Overview of rules, regulations, and procedures Overview of rules, regulations, and procedures necessary to manage an externally funded necessary to manage an externally funded projectprojectReview Principle Investigator’s (PI) Review Principle Investigator’s (PI) responsibilitiesresponsibilitiesSummary of information of PIs necessary Summary of information of PIs necessary responsibilities responsibilities Understanding “why” this is importantUnderstanding “why” this is important

URSA provides faculty support for proposal URSA provides faculty support for proposal preparation, awards management, research preparation, awards management, research compliance and safety, and other aspects of compliance and safety, and other aspects of research research

Awards managementAwards managementWho we are (org chart; department Who we are (org chart; department assignments)assignments)Manuals, policies, formsManuals, policies, formsWebsite at: Website at: www.gsu.edu/research/index.htmlwww.gsu.edu/research/index.html

Office of Sponsored Programs (OSP)Office of Sponsored Programs (OSP)Marca Gurule, Associate DirectorMarca Gurule, Associate DirectorHandles non-financial aspects of grants Handles non-financial aspects of grants

managementmanagementAny official contact with agency officialsAny official contact with agency officials

Research Financial Services (RFS)Research Financial Services (RFS)Michael Mathisen, Associate DirectorMichael Mathisen, Associate DirectorAccounting of expendituresAccounting of expendituresGenerating financial reportsGenerating financial reports

A sponsor awards Georgia State University A sponsor awards Georgia State University Research Foundation (GSURF) that subcontracts Research Foundation (GSURF) that subcontracts out to Georgia State University’s (GSU) fundsout to Georgia State University’s (GSU) fundsExpectation is that GSU has policies and Expectation is that GSU has policies and procedures in place to make sure funds are procedures in place to make sure funds are spent according to Federal guidelines and are spent according to Federal guidelines and are not misusednot misusedAuditors come on campus to checkAuditors come on campus to checkRoles and Responsibilities of Georgia State Roles and Responsibilities of Georgia State University Employees Engaged in Sponsored University Employees Engaged in Sponsored Project Management and Oversight are on Project Management and Oversight are on URSA’s websiteURSA’s website

Notice of AwardNotice of Award

Getting an Account NumberGetting an Account Number

Terms & Conditions of AwardTerms & Conditions of Award

Both PIs and OSP may receive notificationsBoth PIs and OSP may receive notificationsIf PI only receives, then must send to OSP within 7 daysIf PI only receives, then must send to OSP within 7 daysOSP will likewise send to PIOSP will likewise send to PINegotiations:Negotiations:

Changes in budget by sponsor may mean PI wants Changes in budget by sponsor may mean PI wants to make changes in goals/scope of work to make changes in goals/scope of work Done by PI, in consultation with OSP and Legal Done by PI, in consultation with OSP and Legal Affairs (if contract)Affairs (if contract)All All majormajor changes to budget should be “re-routed” changes to budget should be “re-routed” using Proposal Approval Formusing Proposal Approval Form

Don’t announce to public until get “official Don’t announce to public until get “official notification” (and agency allows you)notification” (and agency allows you)

Notice of Grant Award (NGA)Notice of Grant Award (NGA)LetterLetterCheckCheckContractContractPIs are not the “authorizing official” of GSU OR GSURFPIs are not the “authorizing official” of GSU OR GSURFCan’t sign anything for UniversityCan’t sign anything for University

Must get IRB/IACUC approval prior to Must get IRB/IACUC approval prior to establishment of project numberestablishment of project numberCan get approval for general methods and Can get approval for general methods and make amendments latermake amendments laterLetters of cooperation from sitesLetters of cooperation from sitesObligated to comply with all regulations Obligated to comply with all regulations involving human subjects, animals, health and involving human subjects, animals, health and safety. Get copies of compliance letters from safety. Get copies of compliance letters from subcontractors, other sitessubcontractors, other sites

Proposal Approval FormPI certified to adherence of GSU’s:

Conflict of Interest PolicyIntellectual Property PolicyTerms and Conditions of AwardFollow all relevant GSU, State of Georgia, Federal laws, and regulations

11

How is the Regulatory Hierarchy Determined?How is the Regulatory Hierarchy Determined?

OMB Circulars A-21 or A-122, A-110, & A-133OMB Circulars A-21 or A-122, A-110, & A-133

Agency Policy Manual (i.e. NIH GPS, Agency Policy Manual (i.e. NIH GPS, NSF GPM, DHHS, & Selected FAR NSF GPM, DHHS, & Selected FAR

ClausesClauses

University’s University’s Policies and Policies and ProceduresProcedures

Terms and Conditions of Terms and Conditions of Award NoticeAward Notice

YouYou

““Green Sheet” issued by OSPGreen Sheet” issued by OSPDone after official NOA & Compliance Done after official NOA & Compliance requirementsrequirements

Based on information from Proposal Based on information from Proposal Approval Form & NOAApproval Form & NOA

Speedtype or Project IDSpeedtype or Project IDSP000 plus 5 numbers (e.g., SP00010111)SP000 plus 5 numbers (e.g., SP00010111)

OSP & RFS Officers OSP & RFS Officers

Account numbers – code source of fundingAccount numbers – code source of fundingFederal, state, nonprofit, and for-profit Federal, state, nonprofit, and for-profit

Types of projects Types of projects Research, basic, and appliedResearch, basic, and appliedInstructionInstructionOtherOther

Budget categories set up based on awarded Budget categories set up based on awarded budgetbudget““Funded” based on annual budget, even if Funded” based on annual budget, even if awarded 5 yearsawarded 5 years

Cost sharing is when PIs commit “other” Cost sharing is when PIs commit “other” resources to pay for some of the costs resources to pay for some of the costs associated with a sponsored projectassociated with a sponsored project

Noted on Proposal Approval Form and Noted on Proposal Approval Form and submitted budget or just in the narrativesubmitted budget or just in the narrativeShould only do it when is requiredShould only do it when is requiredBut, if in proposal, must documentBut, if in proposal, must documentCan cost share anything that can be a direct Can cost share anything that can be a direct cost on a projectcost on a project

Companion accounts for cost shareCompanion accounts for cost shareMust have funds transferred using a budget Must have funds transferred using a budget amendmentamendment

Project reports (both technical and financial)Project reports (both technical and financial)Close outClose outCost accounting principlesCost accounting principlesRequirements regarding making changes to Requirements regarding making changes to original proposal (original proposal (Prior ApprovalPrior Approval) ) Some changes PI can make without any approvalSome changes PI can make without any approvalSome changes require approval from sponsorSome changes require approval from sponsorExpanded authorities (Federal Awards) Expanded authorities (Federal Awards) authorizes institution (via OSP) to approve some authorizes institution (via OSP) to approve some changeschanges

Need agency approval for:Need agency approval for:Change in scope or specific aimsChange in scope or specific aims

Change in methodology (may not need Change in methodology (may not need approval)approval)Change in Key Personnel. PI always needs OSP Change in Key Personnel. PI always needs OSP and agency approval. Other personnel and agency approval. Other personnel depends on T&Cdepends on T&C

Expanded authority allows expenditures 90 Expanded authority allows expenditures 90 days before start date for Federal grantsdays before start date for Federal grantsNeed to set up account through Institutional Need to set up account through Institutional Prior Approval System (IPAS) Prior Approval System (IPAS) Pre-Award (defined as period before official Pre-Award (defined as period before official start date)start date)Advance Account (prior to receiving official Advance Account (prior to receiving official notification)notification)Requires chair and dean authorizationRequires chair and dean authorization

Available under Awards Management:Available under Awards Management:www.gsu.edu/research/awards_management.htmlwww.gsu.edu/research/awards_management.html

Select IPAS - Institutional Prior Approval FormSelect IPAS - Institutional Prior Approval Form

Depends on T&C: Make sure you know! Ask OSP!!! Depends on T&C: Make sure you know! Ask OSP!!! GSU requires an IPAS completed if change is more GSU requires an IPAS completed if change is more than 25% of a budget category than 25% of a budget category Expanded authorities allow change in expenditures Expanded authorities allow change in expenditures of a single cost category in original budget up to 25% of a single cost category in original budget up to 25% of the total costs. More need agency approvalof the total costs. More need agency approvalPurchase of equipment may need agency approval Purchase of equipment may need agency approval (NIH > $25,000) (NIH > $25,000) Travel may need approval (especially foreign)Travel may need approval (especially foreign)Can’t transfer between indirect and direct costsCan’t transfer between indirect and direct costsCan’t transfer from participant support costsCan’t transfer from participant support costs

Carryover of unobligated balances from one Carryover of unobligated balances from one budget period to another may be automatic budget period to another may be automatic (IPAS Form not necessary)(IPAS Form not necessary)NIH requires indication in progress report if NIH requires indication in progress report if estimated unobligated balance (including estimated unobligated balance (including prior-year carryover) is expected to be greater prior-year carryover) is expected to be greater than 25 percent of the current year’s total than 25 percent of the current year’s total approved budget approved budget

Expanded authorities allow request for one-Expanded authorities allow request for one-year no-cost extension past the project end year no-cost extension past the project end date (IPAS Form)date (IPAS Form)Must be “prior approval” request to OSP Must be “prior approval” request to OSP before end date of the grant and best if before end date of the grant and best if submitted one (1) month beforesubmitted one (1) month beforeAny further requests for no-cost extensions Any further requests for no-cost extensions must be done to the sponsor. Make request must be done to the sponsor. Make request through OSPthrough OSP

ExpendituresExpenditures

Federal Cost Accounting Principles Federal Cost Accounting Principles Costs charged to a sponsored project must Costs charged to a sponsored project must be directly beneficial to project:be directly beneficial to project:Personnel (salaries and fringe benefits)Personnel (salaries and fringe benefits)SubcontractsSubcontractsConsultantsConsultantsSupplies for researchSupplies for researchEquipment (more than $5,000)Equipment (more than $5,000)TravelTravel

Charge Costs that are allowable Direct Costs Charge Costs that are allowable Direct Costs are: are:

Reasonable:Reasonable: Would a reasonable person Would a reasonable person think this was a cost for this sponsored think this was a cost for this sponsored project?project?AllocableAllocable: Be attributable to project. But : Be attributable to project. But can be distributed proportionally between can be distributed proportionally between projects if use some reasonable basis for projects if use some reasonable basis for the distributionthe distributionAllowableAllowable: Must be a cost that is permitted : Must be a cost that is permitted to be charged as a Direct Cost to be charged as a Direct Cost

F&A also known as Indirect Costs F&A also known as Indirect Costs Costs to support research such as building Costs to support research such as building depreciation, libraries, operation and depreciation, libraries, operation and maintenance, general departmental maintenance, general departmental administration, and support for conducting administration, and support for conducting researchresearchPercentage of the Direct Costs Percentage of the Direct Costs Split between University and College/DeptSplit between University and College/DeptShould be used (to the extent necessary) to Should be used (to the extent necessary) to support projectsupport project

Examples of costs typically Examples of costs typically notnot charged as charged as Direct Costs because considered Indirect Costs:Direct Costs because considered Indirect Costs:

Administrative and Clerical CostsAdministrative and Clerical CostsPrinter Toner, Copy Paper, Copying CostsPrinter Toner, Copy Paper, Copying CostsCell Phones/Telephone serviceCell Phones/Telephone serviceRoutine PostageRoutine PostageGeneral Office Supplies and EquipmentGeneral Office Supplies and EquipmentComputers (unless scientifically justified)Computers (unless scientifically justified)PDAs/BlackberriesPDAs/Blackberries

If above “routine” use of these items (e.g., If above “routine” use of these items (e.g., distributing classroom material, surveys)distributing classroom material, surveys)Or project is considered a major project Or project is considered a major project (definitions in policy)(definitions in policy)Or need a computer for an exclusively Or need a computer for an exclusively scientific usescientific use

Justification establishes reason for exceptionJustification establishes reason for exceptionPutting item in approved budget not sufficientPutting item in approved budget not sufficientHave to include it in budget justification with a Have to include it in budget justification with a reason that indicates why it is an exception at reason that indicates why it is an exception at the time of application (so approved by the time of application (so approved by agency)agency)If not in approved proposal has to be reviewed If not in approved proposal has to be reviewed on a case by case basis by OSP Officeron a case by case basis by OSP Officer

Costs that are typically not allowed:Costs that are typically not allowed:Food Food Allowed when traveling away from ATLAllowed when traveling away from ATLFood for participants, typically an Food for participants, typically an

exception, but need to get sponsor exception, but need to get sponsor approvalapproval

Alcohol Alcohol Never allowed except for scientific Never allowed except for scientific purposespurposes

Follow GSU’s standard rulesFollow GSU’s standard rules

Expenses are audited for presence of Expenses are audited for presence of unallowable costsunallowable costsCharges at Staples, Office Depot, etc. are Charges at Staples, Office Depot, etc. are always suspectalways suspectNeed good documentation Need good documentation If no Indirect Costs charged to the project, If no Indirect Costs charged to the project, then okay then okay

Defined as Georgia State University’s Defined as Georgia State University’s Employees and must comply with GSU’s Employees and must comply with GSU’s Human Resource Policies:Human Resource Policies: FacultyFaculty Graduate StudentsGraduate Students StaffStaff

Commitment Commitment = payroll (salary) = effort= payroll (salary) = effortT&C will tell you who they consider T&C will tell you who they consider “committed”“committed”

PI and other faculty PI and other faculty Commitment is what you specified in your Commitment is what you specified in your grant application or approved budget grant application or approved budget (commitment is for the budget year) (commitment is for the budget year) Not specific to the academic year or summerNot specific to the academic year or summerSo “fulfill” your commitment anytime during So “fulfill” your commitment anytime during the budget yearthe budget year

Academic year, typically, corresponds to a Academic year, typically, corresponds to a course buyout but doesn’t necessarily have tocourse buyout but doesn’t necessarily have toSummer salary corresponds to how much you Summer salary corresponds to how much you are paid in the summer are paid in the summer Need to plan out budget year so fulfill Need to plan out budget year so fulfill commitmentscommitments

Commitment = Payroll (Salary)Commitment = Payroll (Salary)Many Federal agencies allow differences Many Federal agencies allow differences between commitment and actual effort to between commitment and actual effort to be 25% (commit 10% only work 8%)be 25% (commit 10% only work 8%)

Check terms and conditions of awardCheck terms and conditions of awardBut can’t change scope or specific aimBut can’t change scope or specific aimLarger change? Need to get agency Larger change? Need to get agency approval approval

Committed Effort % Actual Effort %

Committed Effort %

% Change in Effort

If more than 25% than have to ask permission from sponsor If more than 25% than have to ask permission from sponsor for reduction of committed effort “prior approval”for reduction of committed effort “prior approval”

Commit50%

Charge20%

Commit50%

60% Change in Effort

If more than 25% than have to ask permission from If more than 25% than have to ask permission from sponsor for reduction of committed effort “prior approval”sponsor for reduction of committed effort “prior approval”

Commit50%

Charge20%

Commit25%

Charge20%

Commit25%

20% Change in Effort

If more than 25% than have to ask permission from If more than 25% than have to ask permission from sponsor for reduction of committed effort “prior sponsor for reduction of committed effort “prior approval”approval”

Commitment = payroll (salary) = effortCommitment = payroll (salary) = effortPersonnel Effort Reporting is required to Personnel Effort Reporting is required to document effort spent on sponsored project document effort spent on sponsored project Certify % of effort spent on projectCertify % of effort spent on projectTypically corresponds to % of salaryTypically corresponds to % of salary

ERS systemERS systemHappens 3 times a yearHappens 3 times a yearRequired for all personnel who are paid from Required for all personnel who are paid from a granta grantActs like a receiptActs like a receiptAll faculty certify their ownAll faculty certify their ownPI certifies everyone else (in grant)PI certifies everyone else (in grant)

Committed Effort (for budget year) =

Salary Charged (over budget year) = (within 25% of effort committed)

ERS System: Certify Actual Effort Certified (for semester worked)

(% charged = certified effort + 5% Total Effort)

No more than 50% time allowed (20 hours a No more than 50% time allowed (20 hours a week)week)Requirements for tuition waiverRequirements for tuition waiverRequirements for health careRequirements for health careHiring from outside your Hiring from outside your department/consultation with home department/consultation with home department department

Hiring new staffHiring new staffNamed in grant can immediately hireNamed in grant can immediately hireSponsored funded positions (employment only Sponsored funded positions (employment only and until have funds)and until have funds)Vacation timeVacation time terminates at end of grant terminates at end of grant Expedited procedure; if use approved positions Expedited procedure; if use approved positions described on URSA’s website (and HR’s described on URSA’s website (and HR’s website)website)

Advertising positions: new proceduresAdvertising positions: new proceduresPersonnel Action Form (PAF)Personnel Action Form (PAF)Interviewing 3 peopleInterviewing 3 peopleCompletion of interview formsCompletion of interview formsHR/AA paperwork and reviewHR/AA paperwork and reviewBackground checksBackground checksApproval to offer positionApproval to offer position

Someone who is contributing expertise to Someone who is contributing expertise to projectprojectHourly, daily, or flat feeHourly, daily, or flat feeTravel/expenses can be paid as part of Travel/expenses can be paid as part of consultant payment or separately consultant payment or separately Cannot be a GSU employee or Co-PI on grantCannot be a GSU employee or Co-PI on grantFederal grants can’t pay Federal employeesFederal grants can’t pay Federal employeesState of GA employees & University system State of GA employees & University system need to use different consultant agreements. need to use different consultant agreements. Need to obtain permissionNeed to obtain permission

Policy and proceduresPolicy and proceduresExpedited procedureExpedited procedureDon’t have to interview or post positionDon’t have to interview or post positionCan be a Postdoc Associate (hired as staff with Can be a Postdoc Associate (hired as staff with fringe benefits) fringe benefits) Or, Fellows who are individuals with own Or, Fellows who are individuals with own funding paid as a stipend. Not paid GSU funding paid as a stipend. Not paid GSU fringesfringes

In general, GSU’s rules, regulations, and In general, GSU’s rules, regulations, and procedures govern non-sponsored expenses , procedures govern non-sponsored expenses , govern sponsored projectsgovern sponsored projectsFinance and Administration divisions. Forms Finance and Administration divisions. Forms and procedures:and procedures:

www.gsu.edu/finance/forms.html www.gsu.edu/finance/forms.html Business managers/post-award administrators Business managers/post-award administrators should helpshould help

Equipment is anything = $5,000 or moreEquipment is anything = $5,000 or moreAlso known as Capital EquipmentAlso known as Capital Equipment

Equipment belongs to GSU (not you or, Equipment belongs to GSU (not you or, typically, agency) typically, agency) State contracting (preferred vendors)State contracting (preferred vendors)Sole source bidsSole source bidsTax exempt form on Finance - Business Tax exempt form on Finance - Business ServicesServices

Participant support costs are those costs paid Participant support costs are those costs paid to (or on behalf of) participants in meetings, to (or on behalf of) participants in meetings, conferences, symposia, and workshopsconferences, symposia, and workshops

Registration fees, travel allowances, Registration fees, travel allowances, manuals and supplies, tuition, and stipends manuals and supplies, tuition, and stipends (no F&A charges)(no F&A charges)

Subject fees are payments made to human Subject fees are payments made to human subjects who are participating in your research subjects who are participating in your research to compensate them for their time to compensate them for their time

Cash or gift cards. Refer to URSA WebsiteCash or gift cards. Refer to URSA Website

P’Cards are a method for making purchasesP’Cards are a method for making purchasesTraining required (but training geared to use Training required (but training geared to use with state funds; “allowable” not accurate with state funds; “allowable” not accurate for sponsored projects)for sponsored projects)Can only charge allowable direct costs Can only charge allowable direct costs (especially scrutinized by auditors)(especially scrutinized by auditors)Further info: Further info: www.gsu.edu/accounting/purchasing-pcard.htmlwww.gsu.edu/accounting/purchasing-pcard.htmlForms: Forms:

www.gsu.edu/accounting/purchasing-forms.htmlwww.gsu.edu/accounting/purchasing-forms.html

Handout has a checklist to differentiate the Handout has a checklist to differentiate the three ways people can be involved in a grantthree ways people can be involved in a grant

Individuals who are contributing expertise to Individuals who are contributing expertise to the projectthe projectMust have a consulting agreement if payment Must have a consulting agreement if payment over $5,000over $5,000Step by step guide available:Step by step guide available:

www.gsu.edu/accounting/payment-www.gsu.edu/accounting/payment-contrators-consultants.html contrators-consultants.html

Formal Agreement between GSURF and other Formal Agreement between GSURF and other institution institution Subcontract typically have a PISubcontract typically have a PITerms & Conditions of award apply to Terms & Conditions of award apply to subcontractsubcontractEven if got institutional support letter during Even if got institutional support letter during proposal process, once awarded, need to set proposal process, once awarded, need to set up formal subcontractup formal subcontractIf not part of original proposal, may have to go If not part of original proposal, may have to go back to the agency (depends on agency)back to the agency (depends on agency)

Complete request for subcontract form (OSP)Complete request for subcontract form (OSP)Need statement of work and budget for Need statement of work and budget for subcontractsubcontractOSP will, then, use a standard subcontract OSP will, then, use a standard subcontract form and submit form to the OSP office of the form and submit form to the OSP office of the PI’s institution to be processedPI’s institution to be processedCan only be for one year. Amended annually Can only be for one year. Amended annually by sending request for subcontractby sending request for subcontractIf want own terms, PI must work with OSP and If want own terms, PI must work with OSP and Legal dept and then get final approval by Legal Legal dept and then get final approval by Legal deptdept

Invoices from subcontractInvoices from subcontractResponsible for certifying programmatic Responsible for certifying programmatic aspects of subcontract aspects of subcontract

Did they do the expected work?Did they do the expected work?Responsible for certifying charges on invoiceResponsible for certifying charges on invoice

Are they reasonable, valid, etc.?Are they reasonable, valid, etc.?

Everyone, with fiscal responsibility, must review summary of Everyone, with fiscal responsibility, must review summary of budget monthlybudget monthlySpectrum (Peoplesoft) Drilldown Reports Spectrum (Peoplesoft) Drilldown Reports Difference between budget year and fiscal yearDifference between budget year and fiscal yearImportant to check what has been charged and what has not Important to check what has been charged and what has not been chargedbeen charged

Subcontract and consultant invoices (PI Subcontract and consultant invoices (PI responsible for ensuring work is completed and responsible for ensuring work is completed and expenses appropriate)expenses appropriate)P-Card Activity Log needs to be reconciled with P-Card Activity Log needs to be reconciled with VISA/Bill statement with receiptsVISA/Bill statement with receipts

Indirect Costs (F&A) not charged on participant Indirect Costs (F&A) not charged on participant support costs, equipment, and subcontracts support costs, equipment, and subcontracts above $25Kabove $25KVery important expenses are “properly” coded Very important expenses are “properly” coded because F&A is collected based on expense because F&A is collected based on expense codecode

Cost Transfer: Movement of expense(s) Cost Transfer: Movement of expense(s) between two different university account between two different university account numbersnumbersCharges should be moved within 90 days of Charges should be moved within 90 days of initial chargeinitial chargeExpenditure review should enable you to Expenditure review should enable you to catch errorscatch errors

Charges moved after 90 days require PI’s Charges moved after 90 days require PI’s signaturesignatureNo transfers, involving state funds, goes No transfers, involving state funds, goes beyond current fiscal year (July 1st)beyond current fiscal year (July 1st)Personnel charges can’t be changed over fiscal Personnel charges can’t be changed over fiscal years or overlap yearsyears or overlap yearsNo transfers allowed to a sponsored account if No transfers allowed to a sponsored account if expense is more than a year oldexpense is more than a year old

When error was discovered When error was discovered What the charge was for What the charge was for Why the charge was incorrectly madeWhy the charge was incorrectly madeHow it, specifically, relates to the sponsored How it, specifically, relates to the sponsored project account to which it will be transferred project account to which it will be transferred

Transfer costs on to a project: 1. Are charges Reasonable, Allowable,

Allocable, and consistently Treated?2. Over 90 days requires justification and is a

“red flag” to auditors3. Especially a problem if at end of the grant4. Dubiously looks as if you are just spending

the money$$

Progress ReportsFinal ReportFinancial reports

PI responsible for the “technical” contents of PI responsible for the “technical” contents of the reportthe reportIf required, Research Financial Services will file If required, Research Financial Services will file financial report or supply to you the financial financial report or supply to you the financial information; although you need to request for information; although you need to request for report report

Expenditures toward the end of the grant must Expenditures toward the end of the grant must be reasonablebe reasonableCost transfers should be minimizedCost transfers should be minimizedEverything needs to balanceEverything needs to balance

The Federal government’s auditors are very The Federal government’s auditors are very serious about institutions following the policiesserious about institutions following the policies

Florida International paid $11.5 million in Florida International paid $11.5 million in finesfinesUAB paid $3.39 millionUAB paid $3.39 millionNorthwestern $5.5 millionNorthwestern $5.5 million

DHHS OIG Work Plan:DHHS OIG Work Plan:Effort ReportingEffort Reporting

CommitmentsCommitments Was the Proposed Effort Met?Was the Proposed Effort Met? Are Faculty Overcommitted? Are Faculty Overcommitted? CertificationCertification Was the Certifier appropriate?Was the Certifier appropriate? Account for “All” activities?Account for “All” activities?

DHHS OIG Work Plan:DHHS OIG Work Plan:Effort Reporting Effort Reporting

AllocabilityAllocability Are Payroll Adjustments Are Payroll Adjustments

Appropriate?Appropriate? Do Administrative & Clerical Do Administrative & Clerical

Salaries Appear on Sponsored Salaries Appear on Sponsored Projects?Projects?

Timeliness Timeliness Why are there Delays in Why are there Delays in

Certifying Effort?Certifying Effort? Do Delays Indicate Bigger Issues?Do Delays Indicate Bigger Issues?

DHHS OIG Work Plan:DHHS OIG Work Plan:Cost TransfersCost Transfers Was the “How & Why Was the “How & Why thatthat

Occurred” documented?Occurred” documented? Are charges Reasonable, Are charges Reasonable,

Allowable, Allocable & consistently Allowable, Allocable & consistently Treated?Treated?

Did the PI “certify” the correctness of the Did the PI “certify” the correctness of the new charges to their sponsored project?new charges to their sponsored project?

Are processes changed to prevent future Are processes changed to prevent future cost transfers?cost transfers?

Minimize cost transfers and delays!!Minimize cost transfers and delays!!Review Green Sheets for initial Review Green Sheets for initial awardsawardsCheck project dates Check project dates Check project salary budgetCheck project salary budgetUpdate PAF as soon as possible – Update PAF as soon as possible –

minimize cost transfersminimize cost transfersComplete Monthly Expenditure Complete Monthly Expenditure ReviewReview

QuestionsQuestions ??