Financial Management

Sponsored Research Financial Management:

Current Pre and Post-Award Issues

Sponsored Research Financial Management:

Current Pre and Post-Award Issues

Sponsored Research Financial Management: Current Pre and Post-Award Issues

Moderator/Team Leader:• Jerry Fife

Assistant Vice Chancellor for Research FinanceVanderbilt University

Faculty: • Michelle Fortnam

Associate Director, Internal Audit DepartmentStanford University

• Bob GallowayProfessor of Biomedical EngineeringSchool of EngineeringVanderbilt University

Moderator/Team Leader:• Jerry Fife

Assistant Vice Chancellor for Research FinanceVanderbilt University

Faculty: • Michelle Fortnam

Associate Director, Internal Audit DepartmentStanford University

• Bob GallowayProfessor of Biomedical EngineeringSchool of EngineeringVanderbilt University

Sponsored Research Financial Management: Current Pre and Post Award Issues

Faculty (continued):• F. Edward Herran

Director, Office of Sponsored ProjectsMemorial Sloan-Kettering Cancer Center

• Cynthia WhiteDirector, Research OfficeWashington University at St. Louis

Faculty (continued):• F. Edward Herran

Director, Office of Sponsored ProjectsMemorial Sloan-Kettering Cancer Center

• Cynthia WhiteDirector, Research OfficeWashington University at St. Louis

The Basics of A-21 Cost Allowability

A-21 Standards forCost Allowability

• Reasonable• Allocable• Treated Consistently• These standards apply to both

proposals and active projects. If an unallowable cost is included in a proposal, the cost does not become allowable if it is not removed during the review process

• Reasonable• Allocable• Treated Consistently• These standards apply to both

proposals and active projects. If an unallowable cost is included in a proposal, the cost does not become allowable if it is not removed during the review process

A-21 Standards forCost Allowability (cont’d.)

• All sponsored project awards contain terms and conditions (T&C's), which supersede all other regulations; therefore it is essential that the Research Administrator read, understand and abide by them

Unallowable for Federal Reimbursement

• Expenses that are unallowable for federal reimbursement may be reasonable and necessary business expenses permitted by the University. Departments may incur these expenses but they must code them as unallowable.

AllowabilityAllowability

• For a cost to be allowable, it must conform to:

Terms and conditions of the agreement

A-21 (federal awards) Institutional policy

• For a cost to be allowable, it must conform to:

Terms and conditions of the agreement

A-21 (federal awards) Institutional policy

Allowability (cont’d.)Allowability (cont’d.)

• Some costs may be an appropriate University expense but are not allowable to charge to a sponsored project. For example, fund raising is an appropriate expense for a University, but cannot be charged, either directly or indirectly, to the federal government, according to OMB A-21.

Unallowable Costs can be:Unallowable Costs can be:Unallowableby University

University expenses that are:

• NOT reasonable • NOT necessary • NOT allocable • NOT permitted by

University policy

These expenses will not be paid for by University.

If incurred, they must be paid for by the individual.

Unallowablefor reimbursement by Federal

Government

University expenses that are:• Reasonable • Necessary • Allocable • Permitted by University

policy

but are unallowable for federal reimbursement.

These expenses:• can be paid for by• must be coded as

unallowable

Unallowableby Sponsor

Expenses that do not conform to the sponsors terms and conditions and OMB Circular A-21 (if applicable), or are:

• NOT reasonable • NOT necessary • NOT allocable

These expenses will not be paid for by the sponsor.

University may pay for the expenses, code as appropriate.

AllowabilityAllowability

Section J of OMB A-21 lists examples of allowable and unallowable costs

Some unallowable expenses include:

Section J of OMB A-21 lists examples of allowable and unallowable costs

Some unallowable expenses include:

Alcoholic beverages Alumni activities Commencement Entertainment (incl. Non-business meals)

Fines and penalties Goods for personal use Social membershipsFund raising

ReasonableReasonable

A cost must be reasonable in order to charge it to a sponsored project. Reasonableness is defined as that which reflects the action of a prudent person. The three questions a person must ask to determine reasonableness of cost are: Is it necessary for performance of the award? Does it advance the scope of work? Is it consistent with established institutional

policies and practices?

A cost must be reasonable in order to charge it to a sponsored project. Reasonableness is defined as that which reflects the action of a prudent person. The three questions a person must ask to determine reasonableness of cost are: Is it necessary for performance of the award? Does it advance the scope of work? Is it consistent with established institutional

policies and practices?

AllocableAllocable

• Allocation is the process of assigning a cost, or a group of costs, to one or more cost objectives.

• Costs may be allocated only if they advance the work of the project.

• The cost must be assigned to the project in proportion to the benefit that the project will receive.

• Fund availability should not be used to determine allocability.

• Allocation is the process of assigning a cost, or a group of costs, to one or more cost objectives.

• Costs may be allocated only if they advance the work of the project.

• The cost must be assigned to the project in proportion to the benefit that the project will receive.

• Fund availability should not be used to determine allocability.

ConsistentConsistent

• Requires Costs Incurred for the Same Purpose, In Like Circumstances, to be Handled Consistently as Direct or Indirect Costs

Consistent (cont’d.)Consistent (cont’d.)

• Particularly applicable to costs identified in section F.6.b of A-21 (clerical and administrative salaries, office supplies, postage, memberships and local phone service.

A-21 Section F.6.bA-21 Section F.6.b

• Identifies costs that are normally treated as indirectClerical and administrative salariesOffice suppliesPostageLocal phone serviceMemberships

Possible Exceptions to Section F.6.b

• Costs that are normally treated as indirect can be treated as direct under exceptional circumstances.

• Must meet all three of the criteria:Major Project (Project with needs beyond

that normally provided by department)Specifically IdentifiedExplicitly Budgeted

• Costs that are normally treated as indirect can be treated as direct under exceptional circumstances.

• Must meet all three of the criteria:Major Project (Project with needs beyond

that normally provided by department)Specifically IdentifiedExplicitly Budgeted

Specific Identification?Specific Identification?

Criteria for charging an administrative expense directly to a major project

Cost must be specifically tied to

a particular sponsored project

Cost must be specifically tied to

a particular sponsored project

Specific Identification?Specific Identification?

Must be able to show how the project benefited from the expense using:•Documentation•Or a system

Administrative Charging (Direct)Administrative Charging (Direct)

When all three criteria are met:

The expense can be charged directly to the project

This does not necessarily provide approval to charge any other administrative costs to the project.

In addition, the cost must meet the allowability criteria

When all three criteria are met:

The expense can be charged directly to the project

This does not necessarily provide approval to charge any other administrative costs to the project.

In addition, the cost must meet the allowability criteria

Major ProjectMajor Project

• Requires an extensive amount of clerical or administrative support

• Requires effort that is significantly more than is normally provided by the department/unit

• Requires an extensive amount of clerical or administrative support

• Requires effort that is significantly more than is normally provided by the department/unit

Examples of Possible Major ProjectsExamples of Possible Major Projects

• Large Complex Projects - Center grants, program project grants

• Projects requiring: extensive data accumulation, analysis, reporting, surveying or tabulation

• Projects requiring extensive amounts of travel and meeting arrangements

• Large Complex Projects - Center grants, program project grants

• Projects requiring: extensive data accumulation, analysis, reporting, surveying or tabulation

• Projects requiring extensive amounts of travel and meeting arrangements

Examples of Major ProjectsExamples of Major Projects

• Projects where the principal focus is preparation and production of manuals, large reports, books, monographs

• Projects that are geographically inaccessible to normal departmental administrative services

• Projects requiring specific database management, manuscript preparation, human or animal Protocols or multiple project-related investigator coordination

• Projects where the principal focus is preparation and production of manuals, large reports, books, monographs

• Projects that are geographically inaccessible to normal departmental administrative services

• Projects requiring specific database management, manuscript preparation, human or animal Protocols or multiple project-related investigator coordination

Salaries and WagesSalaries and Wages

Institutional Base Salary (IBS)Institutional Base Salary (IBS)

• Must conform to university policies, consistently applied (A-21)

• Must be paid from the applicant organization and may not be increased as a result of obtaining grant funds (A-21 and NIH Grants Policy Statement)

• Must conform to university policies, consistently applied (A-21)

• Must be paid from the applicant organization and may not be increased as a result of obtaining grant funds (A-21 and NIH Grants Policy Statement)

Current Framework• Paid by the applicant organization• May not be increased as a result of

receiving grant funds• Clinical practice compensation is

considered part of IBS if guaranteed by the university, shown on the appt. form and paid through the university and included in the university’s effort reporting system

Current Framework• Paid by the applicant organization• May not be increased as a result of

receiving grant funds• Clinical practice compensation is

considered part of IBS if guaranteed by the university, shown on the appt. form and paid through the university and included in the university’s effort reporting system

AAMC/COGR Proposal• Institutions with affiliated practice

plans may include salary and effort as part of charges to NIH grants

• Affiliated is defined as those instances where the institution pays or directs the salary decisions for those included in the practice plan.

AAMC/COGR Proposal• Institutions with affiliated practice

plans may include salary and effort as part of charges to NIH grants

• Affiliated is defined as those instances where the institution pays or directs the salary decisions for those included in the practice plan.

• How about VA appointments?• More on this during our effort

reporting discussion

• How about VA appointments?• More on this during our effort

reporting discussion

Salary and Wage IssuesSalary and Wage Issues

• Salary increases• Supplemental Compensation or

Overloads Additional compensation provided

over and above the IBS

• Bonuses

• Salary increases• Supplemental Compensation or

Overloads Additional compensation provided

over and above the IBS

• Bonuses

Salary IncreasesSalary Increases

• Pending promotionOk to include if assured

• How should they be applied?Must be fund source neutralMust be applied consistently

• Pending promotionOk to include if assured

• How should they be applied?Must be fund source neutralMust be applied consistently

Supplemental Compensation or Overloads

A-21 indicates that faculty undertake research as a part of their normal responsibilities; however, it does recognize there are exceptions if:

• The duties are across departmental lines • Involves a separate or remote operation, and

work performed is in addition to regular departmental load and,

• The charges are approved in writing by the sponsoring agency

A-21 indicates that faculty undertake research as a part of their normal responsibilities; however, it does recognize there are exceptions if:

• The duties are across departmental lines • Involves a separate or remote operation, and

work performed is in addition to regular departmental load and,

• The charges are approved in writing by the sponsoring agency

Salary OverloadsSalary Overloads

• Does disclosing an overload in the proposal constitute approval?

BonusesBonuses

Depends on the circumstances – No clear guidance

• What do you think about?Bonuses in lieu of salary increasesBonuses based upon market

competitionBonuses based upon achievement of

departmental goalsBonuses based on financial success

Depends on the circumstances – No clear guidance

• What do you think about?Bonuses in lieu of salary increasesBonuses based upon market

competitionBonuses based upon achievement of

departmental goalsBonuses based on financial success

Fringe BenefitsFringe Benefits

Some typical fringe benefitcomponents:

• FICA• Retirement• Health Care• Life Insurance• Disability• Worker’s Compensation• Unemployment Insurance

Some typical fringe benefitcomponents:

• FICA• Retirement• Health Care• Life Insurance• Disability• Worker’s Compensation• Unemployment Insurance

Fringe BenefitsFringe Benefits

Two methods for budgeting and charging:

• Using an estimated rate for budgeting and then charging actual

• Developing, negotiating and charging rates

Accomplished by pooling fringe benefit costs and then comparing to salaries and wages.

Two methods for budgeting and charging:

• Using an estimated rate for budgeting and then charging actual

• Developing, negotiating and charging rates

Accomplished by pooling fringe benefit costs and then comparing to salaries and wages.

SuppliesSupplies

Two Types• Laboratory (chemicals, gases)• Office (printer paper, sharpies, post it

notes)

Two Types• Laboratory (chemicals, gases)• Office (printer paper, sharpies, post it

notes)

SuppliesSupplies

What does A-21 say about officesupplies?

“In developing the departmental administration cost pool, special care should be exercised to ensure that costs incurred for the same purpose in like circumstances are treated consistently as either direct or F&A costs.”

What does A-21 say about officesupplies?

“In developing the departmental administration cost pool, special care should be exercised to ensure that costs incurred for the same purpose in like circumstances are treated consistently as either direct or F&A costs.”

SuppliesSupplies

So does A-21 say anything else on thistopic?

“Items such as office supplies, postage, local telephone costs, and memberships shall normally be treated as F&A costs.”

So does A-21 say anything else on thistopic?

“Items such as office supplies, postage, local telephone costs, and memberships shall normally be treated as F&A costs.”

SuppliesSupplies

Does this mean that office supplies used in a laboratory must meet the major project definition to be direct charged or does the type of usage make the determination?

EquipmentEquipment

• What is equipment?• Split funding• Fabricated equipment• Service agreements• Lease/purchase analysis• Already available but underutilized

What is Equipment?What is Equipment?

A-110 Definition • Nonexpendable tangible personal

property having a useful life of more than one year and an acquisition cost of $5,000 or more per year

• Institutions can set a lower amount consistent with institutional policy

• Remember this when dealing with other universities

A-110 Definition • Nonexpendable tangible personal

property having a useful life of more than one year and an acquisition cost of $5,000 or more per year

• Institutions can set a lower amount consistent with institutional policy

• Remember this when dealing with other universities

Equipment (Split Funding)Equipment (Split Funding)

Basis for split funding• Equipment benefits more than one

project• Cost sharing

Can non-federal amount be depreciated in your F&A rate?

Basis for split funding• Equipment benefits more than one

project• Cost sharing

Can non-federal amount be depreciated in your F&A rate?

Fabricated EquipmentFabricated Equipment

What is your institutional policy?• Implications of proper budgeting

and chargingProper classifications of costs (CAS

501)F&A budgeted and charged correctly

What is your institutional policy?• Implications of proper budgeting

and chargingProper classifications of costs (CAS

501)F&A budgeted and charged correctly

Service AgreementsService Agreements

• Direct or F&A cost?• Split funding• What if the equipment was not

purchased from the project?

• Direct or F&A cost?• Split funding• What if the equipment was not

purchased from the project?

Lease/Purchase Analysis Lease/Purchase Analysis

A-110• “Where appropriate, an analysis is

made of lease and purchase alternatives to determine which would be the most economical and practical procurement for the Federal Government.”

• What is your institutions policy?• When is this addressed?

A-110• “Where appropriate, an analysis is

made of lease and purchase alternatives to determine which would be the most economical and practical procurement for the Federal Government.”

• What is your institutions policy?• When is this addressed?

Already Available but UnderutilizedAlready Available but Underutilized

A-110 says procurement standards should avoid the purchase of unnecessary items• Is underutilized equipment covered in this

statement?• How do institutions determine what is

available and underutilized?• When is this determined?

During proposal processingBefore purchase

A-110 says procurement standards should avoid the purchase of unnecessary items• Is underutilized equipment covered in this

statement?• How do institutions determine what is

available and underutilized?• When is this determined?

During proposal processingBefore purchase

Subcontract, Consultant or Vendor?

Subcontract or Sub awardSubcontract or Sub award

Distinguishing Characteristics:

• Performs substantive programmatic work under a grant or contract

• Bears responsibility for programmatic decision making and measurable performance requirements

• Must adhere to Federal compliance requirements if the source is a Federal award

• Retains intellectual property rights if a university

Distinguishing Characteristics:

• Performs substantive programmatic work under a grant or contract

• Bears responsibility for programmatic decision making and measurable performance requirements

• Must adhere to Federal compliance requirements if the source is a Federal award

• Retains intellectual property rights if a university

VendorVendor

• The procurement of goods or services from an organization which provides the goods and services to many different purchasers as part of its normal business operations within a competitive environment

• Not subject to the same compliance requirements as a subcontractor (if the source is a Federal award)

• The procurement of goods or services from an organization which provides the goods and services to many different purchasers as part of its normal business operations within a competitive environment

• Not subject to the same compliance requirements as a subcontractor (if the source is a Federal award)

ConsultantConsultant

An individual with the followingcharacteristics:

• Not an employee of your institution• Proven professional or technical competence

and provides this to your organization• Is not controlled with regard to the manner of

performance or the result of the service• Considered a work for hire and does not retain

any rights to the end product

An individual with the followingcharacteristics:

• Not an employee of your institution• Proven professional or technical competence

and provides this to your organization• Is not controlled with regard to the manner of

performance or the result of the service• Considered a work for hire and does not retain

any rights to the end product

Subcontract, Consultant or Vendor?Subcontract, Consultant or Vendor?

Given the definitions, whatactions are taken to ensure the

proper mechanism is used?

Given the definitions, whatactions are taken to ensure the

proper mechanism is used?

SubcontractsSubcontracts

Actions to be taken• Incorporating into the primes proposal• Cost analysis (rates)• Competition• Monitoring (technical, fiscal)• Billing (approvals)• Recognizing the culture of the

subcontractor

Actions to be taken• Incorporating into the primes proposal• Cost analysis (rates)• Competition• Monitoring (technical, fiscal)• Billing (approvals)• Recognizing the culture of the

subcontractor

Other Costs Other Costs

Participant Support CostsParticipant Support Costs

Costs paid on or behalf of participantsin connection with conferences,meetings, symposia, training activitiesand workshops. Includes:

• Transportation costs• Registration fees• Per diem • Stipends• Other related costs

Costs paid on or behalf of participantsin connection with conferences,meetings, symposia, training activitiesand workshops. Includes:

• Transportation costs• Registration fees• Per diem • Stipends• Other related costs

Participant Support CostsParticipant Support Costs

Participant characteristics:• Not employees of the grantee• Generally not a federal employee

although there are exceptions if there is no duplication of funding

Participant support costs are generally not subject to F&A costs

Participant characteristics:• Not employees of the grantee• Generally not a federal employee

although there are exceptions if there is no duplication of funding

Participant support costs are generally not subject to F&A costs

Other CostsOther Costs

What other costs should we discuss?• F&A costs

WaiversAs cost sharingOn-campus vs. off campus

• Travel• Others?

What other costs should we discuss?• F&A costs

WaiversAs cost sharingOn-campus vs. off campus

• Travel• Others?

How about budgeting and modular grants?

Procurement CardsProcurement Cards

Different Models•Which expenses?•Who gets one?•Dollar Limits•Benefits vs. risks

Effort ReportingEffort Reporting

Recent Government ActivitiesRecent Government Activities

Whistleblower Suits • Northwestern University - $5.5

million• Johns Hopkins University – $2.6

million

Whistleblower Suits • Northwestern University - $5.5

million• Johns Hopkins University – $2.6

million

DHHS Office of Inspector General• Review to determine extent that A-133

audits assess and document compliance with time and effort reporting requirements

• Pilot audits focusing on the relationship between effort proposed and effort charged

DHHS Office of Inspector General• Review to determine extent that A-133

audits assess and document compliance with time and effort reporting requirements

• Pilot audits focusing on the relationship between effort proposed and effort charged

Other Planned DHHS Pilot AuditsOther Planned

DHHS Pilot Audits• Cost Transfers – Were they made in

accordance with federal regulations and were they justified?

• Cost Sharing and Matching – Were the amounts committed provided?

• Subrecipient Monitoring – Were appropriate procedures in place to monitor their expenditures and were site visits made?

• Cost Transfers – Were they made in accordance with federal regulations and were they justified?

• Cost Sharing and Matching – Were the amounts committed provided?

• Subrecipient Monitoring – Were appropriate procedures in place to monitor their expenditures and were site visits made?

Recent Government Activities

DHHS Office of Inspector General–Fall 2003

• Sought recommendations for developing Compliance Program Guidance (CPG) for recipients of NIH grants to prevent fraud and abuse

• Identified effort reporting as a risk area and sought suggestions

DHHS Office of Inspector General–Fall 2003

• Sought recommendations for developing Compliance Program Guidance (CPG) for recipients of NIH grants to prevent fraud and abuse

• Identified effort reporting as a risk area and sought suggestions

National Institutes of Health (NIH) has issuedan effort reporting “clarification” in itsGrants Policy Statement as follows:

“Clinical compensation may be considered in the institutional base salary as long as all criteria are met: 1) clinical practice compensation must be guaranteed by the university, 2) clinical practice compensation must be reported on the university’s appointment form and paid by the university, and 3) clinical practice effort must be included and accounted for in the university’s effort reporting .”

National Institutes of Health (NIH) has issuedan effort reporting “clarification” in itsGrants Policy Statement as follows:

“Clinical compensation may be considered in the institutional base salary as long as all criteria are met: 1) clinical practice compensation must be guaranteed by the university, 2) clinical practice compensation must be reported on the university’s appointment form and paid by the university, and 3) clinical practice effort must be included and accounted for in the university’s effort reporting .”

What Are the Issues Behind the Recent Problems?

• The basis for calculating effort• The basis for calculating institutional

base salary (IBS)• Faculty understanding of effort

reporting• How are effort and compensation

estimated, tracked and reconciled?• Are all institutional effort and

compensation systems aligned?

• The basis for calculating effort• The basis for calculating institutional

base salary (IBS)• Faculty understanding of effort

reporting• How are effort and compensation

estimated, tracked and reconciled?• Are all institutional effort and

compensation systems aligned?

What Are the Issues Behind the Recent Problems?

• Pre and post award processes are uncoordinated

• Lack of effective training • Unclear and/or undocumented definition

of full time appointment• Appointment letters/annual letters

vague or unclear on effort commitments

• Pre and post award processes are uncoordinated

• Lack of effective training • Unclear and/or undocumented definition

of full time appointment• Appointment letters/annual letters

vague or unclear on effort commitments

Other Potential Risk AreasOther Potential Risk Areas

• VA Appointments• Supplemental Compensation• Using different IBS for grant budgets vs.

payroll allocation and grant charges• Investigators with greater than 5

awards• Investigators with K awards

• VA Appointments• Supplemental Compensation• Using different IBS for grant budgets vs.

payroll allocation and grant charges• Investigators with greater than 5

awards• Investigators with K awards

An Example An Example

Dr. Jones Works 70 Hours/Week in the Following Fashion:• 35 Hrs. on NIH Grants• 21 Hrs. in Patient Care Activities• 10 Hrs. on Teaching Activities• 4 Hrs. on Dept./Institutional

Activities

Dr. Jones Works 70 Hours/Week in the Following Fashion:• 35 Hrs. on NIH Grants• 21 Hrs. in Patient Care Activities• 10 Hrs. on Teaching Activities• 4 Hrs. on Dept./Institutional

Activities

Correct Allocation on Personnel Action Form

• NIH/federal grants50%

• Cost of practice 30%• Unrestricted 20%

• NIH/federal grants50%

• Cost of practice 30%• Unrestricted 20%

The Myth of the 40 Hour WeekThe Myth of the 40 Hour Week

Some assume that faculty are onlyresponsible for reporting 40 hours/week andthus could erroneously report effort asfollows:

NIH/federal grants 88%Unrestricted/cost of practice 12%

* Assumes research comes first

Some assume that faculty are onlyresponsible for reporting 40 hours/week andthus could erroneously report effort asfollows:

NIH/federal grants 88%Unrestricted/cost of practice 12%

* Assumes research comes first

What can be done tomitigate risk?

Test to determine if there are problems for:

• Review appointment letters for clarity• Who signs• Faculty with VA appointments• Faculty with >5 awards • Faculty with K awards• Train, train, train

Test to determine if there are problems for:

• Review appointment letters for clarity• Who signs• Faculty with VA appointments• Faculty with >5 awards • Faculty with K awards• Train, train, train

How Much Money Do I Have Left?

How Much Money Do I Have Left? How Much Money Do I Have Left?

Faculty needs/desires• Budgetary flexibility• The ability to know how much money

is available• Encumbrance system for salaries• Real time encumbrance system for

other purchases

Faculty needs/desires• Budgetary flexibility• The ability to know how much money

is available• Encumbrance system for salaries• Real time encumbrance system for

other purchases

How Much Money Do I Have Left?How Much Money Do I Have Left?

Given these needs/desires, howcan research administrators helpin the areas of:

• Budgetary flexibility• Balance systems to facilitate vs.

control• Building a departmental system vs.

relying on the general ledger to do it all

Given these needs/desires, howcan research administrators helpin the areas of:

• Budgetary flexibility• Balance systems to facilitate vs.

control• Building a departmental system vs.

relying on the general ledger to do it all

Financial Management

university university

unallowable expenses

unallowable costs

major project project

major project cost

appropriate university

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particular sponsored

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