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I have the grant, now what!?. Presented by John Hulvey, Director Sponsored Programs Admin & Accounting. Introduction. This presentation covers: Understanding the basics Common Misconceptions What’s the PI’s role? What’s Sponsored Programs Accounting’s Role? Expenditure Compliance
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I have the grant, now what!? Presented by John Hulvey, Director Sponsored Programs Admin & Accounting
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
Vocabulary • Department ID = Org. Code = Grant Number • Account # = Expenditure Code • PI = Principal Investigator • Facilities and Administration (F&A) (indirect costs or “overhead) • FinanceSystem = General Ledger
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.”
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 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 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 A-110 independently • Code of Federal Regulations (CFR) • Regulations apply to federal agency, applied 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 • 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 • 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
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)
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
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)
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.
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
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
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.
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.
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
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’ • 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
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.
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
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 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
Where to Get More Information • Sponsored Program Accounting - MSC 5713 JMAC Building 6, Suite 30 • John Hulvey • 83725 hulveyjd@jmu.edu • Brenda Wilburn Seifried • 82314 wilburbc@jmu.edu • Donna Crumpton • 88099 crumptdl@jmu.edu • Kyra Shiflet • 87108 shiflekl@jmu.edu