MRAM Monthly Research Administration Meeting

NOVEMBER 12, 2015UW TOWER AUDITORIUM

NEXT MRAM DECEMBER 10, 2015UW TOWER AUDITORIUM

TOPIC PRESENTER CONTACT MIN

Effort Reporting Update Michael Anthony Executive Director, Management Accounting & Analysis

206 616-1379mda1213@uw.edu 10

Project Certification Michael Anthony Executive Director, Management Accounting & Analysis

206 616-1379mda1213@uw.edu 15

IRB Fee for Industry-Funded & Industry-Initiated Sponsored Studies

Jason MaloneAssistant Director, Regulatory AffairsHuman Subjects Division

206 543-2254jmmalone@uw.edu 15

Compliance Corner Ted MordhorstDirector, Research Compliance & Operations

206 616-8678tedm2@uw.edu 10

CORE Course Update Mara RivetLearning, Outreach & Communications OSP

206 543-1870tfr@uw.edu 2

Effort Reporting UpdateFECs and GCCRs

MRAM - November 12, 2015Michael Anthony

Management Accounting & AnalysisUniversity of Washington

Confirm changes, e.g., OSETS, Cost Share Commitment Adjustments, have processed and appear on the FEC before having faculty certify.

Insufficient Funds – Make sure the predefined comment (“Non-federal grant(s) approved to be used for cost share…”) is checked AND the ‘contributing budget(s) and percent contribution(s) are reflected in the “Additional Comments” section.

Net ID – Certify others – Make sure the individual is eligible for this role (Chair, Dean, Director).

FEC Certifications

University of Washington Management Accounting & Analysis

Salary Cap (monthly rate) Issue for faculty not paid for full FEC cycle, e.g., 2

summer months during spring/summer cycle

FEC can have the appearance there is no salary cap issue when 2 months summer salary is spread over 3 months (summer quarter) which is combined with the Spring quarter

Not OK to be over the cap and charge nothing but grants

Salary Cap Issues

University of Washington Management Accounting & Analysis

Pre-pay / Pre-work Salary charged must reasonably reflect work of

each pay period. 

Cannot misrepresent actual effort for the period. 

Example - Overcharging grant (undercharging department funds) during AY so department can pay summer salary from savings.

Other Issues

University of Washington Management Accounting & Analysis

Issue with fiscal close

When OSETs or other salary transactions occurred during month 25 it resulted in the GCCR report generator resetting for some departments/PUCs

Appeared as though GCCR reports were not downloaded after month 24

If you haven’t, please do and we will stop contacting you

GCCR Issue

University of Washington Management Accounting & Analysis

Project CertificationMRAM - November 12, 2015

Michael AnthonyManagement Accounting & Analysis

University of Washington

A demonstration with 4 universities and 2 federal agencies to

demonstrate a new alternative method for reporting time and effort information on federally

sponsored research grants

FDP InitiativeProject Certification

University of Washington Management Accounting & Analysis

An alternative to Effort Certification

Generally positive response from university communities although some expressed they will not change current procedures

Other institutions encouraged to evaluate to determine if it is a viable option for them

FDP InitiativeProject Certification

University of Washington Management Accounting & Analysis

Alternative to Effort Certification Similar to the current GCCR process

All individuals with direct salary charges and/or cost share commitments to a sponsored project(s) would need to be included

One certification per project would cover all individuals

Frequency TBD (beta sites doing this on a monthly basis)

Project Certification

University of Washington Management Accounting & Analysis

Generally positive response from the Federal government Several audits of the beta site universities did

raise some concerns primarily centered around internal controls

Project Certification

University of Washington Management Accounting & Analysis

NSF – OIG concluded Need to strengthen internal controls to ensure labor

charges to NSF awards are adequately supported

Found problems with 21 of 180 transactions sampled – Not certified in a timely manner, posting errors, missing recertifications due to OSETs

Need to strengthen its IT controls to protect payroll information

Audit ResultsGeorge Mason University

University of Washington Management Accounting & Analysis

NSF – OIG concluded System "generally provided accountability over federal funds" Did not always comply with policies for payroll transactions under

the effort reporting process as well as payroll certification pilot." Issue with the security of Banner (payroll IT program) Of 112 transactions processed under the pilot, OIG found two had

problems "related to changing salary and wage distributions." None were identified as late, and no other problems were noted.

Audit ResultsMichigan Technological University

University of Washington Management Accounting & Analysis

We like the concept (individual championing the FDP initiative former UW Controller)

Similar to GCCR process but lacking many features of eFECS (auto salary cap calculation, cost share commitments, etc.)

Presently do not have IT resources available to devote to a conversion (HR/P, new Financial System)

What is our Perspective?

University of Washington Management Accounting & Analysis

Plan to assess the pros/cons of incorporating the current faculty effort reporting (FEC) and non-faculty (GCCR) processes with project based payroll certification

Work with campus units to understand their preferences, concerns, suggestions

Keep tabs on what is happening at beta sites as well as any other institutions adopting project certification

What are our Next Steps?

University of Washington Management Accounting & Analysis

Any volunteers here today!!

What are our Next Steps?

University of Washington Management Accounting & Analysis

HSD Administrative FeeMRAM - November 12, 2015

Jason MaloneHuman Subjects DivisionUniversity of Washington

A one-time $1500.00 fee to help cover HSD’s costs for fulfilling mandatory regulatory and administrative responsibilities.

It applies to research with an indirect cost rate that does not cover those costs.

What is it?

University of Washington Human Subjects Division

The fee applies only to studies that are both:Industry initiated AND;Industry sponsored

Applicability

University of Washington Human Subjects Division

For studies that go through Clinical Research Budget and Billing (CRBB), the fee is automatically included in the study budget.

For studies that are not using UW clinical services and don’t go through CRBB, the Office of Sponsored Programs (OSP) notes the fee in the Funding Action.

How It Works

University of Washington Human Subjects Division

Indirect costs are charged in connection with the fee.

HSD does not send an invoice for the fee.

The fee is automatically paid to HSD by Grant and Contract Accounting (GCA) when the UW receives initial payment from the sponsor.

How it works

University of Washington Human Subjects Division

Guidance has been posted to the HSD website:

http://www.washington.edu/research/hsd/docs/1904

Contact the HSD IRB Reliance Administrator at:

hsdrely@uw.edu

Resources/Questions

University of Washington Human Subjects Division

Fiscal Compliance CornerRecent Happenings, etc.

MRAM Nov 2015

Ted MordhorstDirector Compliance and OperationsResearch Accounting & Analysis

Audit News

NSF Audit

Covers ALL NSF Awards 4/1/10 – 3/31/13

PreliminaryFindings:

NSF Data Analytics Audit Salaries charged in excess of the 2 month rule

Equipment purchased near the award expiration 18 items

Materials and supplies purchased near the award expiration 5 items

Unallocable tavel transactions

NSF Data Analytics Audit Purchase card transactions without vendor

receipt

Unreasonable or unallowable expenses

Purchases more than 90 days prior to the award effective date

meal expenses not necessary or reasonable

Travel that occurred after award expiration

NSF Data Analytics Audit Auditor Recommendations:

Strengthen the administrative and management controls and processes

Implement university-wide procedures to ensure that all departments are monitoring the allocation of costs charged to NSF awards

NSF Data Analytics Audit Auditor Recommendations:

Strengthen internal controls and processes over allocating expenses for equipment and supplies to sponsored funding sources.

Require documentation of the methodology used to allocate expenses to sponsored projects, as well as a justification for how the methodology was determined.

Final thought Audits are increasingly looking at factors related

to internal controls

Expense documentation must be maintained and demonstrate reasonableness, necessary and allocability

Expenses during the last 90 days of the award are most often questioned

Final thought Both in the UG and in the audit there is an

increased emphasis on “necessary”, “essential” and “integral” to define when a cost is reasonable.

It behooves us to think in these terms when processing transactions

Other Compliance HappeningsResearch Terms and Conditions

(RTC)

Developed by the Federal Demonstration Partnership (FDP)

11 federal agencies participating

Open for comments through 12/14/15

Research Terms & ConditionsSomewhat confusing

We will submit comments

Will have agency specific deviations

Incorporated into awards sometime in the spring?

Will share more as this progresses

QUESTIONS?

CORE is a collaborative effort to provide free, high quality, cohesive training on research administration and compliance to UW researchers and research administrators.

UPCOMING COURSES IN RESEARCH ADMINISTRATION

Nov 16 ORIS 103 – SAGE Budget

Nov 17 GCA 203 – Preparing for an Audit

Nov 17 ORIS 102 – SAGE: Creating NIH Proposals in Grant Runner

Nov 18 MAA 231 – Salary Limitations - Salary Cap

Nov 24 ORIS 101 – SAGE: Creating and Submitting eGC1's

Dec 02 GCA 202 – Direct Billing of F&A Type Costs

Dec 03 ORIS 103 – SAGE Budget

To see a full list of courses and to register, visit https://uwresearch.gosignmeup.com/public/course/browse

Dec 09 MAA 225 – Using the Tools: Calculators, Worksheets and Reports

Dec 10 ORIS 102 – SAGE: Creating NIH Proposals in Grant Runner