Upload
jacob-williamson
View
216
Download
0
Tags:
Embed Size (px)
Citation preview
Controller’s Office
Research Administration Town Hall
Wednesday, October 29, 201410:00-12:00 PM
HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium at Mission Bay & Room 116 at the Fresno
Campus & Live Webcast
Contracts and Grants Accounting
Controller’s Office
Introduction of New AVC, Research Administration – Marge O’Halloran
Coverage Analysis – Eileen Kahaner and Jacquie Eichhorn
NOT-OD Updates – Joyce Abe Uniform Guidance Update – Nilo Mia Final Invoice Preparation – Dan Wikert Clinical Trial Post Award Topics – Michael Grafton Post Award Hot Topics – Michael Grafton and Jean
DeMartini Compliance Update – MC Gaisbauer CGA Survey and Contact Process – MC Gaisbauer
2
Agenda
Controller’s Office
Introduction of new AVC, Research Administration
3
4
Update:Clinical Trial Coverage Analysis
UCSF Clinical Enterprise Compliance Program
(CECP)
Controller’s Office
Agenda
IntroductionsWhat is a Coverage Analysis (CA) and why is it
importantWho performs CAs at UCSFYour role
5
Controller’s Office
UCSF Clinical Enterprise Compliance Program Mission
Promote a culture of compliance with applicable laws, rules, regulations
Provide oversight, guidance, and tools to detect, deter, and resolve non-compliant behavior
Establish an environment that empowers and expects individuals to address conduct that does not conform to the applicable standards
Support UCSF Mission by reducing organizational risk Scope
Clinical activities, including clinical research billing Tools
Training, address questions, review policies/SOPs Perform reviews Oversee corrective actions
6
Controller’s Office
Process
7
Controller’s Office
What is a Coverage Analysis?
Focused review of all clinical trial-related documents to determine who is financially responsible for all items and services provided to the research subjects over the course of the study
Process aligns the Protocol, Clinical Trial Agreement, Informed Consent (ICF), Budget
Creates a reference that all subsequent billing and invoicing decisions should use Study team, post-award, patient billing ICF costs section
UCSF CA mandate as of June 1, 2013
8
Controller’s Office
Some Principles of CA Development
Coverage analysis is based on billing rules Medicare rules typically applied
More well defined Most commercial payors follow, even for pediatrics
Charging for an item does not necessarily mean that item is reimbursable
FDA approval does not guarantee reimbursement
9
Controller’s Office
Why is the CA Important?Respond to government attention re CRB
Industry trials and federal grantsMore accurate assessment of trial costs
Improves budgeting UCSF cost recovery per OP mandate
Allows accurate ICF for expected costsAccurate billing to sponsor and payors
Single reference for study teams, post-award, billers Maintain sponsor and participant trust Reduces need for “back-end” corrections Demonstrates due diligence to bill accurately reducing
fines or penalties if mistakes are made
10
Controller’s Office
Multiple Groups Perform CAs
CA owner depends on type of trial http://hub.ucsf.edu/ca-budget-billing CTBSC: [email protected] Center: [email protected] of Cardiology: [email protected]
Budgeting also performed by multiple partiesNon-industry Sponsored Clinical Trial - RMSIndustry Sponsored Clinical Trial - ITACancer Center - ITRDivision of Cardiology - Cardiology
11
Controller’s Office
Your Role
Encourage study team to seek CA early in process – run in parallel with other activities
Do not finalize CTA without a formal CAAlert CECP to potential issues that
cannot be resolved through standard processes
12
Controller’s Office
Questions?
Jacquie Eichhorn, Manager Clinical Research Billing Compliance [email protected] 415-514-2576
Eileen Kahaner, Director, CECP [email protected] 415-476-8642
CECP – 415-502-2790
13
Controller’s Office
NOT-OD Updates
14
Controller’s Office
Notable NIH Updates
NOT-OD-15-014NOT-OD-13-097NOT-OD-14-113NOT-OD-14-090NOT-OD-14-094NOT-OD-14-095
15
Controller’s Office
Reminder: NOT-OD-15-014
http://grants.nih.gov/grants/guide/notice-files/NOT-OD-15-014.html
Guidance about NIH Type 5 Progress Reports (annual progress reports) • Implements Effective October 17, 2014 NIH requires that all type 5
progress reports be submitted using the Research Performance Progress Report (RPPR) module in eRA Commons
16
Controller’s Office
Reminder: NOT-OD-13-097
http://grants.nih.gov/grants/guide/notice-files/NOT-OD-13-097.html
Guidance about Graduate students/undergraduate students roles
participating on NIH-funded projects for one person month or more
• Implements Effective October 2014 NIH requires eRA Commons IDs for
all graduate and undergraduate student roles reported on annual progress reports (RPPRs)
17
Controller’s Office
Reminder: NOT-OD-14-113
http://grants.nih.gov/grants/guide/notice-files/NOT-OD-14-113.html
Guidance about Individual Development Plans (IDP) for graduate students
and postdoctoral researchers supported by NIH awards • Implements Effective October 1, 2014 Research Performance Progress
Report (RPPR) are required to include a report on the Use of IDPs in Section B, Question B.4.
18
Controller’s Office
REMINDER: NOT-OD-14-113, continued
The Graduate Division has posted information on IDPs and template language for RPPRs on their website: You can get the information on IDPs at: https://career.ucsf.edu/grad-students-postdocs/myIDP
Template language for RPPRs is located at:
https://career.ucsf.edu/sites/career.ucsf.edu/files/PDF/Reporting%20Use%20of%20the%20IDP.pdf
19
Controller’s Office
NOT-OD-14-090 and NOT-OD-14-133
http://grants.nih.gov/grants/guide/notice-files/NOT-OD-14-090.html
Guidance about Update to PA-14-150 (F30) NRSA Individual Predoctoral
Dual-Doctoral Degree Fellowship• Implements Requirement to upload “Additional Educational
Information” under Other Attachments in the Other Project Information section of the application
Applications submitted without this attachment will be considered incomplete and rejected
20
Controller’s Office
NOT-OD-14-094 and NOT-OD-14-134
http://grants.nih.gov/grants/guide/notice-files/NOT-OD-14-094.html
Guidance about Update to PA-14-147 (F31) NRSA Individual Predoctoral
Fellowship• Implements Requirement to upload “Additional Educational
Information” under Other Attachments in the Other Project Information section of the application
Applications submitted without this attachment will be considered incomplete and rejected
21
Controller’s Office
NOT-OD-14-095 and NOT-OD-14-135
http://grants.nih.gov/grants/guide/notice-files/NOT-OD-14-095.html
Guidance about Update to PA-14-148 (F31-Diversity) NRSA Individual
Predoctoral Fellowship to Promote Diversity in Health-Related Research
• Implements Requirement to upload “Additional Educational
Information” under Other Attachments in the Other Project Information section of the application
Applications submitted without this attachment will be considered incomplete and rejected
22
Controller’s Office
OMB Uniform Administrative
Requirements, Cost Principles, and Audit
Requirements forFederal Awards
Controller’s Office
Background – When, Why, Who? Fall 2009, Executive Order 13520 on reducing improper
payments and eliminating waste in Federal programs and Presidential memorandum on promoting administrative flexibility
Set in motion the single biggest regulatory change in the last 50 years of research administration
In the documents, President directed OMB to work with Executive Branch agencies and other key stakeholders to evaluate potential reforms to Federal grants policies
The Council on Financial Assistance Reform (COFAR) was established in October 2011 and has led efforts to improve delivery, management, coordination, and accountability of Federal grants and cooperative agreements, which includes the development of the uniform guidance
24
Controller’s Office
Background – What Did COFAR Do ?
OMB Advance Notice – Spring of 2012Proposed guidance issued February 1, 2013Final guidance issued December 26, 2013Federal agencies had 6 months (to June 26,
2014) to submit THEIR draft(s) of “implementing regulations” to OMB
25
Controller’s Office
Overview of UCSF Review and Campus Coordination Process
Meet every two/three weeks to review guidance and make initial assessment
Form UCSF position and stay connected with UCOP to share concerns and stay abreast of UCOP review process
Coordinate UCSF concerns with Council on Government Relations (COGR)
Establish and maintain communication plan with campus stakeholders
Vet concerns of Grant Reform Task Force with campus administrators and academic community
With stakeholders, establish campus priorities and develop implementation plans
Execute, track, and communicate status of implementation processes
26
Controller’s Office
Parts of UG & Who Is Reviewing It
27
Final Rule Section Title Champion DepartmentSubpart A – Acronyms and Definitions All AllSubpart B – General Provisions NM Budget & Resource Mgmt.Subpart C – Pre-Federal Award Requirements JR& MO Office of Sponsored ResearchSubpart D – Post Federal Award Requirements MC Controller’s OfficeSubpart E – Cost Principles NM Budget & Resource Mgmt.Subpart F – Audit Requirements MC/TP Controller’s Office/AuditAppendices
Notice of Funding Opportunity All All Contract Provisions
Research JR& MO Office of Sponsored F&A Costs…for Institutions of Higher
Education NM Budget & Resource Mgmt.
F&A Costs…for Nonprofit Organizations N/A State/Local Gov’t and Indian Tribe Service
Allocation N/A Public Assistance Cost Allocation Plans N/A States and Local Gov’t and Indian Tribe IDC N/A Nonprofit Orgs Exempted from Subpart E N/A Hospital Cost Principles N/A Data Collection Form (Form SF-SAC) MC Controller’s Office Compliance Supplement MC Controller’s Office
Controller’s Office
Review Timeline
28
Calendar YearFiscal Year 2016
1.0 Administrative
1.1 Establish sub-committee
1.2 Set communication meetings every 2 weeks
1.3 Champions to develop review plan
1.4 Establish campus communication process
1.5 Send second announcement to campus (task force formed)
2.0 Review OMB Final Guidelines for campus impact
2.1 Form initial assessment
2.2 Review with sub-committee
2.3 Strategize / determine options/ priorities
2.4 Vet with stakeholders
2.5 Communicate to leadership on priorities by FYE 2014
3.0 Prioritize and create draft implementation plan schedule
4.0 Brief leadership on initial implementation plans
5.0 Revise campus communication process
6.0 Establish progress tracking process and check in with Costing Policy Group
7.0 UCSF Compliant with New Guidance
MAY
Adm
inis
trati
ve R
equi
rem
ents
and
Cos
t Pri
ncip
les
Aud
it Re
quir
emen
t
2015
Review and Implementation Process and Timeline
FEB
MAR
APR
MAY
JUN
2014 20152014
JUL
DEC
JUN
JUL
AUG
SEP
OCT
NO
V
JAN
FEB
MAR
APR
Controller’s Office
UC Approach to Uniform Guidance, Phase One (6 months) Identify major issues and areas where systemwide guidance or policy will
need to be updated Determine key issues/approaches to inform and engage local campus
constituencies Issue systemwide guidance, where appropriate, and/or begin work to
update policies, as needed
29
Controller’s Office
Uniform Guidance Applicability
Applicability and Dates (200.110)Uniform implementation date of 12/26/14 for all Subparts, except Subpart F Subpart F, Audit Requirements, will be effective the first FY beginning after 12/26/14; for UCSF, this will be FY 2016 (July 1, 2015 – June 30, 2016)The UG will be applicable to all NEW AWARDS and extensions / additions to EXISTING AWARDS with award dates on or after 12/26/14
30
Controller’s Office
Uniform Guidance Applicability Question: Will the Uniform Guidance changes apply
ONLY to awards made after the effective date (December 26, 2014), or do the changes apply to awards made earlier?
Answer: Once the Uniform Guidance goes into effect, it will APPLY TO AWARDS or FUNDING INCREMENTS AFTER THAT DATE (December 26, 2014); it will NOT retroactively change the terms and the conditions for funds (awards) already received
Note: Existing federal awards will continue to be governed by the terms and conditions of that Federal award
31
Controller’s Office
Some Top Highlights and Key Issues 200.112 Conflict of Interest 200.301 Performance Management
Researchers must relate Financial Data to Performance Accomplishments of the federal award
Researchers MUST provide COST INFORMATION to demonstrate COST EFFECTIVE PRACTICES (e.g. – unit cost data); objective is to improve program outcomes, share lessons learned, and spread adoption of best practices
Higher reporting bar overall for Federal contracts Stronger certification language reminds signers of statutory penalties for false
certifications
NOTE: Alert your PI’s now of these requirements…
200.303 Internal Controls Strong emphasis on IA as well as understanding “must” versus “should” Requires recipients to have strong internal controls; should be in compliance with…
Internal Control Integrated Framework (COSO) The Federal “Green Book” – Protecting Personally Identifiable Information Federal statutes, regulations and conditions (Comptroller General of the U.S.)
32
Controller’s Office
Some Top Highlights and Key Issues 200.306 Cost Sharing
Voluntary committed cost-sharing is not expected in Federal research proposals
Cost-sharing obligations must be included in FOA’s (Funding Opportunity Announcements)
Cost-sharing may not be used as a factor in the merit review of applications or proposals
200.307 Program Income 200-313 Equipment
“Conditional Title” is new; not a new concept, but designed to clarify, among other things, Federal equipment should move with the PI if they transfer between Universities; also clarifies that conditional title is calculated using project costs including mandatory cost sharing
“Percentage of Federal participation in the project costs” (A-110 required the “percentage of Federal participation in the cost of the equipment”) and “use and condition” (“use” is not included in A-110) are new; preliminary assessment is that the subtle changes in terminology will NOT require systems changes to the institution’s equipment inventory system
33
Controller’s Office
Some Top Highlights and Key Issues 200.317-326 Procurement Standards
Effective July 1, 2016 (or FY17), but work ahead One year grace period before implementation
200.330 Sub-recipient and Contractor Determinations New option for each Federal agency to require us to document
how we decided each transaction is either a Subrecipient versus a Contractor
Characteristics of a Subrecipient / Contractor have not changed In new agreements with Subrecipients, be certain to reference
the terms and conditions found in the new “Uniform Guidance”, effective December 26, 2014
If you want reports from your “subrecipient”, you must include that requirement in your sub-award documentation
The provisions of the prime sponsor usually flow through to the “sub-awardee”; additional provisions may be added by the awardee
34
Controller’s Office
Some Top Highlights and Key Issues200.331 Requirements for Pass-through Entities
Subrecipients must be monitored to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward
The Uniform Guidance provides recommendations, but does not specify how the pass-through entity should conduct that monitoring
Any monitoring would need to comply with the overall need for sufficient internal controls to meet the requirements in this section
Pass-through entities must honor subrecipient negotiated F&A rate or use 10% de minimis rate, or negotiate one with the subrecipient
35
Controller’s Office
Some Top Highlights and Key Issues 200.332 Fixed Amount Subawards
The uniform guidance allows for the use of fixed amount (fixed-price) subawards but:
– Only with the prior approval of the Federal awarding agency– Only up to the Simplified Acquisition Threshold ($150,000)
Prior approval may be inferred if the intent is included in a proposal submission and awarded
The $150,000 cap may be problematic for some projects 200.343 Closeouts
Campuses must complete final reporting, invoicing, and cash draws within 90 days of the end of the performance period or risk not being able to recover funds expended
Although this requirement is not new, the Uniform Guidance codifies it and imposes a hard stop to adjustments
This could prove challenging in the management of subawards
36
Controller’s Office
Some Top Highlights and Key Issues
200.413 Direct Costs – Clerical & Administrative The Uniform Guidance allows for the direct charging of administrative
and clerical salaries, so long as certain conditions are met: Administrative or clerical services are integral to a project or activity Individuals involved can be specifically identified with the project or
activity Such costs are explicitly included in the budget or have the prior written
approval of the Federal awarding agency The costs are not also recovered as indirect costs
A justification should be included in proposals that addresses the criteria above to facilitate the required agency approval for these charges
Any post-award addition of administrative salaries to a budget would require prior written approval of the funding agency
37
Controller’s Office
Some Top Highlights and Key Issues 200.414 Indirect Costs
4-year extension, 1.3% UCA 200.419 Cost Accounting Standards and DS-2
11th hour push and cautious optimism 200.430 Compensation – personal services
Opportunities and challenges 200.456 Participant Support Costs
Now a federal-wide concept Are defined as direct costs for items such as stipends or
subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training projects
Participant support costs will be an exclusion in the MTDC base
38
Controller’s Office
Some Top Highlights And Key Issues
200.461 Publication and Printing Costs The Uniform Guidance provides institutions
additional flexibility to charge Federal awards after the performance period for page charges in professional journals
This may require a system/procedure change to allow costs to post to an award after the performance period Late charges can create issues for meeting 90 day
closeout requirement for Federal awards
39
Controller’s Office
What’s next?Phase One (Jan – Dec 2014)
Assess & analyze the Uniform Guidance Inform the campus and discuss approaches Issue interim guidance, as needed Issue Assessment document
Phase Two (Jan – June 2015) Update guidance & policies as needed Update DS2s (?) Update training & support, as needed
Phase Three (Jul – ~Dec 2015) Update support systems, as needed Other long-horizon actions needed
40
Controller’s Office
Thoughts on Implementation Planning
41
Controller’s Office
Primary UCSF Grant Reform Task Force Contacts
Nilo Mia - Budget and Resource Management Office
MC Gaisbauer - Controller’s Office Marge O’Halloran - Research Management
Services, Office of Sponsored Research John Radkowski - Government and Business
Contracts, Office of Sponsored Research
42
Controller’s Office
Key Websites
Uniform Guidance, Title II CFR Part 200www.ecfr.gov
Federal Register Notice with Preamblehttps://federalregister.gov/a/2013-30465
Council on Financial Assistance Reformwww.cfo.gov/cofar
Questions and Concerns about the [email protected]
43
Controller’s Office
OMB Circulars Consolidated Into UG A–21, ''Cost Principles for Educational Institutions'' (2 CFR Part 220) A–87, ''Cost Principles for State, Local and Indian Tribal
Governments'' (2 CFR Part 225) and also Federal Register notice 51 FR 552 (January 6, 1986)
A–89, ''Federal Domestic Assistance Program Information'' A–102, ''Grant Awards and Cooperative Agreements with State and
Local Governments'' A–110, ''Uniform Administrative Requirements for Awards and
Other Agreements with Institutions of Higher Education, Hospitals, and Other Nonprofit Organizations'' (codified at 2CFR 215)
A–122, ''Cost Principles for Non-Profit Organizations'' (2 CFR Part 230)
A–133, ''Audits of States, Local Governments and Non-Profit Organizations,''
Those sections of A–50 related to audits performed under Subpart F— Audit Requirements of this Part
44
Controller’s Office
Final Invoice Preparation
45
Controller’s Office
CGA Billing Team ResponsibilitiesContract & Grants Accounting (CGA) is responsible for
billing and payment processes for sponsored projectsKey billing functions:
Prepare timely and accurate invoices in accordance with award documents, University and sponsor policy
Submit invoices to sponsors Exception: Clinical trials invoicing initiated by departments (copy
CGA)Cost Reimbursable - CGA generates invoices based on
actual expenses incurred and posted to the General Ledger up to the authorized spending limit (appropriation)
Exception: approved PETs, submitted / approved journals for a final invoice or a late award set-up
46
Controller’s Office
Departmental Administrator’s Role in the Final Billing Process
Review and ensure that all appropriate project expenses are reflected in the General Ledger prior to termination date
Submit any pending cost transfer requests so that they can be received and processed prior to the award end date or activity period end date
Review any open requisitions, purchase orders and contact Accounts Payables attempting to close immediately
For subcontracts, including those with other University of California campuses (intercampus), ensure final invoices have been submitted and paid
Determine if a carryover justification is required to move the unexpended balance from one activity period to the next
Determine if a no-cost extension (NCE) is required for the award and submit a request for an extension prior to award or activity period end date
47
Controller’s Office
Final Invoices Continued… If UCSF is the subcontractor and another institution is
prime, ensure all services provided have been paid in full
If this is the final year, contact all recharge departments to terminate or change chartstring for any toll charges, phone lines and other UCSF Services such as animal care, storage etc
Review and remove unallowable costs per the office of Management and Budget (OMB) Circular A-21 and UCSF charging practices
For additional requirements, refer to the contract/agreement terms and conditions as well as University policies to fully comply with regulation and sponsor requirements for closing out an award
48
Controller’s Office
Final Invoices Continued…
After the final invoice filed, clear overdraft or deficit within 90 days of the activity period or award end date Overdraft Represents the amount that spending exceeds the
award budget Deficit Represents the amount the total expense exceeds
total revenue
49
Controller’s Office
Clinical Trial Post Award Topics
50
Controller’s Office
Set Up of Clinical TrialsPrivate Industry Clinical Trials
Fund number 4400 is used Award purpose on award profile page is CLIN Award must be registered in www.clinicaltrials.gov by
UCSF Facilities and administration (F&A) is assessed on
gross receipts, not only an expenditure basis Base code is M
The assessment is based upon a “substitution” equation 1 – 1/(1+Rate)
The substitution rate is rounded to one decimal point The rate for clinical trials is negotiated at 33.0% of
total direct costs; the “substitution” rate is 24.8% of gross receipts.
51
Controller’s Office
Set Up of Clinical Trials, continued
Private Industry Clinical Trials The rate for off-campus clinical trials is negotiated at
26.0% of total direct costs; the “substitution” rate is 20.6% of gross receipts
Department is responsible for sending the invoice to the sponsor; the department must also send a copy of all invoices to the Contracts and Grants Accounting unit, so that the invoice can be tracked for payment in the RAS accounts receivable module
The appropriation is done at the time of invoicing or time of sponsor payment, whichever comes first
52
Controller’s Office
Set Up of Clinical Trials, continued
Flow-Through Clinical Trials Fund number 4301 is used Award purpose on award profile page is CLINO Award must be registered in www.clinicaltrials.gov
by the sponsor Facilities and administration (F&A) is assessed on
expenditures, not gross receipts Base code is either C for total direct costs or A for
modified total direct costs The rate for clinical trials is negotiated at 34.0% of
total direct costs or modified total direct costs
53
Controller’s Office
Set Up of Clinical Trials, continued
Flow-Through Clinical Trials The rate for off-campus clinical trials is negotiated
at 26.0% of total direct costs or modified total direct costs
Department is responsible for providing information to the Contracts and Grants Accounting unit, so that it can create an invoice that will be tracked for payment in the RAS accounts receivable module
The appropriation is done at the time of the award activation and subsequent award modifications
54
Controller’s Office
Set Up of Clinical Trials, continued
Pending Matters The definition of clinical trial is going through a
review, to treat all agreements registered in www.clinicaltrials.gov consistently
We are reviewing whether an intercampus clinical trial falls under CLIN and assigned to fund 4400, or CLINO and assigned to fund 4301
Treatment of pre-clinical administrative costs has not been finalized by the campus Costing Policy Group. This oncludes both start-ups costs for a specific clinical trail, and set-up costs prior to proposal for a specific study, such as CHR protocol.
55
Controller’s Office
Set Up of Clinical Trials, continued
56
Controller’s Office
Post Award Hot Topics
57
Controller’s Office
Post Award Topics
Advances GAEL RSA updates STIP Record Retention SAM Registration T32 Management Surplus Transfers
58
Controller’s Office
AdvancesWhy do we need an advance?
Funding for a subsequent year can be delayed for a number of reasons; an advance allows the Department to spend on the award while the negotiation process is being concluded
What is the benefit of getting an advance? Ensures that costs can be placed on the correct
award/project in the General Ledger Ensures that cost transfers are minimalized and that late
cost transfers are avoided Documents financial responsibility should the contract not
be awarded Ensures that compliance concerns are addressed prior to
the initiation/continuation of work on the project
59
Controller’s Office
Advance, continued
What is the process to request an advance? Please consult with your Research
Management Services (RMS) contact early to ensure that the fund advance is completed and sent to CGA in a timely manner
The Award Advance Request Form and Award Activity Period Advance Request can be found on the Office of Sponsored Research website http://osr.ucsf.edu/forms
60
Controller’s Office
GAEL GAEL refers to the General, Automobile, and Employee
Liability (GAEL) assessment The GAEL assessment is tied to the distribution of payroll
expense ledgers for all regular salary lines (HRG, HST), but is NOT an employee benefit
The GAEL assessment posts monthly at the time that the distribution of payroll expense subsidiary ledger is migrated to the general ledger
In the new chart of accounts, the account number is 57400 In the prior chart of accounts, the expenditure NCA code is
437970 The GAEL assessment is exempt from federal or federal flow
through funds with a 100% federal share On sponsored project awards, the GAEL assessment is subject to
the facilities and administration (F&A) base and rate of the project that posts the payroll
61
Controller’s Office
GAEL If an award is coded as a federal flow through with a 100% share
from the federal government, the award will be coded as federal flow through code 3 in the Award Details link Steps to Exempt GAEL from 100% Federal Flow Through Secure proof that the award is 100% federal; there might be an
overlooked section of the award with a pertinent clause, or perhaps a sponsor e-mail will attest to the 100% flow through status
Once proof of 100% federal funding is available, send a request to the Contracts and Grants Accounting service desk to have the award updated and the general ledger reflect the reversal of GAEL entries to date [email protected]
The federal flow through code on the Award Details link will be updated 3, and the prime sponsor agency will be added; any award that is updated to 3 where the prime sponsor is an agency of the Public Health Service will be subject to the federal salary cap
Contracts and Grants Accounting will reverse the cumulative GAEL assessment on the award with a 535 financial journal
62
Controller’s Office
GAELSAMPLE PROOF OF 100% FEDERAL FUND FLOW
From: Hax, John R@DOR [[email protected]]Sent: Tuesday, September 30, 2014 12:10 PMTo:Cc:Subject: RE: Contract #28838 (CFDA #84. 126A) Award A121902
Hi : 100% of the funds you receive as payment on your 801B service invoices are ‘federal’ funds. Once your match is received and the federal draw down funds are received from the federal Rehabilitation Services Administration, all funds are to be identified as ‘federal’ funds. Hope this helps. John R. Hax, Program SpecialistCollaborative Services SectionCA Department of Rehabilitation(916) 558-5438 CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication.
63
Controller’s Office
GAEL
64
Controller’s Office
GAEL
65
Controller’s Office
GAEL
If an award is a non-federal or non-federal flow through, and the sponsor disallows the GAEL assessment, the department will be required to cover the assessment In the case of non-federal GAEL disallowances, the
GAEL will not be reversedDepartments will be required to transfer the
cumulative GAEL accrued on account 57400, at the project level, from the sponsored award to a discretionary fund, using a 535 financial journal
66
Controller’s Office
STIPThe University defines STIP as a general resource
available to the department head to invest in strategic plans as he/she best determines. Therefore, the intradepartmental allocation of STIP is not considered necessary, except where an external sponsor requires the allocation of STIP to the award
If the department head determines an intradepartmental allocation of STIP is necessary to meet the department's strategic objectives, the intradepartmental allocation may not cross fund families
67
Controller’s Office
STIP, continuedWhen the sponsor mandates that STIP be
allocated to the award, the Department is responsible for transferring all reportable STIP onto the award throughout its life
Department must request budget entry through [email protected]
CGA will monitor for compliance with the award terms during the generation of the FSR and at the time of closeout
Information on this policy: Job Aid – to come Contact - Denis Nepveu, Director - Resource Planning
68
Controller’s Office
Record Retention
A records retention schedule defines the period of time that records should be retained and when they should be destroyed Various requirements based in law and university policy
govern the retention of administrative records A retention schedule is critical for promoting responsible
records management, mitigating risk, and ensuring consistent compliance across UC
Record retention resources are as follows: Records Retention and Management Policy 050-19 located at
http://policies.ucsf.edu/policy/050-19 UC Records Retention Schedule located at:
http://recordsretention.ucop.edu/ Campus Records Management Coordinator: Brenda Gee DePeralta
69
Controller’s Office
System for Award Management (SAM)
SAM, launched in 2012, integrated 8 federal procurement systems (including the old CCR) into a single streamlined system
Provides federal government with details of management, performance, representations, certifications, etc.
Registration is updated annually (next due date 3/5/15)
Awards/subcontracts may request UCSF to provide SAM status or expiration date
https://www.sam.gov/portal/SAM/#1
70
Controller’s Office
System for Award Management (SAM)
71
Controller’s Office
T32 ManagementAppointments
Appointment forms must be submitted through xTrain before the start of the trainee’s appointment or reappointment
Must correlate to the trainees identified and stipend charged to the general ledger
Stipend levels detailed at: http://grants.nih.gov/training/nrsa.htm
Generally appointments are for a full-time, 12 month period
Termination Notices PD/PI is responsible for submitting, via xTrain, within 30
days of the end of period of support xTrain – Business Officer is Freddie Robinson
72
Controller’s Office
Surplus Transfers
A surplus may result at the expiration of a fixed priced award/activity period
Sponsor agreements may require that surplus amounts be returned to the sponsor, or may be retained by the University
Surplus transfers, within the University, should be recorded on a 78% account number The amount transferred should consider the IDC
impact Any questions should be directed to the CGA
Award Closeout Team73
Controller’s Office
Compliance Update
74
Controller’s Office
Compliance Update
Transition Initiated search for Compliance Manager Rick Blair will serve as interim Compliance
Manager Key Initiatives
Effort Reporting – period closes 10/31/14 T32 Policy Change Audit Status Updates
75
Controller’s Office
Effort Reporting ConsiderationsRoles
ERC role is to facilitate process, organize and communicate with PI
PI role is to review and certifyFunction – PI is certifying based on first hand
knowledge of effort If a PI has already certified an entire report for
another faculty member, there are two possible solutions If the effort certification is correct, the faculty member
should add a comment to their effort report stating concurrence with the certified percentages; comments may be added after certification by using the Comments tab
If incorrect, the report should be recertified
76
Controller’s Office
T32 Award Policy Change The NIH Grants Policy Statement changed the allowability of Training Related
Expenses in 2014 – for this to be applicable at UCSF, we must adopt a new charging policy and update our payroll system
http://grants.nih.gov/grants/policy/nihgps_2013/nihgps_ch11.htm#_Toc271265131 11.3.8.4 Training-Related Expenses
Our goal is to have the new campus policy in place and the payroll system modified by the end of the year - the final implementation date will be announced in an upcoming newsletter
The new campus policy will allow for the charging of Health benefits (medical, dental and vision) ▪ Tuition and fee Leave rights ▪ Travel Malpractice insurance - if the research training experience involves direct contact with
patients or human subjects The following items will continue not to be chargeable to grant:
Disability insurance ▪ Life insurance Union dues ▪ Unemployment insurance Workers’ Compensation ▪ FICA GAEL (General, Auto, and Employment Liability)
77
Controller’s Office
Audit Status Updates
Audit status Annual Financial Statement Audit A-133 Audit Compliance Reviews – Administrative Expenses
Thank you for your assistance during the audit process and your diligence during the year
78
Controller’s Office
QUESTIONS?
79
Controller’s Office
We Are Here To Serve You
Research Management Services (RMS) for federal grants, fellowships, cooperative agreements and all non-profit sponsors
http://osr.ucsf.edu/find-my-osr-staff Government and Business Contracts (GBC) for federal contracts and
all state, city, county, and foreign government/organization sponsors
http://osr.ucsf.edu/content/gbc-contact-information Industry Contracts Division (ICD) for all industry sponsors (industry
is the prime sponsor)http://ita.ucsf.edu/about/staff CGA Service Desk for post-award issues [email protected] Also a CGA service quality survey at https://ucsf.co1.qualtrics.com/SE/?SID=SV_cuSKJUDE6sZTnjT
80