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TRANSCRIPT
Congratulations! You won a grant proposal
...now what?Post Doc WorkshopApril 19, 2017
Agenda• Introduction
• Understanding the Environment– Government– Agency– Award
• Implement your award– Cost Allowability– Prior Approvals– Budget Flexibility– Reporting Requirements– Procurement Requirements– Subaward Monitoring
• Close out Process
• Review
Introduction• Why is this important?
– 44% of Carnegie funding comes from external sources – 9 month salary for most Universities– Endowments everywhere are facing additional pressures-‐‑ not able to fund everything
• Focus on federal funding-‐‑ but the building blocks will apply to all awards
• Interactive• Ask questions• May not have all the answers-‐‑ but I will get them for you!
Understanding the EnvironmentGovernmentAgencyAward
Guidelines: Government1. Cost Principles2. Administrative Requirements
1. Financial Management2. Cost Sharing3. Budget Revisions4. Prior approval requirements5. Program Income6. Property7. Procurement8. Closeout9. Indirect Costs
3. Audit Requirements/ProcessesUniform Guidance
2 CFR 200
A-‐110
A-‐122
A-‐133
Agency Specific GuidanceNSF-‐ Grants Policy Manual: https://www.nsf.gov/pubs/manuals/gpm05_131/index.jsp?org=BD
NIH Grants Policy Statement:https://grants.nih.gov/policy/nihgps/index.htm
NASA Grants and Cooperative Agreement Manual; https://www.nssc.nasa.gov/grants
DOE Grants Policy Guide:https://science.energy.gov/grants/policy-‐and-‐guidance/
Detective-‐like skills may be required!
Application to non-‐‑federal awards
Guidelines: Award DocumentREAD and LOVE your AWARD!
qPeriod of AvailabilityqBudget CeilingqBudget AwardedqReporting RequirementsqAgency TermsqCost Share/Matching requirementqSpecific Terms and Conditions
I
my award
Review your Award
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Implementing your Award
From start to finish
One very important question…What can I charge to my award?
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It depends!
Cost Principles
Allowable ReasonableAllocable
AllowableIs this cost within the limits of what the government regulations
allow?
Qualifications1. Necessary and reasonable2. Confirm to limitations3. Consistent with policies4. Consistent with other expenses5. Be determined according to GAAP6. Not be cost share for other awards7. Be adequately documented
Examples• Personnel: Timesheets/Effort• Travel: Description of purpose• Equipment: Justification, quotes• All: Inclusion in budget• All: Specific coding in the accounting system• All: Detailed policies and procedures
Reasonable
Qualifications1. Necessary2. Fall within restrictions (sound business, regulations, etc)3. Market Price4. Prudent5. Within established policies
Examples• Personnel: Salary Caps• Travel: Limits on non-‐‑economy and per diems• Equipment: Quotes/Bids• Contractors/Subawards: Experience and detailed justification
Would the cost be incurred by a prudent person under the prevailing circumstances?
AllocableAre the costs assignable with relative benefit received?
Qualifications1. Incurred for award2. Proportionately distributed3. Necessary for overall operation and is
assignable 1. Indirectly2. Not to fund overages3. Allocated based on reasonable manner
Examples• Personnel: Timesheets/effort reporting• Travel: Description of purpose• Equipment: Justification• All: Specific coding in the accounting system
Cost Principles Summary
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Advertising and Public relations InterestAdvisory Councils LobbyingAlcholic Beverages Losses on other awardsAlumni/ae Activities Maintenance and repair costsAudit Services Materials and supplies Costs
Bad DebtsMemberships, Subscriptions, and professional activities
Bonding Costs Organization costsCollections of improper payments Participant support costsCommencement and Convocation Costs Plant and security costsCompensation Pre-‐award costsConferences Professional service costsContingency Provisions Proposal costsContibutions and donations Publication and printing costsDefence and prosecution of criminal and civil proceedings Rearrangement and reconversion costsDepreciation Recruiting costsEmployee health and welcare Relocation costs of employeesEntertainment costs Rental costs of real property and equipmentEquipment and other capital expenditures Scholarships and student aid costsExchange rates sSelling and marketing costsFines, penalties Specialized service facilitiesFundraising and investment management Student activity costsGains and losses TaxesGeneral costs of government Termination costsGoods/Services for personal use Training and education costsIdle facilities and idle capacity Transportation costsInsurance and indemnification Travel costsIntellectual property Trustees
Front Page Test
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“Trust your gut, but verify…” test
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√ X ?X√
Understanding Indirect vs Direct CostsDirect Costs• Identified specifically with a particular
final cost objective, i.e., award– Salaries & Fringe Benefits– Travel & Meetings– Equipment, Supplies & Materials– Consultants, Subawards
Indirect Costs• Incurred for common or joint objectives • Cannot be readily or accurately
identified with a particular award– Administrative support – General info systems support– Facilities– Depreciation or use allowance
• Cannot be reasonably allocated to multiple award: too difficult &/or too expensive to do
• Indirect costs are allocated through the indirect cost rate
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Indirect Costs: Calculation
Modified Total Direct CostsTotal Direct Costs less:– Fellowship and Participant costs– Capital equipment of $5,000 or more– Portion of each subaward in excess of $25,000– Other costs excluded per grant terms
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Total Indirect Costs
Total Direct Cost Base (MTDC)
Indirect Cost Rate61.04%
Item Amount Included in MTDCPersonnel 100,000 100,000 Fringe 32,000 32,000 Equipment 150,000 Subaward (2) 60,000 50,000 ODC 160,000 160,000 Total Direct 502,000 342,000 Indirect 208,757 61.04%Total Budget 710,757
Administrative RequirementsPrior Approval Requirements
In general, advanced approval is required for:1) Subaward Changes2) Reallocation for trainee/participant costs3) Adjustment to cost sharing4) Change in objective or scope5) Change greater than 10% of total grant
amount (see budget flexibility slide)6) Change or significant absence of PI7) Pre-‐‑Award Costs8) No cost extensions
“Written Approval by an authorized official
evidencing prior consent”
Administrative RequirementsPrior Approval Requirements
In general, advanced notification is required or recommended for:1) Initial no-‐‑cost extension; considered a grantee approved no-‐‑cost extension
for < 12 months2) Carry-‐‑forward of unexpended balances to subsequent funding3) Anticipated residual funds in excess of $5K or 5%4) Significant changes/delays or events of unusual interest5) Significant change in methods/procedures6) Short-‐‑term absence of PI, < 3 months
Notifications should be written and are sometimes required, but often recommended as a component of the partnership
Administrative RequirementsBudget Flexibility
Approved Budget Planned Spend Variance % of TotalSalary 150,000 190,000 (40,000) -‐8.6%Fringe 48,000 60,800 (12,800) -‐2.7%Travel 12,500 8,000 4,500 1.0%Supplies 30,000 12,000 18,000 3.9%Subawards 50,000 -‐ 50,000 10.7%Equipment 14,500 10,000 4,500 1.0%Total Direct 305,000 280,800 24,200 5.2%Indirect 161,955 180,438 (18,483) -‐4.0%Total Award 466,955 461,238 5,717 1.2%
Approval Requirements
• General: Movement of 10% or more of total budget
• NSF: Any line item exceeding $25k
• NASA: Any movement exceeds $100k and the accumulation of which is more than 10% or more of total award
Quick Quiz (ie. Are you awake?)Give one example of a prior approval requirement?
How do you know if you need to request a budget approval?
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Administrative RequirementsCost Share
Agency may require grantee to support the project with it’s own money as well as money from government.
• Requirements for Cost Share:– Allowable– Verifiable– Not included as contributions on other awards– Reasonable and necessary– Identified within award budget– Not paid by federal government agency
Administrative RequirementsReporting Requirements (External)
-‐‑ Financial Reports (FFRs)-‐‑ Scheduled
-‐‑ Quarterly-‐‑ Annual Project-‐‑ Total Project (90 days)
-‐‑ Revised NICRA-‐‑ Carryover-‐‑ No Cost Extension
-‐‑ Completed by Office of Sponsored Programs
May vary by agency “No more frequently than quarterly, but no less frequently than annually”
-‐‑ Technical Reports-‐‑ Annual Project-‐‑ Total Project (90 Days)
-‐‑ Completed by PI/Project Team
Administrative RequirementsReporting Requirements (Internal)
Watch out for the following: – Effort is correctly reported– All expenses are reported correctly
• Expense category and coding (PI, Personnel Code, SubawardCode, etc.)
• Amount• Allowable• Vendor, if applicable
– No missing expenses– No missing or incorrect
encumbrances– Remaining balance is what you expect
it to be
If there is a problem or question, contact your business office
Administrative RequirementsProcurement
• Documented Policies• Necessary• Full and Open Competition• Conflict of Interest• Documentation
-‐ Cost and Price Analysis-‐ Vendor Selection
Administrative RequirementsProcurement
1. Micro Purchases ($3k, $10k)• No Quotes, Equitable distribution
2. Small Purchases ($150k)• Quotes Required
3. Sealed Bids (>$150k)• Construction Projects• Price is important
4. Competitive Proposals (>150k)• RFP with Evaluation
5. Sole Source• Strong documentation required• No competition
Quick Quiz (ie. Are you awake?)Who is responsible for completing the technical reports?
What amazing visual has the government created for new procurement policies?
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Administrative RequirementsSubawards
• Funds used to carry out program operations given to another organization:– Collaboration– Partnership– Pass-‐‑thru
• All subawards subject to terms and conditions of the main research award• Ensure proper classification (subaward vs vendor)• Receive consistent monitoring throughout the award
– Financial– Programmatic
• Must have risk assessment performed early
Fun Fact: In FY16, Carnegie had $8.4M in
subrecipient expenses (nearly 20% of our total external
expenses)
Administrative RequirementsSubaward
SubawardServices are needed to accomplish
objectives
Responsible for decision making
Performance based on research objectives
Subject to same Terms and conditions
Often University or non-‐profit
VendorProvides goods and/or services
Not involved in design for research
Performance based on delivery of services
Often commercial or for-‐profit company
Close-‐‑out ProcessComplexity: May depend on size/scope of award
• Financial Considerations– Spending Rates/Available Funding– Subawards
• Equipment/Property– Title is generally passed to the grantee, but not always
• Final Reporting– Technical Report– Financial Report– Intellectual Property
• Audit/Record Retention
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Review
True/False Quizq You can charge donations against your award.q You can use Gates funding for DOE cost share requirement.q You have to get prior approval for a new budget if you have a change in scope
q Federal Financial Reports are provided monthlyq Subawards are held to the same requirements as the primeq You must have a close-‐‑out party as part of the close out process
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If you only have one takeaway…
Questions?