congratulations! you have an award! now what?research.unm.edu/sites/default/files/ras2018... · •...
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CONGRATULATIONS! YOU HAVE AN AWARD! NOW WHAT?Rebecca ValdezFiscal Services Supervisor; Office of Sponsored Projects – Award Team
Shawnee MartinezSenior Sponsored Projects Specialist; Office of Sponsored Projects – Award Team
Denise VigilAccountant III; Contract & Grant Accounting
Teresa HammittFiscal Services Supervisor; Contract & Grant Accounting
2018 Research Administrators Symposium | September 25, 2018 | Breakout Session B
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Award Flow Chart
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Notice of Award (NOA)What is a Notice of Award?• A Notice of Award, NOA or award letter is notification from a sponsor
indicating that a proposal has been funded.
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How and who receives the NOA
How is a Notice of Award received?• A NOA can be received
• Via email directly from the Sponsor • Through a web portal (Example: DOE awards are retrieved from
PAMS and/or FedConnect; NSF awards are retrieved from Research.gov)
• U.S. Mail
• Who receives the NOA?• The Principal Investigator (PI)• The PI and the Office of Sponsored Projects (OSP)• OSP• Email all award documents to [email protected] for review and
processing
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Award Negotiation and Acceptance
Review Terms and Conditions and Negotiate Acceptable Terms
• Before accepting an award on behalf of the University, OSP reviews all award documentation and negotiates terms and conditions (T&C) with the sponsor as appropriate and acceptable terms.
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Award Review
• General Information• Investigators/Research
Team• Budget• Conflict of Interest• Regulatory Compliance• Subcontractors• Export Control
• Intellectual Property• Location of Sponsored
Activities• Proposal Abstract• Proposal Attachments• Approving Units• Additional Notes
Review the Cayuse RecordReview the “Item List” in the Cayuse Record containing:
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Award ReviewReview NOA• Sponsor Name• Prime Sponsor Name• PI Name• Period of Performance (POP)• Award Dollar Amount• Federal/State/Local Regulations• Instrument Type: Contract, Grant, Cooperative Agreement, Unfunded
Agreement or Property Agreement
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Award ReviewReview Compliance – Office of Sponsored Projects works with Office of Research & Compliance (ORC)• Financial Conflict of Interest Disclosure (FCOI) –PI’s private
interests may compete with his or her professional obligations to UNM. FCOI is required annually.
• Public Health Service Disclosure (PHS) – required for Public Health Agency awards (i.e. NIH, CDC, FDA, IHS)
• Institutional Review Board (IRB) –required for human research
• Research Integrity – required for all NSF, NIH and NIFA awards that support new-career Investigators, Postdoctoral researchers and Graduate/Undergraduate students
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Award ReviewReview Compliance – Office of Sponsored Projects works with Industrial Security Department• If a project has international travel, collaboration,
publication, shipments and foreign nationals involved in the project then an Export Control Exclusion Screening Form (ECES Form) needs to be submitted to OSP.
• OSP will review and email the Export Control Officer to review the ECES Form.
• Once the ECES Form is reviewed and approved by the Export Control Officer then the award will be processed further by OSP.
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Award ReviewReview Compliance – Office of Sponsored Projects works with Supporting Technology Transfer And Catalyzing Economic Development At The University of New Mexico (STC)• STC protects the invention with Intellectual Property
(Patents, Trademarks, Copyrights and Trade Secrets).• UNM faculty should disclose an invention at Proposal
Stage before the details of the invention are publicly made.
• OSP will notify STC if the research has potential for a patent.
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Award Review
Review Compliance – Office of Sponsored Projects works with Institutional Animal Care and Use Committee (IACUC)
• IACUC requires that an Animal Protocol be submitted for all educational, research, teaching and testing projects that utilize live animals or (non-living) tissues from species.
• IACUC Approval Letter is required for animal research.
• PI must submit an IACUC Approval Letter to OSP.
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Award Review
Review Budget
§200.8 Budget per Uniform GuidanceBudget means the financial plan for the project or program that the Federal awarding agency or pass-through entity approves during the Federal award process or in subsequent amendments to the Federal award. It may include the Federal and non-Federal share or only the Federal share, as determined by the Federal awarding agency or pass-through entity.
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Award ReviewBudget Template When are these templates used?
At proposal stageExcel templates can be found on OSP’s website:
http://osp.unm.edu/forms/index.htmlTwo versions
Budget Template FY19Budget Multi PI Template FY19
Used to determine the followingWho’s working on the projectWhat’s their base salaryWhat’s their level of effortHow much is the applicable fringeOther direct cost categories
Used at the proposal stage to help determine what is awarded, however, once awarded, then we must have an ABS on file.
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Award ReviewAward Budget Sheet (ABS) When is this budget used?
At award stageExcel template can be found on OSP’s website:
http://osp.unm.edu/forms/index.htmlShould be received at time of award, prior to routing to C&G for index setup.PI Org Code is needed to create an index number.Department cannot spend on index until an ABS is received.
IMPORTANT NOTE:The ABS must match the award document. Careful review should be done to determine that budget categories on the ABS align with the award document and that dollar amounts are correct.
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Award ReviewCost Share Budget (CS) When is this budget form used?
When cost share is required on the award
Excel template can be found on OSP’s website:
http://osp.unm.edu/forms/index.html
Should be received at time of award, prior to routing to C&G for index setup.
IMPORTANT NOTE:The cost share budget should agree with the obligated cost share required within the award document. Unrecovered F&A should be factored in if allowed.
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Award Review – Compliance Review Email Template
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Award Negotiation and AcceptanceSignature Authority• UNM receives NOA from the Sponsor• Sponsored Projects Specialist (SPS) reviews the NOA• Reviews the Terms & Conditions (T&C)• Once T&C are negotiated and accepted • SPS routes the Award to collect signature from the signature
authority on behalf of the University• Once signature is collected, the SPS emails the Sponsor a
Partially Executed (PE) copy• SPS awaits a Fully Executed (FE) copy and will follow up
weekly until received• Once a FE copy of the award is received then it is ready for
award setup
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Award Setup
Award Setup in Cayuse• Proposal is now awarded and assigned an “A” number for the project.
• Example: Proposal 18-1210 is awarded and is assigned as Award No.A19-0074 for the project.
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Award Setup Modifications• Review the NOA for dollar amount and POP • Request an ABS from the PI• Route the modification to UNM’s Authorized
Signatory• Email the sponsor a partially executed copy or
fully executed copy• Once the modification is fully executed, OSP
can process further then route to Contract and Grant Accounting (CGA) to update Banner
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Award Setup Subawards• PI submits Subaward Request Form (SRF) to Contract &
Grant Accounting• CGA reviews and signs. Once all signatures are
collected the SRF is routed to OSP for processing. • Per the information provided on the SRF and
Amendment is drafted and emailed to the Sponsor for signature.
• Once received back from the Sponsor, the partially executed (PE) Amendment will be routed to UNM’s Authorized Signatory for signature.
• The fully executed (FE) Amendment is emailed to the Sponsor, processed by OSP and routed to CGA for processing.
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OSP Award Team Services Services Provided:• Assistance in ensuring that Terms & Conditions comply with
applicable federal, state and local laws. As well as Sponsor guidelines and University policies.
• Request No Cost Extensions (NCE), Budget Revisions, PI Change and Award Transfers on behalf of the PI’s and Departments to the Sponsoring Agency.
• Provide institutional certification and/or assurances when required.• Facilitate signature and finalization of awards.• Serve as a liaison between PI/Departments and the Sponsor to
resolve award-related concerns and issues. • Coordinate with other internal core offices for compliance (i.e.
Office of Research Compliance, Industrial Security Department, Institutional Animal Care and Use Committee etc.)
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OSP Awards Team Contact Information
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Contract & Grant Accounting’s turn!• Review
• Supervisor Review• Budget• Special Terms & Conditions• Reporting & Invoicing
• Set-up• NEED PI ORG CODE!!!• INDEX NUMBER RECEIVED!
• Communication• Email - Includes special notes
regarding award• Signature Authorization Form
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Monitoring the Award
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Financial Research Compliance
2 CFR 200.403: Allowability
• Necessary, reasonable, and allocable• Conform with UG, including period of
performance• Consistent treatment with policies and
procedures• Comply with GAAP• Not to be used to meet cost sharing or matching
requirements• Adequately documented
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Financial Research Compliance2 CFR 200.404: Reasonable
• A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost.
• Ordinary and necessary• Sound business practices, arm’s-length
bargaining• In accordance, with laws, policies, market
conditions
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Financial Research Compliance
2 CFR 200.405: Allocable
• A cost is allocable to a particular award if the goods or services involved are chargeable to that award.
• The cost has been incurred solely to advance the work under the sponsored agreement
• It benefits both the agreement and other work of the institution
• It is necessary to the overall operation of the institution and is deemed to be assignable in part to sponsored projects.
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• University Policy – 4030
• On ALL expenditures
• State WHY the payment is being requested
• State HOW the payment benefits the project
• Merely re-stating what is being purchased is not adequate
Business Purpose
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Cost Transfers
• All transfers must be allowable, reasonable, allocable, and timely.
• UNM Policy 2450• Description of the cost (Original document #
and posting date)• Reason for the transfer• Explanation as to HOW the receiving
sponsored award benefits from the cost• Justification of allowability of the cost to the
receiving sponsored award
• 90 Day Memo
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Cost Transfers
• Compliance Risk – BIG RED FLAG• Cost transfers are always an audit target and can be a
significant compliance risk.• numerous cost transfers• cost transfers with insufficient documentation• cost transfers made more than ninety (90) days after original charge• cost transfers made more than sixty (60) days after the end date of
the award• cost transfer decisions based on available funding (caution: do not
move a charge from one award to another because one is short of funds while the other has available funds)
• inappropriate effort certification for redistributed salaries
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Budget Revisions
• If expenditures are not on budget• Check Terms & Conditions of award• Check Budget Justification• Check Expanded Authority Matrix
cgacct.unm.eduPoliciesFederal AgenciesFederal-Wide Research Terms and ConditionsPrior Approval Matrix
• Procedure for Budget Revisions• IBR• Fiscal Monitor reviews to determine if
Agency approval required
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Budget Revisions
• Approval always required from agency:• Change in scope• Reduction of Key Personnel by 25%• Transfers from Participant Support• Subawards and some Consultants• Changes in the approved cost-sharing or
matching amount• Adding additional funds to the award• Pre-award costs more than 90 calendar
days before the Project Start Date• Extra Compensation
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Recent NSF-OIG Audit Findings• Unreasonable Equipment
“The timing of the purchase… leads us to conclude that the purchases were not necessary, reasonable, or prudent for the administration of the award.”
• Participant SupportParticipant Support was reallocated for travel to a workshop. Verbal – but not written – approval was received from agency.
• Advertising Costs at the end of the award“The late purchase date leads us to believe that the purchases were not necessary, reasonable, or prudent for the administration of the award.”
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• Excessive Meal CostsMeals charged at an advisory board meeting were far greater than GSA per diem rate for meals.
• Unsupported Cost Transfer“We were unable to obtain appropriate evidence to support a journal entry posted by UNM.” It “was not adequately supported and, therefore, not in compliance with Federal regulations.”
• Unreasonable Travel• Trip to Europe where 14 of the 16 days were personal days.
A portion of the airfare was disallowed.• Trip to discuss new award collaborations along with
discussion of award items.
Recent NSF-OIG Audit Findings
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Other Special Attention Items• Key Personnel• Tuition as compensation
(20A1)• Late purchases of
materials and supplies• Subaward Invoices• Burn Rate• Cost Share spending• Program Income
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Workflow – Is the award closing?
• Extensions• From Fiscal Monitor to OSP• OSP starts process
• NSF – FastLane done by PI
• Updates into Banner automatically once extension received
• Closeouts• Allows Fiscal Monitor to begin
reviewing
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Closing the Award• Expenditures posted and reviewed
• Closeout Reconciliation Form returned
• Non-Technical Report• Patent• Materials & Supplies ($5K retainage)• Acct 9060 – Fabrication completed
and moved to 9000• Property Location Verification
• Technical/Final Report• Have any financial information
reviewed by Fiscal Monitor• Verification from PI report has been
completed
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Closing the AwardTimeline
Through-outAward
30-180DaysPriortoEnd EndofAward
30DaysAfterEnd
60DaysAfterEnd
90DaysAfterEnd
NOTE:Basedontypical90daycloseout-someawardsrequireearliercloseout
Department-PI Full ExceptionsFiscalMonitor Full Modified
InterimReporting-Non-Technical
InterimReporting-Technical
FinalReviewofTransactions
MonitoringofAward
FinalPostingofTransactions
ReviewofChargesAfterEndDate
VerificationReviewforReporting
FinalReporting-Non-Technical
FinalReporting-Technical
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Questions???