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MRAM Monthly Research Administration Meeting
NOVEMBER 12, 2015UW TOWER AUDITORIUM
NEXT MRAM DECEMBER 10, 2015UW TOWER AUDITORIUM
TOPIC PRESENTER CONTACT MIN
Effort Reporting Update Michael Anthony Executive Director, Management Accounting & Analysis
206 616-1379mda1213@uw.edu 10
Project Certification Michael Anthony Executive Director, Management Accounting & Analysis
206 616-1379mda1213@uw.edu 15
IRB Fee for Industry-Funded & Industry-Initiated Sponsored Studies
Jason MaloneAssistant Director, Regulatory AffairsHuman Subjects Division
206 543-2254jmmalone@uw.edu 15
Compliance Corner Ted MordhorstDirector, Research Compliance & Operations
206 616-8678tedm2@uw.edu 10
CORE Course Update Mara RivetLearning, Outreach & Communications OSP
206 543-1870tfr@uw.edu 2
Effort Reporting UpdateFECs and GCCRs
MRAM - November 12, 2015Michael Anthony
Management Accounting & AnalysisUniversity of Washington
Confirm changes, e.g., OSETS, Cost Share Commitment Adjustments, have processed and appear on the FEC before having faculty certify.
Insufficient Funds – Make sure the predefined comment (“Non-federal grant(s) approved to be used for cost share…”) is checked AND the ‘contributing budget(s) and percent contribution(s) are reflected in the “Additional Comments” section.
Net ID – Certify others – Make sure the individual is eligible for this role (Chair, Dean, Director).
FEC Certifications
University of Washington Management Accounting & Analysis
Salary Cap (monthly rate) Issue for faculty not paid for full FEC cycle, e.g., 2
summer months during spring/summer cycle
FEC can have the appearance there is no salary cap issue when 2 months summer salary is spread over 3 months (summer quarter) which is combined with the Spring quarter
Not OK to be over the cap and charge nothing but grants
Salary Cap Issues
University of Washington Management Accounting & Analysis
Pre-pay / Pre-work Salary charged must reasonably reflect work of
each pay period.
Cannot misrepresent actual effort for the period.
Example - Overcharging grant (undercharging department funds) during AY so department can pay summer salary from savings.
Other Issues
University of Washington Management Accounting & Analysis
Issue with fiscal close
When OSETs or other salary transactions occurred during month 25 it resulted in the GCCR report generator resetting for some departments/PUCs
Appeared as though GCCR reports were not downloaded after month 24
If you haven’t, please do and we will stop contacting you
GCCR Issue
University of Washington Management Accounting & Analysis
Project CertificationMRAM - November 12, 2015
Michael AnthonyManagement Accounting & Analysis
University of Washington
A demonstration with 4 universities and 2 federal agencies to
demonstrate a new alternative method for reporting time and effort information on federally
sponsored research grants
FDP InitiativeProject Certification
University of Washington Management Accounting & Analysis
An alternative to Effort Certification
Generally positive response from university communities although some expressed they will not change current procedures
Other institutions encouraged to evaluate to determine if it is a viable option for them
FDP InitiativeProject Certification
University of Washington Management Accounting & Analysis
Alternative to Effort Certification Similar to the current GCCR process
All individuals with direct salary charges and/or cost share commitments to a sponsored project(s) would need to be included
One certification per project would cover all individuals
Frequency TBD (beta sites doing this on a monthly basis)
Project Certification
University of Washington Management Accounting & Analysis
Generally positive response from the Federal government Several audits of the beta site universities did
raise some concerns primarily centered around internal controls
Project Certification
University of Washington Management Accounting & Analysis
NSF – OIG concluded Need to strengthen internal controls to ensure labor
charges to NSF awards are adequately supported
Found problems with 21 of 180 transactions sampled – Not certified in a timely manner, posting errors, missing recertifications due to OSETs
Need to strengthen its IT controls to protect payroll information
Audit ResultsGeorge Mason University
University of Washington Management Accounting & Analysis
NSF – OIG concluded System "generally provided accountability over federal funds" Did not always comply with policies for payroll transactions under
the effort reporting process as well as payroll certification pilot." Issue with the security of Banner (payroll IT program) Of 112 transactions processed under the pilot, OIG found two had
problems "related to changing salary and wage distributions." None were identified as late, and no other problems were noted.
Audit ResultsMichigan Technological University
University of Washington Management Accounting & Analysis
We like the concept (individual championing the FDP initiative former UW Controller)
Similar to GCCR process but lacking many features of eFECS (auto salary cap calculation, cost share commitments, etc.)
Presently do not have IT resources available to devote to a conversion (HR/P, new Financial System)
What is our Perspective?
University of Washington Management Accounting & Analysis
Plan to assess the pros/cons of incorporating the current faculty effort reporting (FEC) and non-faculty (GCCR) processes with project based payroll certification
Work with campus units to understand their preferences, concerns, suggestions
Keep tabs on what is happening at beta sites as well as any other institutions adopting project certification
What are our Next Steps?
University of Washington Management Accounting & Analysis
Any volunteers here today!!
What are our Next Steps?
University of Washington Management Accounting & Analysis
HSD Administrative FeeMRAM - November 12, 2015
Jason MaloneHuman Subjects DivisionUniversity of Washington
A one-time $1500.00 fee to help cover HSD’s costs for fulfilling mandatory regulatory and administrative responsibilities.
It applies to research with an indirect cost rate that does not cover those costs.
What is it?
University of Washington Human Subjects Division
The fee applies only to studies that are both:Industry initiated AND;Industry sponsored
Applicability
University of Washington Human Subjects Division
For studies that go through Clinical Research Budget and Billing (CRBB), the fee is automatically included in the study budget.
For studies that are not using UW clinical services and don’t go through CRBB, the Office of Sponsored Programs (OSP) notes the fee in the Funding Action.
How It Works
University of Washington Human Subjects Division
Indirect costs are charged in connection with the fee.
HSD does not send an invoice for the fee.
The fee is automatically paid to HSD by Grant and Contract Accounting (GCA) when the UW receives initial payment from the sponsor.
How it works
University of Washington Human Subjects Division
Guidance has been posted to the HSD website:
http://www.washington.edu/research/hsd/docs/1904
Contact the HSD IRB Reliance Administrator at:
hsdrely@uw.edu
Resources/Questions
University of Washington Human Subjects Division
Fiscal Compliance CornerRecent Happenings, etc.
MRAM Nov 2015
Ted MordhorstDirector Compliance and OperationsResearch Accounting & Analysis
Audit News
NSF Audit
Covers ALL NSF Awards 4/1/10 – 3/31/13
PreliminaryFindings:
NSF Data Analytics Audit Salaries charged in excess of the 2 month rule
Equipment purchased near the award expiration 18 items
Materials and supplies purchased near the award expiration 5 items
Unallocable tavel transactions
NSF Data Analytics Audit Purchase card transactions without vendor
receipt
Unreasonable or unallowable expenses
Purchases more than 90 days prior to the award effective date
meal expenses not necessary or reasonable
Travel that occurred after award expiration
NSF Data Analytics Audit Auditor Recommendations:
Strengthen the administrative and management controls and processes
Implement university-wide procedures to ensure that all departments are monitoring the allocation of costs charged to NSF awards
NSF Data Analytics Audit Auditor Recommendations:
Strengthen internal controls and processes over allocating expenses for equipment and supplies to sponsored funding sources.
Require documentation of the methodology used to allocate expenses to sponsored projects, as well as a justification for how the methodology was determined.
Final thought Audits are increasingly looking at factors related
to internal controls
Expense documentation must be maintained and demonstrate reasonableness, necessary and allocability
Expenses during the last 90 days of the award are most often questioned
Final thought Both in the UG and in the audit there is an
increased emphasis on “necessary”, “essential” and “integral” to define when a cost is reasonable.
It behooves us to think in these terms when processing transactions
Other Compliance HappeningsResearch Terms and Conditions
(RTC)
Developed by the Federal Demonstration Partnership (FDP)
11 federal agencies participating
Open for comments through 12/14/15
Research Terms & ConditionsSomewhat confusing
We will submit comments
Will have agency specific deviations
Incorporated into awards sometime in the spring?
Will share more as this progresses
QUESTIONS?
CORE is a collaborative effort to provide free, high quality, cohesive training on research administration and compliance to UW researchers and research administrators.
UPCOMING COURSES IN RESEARCH ADMINISTRATION
Nov 16 ORIS 103 – SAGE Budget
Nov 17 GCA 203 – Preparing for an Audit
Nov 17 ORIS 102 – SAGE: Creating NIH Proposals in Grant Runner
Nov 18 MAA 231 – Salary Limitations - Salary Cap
Nov 24 ORIS 101 – SAGE: Creating and Submitting eGC1's
Dec 02 GCA 202 – Direct Billing of F&A Type Costs
Dec 03 ORIS 103 – SAGE Budget
To see a full list of courses and to register, visit https://uwresearch.gosignmeup.com/public/course/browse
Dec 09 MAA 225 – Using the Tools: Calculators, Worksheets and Reports
Dec 10 ORIS 102 – SAGE: Creating NIH Proposals in Grant Runner
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