Highlights of Post Award Highlights of Post Award Sponsored Project AdministrationSponsored Project Administration

July 11, 2007July 11, 2007Office of Research Training & Office of Research Training &

ComplianceCompliance

Topics CoveredTopics Covered

Effort ReportingEffort Reporting Cost Transfers Cost Transfers Subawards Subawards Independent ContractorsIndependent Contractors Subrecipient MonitoringSubrecipient Monitoring

What is Effort?What is Effort?

Total professional effort is the amount of time spent on ALL Total professional effort is the amount of time spent on ALL activities including both University (instruction, activities including both University (instruction, departmentally-funded tasks, funded research) and non-departmentally-funded tasks, funded research) and non-University (i.e., clinical services).University (i.e., clinical services).

Effort is not based on a 40 hour work week but rather a Effort is not based on a 40 hour work week but rather a percentage of effort and must equal 100%.percentage of effort and must equal 100%.

Effort distributions should be reasonable estimates of Effort distributions should be reasonable estimates of activities. Effort includes both direct charged and cost activities. Effort includes both direct charged and cost shared effort.shared effort.

Effort ReportingEffort Reporting(A-21 requirement)(A-21 requirement)

GW policy requires that the Effort Certification Report be signed by the GW policy requires that the Effort Certification Report be signed by the employee, PI or responsible official using suitable means of verification employee, PI or responsible official using suitable means of verification that the work was performed. Complete semi-annually: Jan-June and that the work was performed. Complete semi-annually: Jan-June and July-December.July-December.

Effort Certification is not how payroll expense is distributedEffort Certification is not how payroll expense is distributed..

Change in Status (CIS) forms are required to be processed when there Change in Status (CIS) forms are required to be processed when there is a substantial change in the employee’s effort.is a substantial change in the employee’s effort.

Review monthly labor distribution reports to ensure compliance.Review monthly labor distribution reports to ensure compliance.

What are Cost Transfers?What are Cost Transfers?

Cost transfers are after-the-fact re-allocations ofCost transfers are after-the-fact re-allocations ofcosts, either labor or non-labor to a sponsoredcosts, either labor or non-labor to a sponsoredproject.project.

Personnel Costs/Non-personnelPersonnel Costs/Non-personnel- CIS/DCF forms that correct a variety of data entry, - CIS/DCF forms that correct a variety of data entry, admin and acct coding errorsadmin and acct coding errors-- CIS/DCF forms that transfer costs between CIS/DCF forms that transfer costs between continuations of projects or related project/awardscontinuations of projects or related project/awards- CIS/DCF forms that transfer pre-award costs- CIS/DCF forms that transfer pre-award costs

ExclusionsExclusions

Initial allocations of costs from interfaces, service centers Initial allocations of costs from interfaces, service centers and clearing accts, including suspense and failed funds and clearing accts, including suspense and failed funds (N.B., these are not cost transfers b/c they do not involve (N.B., these are not cost transfers b/c they do not involve reallocations)reallocations)

CIS forms that re-distribute salary for a prior period to an CIS forms that re-distribute salary for a prior period to an award prior to effort cert. (N.B., these are not cost transfers award prior to effort cert. (N.B., these are not cost transfers b/c the original allocation is an estimate, so the b/c the original allocation is an estimate, so the redistribution of charges is a revision of an estimate)redistribution of charges is a revision of an estimate)

Credits to awards (N.B….b/c they do not involve allocations Credits to awards (N.B….b/c they do not involve allocations of costs to a sponsored project)of costs to a sponsored project)

Why Document?Why Document?

Reguations specifiy. Every cost transfer must be Reguations specifiy. Every cost transfer must be documented.documented.

Must include info on how the error occurred and Must include info on how the error occurred and approval/certification of the correctness of the transfer by approval/certification of the correctness of the transfer by the organizational official.the organizational official.

For standard cost transfers, initiators should use the For standard cost transfers, initiators should use the remarks box on the relevant CIS/DCF forms.remarks box on the relevant CIS/DCF forms.

Cost Transfers that require a memo to Cost Transfers that require a memo to the Comptrollerthe Comptroller

The correction is initiated 90 days after the error and/or 30 days after The correction is initiated 90 days after the error and/or 30 days after the award has been closed;the award has been closed;

The cost is being transferred for the second time;The cost is being transferred for the second time;

The costs is being transferred to a sponsored project or task to correct The costs is being transferred to a sponsored project or task to correct a cost overrun on a related sponsored project or task;a cost overrun on a related sponsored project or task;

Salary costs are being transferred after the certification of effort Salary costs are being transferred after the certification of effort associated with the costs;associated with the costs;

Any other circumstance in which the certifying official needs additional Any other circumstance in which the certifying official needs additional documentation to verify the cost is allowable.documentation to verify the cost is allowable.

Sub-awards Sub-awards Sub-awards are a formal legal agreement between GW and another Sub-awards are a formal legal agreement between GW and another

legal entity where:legal entity where:

-- a defined portion of our sponsored project’s scope of work a defined portion of our sponsored project’s scope of work (intellectual activity) is assigned to another entity (“the sub-recipient”) (intellectual activity) is assigned to another entity (“the sub-recipient”) to fulfill;to fulfill;

-- Work is performed by the sub-recipients personnel, using Work is performed by the sub-recipients personnel, using their resources, usually at their site;their resources, usually at their site;

-- Terms and Conditions from GW’s prime award are flowed Terms and Conditions from GW’s prime award are flowed down to the third party sub-recipient.down to the third party sub-recipient.

-- Pass through entity’s F&A rate is only charged to the first Pass through entity’s F&A rate is only charged to the first $25,000 of each subaward.$25,000 of each subaward.

- - Sub-awards can sometimes be referred to as sub-grants, Sub-awards can sometimes be referred to as sub-grants, sub-agreements or subcontracts. If the prime award is a contract, sub-agreements or subcontracts. If the prime award is a contract, then the sub-award is subject to procurement regulations. then the sub-award is subject to procurement regulations.

Independent ContractorsIndependent Contractors

Provide goods/services within normal business Provide goods/services within normal business operationsoperations

Sell to the general publicSell to the general public Operate in a competitive environmentOperate in a competitive environment Provide goods and services that are ancillary to Provide goods and services that are ancillary to

GW’s sponsored project.GW’s sponsored project. IP is generally owned by the CompanyIP is generally owned by the Company Non-University Labor or Services (Twenty Factors Non-University Labor or Services (Twenty Factors

Test)Test)

Documentation RequirementsDocumentation Requirements

SubawardsSubawardsDocumentation required at Documentation required at proposal submission from proposal submission from PI:PI: OCRO ChecklistOCRO Checklist

Fair & Reasonable Fair & Reasonable Cost Analysis Cost Analysis

Independent ContractorsIndependent Contractors– At proposal submission:At proposal submission:

Budget and Statement of Budget and Statement of Services from ContractorServices from Contractor

- Resume (if individual)- Resume (if individual)

Postaward:Postaward:-- Selection of Source formSelection of Source form- Supplier registration if new Supplier registration if new

suppliersupplier- Twenty Factors Twenty Factors

Sub-recipient MonitoringSub-recipient MonitoringA-133 RequirementA-133 Requirement

Ensure that monies funded to us from a federal awards are Ensure that monies funded to us from a federal awards are used for authorized purposes and are in compliance with used for authorized purposes and are in compliance with laws and regulations of the prime awardlaws and regulations of the prime award

Ensure that goals and objectives of the work proposed by Ensure that goals and objectives of the work proposed by the sub-recipient are achievedthe sub-recipient are achieved

Monitor invoices of sub-recipient closely to ensure funds Monitor invoices of sub-recipient closely to ensure funds are spent appropriately and work is satisfactory and within are spent appropriately and work is satisfactory and within time constraints. Communicate deficiencies to sub-time constraints. Communicate deficiencies to sub-recipient in a timely manner! Did the sub-recipient commit recipient in a timely manner! Did the sub-recipient commit to cost-sharing? If so, this must be monitored!to cost-sharing? If so, this must be monitored!

Sub-recipient Monitoring (cont.)Sub-recipient Monitoring (cont.)

GW sub-recipient agreements require the sub-GW sub-recipient agreements require the sub-recipient to submit a final report or reports that the recipient to submit a final report or reports that the PI instructs. These reports will be incorporated PI instructs. These reports will be incorporated into GW’s final report to the sponsoring agency.into GW’s final report to the sponsoring agency.

Ensure timely closeout! 90 days before end of Ensure timely closeout! 90 days before end of subaward, confer with sub-recipient. If more time subaward, confer with sub-recipient. If more time is required, GW may need to request a no-cost is required, GW may need to request a no-cost extension from our prime sponsor.extension from our prime sponsor.

Policy SitesPolicy Sites

http://my.gwu.edu/files/policies/CostTransfersSponsoredAghttp://my.gwu.edu/files/policies/CostTransfersSponsoredAgreementsFINAL.pdfreementsFINAL.pdf

http://my.gwu.edu/files/policies/EffortCertificationFINAL.pdfhttp://my.gwu.edu/files/policies/EffortCertificationFINAL.pdf

http://my.gwu.edu/files/policies/Bids,Quotes,SoleSourceFIhttp://my.gwu.edu/files/policies/Bids,Quotes,SoleSourceFINAL.pdfNAL.pdf

http://my.gwu.edu/files/policies/SubrecipientPolicyFINAL.pdhttp://my.gwu.edu/files/policies/SubrecipientPolicyFINAL.pdff