New UVM Policies and Procedures Affecting Grants: Advance Accounts, Cost Transfer, and Residual...

New UVM Policies and Procedures Affecting Grants: Advance Accounts, Cost Transfer, and Residual Balance

Sponsored Projects Training ProgramDecember 8th, 2011

Beverly Blakeney, Ruth Farrell, Michael Meunier

Sponsored Projects Training Program

Welcome

An introduction to the presenters and the topics.

Time line and next steps for implementation of these policies and procedures.

Learning Objectives

Increase awareness of upcoming changes in cost transfer policy and two new, separate procedures that will soon be in place.

Help participants understand new operational practices that they will have to plan for.

Reminder – the Cost Principles

AllocableAllowableReasonableConsistently charged

Advance Account Procedure a.k.a Guaranteed Funding

Advance Account – What?Creation of a sponsored project

chart string before an award document is received or accepted from the sponsor

Advance Account – Why?Need to start the workAllows PIs and Departments to

record and track expenditures in appropriate chart string

Reduces salary and non-salary cost transfers

Eliminates re-work for principal investigators, department administrators, and staff in central offices Sponsored Projects Training

Program

Evaluating RiskWritten confirmation from

sponsorSponsor’s history with UVMNegotiation risks

What needs to be in place? –How?Department or unit must assume

riskWritten confirmation from

sponsorProposal must be fully routed and

approvedRegulatory requirements must be

satisfied◦IACUC, IRB, IBC, COI

Competed request formModified budget (optional)

LimitationsRequest 90-180 daysCan limit dollar amountAny limitations of the sponsor

ResponsibilitiesPI – initiating request, collecting

required documents, spending within the constraints of AA

Unit – submit request, assumes fiscal risks, monitors, ensures expenses and encumbrances conform to advance account duration

VP or Dean of unit – assumes financial risk

SPA – advise on potential risk, confirm all regulatory approvals are obtained, approve AA and establish chart string, provide training

What happens next?Award received and acceptedSPA completes the set up processBilling can occurOr – no award is received charges

need to be moved

ResourcesMonthly reportPS Query

◦UV_GM_FINDINGAWDTHRUREFAWD◦ It can be run on an ad hoc basis, by

department number, award number, reference award number or wide open using wildcards. The search fields are not case sensitive.

◦Can be used to locate an award if you only know the sponsor's award number

◦Can be run at any time to identify all advance accounts by department or for the whole university

Questions?.

Cost Transfers Involving Sponsored Agreements Policy

- Revision Update -

Michael MeunierCost Accounting Services

(CAS)1:30-2:30Memorial LoungeDecember 8, 2011

Cost Transfer Policy Topics

Policy Review Process

Cost Transfers at UVM

Key Policy Changes

Cost Transfer Form

Policy current status: Campus wide policy comments on this policy

are currently being considered.

Cost Transfer Definition

A cost transfer is the assignment of an expense to a sponsored agreement that was initially recorded elsewhere in the University’s general ledger.

◦ Removal of an expense from a sponsored agreement to a non-sponsored chart string will continue to require an explanation and appropriate approvals.

Cost Transfer Policy – Review Process

Profiled university cost transfer activity

Reviewed Grant Lifecycle Committee Report (August 2009)

Benchmarked other University policies/procedures

Analyzed key sponsor specific regulations ◦ HHS, NIH, NSF, Federal Formula grants

Reviewed external audit reports and recommendations

Solicited feedback from Academic Business Managers

Cost Transfers at UVM

UVM has significantly more cost transfers, particularly late cost transfers, than similar Universities

• Allowability concerns (red flag to auditors)

• Inefficient use of University resources

• Fiscal management of sponsored agreements

Cost Transfer Policy – Key Changes

Accountability statement

Minimizing cost transfers

Timeliness

Approvals

Unallowable Expense Transfer Authority

Key Policy Changes - Accountability

All University personnel are expected to be aware of and comply with this University policy and the principles and requirements listed below.

Confirmed violations will result in disciplinary action. In some instances, civil claims and criminal charges may also result.

Key Policy Changes – Minimizing Cost Transfers

• Charge only allowable expenses to sponsored agreements

• Utilize advance accounts

• Minimize posting expenses to department suspense

• Quarterly meetings with PIs (Effort, Non-salary expenses)

• Submit timely and relevant salary distribution changes

• Reallocate PurCard expenses within University deadlines

Key Policy Changes – Timeliness

1) Identifying errors in a timely manner • Monthly verification of financial transactions (PMBR)• Department Suspense Review

2) Timely Cost transfer Submissions • < 90 days after original accounting date (GL)• Salary transfers included (no more 30 day grace

period)• Department submission date is official submission

Note: NIH only allows cost transfers within 90 days after the error was discovered.

Key Policy Changes – Justification / Documentation

Justification

• Detailed explanation• Independent reviewer understanding• Subject to audit (No email threads!)

Supporting Documentation• Current Salary Distribution Form• Original Additional Pay Voucher (APV)• Project monthly budget report (non-salary

xfers)• List of business meal attendees• Certified Effort Report w/ changes

Key Policy Changes – Untimely Submissions

Untimely Cost Transfer Submission (> 90 days)

◦ Original General Ledger accounting date◦ Cost transfer requests > 90 days after the error

is discovered is unallowable (NIH policy)

Additional Written Justification Required

◦ Lateness◦ Extenuating circumstances◦ Corrective action to prevent future occurrences

Key Policy Changes – Required Approvals

Department Approval• No one person has complete control over all

aspects of the cost transfer submission (Preparer, Approver)

Timely Cost Transfer Central Office (< 90 days)

• Cost Accounting Services (CAS) Salary/Wages

• Sponsored Project Administration (SPA) Non-Payroll

Untimely Cost Transfer Request (> 90 days)

• Principal Investigator signature is required• Vice President signature is required

Key Policy Changes – Transfer Authority of Unallowable

Expenses

Non-Payroll Expenses• SPA has authority to transfer expenses to

department general fund account

Uncertified Payroll Charges• CAS has authority to transfer non-certified payroll

expenses to the employee’s home department general fund chart string.

Note: Sponsored Projects Expense Transfer policy will be eliminated.

Cost Transfer Procedure & Form

Required for all cost transfer submissions

• Salary Distribution Changes• Additional Pay Vouchers • Wage Transfers• Non-Payroll cost transfers (email form to

Cost Transfer Procedure/Form

• Standard Form• Salary Distribution Form

Cost Transfer Forms

Cost Transfer Policy Summary - Key Changes -

Minimize cost transfers (Advance accounts, Prospective payroll distribution changes, timely

PurCard transactions)

Timeliness (< 90 days)

(Monthly PMBR review, Sufficient justification)

Untimely Cost Transfers ( > 90 days)

(Additional justification and approvals, Corrective action)

Cost transfer procedures/form (Updated, standardized)

Cost Transfer Policy Changes- Questions/Feedback -

Residual Balance Procedure

What is a residual balance?Residual balance: For fixed-

price agreements only, this is the term for any funds remaining after all charges have been incurred to complete the project and all project activities are complete.

Current practiceResidual balances remain in

sponsored project restricted chart string.

Project end-date is recorded as “indefinite.”

P.I. continues to expend funds for additional research.

Current practice issuesDoesn't recognize the unrestricted

nature of these funds.Cost considerations, such as

required effort and sponsor allowable costs are no longer applicable.

If federal, remains on Schedule of Federal Awards and subject to audit.

New procedure for residual balances

Residual balances remaining at the conclusion of sponsored project funded by a fixed price agreement, less appropriate Facilities and Administrative (F&A) costs, will be transferred to an unrestricted chart-string for the Principal Investigator’s use.

Conditions for transferring residual balances to department accounts

All deliverables have been received and accepted by the sponsor.

All costs for the project have been posted to the project’s chart-string.

All payments for the project have been received from the sponsor.

Conditions for transferring residual balances to department accounts

The residual balance must be more than $200 direct.

If the residual direct cost balance is greater than 20% of the direct costs awarded, an explanation detailing why the actual direct costs were substantially less than anticipated is required.

If the residual direct cost balance is more than $5,000, the intended use must be described.

Process SPA staff will follow the standard

award closeout procedures for all awards within 90 days of end-date.

For balances greater than $200, SPA will contact the Principal Investigator and academic unit administrator for a residual funds chart-string request form.

Once all conditions have been met, SPA will transfer direct funds to unrestricted account.

Re-CapDirect cost residual funds on fixed-

price agreements will be transferred to unrestricted chart string for PI use.

Certain conditions have to be in place for this to occur (project complete, all expenses posted, large balances analyzed).

SPA will request the completion of a request form during close-out if funds remain.

Questions??

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