Department of Medicine RSA Monthly Meeting September 17, 2009 8:30 to 10:00 AM, Laurel Heights 376 Present: Ross Beard, Michele Benjamin, Michele Carter, Alice Chin, Hung Dao, Jane Drake, Lidia Espino, Raymond Fong, Lynn Ha, Lowell Huang, Nancy Huynh, Kathy Judd, Calvin Kwok, Susan Lau, Victoria Lee, Linda Lew, Rashaan Lyons, Annie Mar, Christine Mok, Marienna Murch, Solat Navab, Wendy Ng, William Rypcinski, Suzanne, Sutton, Susana Szeto, Yvette Villacana, Tanjira Wilawanchit, Lei Lei Win, Eric Wu, Samantha Yee Announcements Each monthly meeting will now be organized and led by one of the Department s Research Managers (Kathy Judd, Wendy Ng, Suzanne Sutton, and Joseph Wilson). This meeting was organized and led by Wendy Ng and next month s meeting will be led by Joseph Wilson. The names of the host will be listed in the Upcoming Meetings roster (see below). Please let the appropriate host know when you are suggesting a meeting topic. Suzanne Sutton announced that she is due on March 3, 2010 and expects to take at least 12 weeks of maternity leave. In her stead, the other research managers will be overseeing the Department s research administration. Wendy Ng gave a short introduction to the VAMC. The most distinctive features are that 1) faculty can submit grants through the Northern California Institute for Research and Education (NCIRE), which is an external, non-ucsf entity, and 2) faculty can have joint appointments at the VAMC and UCSF not to exceed 150%. This makes grant management for sponsored awards at three different sites (UCSF, VAMC, and NCIRE) complex. Effective September 1, 2009, Joyce Abe and Alina Leong are the new Interim Managers for Proposals in C&G. Joyce is the Institutional Official and will supervise the Proposal Team. Alina is the point person for Cayuse routing. There are also training modules in Cayuse that are available for reference. In Cayuse, go to the Support Tab, then Training Tab, and refer to Modules 9 and 10. C&G is now enforcing the due date for all proposals. The due date is currently 9 am, 4 business days before the sponsor s deadline. For proposals with a due date of February 1, 2010 and after, the due date will be 9 am, 5 business days before the sponsor s deadline. Controller s Office Christine Durieux, Director of Extramural Funds presented on the reorganization of EMF and the new policies/procedures that are a result of the expired funds closeout project. (Please
see attached materials). The service teams have been reorganized into two areas: Billing & Invoicing ad FSR & Closeout. Stan Zimmerman is the new EMF Service Team Manager who will oversee each of the managers for each area. The Billing & Invoicing Teams will be managed by Azeb Sertsu and the FSR & Closeout Teams will be supervised by Sylvia Ching. Departments can still contact the appropriate supervisor to have needs and questions triaged. The service teams will continue to have the same personnel. For example, Team 1 will still be staffed by Ed Day and Kevin Wong. The SWAT Team closed out all funds with end dates before May 1, 2008. The EMF Service teams closed out funds with end dates between May 1, 2008 and October 31, 2008, and will be working on closing out the funds with end dates after October 31, 2008. As a result of the closeout project, EMF has developed a closeout checklist for departments, a closeout reconciliation template for EMF staff, and has implemented a write-off policy for funds that are $200 or less in surplus or deficit. EMF will be writing these off automatically at the time of closeout. In the future, the due dates for milestones (FSRs, invoicing, report) will be entered into RAS at the time of award set-up to automate when FSRs will be drafted by EMF and when invoices will be sent. EMF expects to have this implemented by the end of the year. Lastly, departmental requests to encumber expenses on the FSRs, including liened expenses on the GL, will no longer be honored by EMF. Lana Tomitch, ARRA Analyst presented on the ARRA reporting and verification period that must be completed by RSAs by September 25, 2009. (Please see attached materials). DOM has received 18 or $5.8 million in ARRA awards thus far. Lana emphasized that any RSA with an ARRA award who will be on vacation anytime between September 26 th and October 10 th should indicate an alternate contact in the RAS profile to enable EMF to contact someone for clarification on the reporting, if needed. When reporting on the number of jobs created or retained (people who are actually on payroll), the number should only include those in the U.S. In some cases, there are international subcontracts on an ARRA award. Personnel at the international location should be excluded from the report. There was not enough time to have Debbie Caulfield, Compliance Manager, fully present her materials so she will be invited back to a subsequent meeting. Upcoming Meetings: RSA Meeting on October 15, 2009 at 8:30-10 am in LH 376 (Joseph Wilson) RSA Meeting on November 19, 2009 at 8:30-10 am in Room TBD (Kathy Judd) Holiday event on December 17, 2009 at 8:30-10 am in LH 376 (Suzanne Sutton) RSA Meeting on January 21, 2010 at 8:30-10am in LH 376 (Suzanne Sutton) RSA Meeting on February 18, 2010 at 8:30-10am in LH 376 (Joseph Wilson) RSA Meeting on March 18, 2010 at 8:30-10am in Room TBD (Kathy Judd) RSA Meeting on April15, 2010 at 8:30-10am in LH 376 (Wendy Ng) RSA Meeting on May 20, 2010 at 8:30-10am in LH 376 (Joseph Wilson) RSA Retreat in June 2010. Details TBD (Suzanne Sutton)
Department of Medicine RSA Meeting Controller s Office Christine Durieux, Director, Extramural Funds August 19, 2009 Thursday, September 17, 2009 8:30-10:00 am Laurel Heights, Room 376
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EMF Update Award Closeouts SWAT Expired Funds prior to 5/1/08 Total population: 6,567 funds To date SWAT has closed 6,195 funds, 94.3% EMF Service Team Expired Funds between 5/1/08 and 10/31/08 Total population: 769 funds To date EMF has closed 415 funds, 54% Controller s Office Thank you for all your assistance and efforts to close these two populations of expired funds!
EMF Update Award Closeouts Change in business procedures Closeout checklist - EZ checklist (7 steps) and Complete checklist (12 steps) http://acctg/extramural_funds/communications/sponsored_projects/ Expired_Funds_Checklist.pdf Closeout Reconciliation Template created to help EMF Accountants analyze awards Expired fund communication to departments regarding surplus or overdraft balances Small Balance Write Off/Up Entries New $200 threshold to eliminate surplus or deficit balances less than or equal to $200. Surplus write offs (decreases revenue to expense): Dr: Revenue NCA & EMF Fund Number Cr: NCA 369999 (Misc Income) & 69029 (Federal Fund) or 69030 (Non-Federal Fund) Controller s Office Deficit write ups (increases revenue to expense) Dr: NCA 369999 (Misc Income) & 69029 (Federal Fund) or 69030 (Non-Federal Fund) Cr: Revenue NCA & EMF Fund Number
EMF Update Controller s Office Award Closeouts Change in business procedures What do these small balances entries mean? Let s look at a small balance write-up example and assume: Award is $10,000 Cash is $10,000 Revenue is $10,000 Expenses are $10,005 Deficit Fund Balance $5 In this example, the small balance write-up entry would increase revenue to $10,005 and then the fund balance would be $0 -> Ready to close! Why not just decrease expenses by $5? This would require multiple steps to ensure that the indirect cost was calculated correctly. No risk that we are retaining surplus Federal Funds as our LOC draw down does not draw past the award limit.
EMF Update Controller s Office Award Closeouts Change in business procedures Let s look at a small balance write-off (non-loc) example and assume: Award is $10,000 Cash is $10,000 Credit Fund Balance ($5) Revenue is $10,000 Expenses are $9,995 In this example, the small balance write-off entry would decrease revenue to $9,995 and then the fund balance (Revenue Expense + STIP) would be $0 -> Ready to close! Why not just increase expense by $5? This would require multiple steps to ensure that the indirect cost is calculated correctly. No risk that we are retaining surplus Federal Funds as our LOC draw down does not draw past the lesser of expenses or the award limit.
EMF Update Award Closeouts Change in business procedures All journal entries affecting the following general ledger accounts: Accounts Receivable, Unbilled Accounts Receivable, Deferred Revenue, must be approved by the Accounting Services Manager before being processed in order increase EMF s internal controls. All refunds must be approved by Christine Durieux, EMF Director and calculated using the Closeout Reconciliation Template. Controller s Office EMF will create the final FSR / Invoice 30 days after the end date of the award (even if it is not due until 90 days after end date) and ask for your concurrence at this time. Note: we will need your assistance to ensure all expenses have posted by this time!
Invoices / FSRs EMF cannot submit invoices and FSRs not supported by expenses in the General Ledger Why has this happened in the past: I know the expense will post, it just hasn t yet The subcontractor invoice is expected to arrive Controller s Office According to the Federal False Claims Act: those who knowingly submit, or cause another person or entity to submit, false claims for payment of government funds are liable for three times the government s damages plus civil penalties of $5,500 to $11,000 per false claim ( 31 U.S.C. 3729-3733)
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Invoices / FSRs This practice will be strictly enforced within EMF. Any exceptions to this rule will need signature from EMF Director, Christine Durieux, and/or Assistant Controller, Susan Lin and/or Controller, Cecilia Hamilton. However, few exceptions will be allowed. One exception: Approved payroll transfers will be allowed. Controller s Office
Controller s Office Questions/Comments?
Total number of prime awards 97 Total number of subcontracts in 4 Total number of awards 101 Total number of proposals - over 1000 Success rate - 10% Over $40M in total awards
9 Medicine SFGH awards 8 Medicine awards 1 subcontract in $5.8 Million in total awards
Process PI/RSA s should ensure: September 14 th - September 25 th : The requested data described later in the presentation is entered in the ARRA Reporting Data Collection Page in RAS September 25 th : PI/RSA verified the data is complete and Certified in RAS September 26 th - October 10th: Respond timely to EMF for requests for clarification on prime award data 4
On the DATA COLLECTION PAGE IN RAS, Select the hyperlink on the Award Profile page: ARRA Reporting This hyperlink will only be available on ARRA awards Other awards will display a grayed-out non-active link 5
Review the RSA name and e-mail is correct. If not, go to Grants>Awards>Project>Department Information tab in RAS and correct the information PRIOR to saving you data. Enter and Verify information on Data Collection Page Verify the data in Section 1 is correct. If any data is incorrect, please contact Lana Tomitch: lana.tomitch@ucsf.edu Save your page after you enter the information! You can save at any point before certifying. If you select ARRA supporting documents after entering your data. RAS will save the information for you. 6
Enter required quarterly reporting data: Award/Project Description- A description of overall purpose and outcomes or results of the award and first tier-sub-awards including significant deliverables Example: This grant provided (type) research involving (#) of (participants, studies, etc) studying (specific area) to determine (what). Please use no more than 254 characters in the description, otherwise your data may be truncated. # of Jobs and Descriptions The data entered into RAS must contain your subrecipient jobs data Attach Supporting Documentation- ARRA Jobs Created and Retained Job Aid Job aid (Excel spreadsheet) located on the Controller s Office EMF website under Communications Completion Status The Completion Status should reflect the status for the duration of the award, not only the quarter you are currently reporting There are only four choices: Not Started Less than 50% Completed Completed 50% or more Fully Completed 7
Complete ARRA Jobs Created and Retained Job Aid Report jobs created and retained for prime award AND sub-recipients Attach it to the ARRA reporting page in RAS to provide support in case of an audit Any employee (RSA, PI-including tenured, etc.) that is DIRECTLY charged to the ARRA award should be documented and reported ; if you have not yet direct charged employees, even, if you plan to going forward, report 0 jobs created/retained for now. Job title is a UCSF term. Job description is an ARRA reporting term. For the purposes of reporting they are interchangeable. Under description of jobs, just put in research working job title. Enter the FTE Calculated Number in RAS Data Collection Page for the Appropriate Quarter 8
Select ARRA Supporting Documents Hyperlink Attach Jobs Created and Retained Job Aids Save Attachment Select Return to ARRA Reporting hyperlink 9
Select Certify button Acknowledge Warning Message You have submitted your ARRA award information for your award in RAS at this time! 10
Step 1: If the prime delegated reporting to you, register in the FederalReporting.gov website at www.federalreporting.gov Step 2: Logon to Federal Reporting.gov Step 3: Enter Report Data 11
Step 4: Enter Subrecipient Reporting Data (Continued) Step 5: Submit Subrecipient Data to Federal Reporting.gov 12
If your prime recipient requests for you to provide the ARRA data directly, then the UCSF Job Aid for Subcontracts In should be filled out by the RSA 13
UCSF does not need to report this information. The answer will always be Yes. 14
UCSF awards has delegated reporting to its sub-recipients (sub-awards out). They will need to register and report in www.federalreporting.gov RSAs are responsible for monitoring and ensuring their sub-recipients report timely PI/RSA are responsible for reporting prime and sub-award jobs data quarterly in RAS Recipients of ARRA flow-through funds are responsible for reporting timely to their prime recipient if they have not delegated responsibility for reporting or if they have, then registering and reporting in www.federalreporting.gov Training and education guides are available on the Controller s Website Your resource for answering ARRA reporting questions is Lana Tomitch (lana.tomitch@ucsf.edu) 15
Effort Reporting Controller s Office Mike Maurer, Director, Internal Controls August 19, 2009
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#1 UNCERTIFIED EFFORT AT THIS POINT, WE ARE MISSING OVER 700 EFFORT REPORTS ~8% FOR THE PAST FISCAL YEAR. AN ESTIMATED 40-60 MILLION DOLLARS OF UNCERTIFIED EFFORT. THIS IS PROBLEMATIC. THIS REPRESENTS AUDIT RISK. #2 100% EFFORT BY PI S AND OTHER RESEARCHERS WITH PROBABLE ACADEMIC AND ADMINISTRATIVE DUTIES. A FEW INSTANCES, WE ARE RESEARCHING AND SEEKING UNDERSTANDING/REMEDIATION. 3
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False Claims Act Liability FOR AWARENESS WHEN CERTIFYING EFFORT. Criminal and Civil Liability: Criminal Liability: Up to 5 years imprisonment for individuals, and Up to $250,000 fine Civil Liability: Civil penalty for each false claim is not less than $5,000 and not more than $10,000 Plus 3 times the amount of damages which the Government sustains because of the act of the defendant Standard of liability Broad and specifically includes payments under grants. Controller s Office
Controller s Office Example of an activity --not Compensated by UCSF and NOT Required to Be Reported on Effort Reporting-- Outside consulting
WHAT: Effort Reporting Defined An effort report is a federally mandated after the fact certification of activities for which the employee was compensated by the institution. Cost sharing commitments must also be confirmed. All faculty who serve as investigators on federally sponsored agreements are personally responsible for certifying the amount of effort that they and their employees spent on sponsored activities. Controller s Office
Why Must Effort Be Certified? It s the law: The federal Office of Management and Budget s OMB Circular A-21 "Cost Principles for Educational Institutions" defines what costs are allowable and allocable to federal grants and other agreements. It sets forth criteria for acceptable methods of charging salaries and wages to federally sponsored projects, and requires that institutions follow acceptable methods for documenting the distribution of activity for all project personnel. Controller s Office
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How do we report cost-shared effort? Cost sharing represents that portion of the total project costs of a sponsored agreement that are not borne by the sponsor of the project. Cost sharing can be either committed or uncommitted. Mandatory/Voluntary Committed cost sharing is always included in an Effort Report. Voluntary Uncommitted Cost Sharing should not be included in an Effort Report. Controller s Office
How do we report minimum effort committed by a PI on a grant? UCSF administrative policy 400-10 states that PIs who propose to head an extramurally-funded research, training or public service project must personally participate in the project to a significant degree. The minimum effort must be sufficient to assume oversight of financial, scientific and compliance aspects of a project, and must be in proportion to the size and scope of a project. For UCSF proposals, PIs must commit a minimum effort level. CLARIFICATION: MINIMUM EFFORT IS NOT 1%. IT CAN BE LESS THAN 1%. MINIMUM EFFORT HAS NOT BEEN DEFINED BY POLICY. Controller s Office
Is there a maximum effort we can charge to sponsored research? For in-residence faculty where the majority of salary support comes from non-state funds, and frequently from contracts and grants, a maximum of 95% of salary may be charged to extramurally sponsored projects. Excerpted from 10/31/96 UCSF memo from D. Bainton to Academic Deans. The 95% rule does not apply to faculty in the clinical or adjunct series. In-residence faculty can t be 100% sponsor-funded since these appointments require them to do teaching, research, University and public service. Controller s Office
WHO: is responsible for certifying the effort reports? Both UCOP and federal policies state that Individuals in Professorial, Professional Research, and Management titles should certify their own effort. Staff, postdocs and students do not certify Effort Reports. Their reports must be certified by a responsible official who has first hand knowledge of the effort using a suitable means of verification that the work was performed. Typically, administrators such as administrative directors, managers, analysts, assistants, etc, will not be allowed to certify for other individuals if they do not directly supervise the individual performing the work and would not have sufficient and verifiable knowledge of the work being performed, including an understanding of another individual s regular duties and responsibilities Controller s Office
WHEN: How often do we have to certify effort reports? Academics and professional employees (MSPs and above) must certify Effort Reports bi-annually July-December = Fall January-June = Spring PI s certify staff employees Effort Reports quarterly. July-September = Summer January-March = Winter October-December = Fall April-June = Spring Controller s Office
Effort Reporting Example 1: Professor A Professor A is Regular Full-Time Faculty during academic year with 40 hours of total weekly effort. Usually works a 40-hour week, 8 hours M-F Works 2 hours per day 10 HOURS PER WEEK on grant activities 100% Professional Effort is 40 hours Grant may be charged 10/40, or 25% time If Professor A adds another grant, which consumes another 2 hours per day of her time (10 hours per week), and does not drop or decrease any other responsibilities, then her full professional effort for UCSF will now be 50 hours per week---and each grant may only be charged 10/50, or 20% effort If Professor A added the same second grant, but decreased her teaching or other non-sponsored activities by 10 HRS per week, such that she still only worked 40 hours per week, then she should continue to charge first grant 25% effort, and same for second grant Controller s Office
Effort Reporting Example 2: Professor B Professor B is Regular Full-Time Faculty during academic year, plus 8-hours consulting for an outside non-ucsf entity. Usually works 32 hours per business week, M-F, for UCSF Consults and is paid by an outside entity for about 8 hours per week of effort which is conducted during business hours. Performs 8 more hours per week for UCSF at night and on weekends. Works average of 10 hours per week on grant activities. 100% Professional Effort for UCSF is 40 hours (32 hours during normal business hours, plus 8 other hours at nights and on weekends) Grant may be charged 10/40, or 25% effort Controller s Office
Effort Reporting Example 3: Professor C Professor C is Regular full-time faculty on a 9-month academic year appointment Works average 40-hour week during academic year Has a grant authorized for full calendar year, and intends to work fulltime on grant in two summer months, for additional compensation Works minimal amount (less than 2 hours per week, on average) on grant during Jan.-May, then devotes full effort on grant in June ERS form and payroll distribution for Jan.-May will reflect 100% academic instructional effort, and ERS form for June will reflect 100% effort on grant Effort certification form for six-month period of Jan.-June will reflect 83.33% (5/6) effort for instruction, and 16.66% (1/6) effort on grant. Controller s Office
Effort Reporting Example 4: Professor D Professor D is Part-time faculty on 9-month academic year appointment at 50 % effort level for UCSF Works average 20 hours per week on teaching and grant duties at UCSF Works average of 2 hours per week grant activities Also works 20 hours per week teaching at another institution 100% Professional Effort for UCSF is 20 hours Grant may be charged 2/20, or 10% Controller s Office
Effort Reporting Example 5: Professor E Professor E is Regular full-time faculty on 12-month academic year appointment in Medical Center Works average 50 hours per week on teaching, grant and administrative duties Also serves for pay on outside scientific advisory board, averaging 5 hours a week Works full calendar year on two grants, spending total of 10 hours a week on Grant A and 5 hours a week on Grant B 100% Professional Effort for UCSF is 50 hours Grant A may be charged 10/50, or 20% effort Grant B may be charged 5/50, or 10 % effort Controller s Office