Grants Management, Financial Responsibilities, and Research Related Issues

1
Grants Management,Financial Responsibilities,and
Research Related Issues

• Carol Hillmer
• Assistant Dean
• CALS Research Division
• November 19, 2003

2
Responsibilities

• Individuals authorized to sign transmittals and
  other actions on behalf of their
  Department/Center need to thoroughly review and
  understand what they are signing
• Departmental/Center signatories are responsible
  for the requests, proposals, documents, etc.,
  which they sign and forward through campus

3
Responsibilities continued

• CALS Research Division will not approve requests
  that are unclear, inaccurate, or incomplete
• Research and Sponsored Programs is delegated
  signature authority (authorized official) by the
  Board of Regents for proposals, agreements,
  contracts, etc. related to extramural support
  activities of the University

4
Responsibilities continued

• Principal Investigator is responsible and
  accountable to the grantee for the proper conduct
  of the project or activity
• Authorized official is held responsible by the
  sponsor to assure that the institution will meet
  the obligations

5
Responsibilities continued

• Each of us is a representative of the UW,
  accountable to the State of Wisconsin, and
  ultimately responsible for assuring efforts of
  good stewardship
• Communications keep departments/ centers,
  college, and RSP in the loop

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Applications, Agreements, etc.

• Applications are submitted by the University of
  Wisconsin-Madison on behalf of the Principal
  Investigator
• Proposals (pre-, full, electronic) all must route
  through the department, college, and RSP for
  review and approval prior to submission to an
  agency/sponsor

7
Awards

• Awards are accepted by the University of
  Wisconsin-Madison and assigned to a Principal
  Investigator
• Terms and conditions may be negotiated and must
  be fully accepted prior to an award number being
  issued
• Protocol approvals must be approved prior to an
  award number being issued

8
Personnel Issues

• Principal Investigator must be payrolled OR cost
  shared on the grant effort must be shown and
  the level must be reasonable
• Principal Investigator is responsible and
  accountable to the grantee for the proper conduct
  of the project or activity and for overall award
  management

9
Personnel Issues continued

• Key personnel are individuals who contribute in a
  substantial way to the scientific development or
  execution of the project
• Includes PI and collaborator(s)
• May include researchers/scientists
• Does not include students (undergrads, grads, or
  post-docts) or general support staff

10
Personnel Issues continued

• Consultant
• provides professional advice or services on the
  basis of a written agreement for a fee
• expertise or skills add value to the project
• not an employee
• Administrative and Clerical support salaries are
  normally not allowable costs on grants they are
  a component of our Indirect Cost Rate

11
Personnel Issues continued

• Fellowship appointments are as Pre-doctoral or
  Post-doctoral Fellows
• Post-doctoral research appointments are as
  Research Associates
• Graduate student research appointments are as
  Research Assistants

12
Personnel Activity Reports

• PARs represent an after-the-fact certification of
  an individuals actual effort
• Employees that are payrolled from or cost-shared
  toward a federally-sponsored project are required
  to complete a PAR
• Total effort cannot exceed 100

13
PARs continued

• Problem Employees that are cost-shared toward a
  non-federally-sponsored project are NOT captured
  on the PAR system
• Problem PARs are on occasion inaccurately
  certified which may be interpreted as an act of
  fraud

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Cost Sharing

• Cost sharing is a portion of the project or
  program costs which are not borne by the awarding
  agency/sponsor
• Although agencies/sponsors may define cost
  sharing, matching, and leveraging differently, at
  UW-Madison each requires the same level of
  documentation

15
Cost Sharing continued

• Required versus encouraged versus voluntary
• If required, only provide up to the required
  level
• If encouraged, only include a reasonable level
• Otherwise, do NOT include
• All must be documentable

16
Cost Sharing continued

• When personnel effort salary plus fringe
  benefits plus indirect costs (if indirect costs
  are allowed)
• When cash must be captured in a 133 account
  designated specifically as a match account
  must be used during the same award period as the
  award it is being used to match

17
Cost Sharing continued

• When an award is made, cost sharing of personnel
  effort must be set up prior to an account number
  being established
• http//www.rsp.wisc.edu/forms/costsharefrm.pdf
• Informational copies of completed forms are sent
  to the Principal Investigator, Department/Center
  Administrator, and Individual(s) being cost shared

18
Cost Sharing continued

• When an award is made, cash match accounts must
  also be set up prior to an account number being
  established
• Other forms of cost sharing manner of
  tracking/reporting and who is responsible for
  such must be defined prior to an account number
  being established

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Criteria for Cost Sharing

• Must be verifiable from the recipients
  accounting records
• May not be included as a contribution for any
  other project or program
• Must be necessary and reasonable for proper and
  efficient accomplishment of the project or
  program objectives

20
Criteria for Cost Sharing continued

• Must be allowable under applicable cost
  principles
• Must be provided for in the approved project
  budget
• Unrecovered indirect costs may be included with
  prior approval of the federal awarding agency
• Federal support cannot be used toward another
  federal award

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Financial Issues

• Do not payroll individuals on awards on which
  they are not associated/working
• Payrolling on a grant account as a holding
  place until a new award or continuation funding
  is received is not allowable
• Establish advance accounts or utilize
  unrestricted funding (i.e., 101s, 133 gifts, etc.)

22
Financial Issues continued

• Be aware of the terms and conditions that apply
  to each award
• FDP (Federal Demonstration Partnership)
  streamlines the administrative process and
  minimizes the administrative burden while
  maintaining effective stewardship of federal funds

23
Financial Issues continued

• Unallowable expenditures
• Administrative clerical salaries
• Local telephone service
• Office supplies
• Postage
• Dues memberships
• Subscriptions, books, periodicals
• General purpose equipment (i.e., computers, copy
  machines, etc.)
• General computer services, networking costs,
  other DoIT services
• Staff recruitment relocation

24
Financial Issues continued

• Use of procurement cards purchases must be
  allowable
• Premium processing fees on visa applications are
  unallowable
• Use of daily rate structures are unallowable
• Special invoicing/reporting requirements flow
  down to the college and departments/centers

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Account Numbers in Advance

• Complete a Request for Account Number in Advance
  of Award (form 88-1)
• http//www.rsp.wisc.edu/forms/88-1.pdf
• Attach copies of approved protocols
• Attach documentation from the funding
  agency/sponsor that award is forthcoming

26
Account Number in Advance continued

• Problem departments are responsible for
  incurred costs when an award is not received
• Problem 90 day pre-spending is not allowable by
  all agencies/sponsors
• Problem some awards are effective upon date of
  last signature

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Subcontracts

• Subcontract costs represent a collaboration of
  work by more than one institution
• UW may be a subcontractor in another
  agency/institutions proposal
• Another agency/institution may be a subcontractor
  within a proposal/award to UW
• Paperwork requires agency/institutional approvals
  prior to inclusion

28
Subcontracts continued

• http//www.cals.wisc.edu/research/infopolproc.html
  
• Issue on a yearly basis
• Prior to continuation, consult with PI to confirm
  acceptable performance to date
• Final period of continuation should end 90 days
  prior to the official award end date
• Subs to UW departments are handled via subaccount
  request form

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Cost transfers

• A cost transfer is a transfer of a previously
  recorded expenditure from one funding source to
  another
• Salary payment transfers
• Non-salary payment transfers

30
Cost Transfers continued

• Why?
• Correction of data entry error
• Service center charges
• Reallocation of effort
• Continuation year of a project
• Pre-award costs

31
Cost Transfers continued

• When allowable?
• In accordance with the terms and conditions of
  the award document
• Supported by acceptable documentation justifying
  the transfer
• Certified as to the correctness of the charge

32
Cost Transfers continued

• When unallowable?
• To meet deficiencies caused by overruns or other
  financial considerations
• To avoid restrictions imposed by law or by the
  terms of the sponsored agreement
• Due to funds terminating with unexpended balances
• Clean up efforts at the end of an award
• For convenience
• After PAR certification has occurred

33
Cost Transfers continued

• What is required?
• Documentation!
• Justification!
• Clarity and detail!
• Documentation must include a full explanation of
  how the situation occurred and actions being
  taken to alleviate future occurrences

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Cost Transfers continued

• Timeliness
• Must submit as soon as issue is discovered
• 90-days is the standard
• CALS strongly encourages actions within 45 days
• Prior to PAR certification!

35
Cost Transfers continued

• Recommendations
• Review accounts monthly
• Do not use grants for parking expenses
• Set up accounts in advance when appropriate
• Keep in mind transfers are a big red flag to
  auditors

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Gifts-in-Kind

• Gifts-in-Kind (non-monetary gifts) require formal
  acceptance by the Board of Regents
• http//www.rsp.wisc.edu/html/giftinkind.html
• Route transmittal form through department/center,
  college, and RSP for review and approval
• Attach letter from donor

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Equipment Loans

• Risk Management has a property program which
  manages equipment located at off-campus
  facilities or loaned to another institution
• For information refer to their website
• http//www.bussvc.wisc.edu/risk_mgt/property_progr
  am.html
• For form to authorize equipment loans
• http//www.bussvc.wisc.edu/acct/propcont/propform.
  html

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No Cost Extensions

• Extension on an award needs to be requested and
  approved prior to the award end date
• Requests need to route from PI through
  department/center, college, and RSP to the
  agency/sponsor
• http//www.cals.wisc.edu/research/forms.html
• FDP awards request must still be routed campus
  has authority to approve first extension

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Reporting, Modifications, etc.

• Communication keep departments/ centers,
  college, and RSP in the loop
• Budget modifications
• Scope of work/project modifications
• Addition/deletion of subcontractors or
  consultants
• Exceptions
• Reports
• Etc.

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RSP Update

• Director RSP William Vance
• Assistant Director Pre-award Diane Barrett
• Assistant Director Post-award Bob Andresen
• Policy Planning Analyst Francine Massey
• Pre-award Team 2 Stephanie Gray, Christy
  Wipperfurth, and vacancy
• Post-award Non federal accountant Jane Braun
  Federal accountants by agency Team transition
  pending
• Material transfer agreements Mark Doremus

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PALS

• RSPs Pre-Award Login System
• Proposals are logged in when received at RSP
• Actions/status information is accessible via
• https//www.rsp.wisc.edu/services/admin/pals/c_slo
  okup.cfm
• Query by PI Name, UDDS, Agency, etc.
• CALS will be a test site
• Departments will be involved through transmittal
  entry which will capture data and allow for
  tracking from department/center issuance to
  college to RSP to agency/sponsor

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Helpful Websites

• CALS Research Division
• http//www.cals.wisc.edu/research
• Research Sponsored Programs
• http//www.rsp.wisc.edu

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Questions???

• How can we help?
• What can we clarify?
• Need us to meet with departments, centers,
  individuals?