Effectively Managing Your Grants and Contracts Office of Sponsored Programs Office of Research and Graduate Studies Jeanne WicksDon Holdegraver Director

Effectively Managing Your Effectively Managing Your Grants and ContractsGrants and Contracts

Office of Sponsored Programs

Office of Research and Graduate Studies

Jeanne WicksJeanne Wicks Don HoldegraverDon HoldegraverDirector of Post-Award Director of Operations Analysis472-1825 [email protected]

[email protected]

10-year UNL Research Awards10-year UNL Research Awards

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1996 1997 1998 1999 2000 2001 2002 2003 2004 2005

Total Research

Federal Research

Effectively Managing your Grants and Contracts

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Proposal Development Animal and Human Subjects Compliance Technology Development Office of Sponsored Programs

Pre-Award Post-Award

Office of Research and Graduate Studies services:


Proposal Development and Submission

Idea Development

FundingSource

Identification

ProposalPreparation

Proposal Submission, Approval, Routing

and Mailing

Timeliness is critical.Avoid excess or voluntary cost share.

Award

Decline


Project Management

WBSEstablishment

(Award Cost Center)

ProjectManagement

ProjectCloseout

Audit


Why is financial compliance so important?


NorthwesternHarvardSouth FloridaJohn HopkinsMinnesotaCornellFlorida International University

Audit Findings


Awards are granted to UNL

• Risk to Principal Investigator• Risk to Department• Risk to UNL

Federal Awards covered by federal, state, and university policies and regulations

Awards covered by specific funding agency regulations

Awards covered by specific award requirements


Cost Share (Equals Increased Documentation – PARs)

Burdensome requirements:Special reports or reporting dates

Ensure any sub-awardees are working with their OSP commitment letter (and prepare a budget and work statement for each).

Proposal Considerations

Sub-awards to end 30 days before the prime agreement.


Needed to set up WBS:

Official award document

Routing form – all signatures/cost share documented

Compliance – IRB, IACUC, Ionizing Radiation, Hazardous Materials,Biosafety approval

Conflict of Interest

Subaward information – Contact information, budget, WorkStatement

Proposal – electronic or paper


Pre-Award Costs

Institutional Prior Approval to Spend (IPAS) Form

Not allowed on “24” grants–State Single LOC

May not be available on all grants

At the risk of the department

No more than 90 days prior to the effective date of the award - must obtain written permission from the granting authority to exceed 90 days


Primary Principle - All costs must:

be reasonable – ‘prudent person’

be allocable

be treated consistently across the institution

conform to any limitations or exclusions set forth in these principles or in the sponsored agreement for types or amounts of cost items

The cost is unallowable if these are not all met.


Direct versus Indirect (F & A) Costs:Facilities & Administrative costs are those that are incurred for common or joint objectives and, therefore, can’t be identified readily and specifically with a particular sponsored project, an instructional activity or any other institutional activity. These can include items such as building costs (depreciation and use, operational and maintenance costs), library costs, departmental administration, sponsored projects administration, student administration and services.

The F & A Rate is a rate that is negotiated with our cognizant federal agency. A copy of our most recently approved rate agreement can be found at our web site. http://www.unl.edu/osp/indirect.html


Direct versus Indirect Costs

• Direct Costs can be identified specifically with a particular sponsored project activity with a high degree of accuracy

PI salary, lab supplies, scientific equipment


Direct versus Indirect Costs

Indirect costs are incurred for common or joint objectives and cannot be readily and specifically associated with a particular sponsored project.

utilities, administration, depreciation, interest, maintenance, office

supplies


Specific Costs:

Unallowable: Advertisement (except for grant specific positions*) Alcohol Entertainment, alumni activities Charitable donations and contributions Lobbying Fines and penalties Fund raising costs To cover losses on other sponsored agreements or

contracts Travel beyond lowest commercial fare – Fly America Act Goods and services for personal use Telephone Computers for offices or labs

* Requires specific (written) grant authority


Personal Services (Salaries/Wages/Fringe Benefits)

Personal Services are allowable charges to the award provided that the charges are documented adequately. OMB Circular A-21 requires educational institutions to document 100% of the distribution of charges for personal services paid from federal funds. The system chosen will reflect activity applicable to each sponsored agreement.

The University of Nebraska-Lincoln has chosen the After-the-fact Activity Records method for documenting payroll distribution, which under Section J.10.c.(2)(c) of Circular A-21 requires reports to reasonably reflect the activities for which employees are compensated by the institution.


PAR = Invoice for personal services


Personal Services (Salaries/Wages/Fringe Benefits)

“To confirm that the distribution of activity represents a reasonable estimate of the work performed by the employee during the period, the reports will be signed by the employee, principal investigator, or responsible official(s) using suitable means of verification that the work was performed.”

This is performed on a Personnel Activity Report (PAR) and is required for any direct charges as well as cost share for an award.

PARs and payroll charges should support each other

Retro payroll adjustments should also prompt a review of the PAR’s for that time period


“Costs allocable to a particular sponsored agreement may not be shifted to other sponsored agreements in

order to meet deficiencies caused by overruns or other fund considerations, to avoid restrictions imposed by law or by terms of the sponsored

agreement, or for other reasons of convenience.” (Source: A-21)


Cost Transfers

Red flags to auditors:

Multiple transfers – “Don’t you guys know what you are doing?”

Late transfers – “Aren’t you guys checking your reports?

Incomplete or poor explanations – “Why aren’t you telling us the whole story? What are you hiding?”


Extensions

Determine if an extension will be needed.

“No cost” extensions available on some, but not all awards.

Document the need for an extension

• Describe progress toward timeline• Define time needed to complete project.• Describe challenges to complete project.

“I still have money to spend is not a good reason to extend.”


Overspending an AwardCosts must be removed from the grantAdditional budget available?Use Commitments to avoid deficitsSpecial IssuesChanging a PI during the grantLeave of absence (3 months or more)Changing the effort promised Sub-awarding part of the grantTransferring Award to another institutionTiming of expenditures – last 30 – 90 days

“replacing what I used”


Cost Share

If you quantified cost share in your proposal, you must document that you provided it.

Cost share provided by effort (salary) will be documented via a Personal Activity Report (PAR).

Cost share provided by other forms ofexpenses will be documented andsubstantiated in files maintained by the department and, in some cases,by PAA. The original invoice andpayment document should have a notation that the cost is used as costshare for grant “XYZ.”


•You are ultimately responsible for ensuring that expenditures are in compliance with the terms and conditions of the award.• Post-Award can delay payment to a third party until adequate documentation is received.

Sub-awards


DocumentationPARsInvoicesFinancial reportsCopy of or evidence of submission of final technical or

progress report (final payment may depend on this!)Cost Share (outside of PARs)

Retention3 years after the final report is filedMulti-year awardsKeep documentation centrally located.Keep project notes with documentation.


• Use Proposal Development – Marla Rohrke

• Communicate with Pre-Award early and often. Provide budgets early if available.

• Communicate with your financial personnel.


• Modular budgets – Expand them and use as a tool to make sure you don’t overspend.

• Communicate with Post-Award. • Document costs appropriately• Obtain authorization in writing.

Provide copy to your financial personnel.


• File final reports on time. Funding can be withheld or refunds can be requested.

• Retain evidence that final reports were completed and submitted.


Contact Post-Award,

UNL Accounting or

Operations Analysis if

notified of an audit.


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Documents

Effectively Managing Your Grants and Contracts Office of Sponsored Programs Office of Research and Graduate Studies Jeanne WicksDon Holdegraver Director