WSU Research Administration Series: Research Administration Update Dan Nordquist, Kim Small, Sponsored Programs Heather Lopez, Internal Audit September 12, 2014 Recording date of this workshop is September 12, 2014 Some of the rules and procedures discussed in this workshop are subject to change. Please check university resources before relying exclusively on this recorded presentation. Why are we here today? This 13 part series is designed for those employees who have sponsored management responsibilities to gain a better understanding of what research administration is made up of - the pre-award and post-award processes, requirements and compliance from A to Z. Template D Plain-crimson-dark 1
Session One Agenda Office of Grant & Research Development Research Development Resources Proposal and Award Processing Services Training and Outreach Sponsored Programs Services (SPS) SPS Role and Responsibilities Updates Audits Purpose Internal and External Auditor Roles Types of Audit Negative Effects Common Findings Issues and Reminders Office of Grant and Research Development Pre-Award Research Development Resources Training and Outreach Proposal and Award Processing Assist Faculty and Graduate Students to Obtain Extra Mural Funding Our Mission Template D Plain-crimson-dark 2
ORG Chart Research Development Resources Identify & Disseminate Funding Opportunities COS Pivot funding database & training Informer Limited submission Proposal Management Unit (PMU) RFP review, timeline assistance, meeting coordination Templates/models development, editing & budget support Serve as a point-of-contact for collaborating partners Help with special needs and proposal submission Research Development Resources Graduate Student Support Provide assistance and resources for extramural funding Graduate student funding announcements Graduate proposal writing workshops Training at graduate student orientations Single Investigator Support Assist in finding extramural funding RFP review, provide access to models/templates, editing support Template D Plain-crimson-dark 3
Training and Outreach Grantsmanship Training Writing Winning Grants Seminar Mentored Proposal Writing Program Productive Proposal Writing Class Grant Writing Resources Library of resources Outreach & Collaboration Building Activities Coordinate meetings, workshops, seminars and state-wide outreach activities Coordinate WSU internal grant competitions Promote prestigious faculty awards & provide applicant support Proposal and Award Processing Review & Authorize Proposals Provide guidance on RFP compliance/help with forms Review of final proposal Submission of proposal to sponsor Tracking & monitoring of proposal Negotiate Contracts & Accept Awards Budget preparation F&A issues Review contractual language Prepare & Execute Standard Agreements & Contracts Draft various subawards & contract Material transfer, non-disclosure, no-money, data set & equipment loan agreements 11 Proposal and Award Processing Certify and assure university adherence to governmental policies U.S. Code of Federal Regulations and other federal regulations OMB Circulars Revised Code of Washington (Title 28B) WSU Business Policies & Procedures Manual WSU s Faculty Manual Monitor and report sponsored project activity Work with SPS and sponsor on award changes Help with additional materials Advise faculty, staff & graduate students on these functions & activities 12 Template D Plain-crimson-dark 4
Cool Stuff Updates Received funding for the Health Sciences building in Spokane Largest USDA award ever made for biofuels research-$40 million $900 million/2370 proposals,$237 million/1850 awards (FY13) Reporting is HUGE Work with Institutional Research to give them all our numbers to determine WSU's national ranking Data shack or canned reports are now available through MyResearch (Training provided: contact Derek Brown for dates) 13 Updates Hot Issues -- IP assignment forms for PI s (Roche v. Stanford) & FCOI Changes in Guidelines: New F&A rate agreement (51% until 2015) Reminder - Sign up for the WSU Research Admin list serve. Contact Derek Brown to signed up. Important Websites/Resources www.ogrd.wsu.edu RAC list, quick guide, policies, guidelines, templates, etc. https://myresearch.wsu.edu Database www.grants.gov; https://www.fastlane.nsf.gov/fastlane.jsp Federal generic proposal submission sites informer.ogrd.wsu.edu funding opportunities www.youtube.com/user/wsu Grant & funding tips for the greater WSU community http://www.facebook.com/pages/office-grant-research- Development--WSU/185924391445269?ref=hl Find us on Facebook 15 Template D Plain-crimson-dark 5
Sponsored Programs Services (SPS) Post-Award SPS s Role As WSU Post Award Office Provide fiscal administration. Educate and train. Establish accounts and input budget allocations. Maintain data systems and project files. Prepare, submit & record financial reports & associated payments. Subcontract payments. Periodically notifying departments of overdrafts. Draw funds from federal government, prepare receipts for checks and electronic funds transfers. 17 SPS Updates F&A Rates E-Verify (FAR clause 48 CFR 22, Subpart 22.18) Excess Compensation Stipends / Fellowship Payments Subrecipient Monitoring Cost Transfers Effort Reporting / Cost Share 18 Template D Plain-crimson-dark 6
F&A Rates (On-Campus) 51% rate is the current rate for on-campus awards 50% rate is applicable only after 7/1/11 51% rate is applicable only after 7/1/12 The rate changes are based upon the state fiscal year. 19 E-VERIFY E-Verify is an internet-based system, operated by the US Department of Homeland Security in partnership with Social Security Administration. The program compares the I-9 information reported to US government records to determine employment eligibility. We have 3 business days to enter the names of the employee(s) into the online E-Verify system. It is the department s responsibility to give HRS the names of the employees once they know they are going to receive the award. 20 Excess Compensation/Faculty Timecards SPS approval is required for faculty time cards that are charged against a sponsored project. Since this is the mechanism for paying faculty for duties above and beyond or outside their normal duties, this is usually an unallowable expense on a grant. Excess compensation for the PI is obvious. Not so obvious is paying other, non-grant faculty for their time and assistance. Template D Plain-crimson-dark 7
Excess Compensation/Faculty Timecards Say you want to pay a WSU faculty member a travel allowance for attending your conference, or an honoraria for participation, or even payroll for guiding/mentoring a summer project If that faculty member is already at 1.0 FTE for that time period this translates to Excess Compensation. Excess Comp has the same regulations and requirements at this point in the project as at initiation. See guideline #21 See A-21 section J(8)(d)(1) To approve this request SPS will require: Agency approval & Provost office approval specifically stating it is allowable to pay excess compensation for this person. Stipends Stipends and Fellowships should be paid as object 08 rather than as wages and benefits. When we pay the student as wages we are shorting the students the amount of money they were awarded. It is the student's responsibility to report the income and pay the taxes on it if owed. The idea of paying wages and benefits suggests that the student is required to do something in order to receive the funds. 23 Subrecipient Monitoring This is an ongoing requirement that bridges from subcontract initiation to closeout. It is shared and documented in the department, in and in SPS. There is a class in this series that will go through WSU s subcontracting process and help you define who is responsible for doing which parts and how it all ties together. 24 Template D Plain-crimson-dark 8
Cost Transfers It is the expectation / understanding that the expense was initially applied correctly. Now the story is we have changed our mind. Be sure your transfers are timely with complete information. 90 day justification 25 Effort Reporting The proportion of time spent on any activity; expressed as a percentage of WSU compensated time. Salaries/Wages must reflect actual effort expended and not the proposed/budgeted effort. Effort Reports account for the total activity an employee is compensated for and required to fulfill their obligations to WSU. 26 Effort Reporting WSU's Effort Certifications use an after the fact determination so that the cost distributions represent actual costs based upon actual effort. Effort Certifications are distributed 4 times a year. Based upon semester (2 summer) They are run the month following the end of the semester so they include all the information for that semester. It is the expectation that all Effort Certs will be returned within 90 days. 27 Template D Plain-crimson-dark 9
SPS Website http://sps.wsu.edu/ Contact information Who does what Expenditure Information in various formats 28 Audits Purpose of Audits Required By accepting federal money, grantee agrees to comply with rules Grantor has an expectation for Accountability Proper stewardship Terms carried out results, product, service, etc 30 Template D Plain-crimson-dark 10
Role of Auditors Internal or External Auditors test to ensure, and, opine on whether management has adequate controls and processes in place to: Comply with applicable rules Adequately safeguard resources Properly present and report activity 31 Role of WSU Internal Audit Act as liaison between WSU and external auditor With SPS and unit, ensure information requested is provided complete and accurate to support conclusions Work with auditor on reporting Internal advisory for management on controls, policy, training Audits and investigations Types of Audits Compliance Circular A-133, Single Audit Program reviews Financial Statement Operational Reviews assessments Investigations 33 Template D Plain-crimson-dark 11
Effects of a Negative Audit Report Loss of future awards Bad publicity Potential undermining of public trust and confidence in agency and government Personal losses 34 Common Issues The following are some examples of common issues that may result in questioned costs and subsequent cost disallowances: Lack of time records to support labor costs charged to awards. Lack of consulting agreements and invoices to demonstrate allocability to the award and that the charges are reasonable. Indirect cost recovery charges in excess of the amount allowed by the type of indirect cost. More Common Issues Costs that are unallowable in accordance with applicable cost principles and, therefore, cannot be charged to Federal awards. Proposed participant support costs that were rebudgeted to other cost categories without the required written approval of granting agency. Inadequate supporting documentation for expenditures claimed as cost sharing. Template D Plain-crimson-dark 12
Uniform Guidance Final Guidance document published in the Federal Register Dec 26, 2013. Codified in 2 CFR 200 Replaces 8 previous OMB Circulars: Circular A-110 Circular A-21 Circular A-102 Circular A-87 Circular A-89 Circular A-102 Circular A-133 Circular A-50 Uniform Guidance, 2014 Applicable to Direct Federal Grants, Cooperative Agreements and Cost-reimbursable contracts. Each federal awarding agency must implement Effective for new $ received on or after Dec. 26, 2014 Audit effective for the entities first full fiscal year after 12/26/14. Example: Entities fiscal year ends June 30 th New audit requirements apply to fiscal year that ends June 30, 2016 Uniform Guidance, Continued There are still some open issues: conflict of interest, procurement, etc. As changes to the Circulars become final, communications and training will be provided to the research community. Potential impacts: Audit Direct charge of admin/clerical salaries, equipment, time and effort, procurement Subrecipient monitoring Template D Plain-crimson-dark 13
Audit reminders When approached by external auditor: Always verify auditor s credentials before giving information Notify supervisor and SPS Notify Internal Audit Be prepared Be organized Do it right the first time 40 Resources WSU Sponsored Programs Service WSU Office of Grant & Research Development Internal Audit 5-5336, hlopez@wsu.edu OMB Circulars - http://www.whitehouse.gov/omb/circulars/ SAO http://www.sao.wa.gov 41 This has been a WSU Training Videoconference If you wish to have your attendance documented in your training history, please notify Human Resource Services within three days of today's date: hrstraining@wsu.edu Template D Plain-crimson-dark 14