Audits and Reviews: Who is Looking and How Can We be Prepared?

Similar documents
3 rd Annual Symposium for Research Administrators

An Exercise in Effort

Effort Reporting: A Conversation. Christine K Lawless Central Effort Administrator Office of Sponsored Research

Expense Review Process and Internal Controls for Award Closeout. Semi-annual Networking Event February 2017

OMB Uniform Guidance ( UG ) Briefing. ASRSP & OSR Brown Bag Tuesday, January 27 th

DFA Conversations Research Administration Forum

Sponsored Programs Roles & Responsibilities

Sponsored Programs Roles & Responsibilities

FAQ S FOR UNIFORM GUIDANCE

Federal Rules for Sponsored Programs. Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 CFR 200

U.S. Patents Awarded in 2005 Top 20 Universities

Research Administrators Round Table

Principal Investigator

Grant and Contract Accounting

Navigating the New Uniform Grant Guidance. Jack Reagan, Audit Partner Grant Thornton LLP. Grant Thornton. All rights reserved.

Office of Sponsored Programs RESEARCH ADMINISTRATORS FORUM. December 2017

Financial Research Compliance. April 2013

Effort Certification

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. AU SPAN Martha Taylor Larry Hankins

Jason Galloway, Associate Controller HSC Contract and Grant Accounting

US News and World Report Rankings Graduate Economics Programs Ranked in 2001

Template D Plain-crimson-dark 1

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

Post Award Functions. Department/ Principal Investigator. Sponsored Research

MSU s Financial Administrator Development Program Post-Award Contract and Grant Administration

NCURA Region II. Hot Topics in Research Administration 1. Denise Clark Associate Vice-President for Research, University of Maryland College Park

UNIFORM GUIDANCE IMPLEMENTATION

Here Come the Feds! What a Sponsor Audit is Looking for and How to Prepare Your Institution

University of Pittsburgh SPONSORED PROJECT FINANCIAL GUIDELINE Subject: SUBRECIPIENT MONITORING

OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

Principal Investigator Roles and Responsibilities for Sponsored Programs

Wake Forest University Financial Services: Grants Accounting and Compliance

Summary of Audits, Settlements and Investigations Related to Sponsored Programs For Educational Purposes Only

Dept/ College. Dept/ College. Dept/ College

Recent OIG Audit Findings in Brief! Kris Rhodes, Director, MAXIMUS Doyle Smith, Director, MAXIMUS

TEXAS TECH UNIVERSITY HEALTH SCIENCES CENTER EL PASO

APPENDIX VII OTHER AUDIT ADVISORIES

Diane Dean, Director Kathy Hancock, Assistant Grants Compliance Officer Joel Snyderman, Assistant Grants Compliance Officer

Section IV. Findings

Grants - Uniform Guidance/Tracking & Reporting. Presented by: Marc Grace, CPA, Partner Stephen Emery, CPA, Manager

Safeguarding Federal Funds

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (New Uniform Guidance)

The OMB Super Circular: What the New Rules Mean for Nonprofit Recipients of Federal Awards

Table 2 Overall Heterodox-Adjusted Rankings for Ph.D.-Granting Institutions in Economics

Felipe Lopez, Vavrinek, Trine, Day & Co., LLP

Step 2 From the Modifications Summary in the Award Workspace click the link to the newly created Modification.

2017 SRA International Annual Meeting October 14-18, Federal Demonstration Partnership (FDP)/Council on Governmental Relations (COGR) Update

OSR s Annual Symposium for Research Administrators: Conflict of Interest The Kitchen Sink Version

Uniform Guidance Sponsored Projects Services

Seminar on Financial Management. VOCA s National Conference

Federal Regulatory Cost Burden: A Multi-institutional Study Overview and Findings Completed by and with the Boston Consulting Group

FDP Expanded Clearinghouse

Implementing the OMB s Super Circular (aka UGG) Presented by: Anne Fritz, Finance Director, City of St. Petersburg, Florida

CARY, NORTH CAROLINA. A1 UC Berkeley 3 0 Gold A2 University of Oregon 1 2 Bronze A3 Vanderbilt University 2 1 Silver A4 Lamar University 0 3 Copper

Grants Management Scenarios

University of Pittsburgh

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. AUSPAN Martha Taylor

Sponsored Program Administration Meeting. September 2016

ARL ACADEMIC HEALTH SCIENCES LIBRARY STATISTICS

University of North Carolina Finance Improvement & Transformation Contracts and Grants Standards. January 2015 Version 8

Any observations not included in this report were discussed with your staff at the informal exit conference and may be subject to follow-up.

The OmniCircular - 2 CFR 200

2014 Salary and Benefits Report

Understanding the Adult Education State Director s Fiscal Responsibilities

How to Manage Externally Funded Grants PROJECTS - FUND CODE 501 or 502

Please fill out the survey forms 2/9/2012. Upcoming ORA Training Opportunities. Agenda

Northwestern University Key Effort Reporting Policies Introduction

NSF OIG Audit Update NORTHEAST CONFERENCE ON COLLEGE COST ACCOUNTING

SPONSORED PROGRAMS POST AWARD CALIFORNIA POLYTECHNIC STATE UNIVERSITY, SAN LUIS OBISPO. Audit Report February 4, 2014

Single Audit Entrance Conference Uniform Guidance Refresher

Any observations not included in this report were discussed with your staff at the informal exit conference and may be subject to follow-up.

Registration Priority for Athletes -- Survey of Universities Updated February 2007 Alice Poehls, UNC Chapel Hill

Something for Everyone: Adjusting to the OMB s Super Circular May 25, :30 10:10 am 2 CPE

4.12 Effort Certification

College of Liberal Arts and Sciences Aspirational and Operational Peers

Performance and Financial Monitoring and Reporting

CAMP KESEM SWIPER1 INSTRUCTIONS PAGE TABLE OF CONTENTS

The Uniform Guidance (2 CFR, Part 200)

Building a Budget. Rebecca Hunsaker Gaye Bugenhagen University of Maryland, College Park

Post Award Administration. Presented by ORA, Finance, Biology & International Offices

Division of Grants Compliance and Oversight Office of Policy for Extramural Research Administration, OER National Institutes of Health, DHHS

Time and Effort Certification

Effort Certification Training

The Uniform Guidance 2 CFR 200 A Guide to Risk-Based Grants Management

Federal Grants Compliance 101

THE COLLEGE OF WILLIAM & MARY

How Did We Get into this Mess? A Micro View of Effort Reporting and Other Research Compliance Problems

TIME & EFFORT. project, then how much effort did Dr. Jones apply toward the NIH project?

Presenter. Changes to Federal Programs & Single Audits (A-87, A-21, A-122, A-102, A-110, A-89, A-133 & A-50) The New OMB Uniform Guidance

Overview What is effort? What is effort reporting? Why is Effort Reporting necessary?... 2

UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS - UPDATE FEBRUARY 2015

Steve Relyea Executive Vice Chancellor and Chief Financial Officer. Audit Report 18-67, Sponsored Programs Post Award, Office of the Chancellor

Rebecca Trahan. Office of Sponsored Programs December 9, ORED Limited Submission Update

ACNM - Clinical Opportunities

COST PRINCIPLES AND PROCEDURAL STATEMENTS FAQs

POLICY STATEMENT EFFECTIVE DATE

Office of Internal Audit

Harvard University Schedule of Findings and Questioned Costs Year Ended June 30, 2015

Duke/UNC Chapel Hill CTSA Consortium Collaborative Translational Research Pilot Grants Request for Applications

ROLES AND RESPONSIBILITIES* FOR EXTERNAL AWARDS MADE TO DAVIDSON COLLEGE

Transcription:

Audits and Reviews: Who is Looking and How Can We be Prepared? 2015 Office of Sponsored Research Symposium Sharon Brooks Director, OSR Robin Cyr, AVC for Research, OSR

Session Agenda What Should You Do and Not Do When Contacted by an External Auditor/Reviewer? Who Audits Us and Why? What Do Auditors Often Ask For? What Do Auditors Often Find? Who is Responsible for What? Before During After the Engagement Hot Topics Recent Audits & Findings Who is Looking? Find Out Here Questions?

What To Do When Contacted By an External Auditor/Reviewer? Introduce the auditor/reviewer to the Office of Sponsored Research (OSR) - provide ORS contact names and/or email contact information - OSR Contacts: Vanessa Peoples, Sharon Brooks, Jenifer Gwaltney Forward any written communication from the auditor to OSR Communicate that it is the institution s position to include the OSR as the lead liaison during their engagement - share that OSR will be contacting them soon for additional information Advise the respective Departmental/School/Center or Institute and the Principal Investigator(s) of the contact

What Not to Do When Contacted by an External Auditor/Reviewer? Provide financial or technical details immediately upon contact Respond to/agree to a start date of engagement

Who Audits Us and Why? Who? The State Our Cognizant Agency Dept. of Health and Human Services Defense Contact Auditing Agency Specific Sponsors Department of Justice Internal Audit Why? Federal requirement - $750,000 or more expended in a year Representing federal sponsors Hired by the cognizant or specific agencies Assurance that funds were properly expensed Allegations of fraud or misrepresentations have occurred (Whistle Blower/Qui Tam)

What Do Auditors Often Ask For? Policies and Procedures Organizational Charts/Contact Names Details on any prior audits Access to responsible faculty and staff Access to research space Award/Project documents budgets/narratives Complete and detailed financial transactions Supporting documentation/justification ANSWERS.

What Do Auditors Often Find? Inadequate policies and procedures Failure to act in accordance with policies/procedures Inconsistent practices Lack of or inadequate documentation Lack of understanding with institutional practices

Who Is Responsible for What Before the Engagement Starts OSR Obtaining the scope of the audit (if shared) Providing adequate workspace Providing documentation prior to on site visit PI/Department/School Providing documentation as requested by OSR Locating supporting documentation Responding to OSR requests in preparation See UNC-CH Policy 800.1 http://research.unc.edu/offices /sponsored-research/policies- procedures/section-800/policy- 1/

Who Is Responsible for What During the Engagement OSR Acting as the liaison between the auditor and department Providing documentation that is retained at an institutional level Helping to schedule interviews and visits with key stakeholders Keeping abreast of any concerns PI/Department/School Providing documentation as requested by OSR Ensuring access to personnel and facilities PI/key stakeholders involvement (Q&A)

Who Is Responsible for What After the Engagement Ends OSR Attending the exit conference Preparing the institutional response Assuring that all findings/corrective actions are taken by the respective PIs/unit(s) Updating institutional policy/procedure PI/Department/School Acting in accordance with institutional response Taking action in correction of all noted findings (financial transactions are completed) Correcting any operational, financial or other deficiencies

HOT Topics Internal Controls Payroll Distribution/Compensation Practices and Effort Certifications Costing Practices Direct and Indirect Decisions Travel and Food Costs (food charged when not in travel status) Cost Transfers Cost Allocations charges commensurate with benefits gained by the project(s) sponsored and non-sponsored Subrecipient Monitoring Recharge/Service Center Rates Cost Sharing Financial Reporting and Closeout Always in play: Non-Financial Compliances Conflict of Interest Human and Animal Subjects

Recent and Landmark Audits and Findings Univ. of Minnesota - $32 million Numerous cost transfers charging sponsored awards could not be supported; program income and human subjects non-compliance Columbia - $9 million Mischarging effort Qui Tam Florida State - $6 million (resolved $3 million) Improper cost allocation practices for lab research expenses pipette tips; graduate compensation exceeded the NIH threshold

Recent and Landmark Audits and Findings Virginia Tech - $1.6 million NSF PI salary over the 2 months limit Univ. of California San Diego -?? Administrative/Clerical costs; uncertified effort reports New York Univ. - $78 thousand Unallowable indirect costs, charges for travel and equipment late in the project period of performance

Recent and Landmark Audits and Findings Northwestern Univ. - $3 million PI charging federal funds for personal family travel and subaward to family Qui Tam Duke Univ. - $1.6 million Administrative/Clerical costs and inconsistent costing practices Yale Univ. - $11.7 million $10 million in unsupported cost sharing; inadequate subrecipient monitoring

Who is Looking: Find Out Here! National Conference on College Cost Accounting (NACCA) Summary of Audits and Findings http://www.costaccounting.org/audits Department of Health and Human Services http://oig.hhs.gov/reports-and-publications/oas/nih.asp; http://oig.hhs.gov/oas/reports/region4/41301024.asp (UNC- Chapel Hill) National Science Foundation http://www.nsf.gov/oig/reports/