Sponsored Programs Administration Uniform Guidance ...
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Office of Business Affairs Sponsored Programs Administration
Sponsored Programs Administration Uniform Guidance Compensation Compliance
Alternatives to Effort Reporting
Provost Office Meeting
SPA Department All Pod Meeting
May 18, 2016
Office of Business Affairs Sponsored Programs Administration
Uniform Guidance Research Financial Compliance
• 2 CFR 200.430 – Pathways for alternative methods to comply – Emphasis on system of internal controls
• National Dialogue – Opportunity and expectation to alleviate faculty
administrative burden
• NCURA Research Award – National Model Policy Cohort
• UTSW Collaboration – Provost’s Office, Office of Compliance, Office of Internal
Audit, Office of Accounting & Fiscal Services, Academic and Administrative Information Resources
Office of Business Affairs Sponsored Programs Administration
Documents on the SPA Website
SPA Uniform Guidance Webpage
1. National Dialogue on Effort Reporting and Faculty and
Administrative Burden in the Conduct of Research 2. Alternatives to Effort Reporting 3. Executive Summary: CFR 200.430 Compensation personal services 4. Dept Admin Guidelines for Proposing, Managing and Confirming
Payroll Associated with Sponsored Projects 5. Payroll Confirmation Internal Controls Risk Assessment 6. Alternatives to Effort Reporting Methodology for UG Compliance 7. Alternatives to Effort Reporting – 1 page memo for UTSW Admins
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A QUICK HISTORY LESSON
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Some History
5
1965: Effort reporting was first proposed
1966-1968: Heavily protested so the regs
were not implemented
1967: First addressed in A-21, requirements
were tedious and unclear so the university
response was primarily negative
1979: This revision gave examples of
acceptable methodologies
1982: Revised again after further
stakeholder involvement
Anthony, M. D., & Gindhart, J. M. (2009). Effort reporting: An overview. Washington, DC:
National Council of University Research Administrators.
Boffey, P. M. (1968). Effort Reporting: Government Drops Much-Criticized Paperwork. Science,
160(3834), 1322-1324.
Council on Governmental Relations. (2007). Policies and practices: Compensation, effort
commitments, and certification. Retrieved from http://www.cogr.edu/viewDoc
.cfm?DocID=151565
Lang, S. (1980). Time and effort reporting: Déjà vu. Science, 207, 1148-1151.
Selby, S. E. (1982). Effort reporting alternatives. SRA Journal, 15-19.
Walsh, J. (1980). Universities face new accounting rules. Science, 210, 34-36.
Office of Business Affairs Sponsored Programs Administration
Some History
6
• Several articles were written protesting the
requirements and suggesting alternative
strategies:
• Burden was foreseen and predicted
• Extent of compliance with the “new”
regulations could only be seen once they
were audited unless baseline data were
collected for comparison
• Regulations remained unchanged until…
Anthony, M. D., & Gindhart, J. M. (2009). Effort reporting: An overview. Washington, DC:
National Council of University Research Administrators.
Boffey, P. M. (1968). Effort Reporting: Government Drops Much-Criticized Paperwork. Science,
160(3834), 1322-1324.
Council on Governmental Relations. (2007). Policies and practices: Compensation, effort
commitments, and certification. Retrieved from http://www.cogr.edu/viewDoc
.cfm?DocID=151565
Lang, S. (1980). Time and effort reporting: Déjà vu. Science, 207, 1148-1151.
Selby, S. E. (1982). Effort reporting alternatives. SRA Journal, 15-19.
Walsh, J. (1980). Universities face new accounting rules. Science, 210, 34-36.
Office of Business Affairs Sponsored Programs Administration
OPPORTUNITY TO REDUCE BURDEN
Office of Business Affairs Sponsored Programs Administration
Uniform Guidance Research Financial Compliance
• National Dialogue on Effort Reporting and Faculty and Administrative Burden
– In 2005 and 2012, Federal Demonstration Partnership (FDP) surveys of PIs with federally sponsored research projects found that PIs spend, on average, 42% of their research time on administrative tasks
Office of Business Affairs Sponsored Programs Administration
Pilots – UG Alternatives
Federal Demonstration Partnership
Pilots Started at George Mason, UC Irvine, UC
Riverside, Michigan Tech
Payroll certification system
Eliminates “effort” in favorable of reasonable
charges
PI verify annually
Department of Labor Workforce Innovation Fund
OMB may allow waiver of effort reporting for Innovation
Fund grantees
Verify activity based on outcomes, not promise of
success
Examples include case counts or employment placements
Applicants may propose alternate plans with
application
Department of Education Request for Ideas
Soliciting detailed and general ideas for effort alternatives
Evidence that funds are producing outcomes tied to
overall program goals
Development and linkage of data systems
Long-term efficiency and productivity benefits
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From: Federal Demonstration Partnership September 4, 2015 Meeting presentation.
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FDP Pilot Audit Results OIG
Report Issued
Pilot-Specific Results*
George Mason University
NSF August 2015
Enforce written policies on payroll certification; enhance internal controls over IT; issues identified are not as a result of inadequate design of pilot system controls; having direct visibility to full payroll allocation could be an important control; less frequent certification requires diligence in communicating and adhering to control procedures
University of California - Irvine
DHHS December
2014 DHHS IG did not express an opinion regarding the payroll certification process
University of California - Riverside
DHHS Report has not been issued
Michigan Technological
University NSF
September 2015
System generally provided accountability over federal funds but did not always comply with its documentation policies; a risk to report on awards rather than individual effort; budget estimate process was unchanged; internal controls surrounding accounting system should be strengthened
*FDP conclusion is that payroll certification is permitted under 2 CFR 200; approval from cognizant agency is NOT required but guidance on internal controls should be considered in implementation.
*Comprehensive report summarizing conclusions from all pilots is forthcoming.
*Results summarized from agency audit reports and FDP presentations at the September 2015 meeting.
Office of Business Affairs Sponsored Programs Administration
UG COMPENSATION COMPLIANCE
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Compensation Reporting Basics
The process by which the salary charged to a sponsored project is reviewed after-the-fact to assure that the salary charged was reasonable in relation to the effort expended on that project.
Effective December 26, 2014, the OMB Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance) regulates the compensation reporting requirements for recipients of federal funding. Like Circular A-21, the Uniform Guidance requires an after-the-fact review of charges made to Federal awards that were based on budget estimates.
Office of Business Affairs Sponsored Programs Administration
Compensation Reporting Requirements
Governing Regulations
• 2 CFR Part 200.430, paragraph (a) notes that compensation is allowable if it is reasonable, conforms to established written policies, is consistently applied, follows an appointment, and is supported by paragraph (i)
• 2 CFR Part 200.430, paragraph (i) Standards for Documentation of Personnel Expenses outlines the compensation reporting requirements
• Clarification of OMB A-21 Treatment Voluntary Uncommitted Cost Sharing and Tuition Remission Costs (January 5, 2001)
Office of Business Affairs Sponsored Programs Administration
Major Regulatory Changes
• Allows for additional flexibility in how entities implement processes to meet standards
– Removed formal reference to many elements of guidance
• specific examples of appropriate methodologies for monitoring effort
• prescribed effort reporting time periods
• specification on who must certify/document compensation costs
• concept of independent evaluation removed
• But, must be based on a strong system of internal controls and records must accurately reflect the work performed
Office of Business Affairs Sponsored Programs Administration
Compensation Reporting Requirements 2 CFR 200.430, paragraph (i) Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages
must be based on the records that accurately reflect the
work performed. These records must:
•Be supported by a system of internal control which provides
reasonable assurance that the charges are accurate,
allowable, and properly allocated;
•Be incorporated into the official records of the non-Federal
entity;
•Reasonably reflect the total activity for which the employee
is compensated by the non-Federal entity, not exceeding
100% of compensated activities (for IHE, this per the IHE’s
definition of IBS);
Translated
• Salary charges must be based on official records
• Records must be supported by a system of internal controls
• Records must reflect employee’s total activity; not exceed 100%
• Encompass all activities in IBS
Office of Business Affairs Sponsored Programs Administration
Compensation Reporting Requirements 2 CFR 200.430, paragraph (i) Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must
be based on the records that accurately reflect the work
performed. These records must (CONTINUED):
•Encompass both federally assisted and all other activities
compensated by the non-Federal entity on an integrated basis, but
may include the use of subsidiary records as defined in the non-
Federal entity’s written policy;
•Comply with the established accounting policies and practices of
the non-Federal entity (see paragraph (h)(1)(ii) above for treatment of
incidental work for IHEs,); and
•Support the distribution of the employee’s salary or wages among
specific activities or cost objectives if the employee works on more than one
Federal award; a Federal award and non-Federal award; and indirect cost activity and a direct cost activity;
two or more indirect activities which are allocated using different allocation bases; or an unallowable
activity and a direct or indirect cost activity.
Translated
• Records must include all activities; supplementary records can be used
• Comply with accounting policies/practices
• Support salary/wage distribution
Office of Business Affairs Sponsored Programs Administration
(1) Charges to Federal awards for salaries and wages must be based on
records that accurately reflect the work performed. These records must
(CONTINUED):
•Budget estimates (i.e., estimates determined before the services are performed)
alone do not qualify as support for charges to Federal awards, but may be used for
interim accounting purposes, provided that:
•(A) The system for establishing the estimates produces reasonable
approximations of the activity actually performed;
•(B) Significant changes in the corresponding work activity (as defined by the
non-Federal entity’s written policies) are identified and entered into the records
in a timely manner. Short term (such as one or two months) fluctuation between
workload categories need not be considered as long as the distribution of salaries
and wages is reasonable over the long term; and
•(C) The non-Federal entity’s system of internal controls includes processes to
review after-the-fact interim changes made to a Federal awards based on budget
estimates. All necessary adjustment must be made such that the final amount
charged to the Federal award is accurate, allowable, and properly allocated.
Compensation Reporting Requirements 2 CFR 200.430, paragraph (i) Standards for Documentation of Personnel Expenses
Translated
• Budget estimates (BEs) can be used for interim accounting purposes only; alone they do not qualify
• Process to establish BEs is important
• Significant changes made timely
• Short term fluctuations OK
• After-the-fact review (w/adjustment, as applicable) of BEs required
Office of Business Affairs Sponsored Programs Administration
(1) Charges to Federal awards for salaries and wages must be
based on records that accurately reflect the work performed.
These records must (CONTINUED):
•Because practices vary as to the activity constituting a full workload
(for IHEs, IBS), records may reflect categories of activities expressed
as percentage distribution of total activities.
•It is recognized that teaching, research, service, and administration
are often inextricably intermingled in an academic setting. When
recording salaries and wages charged to Federal awards for IHEs, a
precise assessment of factors that contribute to costs is therefore not
always feasible, nor is it expected.
Compensation Reporting Requirements 2 CFR 200.430, paragraph (i) Standards for Documentation of Personnel Expenses
Translated
• Allows distribution to be expressed as a % of the total
• Precise estimates for IHEs is not expected
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• (2) For records which meet the standards required in paragraph (i)(1) of this
section, the non-Federal entity will not be required to provide additional
support or documentation for the work performed, other than that
referenced in paragraph (i) (3) of this section.
•(3) In accordance with Department of Labor regulations implementing the
Fair Labor Standards Act (FLSA) (29 CFR Part 516), charges for the salaries
and wages of nonexempt employees, in addition to the supporting
documentation described in this section, must be also supported by records
indicating the total number of hours worked per day.
•(4) Salaries and wages of employees used in meeting cost sharing or
matching requirements on Federal awards must be supported in the same
manner as salaries and wages claimed for reimbursement from Federal
awards.
Compensation Reporting Requirements 2 CFR 200.430, paragraph (i) Standards for Documentation of Personnel Expenses
Translated
• If meet these standards, no additional support documentation required
• FLSA documentation still required for non-exempt employees
Office of Business Affairs Sponsored Programs Administration
•(5) For states...
•(6) Cognizant agencies for indirect costs are encouraged to approve
alternative proposals based on outcomes and milestones for program
performance where these are clearly documented. Where approved by
the Federal cognizant agency for indirect costs, these plans are
acceptable as an alternative to the requirements of paragraph (i)(1) of
this section.
•7)…(blended funding…
•(8) For a non-Federal entity where the records do not meet the
standards described in this section, the Federal government may
require personnel activity reports, including prescribed certifications, or
equivalent documentation that support the records as required in the
section.
Compensation Reporting Requirements 2 CFR 200.430, paragraph (i) Standards for Documentation of Personnel Expenses
Translated
• Treat cost sharing the same
• Propose alternatives to your cognizant agency
• If you don’t do this = additional sanctions
Office of Business Affairs Sponsored Programs Administration
It’s Not an Exact Science!
• Precision is not required
• Sponsors recognize that
research, teaching, service,
and administration are
often inextricably
intermingled
• Reasonable estimates are
expected
o But there are some
rules to follow!
Office of Business Affairs Sponsored Programs Administration
In Summary: The Rules Require Us To…
• Be careful about what we offer in a proposal
• Be careful when making commitments at award time
• Change commitments when needed, and document
the changes
• Fulfill commitments
• Charge salary in a way that’s congruent with actual work, based on reasonable budget
estimates
• Periodically review and make changes to budget estimates
• Verify salary is congruent with what actually happened
• Charge a grant only for time that pertains specifically to the grant
• Not charge a grant for time spent writing a proposal for a new project or a competing
continuation
– Time spent on these activities must be covered by institutional or gift funds
• Transfer salary charges off of a grant if the level of effort does not justify the salary charges
Office of Business Affairs Sponsored Programs Administration
INTERNAL CONTROLS
Office of Business Affairs Sponsored Programs Administration
Establishing Strong Policies
• Must now be “supported by a system of internal control which provides
reasonable assurance that charges are accurate, allowable, and properly
allocated”
• How did your institution establish its policies?
• What are some strategies for making your policy effective?
Focus the attention
of Leadership
Persuasive Power of fines and penalties
Effective Policies
Office of Business Affairs Sponsored Programs Administration
Internal Controls
• Internal controls are addressed in section
200.303 and specifically mentioned in 200.403
Compensation - Personnel Services
• Internal controls should be in compliance with
guidance in:
– “Standards for Internal Control in the
Federal Government” (Green Book)
issued by the Comptroller General of the
U.S. (Updated September 2014)
– “Internal Control Integrated Framework”
issued by COSO (2013)
– Appendix XI, Compliance Supplement –
Part 6 Internal Control (which follows
COSO but will consider both the Green
Book and COSO in the 2015 update)
The Components, Objectives, and Organizational Structure of Internal Control
Sources: COSO and GAO. GAO-14-704G
Office of Business Affairs Sponsored Programs Administration
Internal Controls
Office of Business Affairs Sponsored Programs Administration
Control Environment • What office supports the process?
• Communication from the top?
• Enforcement
• Penalties • Setting consequences for failure to comply
with policies and practices
• Penalties for failure to complete requirements?
Attend training?
• Monitoring?
• Training requirements • How will you handle training? Is it voluntary or
mandatory?
• Delivery – online? Classroom? Web
resources?
• Target groups: PIs/researchers, administrators
The Components, Objectives, and Organizational Structure of Internal Control
Sources: COSO and GAO. GAO-14-704G
Office of Business Affairs Sponsored Programs Administration
Risk Assessment
• Internal review
• Post period sampling
• Are re-certifications (“re-dos”)
allowed? Under what
circumstances?
The Components, Objectives, and Organizational Structure of Internal Control
Sources: COSO and GAO. GAO-14-704G
Office of Business Affairs Sponsored Programs Administration
Control Activities
• Who must perform after-the-fact review?
• PI or staff?
• Include all sponsored programs, or federal
only? Required for individuals who have paid
or committed effort on sponsored projects
• Include all individuals, even those with no effort
on grants?
• What is 100% effort?
•Total professional effort performed for
institutional base salary. Weekends count!
•What’s included in IBS?
• Who can see what information in system?
• Frequency of certification/verification? How
often and how long to complete?
• Who reviews and has final sign off?
The Components, Objectives, and Organizational Structure of Internal Control
Sources: COSO and GAO. GAO-14-704G
Office of Business Affairs Sponsored Programs Administration
Information and Communication
• Method of communication
• Frequency of communication
• Who is involved in the process?
• How is information disseminated to
all groups?
The Components, Objectives, and Organizational Structure of Internal Control
Sources: COSO and GAO. GAO-14-704G
Office of Business Affairs Sponsored Programs Administration
Monitoring
• Internal audits
• Random Sampling
• Monitoring in between periods
• How will you handle commitments of effort?
Captured electronically? Revisions based on prior
approval requests? Committed cost sharing?
• May not exceed 100%! / Minimum
commitments (varies by sponsor)
• De minimis effort, defining it: < 1%?
• Reviewing completed reports
•Who follows up on CTs when effort
commitments change during after-fact review?
•Policy on timely processing of significant
changes? 15 days? 30 days? 45 days?
• Reviewing individual/department process
The Components, Objectives, and Organizational Structure of Internal Control
Sources: COSO and GAO. GAO-14-704G
Office of Business Affairs Sponsored Programs Administration
Compensation Reporting Requires Collaboration Across Departments
Central RA Office Academic Units
(or Business Office) Certifier
• Manage commitments with sponsor
• Manage the reporting system
• Send reminders to certifiers
• Answer questions about associated principles and process
• Monitor the compensation reporting process
• Review compensation reports for compliance with University Policy
• Archive compensation reports
• Manage payroll distribution • Facilitate the review the
compensation report. • Is a cost transfer needed
or is it voluntary uncommitted effort?
• Execute cost transfers in accordance with university policy.
• Retain supporting compensation documentation (per policies)
• Review activities listed on the report and the % of salary charged.
• If not accurate, add any missing activities and/or correct percentages.
• Ensure all salary distribution %s match actual effort on each activity.
• Sum total effort to 100%. • Read the report and verify
accuracy.
Office of Business Affairs Sponsored Programs Administration
Process Impacts Proposal Submission
• Verify available time/documenting other support
• Approve proposed cost shares
Award Setup • Establish cost share accounts
• Assign the distribution
Scope changes • Request prior approvals for adjustments over 25%
Compensation Reporting
• Distribute compensation reports
• Collect compensation reports
• Verify completeness
Cost Transfers
• Transfer costs for completed compensation reports w/ changes
• Make timely cost transfers during the reporting period
• Make institutional base salary adjustments (if not established through distribution)
Account management • Change labor distributions
• Manage adjustments for no cost extensions
Closeouts
• Verify reports completed
• Verify cost sharing requirements were met
• Archive reports
Office of Business Affairs Sponsored Programs Administration
Tools
• Existing Tools
– PI All Funds Report – Dept Admin manual
– Monthly Monitoring financial review toolset
– Guidance to utilizing PeopleSoft for Post Award
• ABBA Team Reports being built
– 25-30 new reports
Office of Business Affairs Sponsored Programs Administration
AWARD MANAGEMENT & AWARD CLOSEOUT
Supplemental Information – Will not be presented
Office of Business Affairs Sponsored Programs Administration
The Big Picture
Office of Business Affairs Sponsored Programs Administration
Award Management – Audit Resources
SPA Trainings
• Financial Grants Management Trainings
• SPA daily POD staff Trainings
• RAD trainings
• Office Hours
SPA Guides and Manuals
• Staff operations manuals, checklists, frequently encountered issues
• Monitoring reports
• Monthly Financial Monitoring Guide (UTS 142.1)
• PI Guide Brochure
• SPA website
Meet & Greet
• HR PI Online Onboarding
• New PI Orientation
Office of Business Affairs Sponsored Programs Administration
Award Management – Upstream, Foundational Internal Controls
Proposal Development &
Submission
• Adheres with Cost Accounting Standards 501-504
• Consistent budget building (using eGrants)
• Consistently utilize RFP allowable/unallowable costs
Award Acceptance
• Clear, Concise Guidance
• Operations manuals, Checklists, Terms & Conditions
• Grant Notifications
• Confirmation of allowable/unallowable
Direct Cost Justification
• Direct Cost initiator checks: Allowable, Allocable, Reasonable, Necessary
• PS account codes for normally unallowable cost has special routing
• Direct cost justification form of normally unallowable cost at the time of charge
• Post Award accountant to review and approve of normally unallowable cost
Office of Business Affairs Sponsored Programs Administration
Award Management – Monitoring Internal Controls
Daily Monitoring
• PeopleSoft Daily Error/Exception Report
• Daily fixes of data
Monthly Monitoring
• SPA Self-Audit
• Departmental Monthly Financial Review of Expenditures
• SPA PI All Funds Report v2.0
• Provost Office Dept All Funds Report
Quarterly Monitoring
•SPA Quarterly Check-in/Financial Advising Sessions
•Allowable/allocable/reasonable/necessary, POA mismatches
•Anomalies/burn rate spikes
•Normally unallowable charges that were approved/review cost justification form
•Subawards: invoice statuses, spending/burn rate, single audit/monitoring
Closeout Monitoring
•Proactive Determination
•SPA 90/60/30 day email prior to award end date – closeout or incremental?
•If ending, specific checklist of items to begin doing
•If incremental: submit progress report, budget & SOW, subrecipient documents, carryover request, NCE - for next segment
Office of Business Affairs Sponsored Programs Administration
Award Management – After the Fact, Reconciliation Internal Controls
NOTE: No Transfers >90
days from discovery
0-45 Days: Auto Transfer
45-70 Days: Post Award Accountant
Approval Needed
70-90 Days: Director Approval Needed
Over 90 Days: SPA AVP Approval Needed
(RARELY will be approved)
New Cost Transfer Tool
Office of Business Affairs Sponsored Programs Administration
Award Closeout
Tracking
• eGrants
• Final progress
• Final invention
• Final financial
Timely Submission
• SPA 25/50/75 day email after award end date – reminders that closeout documents are due
• All closeout documents submitted together
Closed
• SPA PMS report and LOC reconciliation – comparison for match to FSR
• Collections, AR/AP
• Verification of completed sponsor award closeout
• Full UTSW award closeout
Office of Business Affairs Sponsored Programs Administration
Award Closeout Timeline
Office of Business Affairs Sponsored Programs Administration
HIGHLIGHTED ELECTRONIC TOOLS
Office of Business Affairs Sponsored Programs Administration
PI All Funds Report: PI Quick Glance View
Office of Business Affairs
Office of Business Affairs Sponsored Programs Administration
PI All Funds Report: PI View Summary
Office of Business Affairs
Office of Business Affairs Sponsored Programs Administration
PI All Funds Report: Admin View
Office of Business Affairs
Office of Business Affairs Sponsored Programs Administration
PI All Funds Report: Pending Salary by Person
Office of Business Affairs
Office of Business Affairs Sponsored Programs Administration
PI All Funds Report: Pending Salary by Award
Office of Business Affairs
Office of Business Affairs Sponsored Programs Administration
PI All Funds Report: Funds Expensed by Month
Office of Business Affairs
Office of Business Affairs Sponsored Programs Administration
Award Burn Rate Report
Office of Business Affairs Sponsored Programs Administration
Subrecipient Issuance – Risk Assessment
Office of Business Affairs Sponsored Programs Administration
Grant Notification Email Award Activation
Office of Business Affairs Sponsored Programs Administration
Grant Notification Receipt Award Information
Office of Business Affairs Sponsored Programs Administration
Grant Notification Receipt Amendments/Certifications/Additional Information/Project Details
Office of Business Affairs Sponsored Programs Administration
Grant Notification Receipt Terms and Conditions/Project Activity Details/F&A Details
Office of Business Affairs Sponsored Programs Administration
Grant Notification Receipt Budget Details/Subledger number/Future anticipated funding
Office of Business Affairs Sponsored Programs Administration
Weekly Outreach Email – Subledger Notification Summary
Office of Business Affairs Sponsored Programs Administration
Award Setup Checklists
Award ID: UTSW Sponsor Name:
Subledger #: UTSW Sponsor Award Reference #:
Project #: Prime Sponsor Name (If flow through):
Principal Investigator: Prime Sponsor Award Reference # (If flow through):
Dates of Current Budget Period: Total Anticipated Budget All Years:
Dates of Entire Project Period: Current Annual Budget: $
Department/POD #: F&A Rate:
Award ID: UTSW Subawardee Name:
Subledger #: Subawardee Principal Investigator:
Project #: Dates of Budget Period:
Principal Investigator: Subawardee Budget: $
Department/POD #: Subawardee F&A Rate:
Subawardee Email Address:
Notify SPA Contracts Team of outgoing subaward Provide dollar amount of subaward
Provide award documents for flow through terms
Notice of Award received? If YES -> Continue with award set up below AWARD SET UP (CONTINUED)Notice of Award received? If NO -> SEE BELOW FOR OPTIONS: Funding Inquiry Tab - ALL MUST EQUAL
PRE-AWARD SET UP CRITERIA Total Projected Award Amount
Must have Letter of Intent or confirmation to fund from sponsor Total Reported Award Amount
Does sponsor allow pre-award spending up to 90 days of award start date? Total Posted Budget Amount
If YES to above criteria -> Set up as Pre-Award with up to 25% of budget Total Limit Amount
If NO - > SEE BELOW FOR OPTION Chartfield 1 Tabs - THESE MUST BE COMPLETE FOR REPORTING PURPOSES
COMPLIANCE - If IRB or IACUC Protocols have not been approved yet, these funds must be SubLedger
restricted General Information
ADVANCED ACCOUNT SET UP CRITERIA Owners
Letter of Intent or confirmation to fund from sponsor? No Reporting
Unsigned contract? Yes Is this a FELLOWSHIP or TRAINING GRANT?
Partially-executed agreement? Yes Review additional fiscal management of these types of awards
If SPA doesn't have anything concrete, the Department may request an Advanced Account Funds should be loaded in Wages
and initiate a Funding Proposal in eGrants
Must provide guaranteed subledger and load budget per department request
COMPLIANCE - If questions, refer to
Training Materials & Contact SheetCOMPLIANCE - If IRB or IACUC Protocols have not been approved yet, these funds must be IRB approval letter on file? Verify in eIRB (in eGrants platform)
restricted IACUC approval letter on file? Verify in eSirius/TOPAZ
Financial Conflict of Interest on file? Verify in eCOI (in eGrants platform)
AWARD SET UP Conflict of interest training - Every 4 years
Type of Award - Federal ___ State ___ Local ___Private ___ Financial Conflict of Interest Disclosure - Annual
Contract for Services ___Contract Office of Tech/Dev___ If training and or disclosure is not current - Send email to PI/Covered personnel and
Contract-Fixed ___ Contract-Scheduled ___ Contract Not Billed through PeopleSoft ___ cc: Sheria Oswalt.
CONTRACT TYPE - Choose one below If there is a Conflict and on a Management Plan - Send email to Sheria Oswalt
CRB ____ LOC ____ SCH ____ FIX ____ NBP_____ Export controls?
Dates of budget period - eGrants and PeopleSoft are the same
Dates of overall project - eGrants and PeopleSoft are the same BILLING/INVOICINGDollar amount of award correct? Invoice template required? Yes ____ No ____
Are there multiple Principal Investigators? Payment Management System (PMS) ID
Do multiple subledgers need to be set up? LOC DOC ID
CFDA# (If federal) must have even for Flow Through Awards Milestone -> Monthly ____ Quarterly ____ Annual ____
NOTE: Federal contracts do not have CFDA#'s PO required on invoice? Yes____ No ____
LOC DOC # New? If YES -> NEW AWARD NUMBER REQUIRED LEADING TO NEW SUBLEDGER #
FAIN Number - Add in PeopleSoft - Additional Information - Type - Add to Comment REPORTINGF&A Rate (On campus/Off campus/Special Rate) Is a Financial Report required? Yes ____ No ____
Review Terms and Conditions on Notice of Award & note in eGrants/PeopleSoft Reporting template required? Yes ____ No ____
Automatic Carryforward from year to year? Yes ____ = eGrants Continution and PeopleSoft
same subledger # throughout project (R01s) Milestone -> Monthly ____ Quarterly ____ Annual ____
Automatic Carryforward from year to year? No ____ = eGrants NEW FUNDING PROPOSAL
and PeopleSoft NEW ACTIVITY (Ex. CPRIT)
Automatic Carryforward from year to year? No ____ = eGrants NEW FUNDING PROPOSAL
and PeopleSoft NEW AWARD (Ex. U Grants / T Grants, etc. READ TERMS AND CONDITIONS)
SPECIAL CIRCUMSTANCES - OUTSIDE THE NORM
PLEASE COMMENT BELOWOutgoing subcontract? SECOND CHANCE FOR NOTIFICATION TO CONTRACTS
Yes ____ (Provide information to Contracts Team - see section above)
No ____
Cost share required?
AWARD SET UP COMPLETED BY: SPA SELF-AUDIT BY:
DATE COMPLETED AND CHECKLIST SCANNED INTO ONBASE: DATE:
THINGS TO LOOK FOR AND VERIFY
UT SOUTHWESTERN MEDICAL CENTER
SPONSORED PROGRAMS ADMINISTRATION
AWARD SET UP CHECKLIST
SPA CONTRACTS TEAM (this information should be found in original funding proposal and or provided by the Department)
OUTGOING SUBAWARD - PRINT THIS PORTION OF CHECKLIST FOR EACH SUBAWARD AND PROVIDE INFORMATION TO
UT SOUTHWESTERN MEDICAL CENTER SPONSORED PROGRAMS ADMINISTRATION
FLOW THROUGH AWARD CHECKLIST
eGrants Award #: UTSW Sponsor Name: Principal Investigator: UTSW Sponsor Award Reference #: Dates of Current Budget Period: Prime Sponsor Name (If flow through):
Dates of Project Period: Prime Sponsor Award Reference # (If flow through): Department/POD #: Current Annual Project Budget: $
F&A Rate:
THINGS TO LOOK FOR AND VERIFY
Send department Incoming Contract Request form Ensure CFDA # is included in the contract
Ensure eGrants # is included on the form and the department has taken the necessary action in eGrants to allow SPA to initiate the New Award Set Up once contract is fully executed Statement of Work obtained
Update log -> O:\GRANTS\Grants Management\Contracts Detailed Budget is obtained
Negotiate the agreement Send the final draft to the department to review
Review Attachment 2 of the Research Award Agreement (if applicable) and determine if automatic carryforward has been marked "Yes" or "No". If it has been marked "No", and you see the Prime Sponsor grants automatic carryforward, request the Flow Through Sponsor grants UTSW carryforward. Receive the fully executed agreement
Ensure invoices are required to be due toward the end of the month. The 20th or later would be ideal and helpful to the Billing/Accounts Receivable group. Update the Denzel log
Invoices should reference the subaward number and purchase order
Provide the fully executed agreement to RAA Team for new award set up
Include copy of invoice template
Fixed - Per Patient Contracts - budget is not needed since it is not known how many patients will be enrolled - Request department include startup costs (Administrative Costs associated with the project) If there are no startup costs, the department will only need $1 in the budget to push it to eGrants
FLOW THROUGH AWARD COMPLETED BY: SPA SELF-AUDIT BY:
DATE COMPLETED AND CHECKLIST SCANNED INTO ONBASE: DATE:
Office of Business Affairs Sponsored Programs Administration
Subaward Issuance Checklist
Award ID: UTSW Subawardee Name:
Subledger #: Subawardee Principal Investigator:
Project #: Date of Budget Period:
Principal Investigator: Award Amount to Subawardee: $
Department/POD #: Subawardee F&A Rate:
Subawardee Email Address:
Notify SPA contracts of outgoing subaward Provide dollar amount of subaward
Provide award documents for flow through terms
Outgoing subaward checklist received from RAA? Determine whether carry forward is automatic or requires approval
Perform Risk Assessment Create GMO number for new outgoing subaward and place on FDP template
Send the following information to Subrecipient Create purchase order, encumber funds in PeopleSoft
___Subrecipient Profile Questionnaire Send completed package to subrecipient
___3B2 form to get subrecipients contact information ___New subrecipient welcome letter
___Attachment 4 & 5: Include Budget and Statement of Work ___Final contract forms
Confirm budget and project period dates and insert into subaward docs ___Sample Invoice template
Review Terms and Conditions on Notice of Award for any restrictions
Include CFDA# (If federal-found on NOGA)
Save copy of fully executed agreement in Onbase
OUTGOING SUBAWARD COMPLETED BY: SPA SELF-AUDIT BY:
DATE COMPLETED AND CHECKLIST SCANNED INTO ONBASE: DATE:
UT SOUTHWESTERN MEDICAL CENTER
SPONSORED PROGRAMS ADMINISTRATION
OUTGOING SUBAWARD CHECKLIST
THIS PORTION OF COMPLETED CHECKLIST SHOULD BE RECEIVED FROM RAA FOR EACH OUTGOING SUBAWARD
UNDER SEPARATE COVER
CHECKLIST BEGINS HERE - THINGS TO LOOK FOR AND VERIFY
Office of Business Affairs Sponsored Programs Administration
Subrecipient Welcome Letter
Office of Business Affairs Sponsored Programs Administration
UTS 142.1 Monthly Monitoring
Office of Business Affairs Sponsored Programs Administration
Monthly Monitoring Tool Set
Office of Business Affairs Sponsored Programs Administration
Monthly Monitoring Tool Set
Office of Business Affairs Sponsored Programs Administration
Quarterly Check in/Reconciliation
• “The Yellow Folder”
Office of Business Affairs Sponsored Programs Administration
PI Guidance on Allowable Costs for Sponsored Programs
Office of Business Affairs Sponsored Programs Administration
Direct Cost Justification Form
Office of Business Affairs Sponsored Programs Administration
Subrecipient Monitoring Plan
Office of Business Affairs Sponsored Programs Administration
Subrecipient Sample Invoice & Invoice Monitoring Guide
Office of Business Affairs Sponsored Programs Administration
Subrecipient Invoice – PI Approval
Office of Business Affairs Sponsored Programs Administration
Subrecipient Monitoring Record & Problematic Subrecipient Letter
Office of Business Affairs Sponsored Programs Administration
90-60-30 Day
Before Award End Date Notification
Office of Business Affairs Sponsored Programs Administration
25-50-75 Day After Award End Date/Award Closeout Notification
Office of Business Affairs Sponsored Programs Administration
Award Closeout Checklist
Office of Business Affairs Sponsored Programs Administration
Sponsored Programs Administration Contact Information
Contact Us • Phone: 214-648-0860 (Main Line) • Fax: 214-648-0873 • Website
General Inquiry Email: [email protected] • For SPA Outreach, please send an email to [email protected] or
submit a ticket through ServiceNow. Physical Location UT Southwestern Medical Center Paul M. Bass Administrative & Clinical Center 6363 Forest Park Road, BL2.103 Dallas, TX 75390-9020
Hours of Administrative Operations: Monday - Friday, 8 a.m. to 5 p.m.