Post-Award Issues for the Pre-Award Administrator

1
Post-Award Issues for the Pre-Award Administrator

• Panelists
• Tim Leung
• Senior Research Accountant
• Stanford University
• Craig Johnson
• Compliance Analyst
• University of Washington
• Csilla M. Csaplár
• Contract Grant Officer
• Stanford University

2
Agenda

• Discussion of common issues (and solutions) that
  arise during proposal development and award stage
  that impact post-award
• Terms and conditions to avoid
• Ways to be proactive!
• Building the bridge between pre-award and
  post-award to facilitate effective
  project management

3
Budgets

• Identify Cost Categories
• Unidentified costs
• May require sponsor approval for rebudgeting
• Bottom line Not in the budget? Ask.
• Personnel Costs Proposal vs. Expenditures
• Materials/Supplies vs. Equipment
• Subawards vs. subcontracts
• Correct rates applied

4
Budgets, continued

• Budget projections
• Impacts of poor planning
• Loss of direct cost funding available to the
  project
• Loss of FA/indirect cost recovery
• Disallowances
• Open communication reduces potential for
• Excessive, inappropriate, or late cost transfers
• Manual adjustments
• Disallowances
• Revised invoices/financial reports
• Audit findings
• Loss of expanded authorities or letter of credit
  drawdown eligibility

5
Awards

• Award classification award type, award
  instrument, sponsor type
• Single PI vs. Multiple PIs
• One shared account or separate accounts for each?
• PIs from different departments/divisions
• Access? Controls?
• Budget years vs. cumulative project period
• Separate accounts?
• Is carryforward automatic or is prior approval
  required?

6
Award Notices

• Identify important information that post-award
  will need
• Payment terms or schedule
• Financial reporting requirements and timelines
• PO or award number to be included on invoice
• Restrictions
• Milestones

7
Award Set-up

• Interest earned
• Return to sponsor?
• Use toward the project?
• For use at institutions discretion?
• Tracking
• Reporting
• Interest Income
• Tracked separately from revenue
• Recorded as income, not expense
• Cost sharing

8
Award Set-up, continued

• Period of Performance dates
• Effective date vs. execution date
• Funding authorizations
• Budget periods
• Incremental funding
• Supplemental funding
• Impacts allowability of expenditures
• Rebudgeting
• Institutional policy
• Sponsor policy/prior approval requirements
• Impacts ability to get reimbursed and project
  planning

9
Billing/Invoicing

• Invoicing
• Format and documentation
• Standard or Sponsor-specific?
• Back up documentation required (negotiate!)
• Tied to award type - Cost reimbursement or fixed
  price
• Frequency
• CR in arrears monthly, quarterly, semi-annually,
  annually?
• FP up-front, per milestones reached, at
  completion?
• Combination tied to progress or deliverables?

10
Payment Terms

• Upon execution/initiation
• Fixed schedule of installments
• Milestone payments
• Upon completion/termination
• Withholding of percentage or amount
• Net 30 standard
• Non-standard can impact institutions cash flow
• Advances/refunds

11
Reporting Requirements

• Technical
• Progress/interim
• Final
• Financial
• SF 269 and SF 270 for federal awards
• Sponsor-specific forms for others
• Timeframe for submission at least 60 days
  preferable
• Who is responsible department? Central
  post-award?
• Be timely!
• Timely report submission impacts A/R,
  relationship between central offices
• with responsibility/oversight, and
  PI/institutions reputation with sponsor
• Delinquent reports may cause sponsors to withhold
  funding on all awards
• Your institution may be identified as not
  responsible can impact future competitions

12
Sponsor Approvals

• Rebudgeting
• Carryforward
• Change of PI or level of effort
• Pre-award spending
• Flowdowns additional oversight

13
Compliance Requirements

• Waivers (PI effort, indirect costs)
• Human/animals subjects approvals
• Cost-sharing
• Conflict of Interest
• Impacts level of risk to PI, department, and
  institution

14
Sticky Award Terms

• Publication
• Restrictions
• Impacts restriction on ability to disseminate
  research results
• Export controls
• Acceptance of controlled or proprietary
  technology, items covered by EAR/ITAR
• Impact loss of fundamental research exclusion
• Intellectual property
• Disclosure internally and to sponsor
• Ownership
• Impacts loss of ability to file provisional
  patents, legal battles over inventorship if
  proper disclosures not made
• Legal terms (indemnification, venue, governing
  law, etc.)

15
Closeout

• Meet with PIs before the grant period is over
• Develop a process
• Use checklists to track items of special concern
• (i.e. cost-sharing, unliquidated
  encumbrances,
• final invention statements, etc.)
• Contact your grant accounting team in advance
• Avoid first among equals thinking

16
Terms to Avoid

• Detailed financial reporting and back-up
  documentation
• Payments or reporting in non-U.S. dollars
• Reporting deadlines on end date of award (60 days
  after end date preferred)
• Final invoicing deadline less than 45 days after
  end date
• Monthly interim financial reporting
• Return of all award funds if project is
  terminated early
• Any restrictions on publication
• Others?

17
Be Proactive!

• Training
• PIs Explain the process and your expectations,
  answer questions
• Department administrators Understand their role
  and the relationship with the PI, help facilitate
  the process with both
• Encourage them to take advantage of training
  opportunities
• Acting on behalf of the Institution
• Explain the impacts of a poorly planned budget or
  a rushed proposal
• Remind your team and your departments that you
  have their interests and those of the institution
  in mind
• Get to know your neighborhood
• Meet your customers!
• Know who does what and who can help during a
  crisis
• Be patient and be a resource!

18
Collaborative Solutions

• What Pre-award can do
• Serve as the primary point of contact for the PI,
  department, and sponsor
• Learn about and anticipate the needs of your
  post-award counterparts
• Understand impacts of award terms and conditions
  so you can negotiate the best deal for all the
  players
• Educate your post-award counterpart on project
  specifics
• Communicate often, and keep people apprised of
  your expectations
• Recognize sponsor restrictions and special
  requirements, negotiate to standardize when it
  makes sense and is possible
• Realize restrictions of institutions systems,
  work to accommodate whenever possible

19
Collaborative Solutions

• What Post-award can do
• Understand award terms and conditions, and how to
  adhere to them
• Interact regularly, not just when there are fires
  to be put out
• Ask questions communication is key
• Be flexible! Not all sponsors and awards are
  created equal.

20
Questions?

• Tim Leung
• Senior Research Accountant, Stanford University
• tnleung_at_stanford.edu
• Craig Johnson
• Compliance Analyst, University of Washington
• erfalas_at_u.washington.edu
• Csilla M. Csaplár
• Contract Grant Officer, Stanford University
• csaplar_at_stanford.edu

With thanks to Marti Dunne, New York University,
and Diane Barrett, University of Wisconsin.