Sponsored Programs Administration Uniform Guidance ...

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


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


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

http://www.utsouthwestern.net/intranet/administration/sponsored-programs/research-lifecycle/award-management/uniform-guidance.html


A QUICK HISTORY LESSON


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.


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.


OPPORTUNITY TO REDUCE BURDEN


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

http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2887040/

http://sites.nationalacademies.org/cs/groups/pgasite/documents/webpage/pga_087667.pdf


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


From: Federal Demonstration Partnership September 4, 2015 Meeting presentation.


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.


UG COMPENSATION COMPLIANCE


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.


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)


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


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



(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


(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.


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


(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.


Translated

• Allows distribution to be expressed as a % of the total

• Precise estimates for IHEs is not expected


• (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.


Translated

• If meet these standards, no additional support documentation required

• FLSA documentation still required for non-exempt employees


•(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.


Translated

• Treat cost sharing the same

• Propose alternatives to your cognizant agency

• If you don’t do this = additional sanctions


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!


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


INTERNAL CONTROLS


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


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


Internal Controls


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




Risk Assessment

• Internal review

• Post period sampling

• Are re-certifications (“re-dos”)

allowed? Under what

circumstances?




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?




Information and Communication

• Method of communication

• Frequency of communication

• Who is involved in the process?

• How is information disseminated to

all groups?




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




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.


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


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

http://www.utsouthwestern.net/intranet/administration/sponsored-programs/doclib/pi-all-funds-admin-report-user-manual.pdf







http://www.utsouthwestern.net/intranet/administration/sponsored-programs/doclib/monthly-financial-review-toolset-guide.pdf

http://www.utsouthwestern.net/intranet/administration/sponsored-programs/research-lifecycle/award-management/peoplesoft-resources.pdf


AWARD MANAGEMENT & AWARD CLOSEOUT

Supplemental Information – Will not be presented


The Big Picture


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


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


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


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


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


Award Closeout Timeline


HIGHLIGHTED ELECTRONIC TOOLS


PI All Funds Report: PI Quick Glance View

Office of Business Affairs


PI All Funds Report: PI View Summary



PI All Funds Report: Admin View



PI All Funds Report: Pending Salary by Person



PI All Funds Report: Pending Salary by Award



PI All Funds Report: Funds Expensed by Month



Award Burn Rate Report


Subrecipient Issuance – Risk Assessment


Grant Notification Email Award Activation


Grant Notification Receipt Award Information


Grant Notification Receipt Amendments/Certifications/Additional Information/Project Details


Grant Notification Receipt Terms and Conditions/Project Activity Details/F&A Details


Grant Notification Receipt Budget Details/Subledger number/Future anticipated funding


Weekly Outreach Email – Subledger Notification Summary


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:



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:


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


Subrecipient Welcome Letter


UTS 142.1 Monthly Monitoring


Monthly Monitoring Tool Set


Quarterly Check in/Reconciliation

• “The Yellow Folder”


PI Guidance on Allowable Costs for Sponsored Programs


Direct Cost Justification Form


Subrecipient Monitoring Plan


Subrecipient Sample Invoice & Invoice Monitoring Guide


Subrecipient Invoice – PI Approval


Subrecipient Monitoring Record & Problematic Subrecipient Letter


90-60-30 Day

Before Award End Date Notification


25-50-75 Day After Award End Date/Award Closeout Notification


Award Closeout Checklist


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.

mailto:https://myutsouthwestern.swmed.edu/intranet/administration/sponsored-programs/,DanaInfo=www.utsouthwestern.net+

mailto:[email protected]



https://utsw.service-now.com/ess/

Sponsored Programs Administration Uniform Guidance ...

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