. W W W W W 9 R W W W W Equipment not in approved budget W W W W W 8 W W W W 22 Capital expenditures for improvement of equipment not in the Prior approval waived 22 Alterations and Renovations costing less than $25,000 W W W W W 11 W W W W W Foreign Travel W 10 W R W W W W W W W Inclusion of costs requiring prior approval in Cost Principles W W W W W 12 W W W W 22 Faculty consulting compensation that exceeds base salary Prior approval waived 22 Restrictions on costs not explicitly unallowable under Cost Principles none none none none none none 16 none 13 R Prior approval required. "Prior approval" means prior written approval from the sponsor. Prior approval can take the form of the sponsor's acceptance of the proposal and/or proposal budget and subsequent incorporation into the award, or written approval of a separate request submitted by the recipient. W Prior approval requirement waived 1 Waived except when subaward would be more than 25% of the total dollars of the award 2 Waived unless change in scope and except when subawardee is foreign 3 Waived except when subaward(s) would be more than 50% of the total dollars of the award; required for any subaward to federal agencies 4 Waived except for extensions that would result in a project period in excess of five years 5 Waived only for first-time requests for extensions of 12 months or less 6 Uncommitted carryforward funds are to be included in the continuation proposal if they are "substantial." 7 Waived except when award indicates prior approval is required 8 Waived unless change in scope 9 Waived except for Kirschstein-NSRA grants 10 Waived, but trip report is required within 30 days after trip completion. See agency specific requirements, Article No. 17, Foreign Travel Reporting Requirements. 11 Waived for alterations and renovations costing up to $300,000, unless change in scope or rebudgeting into A&R exceeds 25% of budget period total 12 Waived, but costs not specifically covered in the Circulars are subject to NIHGPS. 13 Interest penalties for late payment are not allowable 14 Prior approval required for patient care costs if change in scope 15 Prior approval required to modify the amount of cost sharing reflected on Line M of the award budget. 16 Non-working meals and compensation for harm to persons or property are unallowable; also other unallowable costs for awards made under statutory authority cited in Article 3 of the ASR are: graduate assistant tuition remission, F&A in excess of statutory amount, and fixed and real property. 1 Maintained by the NSTC RBM Terms and Conditions Working Group October 2008

37 Research Terms and Conditions Prior Approval and Other Requirements Matrix* ** October 2008 AFOSR ARO AMRMC EPA NASA NIH NSF ONR USDA DOC DOE Cost-related Requirements (cont.) Inclusion of unrecovered F&A costs as cost sharing Permitted P Transfer of funds between construction and non-construction Prior approval required R Use of program income earned during the project period Funds added to the amount available for the project Same Use of program income earned after the project period No obligation to the federal government 23 Property-related requirements Title to supplies with value of more than $5,000 at the end of a R R R W W W W R W W W Acquire j t real property Prior approval required R Encumber real property acquired with federal funds Prior approval required R Use real property acquired with federal funds for other non-federal Prior approval required projects rather than compensating the federal government for its fair R Encumber equipment acquired with federal funds Prior approval required R Trade in equipment purchased with project funds to buy replacement Permitted P Own equipment upon acquisition without conditions or without Permitted obligation to the sponsor at termination of project P Funding agencies' rights in data Not waived Not waived Use of valuation methods other than the lesser of book value or fair Permitted market value for contributed capital assets P Procurement requirements associated with the simplified acquisition Wherever FDP Terms and Conditions incorporate A-110 provisions referring to the "Small Purchase threshold Threshold," the term "Simplified Acquisition Threshold" is substituted. Same Equipment threshold Even if institutions establish a threshold for equipment lower than $5,000, the FDP provisions relating to equipment apply only to those items costing $5,000 or more. Same Project Management Requirements Monthly submission of Cash Transaction Reports when advances exceed $1 million/year Not required 24 Up-front specification of interrelationship among projects Not required 24 Publication acknowledgment and disclaimers Required R Additional requirements for use of human subjects beyond those imposed by federal law none none 17 none none none none none none none none Additional requirements for use of anatomical substances beyond those imposed by federal law none none 17 none none none none none none none none Use of sponsor budget forms for budget revisions Use of electronic records to meet record retention requirements Permitted P 17 Army Surgeon General approval also required 18 Not required, but budget should be in same general format as original 19 Not required for SNAP awards; but others use "Next Period Budget" form page from PHS Must be submitted electronically via the NSF FastLane system at 21 Required for the PI and any other individuals specifically named in the Notice of Award 22 Prior approval required for non-profits 23 For universities - no obligation to the federal government; for non-profits see special terms and conditions 24 Not required for universities * Any of the waivers noted above may be over-ridden by a special term or condition of award. ** Only the full text of the Research Terms & Conditions and the Agency-specific Requirements (ASR) available electronically at: are authoritative. 2 Maintained by the NSTC RBM Terms and Conditions Working Group October 2008