I have the grant, now what!? Presented by John Hulvey, Director
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I have the grant, now what!? Presented by John Hulvey, Director
I have the grant, now what!? Presented by John Hulvey, Director Sponsored Programs Admin & Accounting 1 Introduction This presentation covers: – Understanding the basics • Common Misconceptions – What’s the PI’s role? – What’s Sponsored Programs Accounting’s Role? – Expenditure Compliance – Reading PS Financial Reports – “Gotcha’s”! & Summary 2 Vocabulary • Department ID = Org. Code = Grant Number • Account # = Expenditure Code • PI = Principal Investigator • Facilities and Administration (F&A) (indirect costs or “overhead) • Finance System = General Ledger 3 Common Misconceptions • All sponsored program awards are “grants.” – Also Contracts and Cooperative Agreements • That funds are totally controlled by the PI. – JMU Policy 2201 states “All funds received for sponsored programs are under the fiscal control of the assistant vice president for finance.” 4 Common Misconceptions • That we can change the scope of work or use of funds without the sponsor’s permission. – Must be good stewards of the funds; they were given for a purpose. • There is a ‘pool of money’ with an award. – Most cash is received on an expenditure reimbursement basis. – Sponsor may refuse to reimbursement 5 unallowable expenses Common Misconceptions • Standard JMU rules don’t apply to these funds. – Very wrong; in fact, control over expenditures may be more strict. – Everyone wants to add a regulation! • Specific grant instructions; JMU policy (2201 states awards must follow JMU procedures); state regulations; federal 6 regulations; federal law. Common Misconceptions: The rules don’t apply (continued) • Grants & Coop Agreements are governed by OMB Circular A-21; Contracts by FAR clauses (Federal Acquisition Regulation). • Costing standards and allowable costs • All awards governed by A-110 • Administrative requirements • Federal Agencies “codify” FAR and A110 independently • Code of Federal Regulations (CFR) • Regulations apply to federal agency, applied 7 to award recipients through CFR What’s the PI’s Role? • Person of many hats – Researcher, Manager, Accountant. • Has DIRECT responsibility for award – Must complete responsibilities of award – Must work within approved budget – Must ensure “Matching” is met and “Effort” is applied – Maintain Adequate Documentation 8 – May delegate workload What’s Sponsored Programs Accounting’s Role? • Establish Financial Framework – Department ID(s); Budgets • Maintain ‘auditable’ file • Post-award compliance officers for the University • Billing/Collection from Sponsors • Prepare Financial Reports 9 • Timely close-out of grant Purchasing Rules • Same for Grants as other University funds – (Unless stated in Award) • May actually be more restrictive – Must relate to grant work & budget. – Must comply with A-21 or FAR regulations – No Membership fees, subscriptions 10 Purchasing Rules • EVa must be used • SP Cards must be used & reconciled • Forms: – – – – – Accounting Voucher Travel Authorization Travel Reimbursement Voucher Agency Transfer Voucher (ATV) Personnel Action Request (PAR) 11 Procurement Rules • Required for all purchases of goods and services $5000 or more. • Must use Va State Contracts • Some procurements can be built into the Sponsored Program as a Sub-agreement 12 Expenditures (Travel and Business Meals) • This is one area where otherwise rational people loose their minds with Sponsored awards!! • Simply stated: VA State (JMU) rules apply (Unless specifically addressed in the award) 13 Expenditures (Travel and Business Meals) • Common Unallowable Expenses: – A business meal with no non-JMU employee attending (this is a “meeting”, not a “business meal”) – ‘Pizza parties’ for student employees – Staying at over-priced hotels or eating at over-priced restaurants. – Charging a rental vehicle when cab fare to and from the airport was reasonable. • This is particularly obvious when the family accompanies the traveler to the conference. 14 Additional Travel Regulations • Foreign flights (Coach Class) – Must be on US flag bearer when using Federal dollars! • Cost is not a factor; however, there are some exceptions related to service destinations or arrival/departure times • Use a JMU authorized Travel Agency and indicate “Fly America Act” must be followed – JMU approval still needed for Travel Authorizations • Not automatic with the sponsored program award 15 Personnel Considerations • Employee vs. Contractor – Has bearing on taxes withheld – What ‘control’ exists over person? • See 20 questions on Payroll Website • If in doubt, contact Payroll • Must follow immigration rules to hire non-US Citizen on Award – Contact office of international programs with questions 16 F&A (Facilities and Administration) • Part of the award budget – Seldom reduces direct expense budget • 50% returned to Institution – 30% Department; 10% Dean; 10% Provost – Must be spent in support of Grants • Withheld from award budget loaded to Finance System. – Budget then increased with each monthly F&A charge. 17 Matching (Cost Sharing) • Mandatory vs. Voluntary – Voluntary Match is discouraged by University policy and restricted by some funding agencies • What is allowed? – Must have a basis for value – Space/Equipment must be 100% designated to the project. – Must be documented / reported at the conclusion of the project. 18 Effort • Percentage of time applied to a project related to all PAID JMU activities. – Must ALWAYS equal 100% – Does not change based on number of hours worked – Cannot ‘over commit’ effort – JMU certifies effort each semester 19 Why should the PI keep records? • PI’s responsibility! (Stewardship) – Like reconciling a checkbook – Tie expenditures to award budget • Ensure accuracy of keyed data • Track Timing differences • Track ATV (automatic) charges – Postage, telephone, Copy Center, JMU car rental • Document ‘matching’ and ‘effort’ 20 • Up to 5 year record retention Budget Revisions • May require sponsor’s written approval • Processed through Office of Sponsored Programs • PI must justify how a budget line can be reduced and how the new budget would improve the project 21 Close out • Most projects have defined ending date where work must be completed and expenditures incurred – Processing of incurred expenditures generally may continue after project end-date, but NO NEW expenses. • PI records are a MUST at this time and are difficult to construct if not already prepared. 22 Close out (No cost extension?) • PI should request a ‘no-cost extension’ through Office of Sponsored Programs if needed – At least 30 days before the project end date – Not just for convenience or to spend remaining funds 23 GOTCHA’s • Timing of transactions to General Ledger • Grant Period ending before project is done • Forgetting that FICA is added to Lump Sum salary amount on PAR form • Not following the awarded 24 budget and budget justification Summary • Generally, JMU rules apply • Buck stops with PI (and department) • Sponsored Programs Accounting provides assistance and reviews for compliance • When in doubt, refer to the award 25 Where to Get More Information • Sponsored Program Accounting MSC 5713 JMAC Building 6, Suite 30 • John Hulvey – 83725 [email protected] • Brenda Wilburn Seifried – 82314 [email protected] • Donna Crumpton – 88099 [email protected] • Kyra Shiflet – 87108 [email protected] 26