Task Force on Federal Grant and Contract Compliance: Implementation Activities Dr. Jack Finney and Dr. Bill Knocke.

Task Force on Federal Grant and Contract Compliance: Implementation ActivitiesDr. Jack Finney and Dr. Bill Knocke

Task Force on Federal Grant and Contract Compliance: Implementation ActivitiesDr. Jack Finney and Dr. Bill Knocke

Office of the Vice President for Research

Violations of Basic PrincipleViolations of Basic Principle

• Recipients of Federal grants are allowed to charge to the grant only “allocable” costs, which are the costs directly related to the objectives of that project.

Office of the Vice President for Research

Two Types of MischargesTwo Types of Mischarges1. Improper charges or expense transfers to

a grant • End-of-project expense transfers in order to

spend down the funds before grant expiration; expenses not “allocable” to specific project

2. Salary charges not related to actual time and effort • 100% salary charged to project during

summer but also carrying out other university responsibilities during period of charges

Office of the Vice President for Research

What are the potential problem areas for VT?

What are the potential problem areas for VT?

• Inappropriate charges to grants • OSP and departments/colleges monitor and

restrict use of grant funds for administrative and clerical expenses, office supplies, etc.

• Careful attention to expense transfers and “allocability” to a specific grant needs to be carefully monitored, particularly if overspending on a project occurs

Office of the Vice President for Research

Potential Faculty Salary Problem Areas at VTPotential Faculty Salary Problem Areas at VT

• Faculty salary charges• Faculty often engaged in university or professional work

while salary is charged solely to a research grant/contract• This is a particular concern for AY faculty in the summer and special

research faculty year round

• Inappropriate time/effort charges to grants:• New proposal preparation• Professional conferences unrelated to project• Committee meetings • Teaching or preparing for AY classes• Working with graduate students on other projects• Vacation if on summer pay• Consulting

Office of the Vice President for Research

Highest RiskHighest Risk• Academic year faculty with 100% of summer

salary on grants (or another percentage that does not match the effort on the grant)

• Special research faculty (Research Asst., Assoc., Full Professors; Postdocs, Research scientists, Research associates) who are supported 100% on grants

• Engaged in writing new proposals?

• Overseeing work of graduate students on other projects?

Office of the Vice President for Research

Alternatives for AY Faculty Summer Funding ConcernsAlternatives for AY Faculty Summer Funding Concerns

• Revision of Policy 6200 (Research extended appointments - applies only to AY faculty)• Salary charges throughout the year, not just

concentrated in summer. Salary savings during AY cover summer charges to departmental budget

• Modified Policy 6200 is more “user friendly” in terms of initiation dates for appointment ( must be approved two weeks prior to effective date; extended by increments of a full month)

• Faculty on research extended appointments earn annual leave at rate of 2 days per month (granted five days at beginning of appointment if occurs after January 10th)

Office of the Vice President for Research

AY Faculty Summer Research on WagesAY Faculty Summer Research on Wages

• Ways of approaching compliance:• If less than 3 months of summer funding on research

grants then spread out salary payments to grants over summer period (when projects are in force) so less than 100% time is charged to research grants/contracts during any one pay period

• Charge some salary to projects during AY when working on those projects; then, apply salary savings funds to University responsibilities during the summer

Office of the Vice President for Research

Sample AlternativesSample Alternatives• One month of salary from grants/contracts is

spread over more than two summer semi-monthly pay periods at less than 100% effort during any one pay period. (Remainder of time is uncompensated University effort or personal time.)

• Small percentage charged to grants/contracts during AY period, reflecting no more than actual work pattern on project. Remainder charged to summer at less than 100% per pay period.

Office of the Vice President for Research

Consulting Policy in SummerConsulting Policy in Summer

• Acceptable for 1 day/week if no more than 80% funded on research grant

• Special research faculty funded by sponsored grants or contracts may only consult using approved annual leave

Office of the Vice President for Research

Special Research FacultySpecial Research Faculty

• If special research faculty are involved in tasks outside of the objectives of their grant or contract, an alternative source of funds must be used for such activities. (NOTE: Task Force on Special Research Faculty considering this issue in ongoing effort)

Office of the Vice President for Research

Special exceptions may apply for POSTDOCSSpecial exceptions may apply for POSTDOCS• NSF grant guidelines require a mentoring

plan for postdocs. • “Examples of mentoring activities include, but

are not limited to: career counseling; training in preparation of grant proposals, publications and presentations; guidance on ways to improve teaching and mentoring skills; guidance on how to effectively collaborate with researchers from diverse backgrounds and disciplinary areas; and training in responsible professional practices.”

Office of the Vice President for Research

Policy 3105Policy 3105• Effort Reporting (PARS)• Faculty will need to provide an accurate

report of effort during the reporting period. (Summer certified across entire period).

• Initial payroll allocation is estimate that must be confirmed through effort certification

• Required by Federal regulations governing terms and conditions of grants and contracts

• Each faculty member must certify their own effort report

Office of the Vice President for Research

Sanctions for non-compliance of effort reportingSanctions for non-compliance of effort reporting• Salary costs associated with uncertified

grant activity may be charged to department accounts

• The university may suspend submission on any new proposals by noncompliant PI

• Submitting effort reports known to be inaccurate may subject the individual to personal disciplinary action

Office of the Vice President for Research

Faculty To-Do ListFaculty To-Do List• Complete accurate, timely effort reports (PARS)• Do not charge 100% of effort to funded grants and

contracts at any given time if an AY faculty member• Do not charge a period of vacation or unrelated absence

solely to a sponsored grant/contract • Rebudget existing grants, if necessary, to cover some AY

salary charges• Budget salary on new grants and contracts during the AY

as well as the summer to recognize effort• Assure that special research faculty working under their

direction and with 100% funding on grants/contracts are not involved in other activities (or must find alternative sources of funding)

Office of the Vice President for Research

Department Head To-Do ListDepartment Head To-Do List

• Work with faculty to prepare for compliance by Summer 2011 regarding anticipated summer salary payments

• Make sure that new grants are budgeted to include some faculty AY salary charges if allowed by sponsor

• Confirm that effort reports are completed in a timely and accurate way

• Consider alternative funds for special research faculty if necessary for compliance

Office of the Vice President for Research

Department Fiscal Manager To-Do ListDepartment Fiscal Manager To-Do List

• Work with each faculty member to be sure there is a plan in place for salary charges that will bring them into compliance for Summer 2011

• Assure that salary savings accrued from grant charges during the academic year are available for faculty salary in the summer

• Assure that adequate reasons for any changes in salary or percent effort on grants are documented and retained for audit purposes

• Training program being developed for late fall