Title: DS2 - Faculty Preparation
1DS2 - Faculty Preparation
- Overview of UGA Policies and Procedures in
complying with OMB Circular A-21
2DS2 - General Information
- Disclosure Web Site
- www.busfin.uga.edu/disclosure
- All Policies and Procedures related to the
University Disclosure Statement may be found
under the Disclosure Policies and Disclosure
Procedure links - Policies are effective January 1, 2006
- Substantial Changes must be approved by our
Cognizant Federal Agency
3DS2 - Meeting Agenda
- What is a DS2?
- How was the UGA DS2 developed?
- Policy and Procedures - overview
- Additional References
- Conclusion
- Questions
4What is a DS2?
- Documents and discloses University cost
accounting practices - Required to be submitted to cognizant agency and
cognizant audit agency. - Policies and procedures, instructions, and
guidelines for individual investigators,
department heads, and administrators need to be
made available because it is their responsibility
to understand and know them. - Provides Guidelines for charging costs to
sponsored awards - Defines University direct costing policies and
procedures - Cost-sharing policies
- Time and effort reporting policies and procedures
- Policies on Service Centers
5DS2 How was it Developed
- Three working group committees were formed
comprised of College and Departmental Business
Managers and Faculty representatives - Steering Committee comprised of
Associate/Assistant Deans, Department Head, and
Center Director representatives
6DS2 - Policies
- New Policies
- Cost Transfer
- Program Income
- Service Center
- Existing Policies Revised
- Cost Share
- Direct Cost
- Personnel Activity Report
7DS2 New PoliciesCost Transfers
- Cost Transfer movement of expense(s) between
two different university account numbers - Charges should be moved within 90 days of initial
charge - Charges moved after 90 days require PI signature
- All transfers must have adequate
explanation/justification - No transfers allowed to a restricted account if
expense is more than a year old
8DS2 New PoliciesCost Transfers
- Appropriate Justification Includes
- When the error, or need for a transfer was
discovered - What the charge was for
- Why the charge was identified with a different
project originally - How the charge relates to the project that it is
being transferred to
9DS2 New PoliciesCost Transfers
- Conditions for not Allowing Cost Transfers
- No benefit to the project can be demonstrated
- Cost overruns are being transferred to an account
with budget available - Charges are being parked on one account with
the intention of being moved to another
10DS2 New PoliciesProgram Income
- Program Income is gross income earned by the
recipient that is directly generated by a
supported activity or earned as a result of the
award. - Principal Investigator must
- Identify potential sources at proposal stage,
note on transmittal and application - Plan for use, prepare budget for program income
accounts - Verify program income on reports
- Address account balance issues at project
termination
11DS2 New PoliciesProgram Income
- Federal Sponsors
- Use program income funds before sponsor funds.
- If funds remain in the project or program income
account after the project has terminated,
balances will revert to sponsor. - If the PI wishes to retain these funds, he or she
must write a letter to the sponsor requesting to
use these funds, and outlining a plan for their
use. - Letter must be sent to OSP for endorsement and
forwarding to the sponsors for approval. - Non-Federal Sponsors
- In many cases, the sponsor does not have an
established program income policy. If the sponsor
is silent on this issue, the income is not
reportable and is handled as a departmental sale
or recharge activity.
12DS2 Existing Policies-RevisedCost Share
- The policy of the University of Georgia is to
limit its cost sharing on externally funded
projects to the amount specifically mandated in
the application guidelines of the sponsor. - The University of Georgia will support committed
cost share that is either voluntary or mandatory
by the sponsor when
13DS2 Existing Policies-RevisedCost Share
- All cost shared amounts are specified on the
Office of Sponsored Programs Transmittal Form,
and - Each cost shared amount is approved on the OSP
Transmittal Form by the relevant dean, director,
or department head. Approval signatures are
binding and indicate a willingness to provide
cost share resources in support of the proposed
project.
14DS2 Existing Policies-RevisedCost Share
- Example of committed cost sharing and how it
should be tracked - PI stated in proposal narrative that they would
spend 10 of their time on project. PIs monthly
academic salary is 7,000.
Cost Share Not Tracked Cost Share Not Tracked Cost Share Not Tracked Cost Share Tracked Cost Share Tracked Cost Share Tracked
(PAR not issued) (PAR not issued) (PAR not issued) (PAR required) (PAR required) (PAR required)
Type of Account Percent Effort Salary Percent Effort Salary
Instruction (1011GH) - state Instruction (1011GH) - state 25 1,750 25 1,750
Dept. research (1025GR) - state Dept. research (1025GR) - state 75 5,250 65 4,550
Cost Share (1021CR) - state Cost Share (1021CR) - state 10 700
100 7,000 100 7,000
15DS2 Existing Policies-RevisedCost Share
- Alternative
- PI stated in proposal narrative that they would
spend 10 of their time on project and asks
sponsor to fund this effort. PIs monthly
academic salary is 7,000.
PAR not issued PAR not issued PAR not issued PAR required PAR required PAR required
Type of Account Percent Effort Salary Percent Effort Salary
Instruction (1011GH) - state Instruction (1011GH) - state 25 1,750 25 1,750
Dept. research (1025GR) - state Dept. research (1025GR) - state 75 5,250 65 4,550
Sponsored research (1021RR) - grant Sponsored research (1021RR) - grant 10 700
100 7,000 100 7,000
16DS2 Existing Policies-RevisedCost Share
- Cautionary Notes
- Cost share commitments can be stated in several
places within a proposal. - When faculty time is contributed as cost share in
support of a project, it is expected that
budgeted research time be utilized for cost share
before instructional time is considered. Whenever
cost share involves instructional time, the
faculty member's department head and/or dean must
be notified so that approval can be obtained. - In all instances where cost sharing is described,
the institution is committed to account for these
expenditures. The budgetary unit of record is
responsible for documenting and tracking all
commitments made on a project, whether made by
that department or not, unless subaccounts are
established so that the responsibility can flow
down to other units.
17DS2 Existing Policies-RevisedCost Share
- Principal Investigator
- Carefully consider cost share before including in
proposal - Identify source of cost share funds and ensure
they are not federal (unless authorized by
statute) - Monitor budget and expenditures on cost share
account - Ensure accuracy of cost sharing/matching
18DS2 Existing Policies-RevisedDirect Cost Policy
- Major Changes
- More specific in order to address consistency
- Determination factors defined Allowable,
Allocable, Reasonable - Determination Strategy
- Treatment of direct and facilities and
administrative (indirect) costs - Unallowable Costs
19DS2 Existing Policies-RevisedDirect Cost Policy
- Principal Investigator
- Development of proposal budget, and financial
management of project, consistent with UGAs
Direct Cost Policy Procedures - Allocation of costs to benefiting projects
- Review of project budgets and actual costs to
ensure timely correction of any errors
20DS2 Existing Policies-RevisedDirect Cost Policy
- Examples of Problematic Costs
- Administrative and Clerical Costs
- Cell phones
- Routine Postage
- Individual Professional Memberships
- General Office Supplies and Equipment
- Printer Toner, Copy Paper
- Computers (unless scientifically justified)
- PDAs/Blackberries
- Submission of technical/final reports
21DS2 Existing Policies-RevisedDirect Cost Policy
- Example of appropriate use of different funds
- 1011GH Instruction salaries materials
- 1025GR Dept. or general research salaries
materials - 1011GJ Dept. admin. salaries, general office
supplies, paper, basic telephone, routine
postage, computers - 102xAR Same as GJ, but another funding source
or use to supplement research costs - 1021RR Organized research salaries materials
-- charges that directly benefit aim of project
22DS2 Existing Policies-RevisedDirect Cost Policy
- Major Projects and Exceptions
- - Modular Grants rarely qualify for major project
status. - - To qualify for a Major Project you must apply -
- Large , complex programs, such as general
clinical research centers, primate centers,
program projects, and projects requiring managing
teams of investigators from other institutions. - Projects which involve extensive data
accumulation, analysis and entry, surveying,
tabulation cataloging, searching literature, and
reporting, such as epidemiological studies,
clinical trials, and retrospective clinical
records studies. - Projects that require making travel and meeting
arrangements for large numbers of participants,
e.g. conferences or seminars.
23DS2 Existing Policies-RevisedDirect Cost Policy
- Major Projects and Exceptions (Continued)
- Projects where the principal focus is the
preparation and production of manuals and large
reports, books and monographs - Projects that are geographically inaccessible to
normal departmental administrative services, such
as seagoing research vessels, radio astronomy
projects, and other research field sites that are
remote from the campus - Individual projects requiring project-specific
database management individualized graphics or
manuscript presentation human or animal
protocol IRB or multi-faceted coordination. - Extraordinary and extensive administrative
support, significantly greater than the routine
level provided by academic department staff may
be budgeted and charged to sponsored projects
including research data gathering, computer
programming, research training,developing
materials for presentations, etc...
24DS2 Existing Policies-Revised Personnel
Activity Reports (PARs)
- OMB Circular A-21 (Section J.10) contains
requirements for procedures and documentation to
support the distribution of salaries and wages
charged directly to an award or through
Facilities and Administrative (indirect)
activities. - The employees salary must follow consistently
applied institutional policies regarding
compensation and be allocated through an official
payroll system that ties with the financial
records of the institution.
25DS2 Existing Policies-Revised Personnel
Activity Reports (PARs)
- The payroll distribution must reasonably reflect
the activity for which the employee is
compensated. - The method must recognize the principle of
after-the-fact confirmation so that costs
distributed represent actual costs. - The main objective of A-21 is verification that
compensation charged is appropriate to the
activity performed.
26DS2 Existing Policies-Revised Personnel
Activity Reports (PARs)
- Our verification method is in the form of
Personnel Activity Reports (PARs). - PARs are used to confirm that the distribution of
activity represents a reasonable estimate of the
work performed by the employee during the period. - University wide, only 5 of PARs are adjusted.
For the majority of employees, the review and
certification of a PAR is not a burdensome task.
27Personnel Activity Reports (PARs)Who receives a
PAR?
- In any of the following situations an employee
will receive a PAR - 1. A portion of their salary charged directly
to restricted accounts or cost sharing accounts. - 2. A portion of their salary charged to a major
function and an indirect cost activity. - 3. A portion of their salary charged to more
than one indirect cost activity. -
28Personnel Activity Reports (PARs) How do I
verify and submit a PAR?
- A PAR will be generated for each pay period for
which an employee is paid. - To confirm that the distribution of activity
represents a reasonable estimate of the work
performed by the employee during the period, each
PAR must be reviewed for accuracy and approved by
the employee or by a responsible official having
first-hand knowledge of the work performed.
29Personnel Activity Reports (PARs)How do I verify
and submit an e-PAR?
- When PARs are generated, an email notification
will be sent to employees registered email
address and to their home departmental
administrator. - The electronic PAR system can be accessed at
https//webapps.ais.uga.edu/PCTE/ - You will log on to the electronic PAR system
using your MyID and password.
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31Personnel Activity Reports (PARs)How do I verify
and submit an e-PAR?
- If the PAR reflects accurately the time expended
on a project tracked by a University account
number, you will check the Check here to return
this PAR without any changes check box. - Next, you will click the Save and Submit button
to transmit the approved document to the
Accounting Department.
32Personnel Activity Reports (PARs)How do I verify
and submit an e-PAR?
- In those situations where the current
distribution does not reflect the time actually
expended on a project for the period covered by
the PAR, your department administrator should be
notified of the necessary changes. - Your department administrator will be able to
enter the changes and submit the revised PAR to
the Accounting Department.
33DS2 New Policies Service Centers
- A departmental sales unit established for the
purpose of providing goods and services to
university departments, and only incidentally to
customers outside the university. - Service centers offer goods and services that are
unique, benefit the effectiveness of the
University when conveniently available, may
require special controls, are subject to federal
and/or state regulations, or are not readily
available from external sources. - Service Centers that generate revenues greater
than 100,000 per year need to prepare business
plan.
34DS2 New Policies Service Centers Billing Rates
- Departments are responsible for the development
and review of Service Center billing rates. - The billing rate should be calculated to break
even at the end of a fiscal year (accounting
period). - The billing rate should only include costs to be
recovered (no profit margins). - The same billing rate must be used to charge all
UGA accounts (internal customers).
35DS2 - Policy Summary
- Effective January 1, 2006
- Cost Transfers (JVs)
- Must be performed within 90 days of charge.
Otherwise will require PI signature - Must have adequate explanation/justification
- No transfers to a restricted account more than a
year old - Program Income
- Used before sponsored funds or must have approved
authorization - Must have approval from sponsor for UGA to retain
any funds - Cost-Share
- Try to limit and specify on Sponsored Program
Transmittal Form
36DS2 - Policy Summary
- Direct Cost
- Can not routinely charge cell phones, routine
postage, membership dues, general office supplies
and equipment to sponsored awards (exceptions may
be granted by justification through Sponsored
Programs. General Federal Funded Research
projects seldom qualify for such an exception) - PARs
- Electronic PARs will be implemented by July 1,
2006 - Everyone will be able to certify with no changes
- Departmental administrators will be only ones
that can make changes - Service Centers
- Departments must develop billing rates
- Must break-even (no profit)
- Must charge same rate to all UGA customers
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38DS2 Additional Training
- Faculty Preparation Course will be offered at
Training and Development on an ongoing basis. - Business Manager, Departmental Administrators and
Office Manager training will be offered either on
request and/or at Training and Development (Six
Courses lasting approx. two hours per course).
39DS2-Faculty Presentation