office of sponsored projects for pis: managing your sponsored project september, 2013 osp/ osp

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Office of Sponsored Office of Sponsored Projects Projects For PIs: For PIs: Managing your Sponsored Managing your Sponsored Project Project September, 2013 September, 2013 http://www.dartmouth.edu/~osp/

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Page 1: Office of Sponsored Projects For PIs: Managing your Sponsored Project September, 2013 osp/ osp

Office of Sponsored ProjectsOffice of Sponsored ProjectsFor PIs:For PIs:

Managing your Sponsored Managing your Sponsored ProjectProject

September, 2013September, 2013http://www.dartmouth.edu/~osp/

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PI HANDBOOKPI HANDBOOK

http://www.dartmouth.edu/~osp/resources/http://www.dartmouth.edu/~osp/resources/handbook/handbook/

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SHARED RESPONSIBILITIESSHARED RESPONSIBILITIES

Stewardship and complianceStewardship and compliance Effective management of public Effective management of public

funds/taxpayer dollars to maximize research funds/taxpayer dollars to maximize research outcomesoutcomes

Avoidance of serious cases of fraud, Avoidance of serious cases of fraud, institutional mismanagement, or poor institutional mismanagement, or poor management of sponsor fundsmanagement of sponsor funds

The ultimate responsibility for the management The ultimate responsibility for the management of the agency funds rests with the PIof the agency funds rests with the PI

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WHAT PI/DEPT ADMIN. DOESWHAT PI/DEPT ADMIN. DOESReview notice of awardReview notice of award

Monitor spending - budget vs. actual expensesMonitor spending - budget vs. actual expenses

Keep all participants informedKeep all participants informed

Process employee paperworkProcess employee paperwork

Monthly reconciliationsMonthly reconciliations

Submit transfers (CTs, LADCs & journals)Submit transfers (CTs, LADCs & journals)

Subs:Subs:

Prepare and submit sub-award requestsPrepare and submit sub-award requests

Review progressReview progress

Review and approve invoicesReview and approve invoices

Prepare prior approval documentsPrepare prior approval documents

Request no cost extensionsRequest no cost extensions

Inform OSP of pending changes:Inform OSP of pending changes:

Project changesProject changes

Financial changesFinancial changes

Personnel changesPersonnel changes

Provide PI with:Provide PI with:

ProjectionsProjections

Portfolio statusPortfolio status

Employee verify/sign labor reportsEmployee verify/sign labor reports

Closeout-Closeout-

Provide final reconciled direct cost $sProvide final reconciled direct cost $s

Prepare supporting documents of outstanding Prepare supporting documents of outstanding debits/creditsdebits/credits

Submit timely technical/progress and invention Submit timely technical/progress and invention reportsreports

WHAT OSP DOESWHAT OSP DOESMonitor the awardMonitor the award

Review budgetReview budget

Review IDC, C/S, allowable & unallowable costsReview IDC, C/S, allowable & unallowable costs

Labor verification reports by employeeLabor verification reports by employee

Process sub-award requestsProcess sub-award requests

Review/approve those documents requiring prior Review/approve those documents requiring prior approval approval

Use OGA/IRA ReportsUse OGA/IRA Reports

Approve/process:Approve/process: No-cost extensionsNo-cost extensions Requests for:Requests for:

rebudget rebudget change in PIchange in PI transferstransfers

Financial reportingFinancial reporting

Compliance: interpret guidelines, rules & Compliance: interpret guidelines, rules & regulationsregulations

Communicate with sponsorCommunicate with sponsor

Cash management & collectionsCash management & collections

Prepare and negotiate F&A proposalPrepare and negotiate F&A proposal

A-133 and other auditsA-133 and other audits

CloseoutCloseout

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COMMUNICATIONCOMMUNICATIONThe ultimate responsibility for the management of the agency The ultimate responsibility for the management of the agency

funds rests with the PIfunds rests with the PI PI must be very familiar with the NOA and its terms and conditionsPI must be very familiar with the NOA and its terms and conditions

PI’s responsibility to meet/communicate with the PI’s responsibility to meet/communicate with the Department/Research Grant Manager on a regular basis to inform Department/Research Grant Manager on a regular basis to inform Department Grant Manager of:Department Grant Manager of: Personnel changes, change in scopePersonnel changes, change in scope Supplies and equipment purchasesSupplies and equipment purchases SubawardsSubawards No-cost extensionsNo-cost extensions

Department/Research Grant Manager’s responsibility to:Department/Research Grant Manager’s responsibility to: Keep the PI informed ofKeep the PI informed of

Award Terms and ConditionsAward Terms and Conditions Expenses and remaining balancesExpenses and remaining balances Reporting requirements (including closeout)Reporting requirements (including closeout) Non-competing and competing renewal budgets and deadlinesNon-competing and competing renewal budgets and deadlines

Work with Work with Sponsored Research Manager OSP’s responsibility to serve as direct liaison with sponsorOSP’s responsibility to serve as direct liaison with sponsor

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5 Principles of Financial Transactions 5 Principles of Financial Transactions ManagementManagement

ConsistencyConsistency: Transactions must be handled in a consistent manner. : Transactions must be handled in a consistent manner. Policies and procedures have been established to address similar types Policies and procedures have been established to address similar types of transactions in a routine manner.of transactions in a routine manner.

TimelinessTimeliness: Transactions must be handled within a reasonable period : Transactions must be handled within a reasonable period of time consistent with time frames outlined for federal agencies, a of time consistent with time frames outlined for federal agencies, a private sponsor, and Dartmouth College.private sponsor, and Dartmouth College.

JustificationJustification: There must be a reason for the transaction that supports : There must be a reason for the transaction that supports the project’s goals, and adheres to guidelines outlined by federal the project’s goals, and adheres to guidelines outlined by federal agencies, a private sponsor, and Dartmouth College.agencies, a private sponsor, and Dartmouth College.

DocumentationDocumentation: Sufficient documentation to support the transaction : Sufficient documentation to support the transaction must exist. The documentation must be retained, organized and must exist. The documentation must be retained, organized and complete enough to stand up to an audit.complete enough to stand up to an audit.

CertificationCertification: Transactions must be approved and carry all the correct : Transactions must be approved and carry all the correct authorizing signatures.authorizing signatures.

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Allowable, Allocable & Reasonable CostsAllowable, Allocable & Reasonable Costs AllowabilityAllowability: Expenses charged to a sponsored research award : Expenses charged to a sponsored research award

must meet the following criteria:must meet the following criteria: The costs must be reasonableThe costs must be reasonable The costs must be given consistent treatment through The costs must be given consistent treatment through

application of generally accepted accounting principals application of generally accepted accounting principals appropriate to the circumstancesappropriate to the circumstances

AllocabilityAllocability: The cost has been incurred solely to support or : The cost has been incurred solely to support or advance the work of a specific sponsored research awardadvance the work of a specific sponsored research award

ReasonablenessReasonableness: Must be able to withstand public scrutiny: Must be able to withstand public scrutiny Dartmouth policy takes precedence over sponsor requirementsDartmouth policy takes precedence over sponsor requirements Reference Office of Management & Budget (OMB) Reference Office of Management & Budget (OMB) Circular A-21

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Advance Account/Pre-award Spending Advance Account/Pre-award Spending RequirementsRequirements

PI has a good sense that the proposal/renewal will be fundedPI has a good sense that the proposal/renewal will be funded Department is responsible for covering the expenses if not funded by the Department is responsible for covering the expenses if not funded by the

sponsorsponsor Allowable costs prior to fundingAllowable costs prior to funding

Payroll Payroll Purchasing of equipmentPurchasing of equipment

PI/Department to complete routing form, budget, scope of workPI/Department to complete routing form, budget, scope of work True pre-award costsTrue pre-award costs PTAEO String in advancePTAEO String in advance

Internal Internal Advance Account Request form Current Conflict of Interest Disclosure (COID)Disclosure (COID) Invention Agreement must be on file – one time submissionmust be on file – one time submission Current/updated CPHS and/or IACUC Approval Number(s)Current/updated CPHS and/or IACUC Approval Number(s) Department Chair signature required Department Chair signature required Department submits the signed form to OSP for their review and approvalDepartment submits the signed form to OSP for their review and approval

Not all sponsors allow Pre-award; OSP to check with sponsorNot all sponsors allow Pre-award; OSP to check with sponsor

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SubawardsSubawards

PI/DGM/RGM review proposal/NOA for new/existing subawardsPI/DGM/RGM review proposal/NOA for new/existing subawards

If not in budget/proposal – prior approval (agency/sponsor specific) If not in budget/proposal – prior approval (agency/sponsor specific)

Setup: Submit request to OSP SRM (2 week turnaround under normal Setup: Submit request to OSP SRM (2 week turnaround under normal circumstances)circumstances)

Request must include:Request must include: Statement of work (SOW)* Statement of work (SOW)* Budget (even if in proposal)*Budget (even if in proposal)* Carryover funds need separate budgetCarryover funds need separate budget

*Agreement cannot be prepared and issued if either, or both are not attached*Agreement cannot be prepared and issued if either, or both are not attached

PI in communication with subrecipientPI in communication with subrecipient

Before PI signs off on an invoice, Dept/OSP ensures that:Before PI signs off on an invoice, Dept/OSP ensures that: There is a fully executed agreement on file with the OSP SRMThere is a fully executed agreement on file with the OSP SRM Invoices are submitted in accordance with Terms & Conditions of the subawardInvoices are submitted in accordance with Terms & Conditions of the subaward There are no duplications of invoices or costsThere are no duplications of invoices or costs Invoices include only expenses that are allowable, allocable and reasonableInvoices include only expenses that are allowable, allocable and reasonable Expenses follow the budget and are for actual costs incurred during the invoice periodExpenses follow the budget and are for actual costs incurred during the invoice period Invoice includes a signed certification statement verifying financial data. The subrecipient PI is Invoice includes a signed certification statement verifying financial data. The subrecipient PI is

usually not this personusually not this person

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Subawards cont.Subawards cont. The PI is responsible for monitoring the periodic progress of the SOW and The PI is responsible for monitoring the periodic progress of the SOW and

all invoices all invoices PI’s Review of Invoices for Payment:PI’s Review of Invoices for Payment: Determine if expenses reported on each invoice align with the technical Determine if expenses reported on each invoice align with the technical

progressprogress PI’s signature attesting to: “In signing below, I approve payment of this PI’s signature attesting to: “In signing below, I approve payment of this

invoice and attest that the charges appear reasonable and progress to invoice and attest that the charges appear reasonable and progress to date on this project is satisfactory and in keeping with the statement of date on this project is satisfactory and in keeping with the statement of work”work”

Only the DC PI can approve paymentOnly the DC PI can approve payment Non-compliance by subrecipient with technical reporting requirements or Non-compliance by subrecipient with technical reporting requirements or

DC PI dissatisfaction with the level of progress should be reported DC PI dissatisfaction with the level of progress should be reported immediately to OSP SRMimmediately to OSP SRM

CloseoutCloseout PI must verify by email to OSP SRM that all required reports have been PI must verify by email to OSP SRM that all required reports have been

submitted and are acceptablesubmitted and are acceptable Sub-recipient has up to 60 days to send final invoice. If invoice is sent after Sub-recipient has up to 60 days to send final invoice. If invoice is sent after

this we are not obligated to paythis we are not obligated to pay If award is not under FDP then subrecipient needs prior approval to If award is not under FDP then subrecipient needs prior approval to

carryover fundscarryover funds

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PayrollPayroll

PI’s responsibility to:PI’s responsibility to: Make certain that payment of salary or wages to an individual Make certain that payment of salary or wages to an individual

charged to a given project is commensurate with the individual’s charged to a given project is commensurate with the individual’s contribution to THAT project and per agreement/ESNAP Reportcontribution to THAT project and per agreement/ESNAP Report

Notify DGM/RGM of any personnel changesNotify DGM/RGM of any personnel changes Notify OSP SRM if there is a 25% or more decrease in salary/effort Notify OSP SRM if there is a 25% or more decrease in salary/effort

for any key personnel. OSP SRM, in turn, must notify sponsorfor any key personnel. OSP SRM, in turn, must notify sponsor Largest expense for most projects Largest expense for most projects PI cannot have 100% effort on sponsored projects- Exclusions: PI cannot have 100% effort on sponsored projects- Exclusions:

teaching, writing of grant proposals and other non-sponsored project teaching, writing of grant proposals and other non-sponsored project administrative dutiesadministrative duties

NIH NIH Salary cap – key personnel salary cannot exceed NIH salary cap – key personnel salary cannot exceed NIH salary cap Salary distribution – notify DGM/RGM of any changesSalary distribution – notify DGM/RGM of any changes

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Wage TransfersWage Transfers

LADC/Retroactive Labor charges (Wage Transfer form) to move actual salary charges to move actual salary charges to or from a sponsored research accountto or from a sponsored research account

Need only to supply affected PTAEO strings Need only to supply affected PTAEO strings Reason/justification to be included in the comment sectionReason/justification to be included in the comment section Signatures required : Signatures required :

DGM or FC when $500 (excluding fringe) or less and correction made within 90 DGM or FC when $500 (excluding fringe) or less and correction made within 90 days following the GL Transferred Date found on IRA using the “Transaction days following the GL Transferred Date found on IRA using the “Transaction Detail” reportDetail” report

PI (Dept Chair or equivalent if PI is unavailable) if over $500 (excluding fringe) PI (Dept Chair or equivalent if PI is unavailable) if over $500 (excluding fringe) and not yet over 90 days following the GL Transferred Dateand not yet over 90 days following the GL Transferred Date

PI (Dept Chair or equivalent if PI is unavailable) if correction not made within PI (Dept Chair or equivalent if PI is unavailable) if correction not made within 90 days following the GL Transferred Date. The PDF version will be reviewed 90 days following the GL Transferred Date. The PDF version will be reviewed but may not be approved depending on the circumstancesbut may not be approved depending on the circumstances

When multiple accounts are involved each PI must signWhen multiple accounts are involved each PI must sign Importance of review, reconciliation and communicationImportance of review, reconciliation and communication

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Labor Verification/CertificationLabor Verification/Certification

Labor Verifications-By Employee Labor Verifications-By Employee Report is generated at the end of the fiscal yearReport is generated at the end of the fiscal year Employee has to sign, if they no longer work at Dartmouth Employee has to sign, if they no longer work at Dartmouth

then Department Chair should signthen Department Chair should sign

Required by Federal Regulations Required by Federal Regulations Documents and supports salary and fringe benefit allocations - Documents and supports salary and fringe benefit allocations -

after the fact (including cost shared effort) after the fact (including cost shared effort) Are we following through on commitments (proposed & awarded)?Are we following through on commitments (proposed & awarded)?

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Compensation Funding AgreementsCompensation Funding Agreements

Compensation Funding Agreement is required whenever a Clinic or is required whenever a Clinic or Hospital Employee will be paid off of a Sponsored Research AccountHospital Employee will be paid off of a Sponsored Research Account

Separate agreement required for each grant/project yearSeparate agreement required for each grant/project year New agreement if any changes in time commitment or rate of New agreement if any changes in time commitment or rate of

compensation compensation Not included in Labor Verification Reports and do not appear in the Not included in Labor Verification Reports and do not appear in the

Dartmouth HRMS payroll systemDartmouth HRMS payroll system

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Reallocation of Charges Involving Sponsored Reallocation of Charges Involving Sponsored FundsFunds

Simple Reclassification Journals and Cost Transfers are used to move are used to move expenditures from one account to another.expenditures from one account to another.

Simple Reclassification Journals and Cost Transfers should not be used to Simple Reclassification Journals and Cost Transfers should not be used to manage sponsored research fundsmanage sponsored research funds

Frequent journals and cost transfers may indicate lack of proper oversightFrequent journals and cost transfers may indicate lack of proper oversight Budget must be managed to minimize frequency and retroactivity of Budget must be managed to minimize frequency and retroactivity of

journals and transfersjournals and transfers Expenses must be allowable, allocable, documented, justified and in some Expenses must be allowable, allocable, documented, justified and in some

instances approved by OSPinstances approved by OSP Federal cost principals prohibit transferring expenses from overspent Federal cost principals prohibit transferring expenses from overspent

sponsored research awards to other sponsored research awardssponsored research awards to other sponsored research awards Cost transfers that are over 90 days create an audit risk and are rarely Cost transfers that are over 90 days create an audit risk and are rarely

approvedapproved Late cost transfers will not be tolerated without a solid justification and Late cost transfers will not be tolerated without a solid justification and

will be highly scrutinized by the OSP Sponsored Research Managerwill be highly scrutinized by the OSP Sponsored Research Manager All PIs on the debit and the credit side need to sign the form as well as All PIs on the debit and the credit side need to sign the form as well as

OSPOSP

Timely corrections avoid deficits and risk of auditTimely corrections avoid deficits and risk of audit

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Simple Reclassification JournalSimple Reclassification Journal

Does not require documentation of the expense (invoice copy, Does not require documentation of the expense (invoice copy, transactions report) nor the PI’s signature. If the correction is transactions report) nor the PI’s signature. If the correction is made within the month following the original Transferred Date the made within the month following the original Transferred Date the transaction may be of any dollar amount.transaction may be of any dollar amount.

If the correction is made with 90 days of the original Transferred If the correction is made with 90 days of the original Transferred Date then to be considered a Simple Reclassification Journal it Date then to be considered a Simple Reclassification Journal it must be less than $500/transaction, or within the same PTAEO must be less than $500/transaction, or within the same PTAEO string or be moving the expense from a PTAEO string to a GL string or be moving the expense from a PTAEO string to a GL account.account.

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Cost TransfersCost Transfers

If the transaction is over $500 but not yet over 90 days from the If the transaction is over $500 but not yet over 90 days from the GL Transferred Date the cost transfer or wage transfer form is GL Transferred Date the cost transfer or wage transfer form is completed by the department grant manager, signed by the PI completed by the department grant manager, signed by the PI and is sent to OSP with accompanying documentation for and is sent to OSP with accompanying documentation for approval. Processing will be done by OSP or the appropriate approval. Processing will be done by OSP or the appropriate finance center.finance center.

If the transaction is over 90 days it is highly unlikely that it will be If the transaction is over 90 days it is highly unlikely that it will be approved. Extenuating circumstances that would allow such a approved. Extenuating circumstances that would allow such a transfer include receipt of an award with a retro start date.transfer include receipt of an award with a retro start date.

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Most Common Unallowable CostsMost Common Unallowable Costs Advertising, Public RelationsAdvertising, Public Relations Goods/Services for Personal Use Goods/Services for Personal Use*Alcoholic Beverages*Alcoholic Beverages *First Class Air Travel*First Class Air Travel Alumni ActivitiesAlumni Activities Lobbying Costs Lobbying Costs Bad DebtsBad Debts Cell phones including monthly chargesCell phones including monthly charges Internet chargesInternet charges *Memberships in Community*Memberships in Community Charitable ContributionsCharitable Contributions Organizations, Country Clubs, Organizations, Country Clubs,

Social ClubsSocial Clubs*Entertainment*Entertainment Housing of Officers Housing of Officers

Selling and Marketing CostSelling and Marketing Cost Fines and Penalties Fines and Penalties Certain Legal Costs Certain Legal Costs Losses on Sponsored Agreements (Overruns)Losses on Sponsored Agreements (Overruns) Fund Raising & Investment Mgmt Costs Fund Raising & Investment Mgmt Costs Interest Expense for Operating PurposesInterest Expense for Operating Purposes*Postage (usually part of indirects)*Postage (usually part of indirects)*Telephone Line Charges and basic monthly charges(usually part of indirects)*Telephone Line Charges and basic monthly charges(usually part of indirects)*Copying (usually part of indirects)*Copying (usually part of indirects)

*Unallowable unless clearly itemized and justified *Unallowable unless clearly itemized and justified in the proposal and approved by sponsorin the proposal and approved by sponsor

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Travel, Entertainment & MealsTravel, Entertainment & Meals The PI and department are responsible for adhering to the College The PI and department are responsible for adhering to the College

travel policy- see travel policy- see Dartmouth Travel Policy Guidelines (Procurement Office)(Procurement Office)

All parties are responsible for reviewing Notice of Award for travel All parties are responsible for reviewing Notice of Award for travel terms & conditionsterms & conditions Foreign travel – US CarrierForeign travel – US Carrier Is prior approval requiredIs prior approval required Department scrutinizes chargesDepartment scrutinizes charges

OSP reviews travel charges reported on the OSP reviews travel charges reported on the Travel Reimbursement Form when greater than $500 (after the when greater than $500 (after the fact)fact)

Purchasing Cards (procards) cannot be used for meals (only for (procards) cannot be used for meals (only for supplies and equipment up to $2,500) but can be used for take-supplies and equipment up to $2,500) but can be used for take-out and if order is deliveredout and if order is delivered

Dartmouth Travel Policy takes precedence over sponsor Dartmouth Travel Policy takes precedence over sponsor requirementsrequirements

Windows User
What did we decide about the Dartmouth Travel Policy Guidelines?Remover OSP reviews tranave charges. We don't.Do we allow p-cards (not procards?) to be used for take-out?
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Examples of Entertainment & Meal Examples of Entertainment & Meal SituationsSituations

After the meeting, the dean of the Medical School holds a After the meeting, the dean of the Medical School holds a reception for the scientists where beer, wine and hors reception for the scientists where beer, wine and hors d’oeuvres are served. The costs are considered d’oeuvres are served. The costs are considered entertainment and are disallowed on a federally sponsored entertainment and are disallowed on a federally sponsored research award.research award.

The Physics Department receives a sponsored research The Physics Department receives a sponsored research award to hold a symposium for leading scientists to discuss a award to hold a symposium for leading scientists to discuss a new particle. In its sponsored research application, the new particle. In its sponsored research application, the Department listed the activities it planned to conduct, and Department listed the activities it planned to conduct, and the sponsored research award specifically provided for a the sponsored research award specifically provided for a working dinner the night before. This would be allowable on working dinner the night before. This would be allowable on the sponsored research award since there was such a specific the sponsored research award since there was such a specific provision.provision.

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Capital EquipmentCapital Equipment

Capital equipment is tangible personal property having a useful life is tangible personal property having a useful life of one year or more and an acquisition cost of $5,000 or more per of one year or more and an acquisition cost of $5,000 or more per unit.unit.

Capitalized fabricated equipment that is assembled or Capitalized fabricated equipment that is assembled or manufactured by the College using purchased materials, in-house manufactured by the College using purchased materials, in-house machinery or tools and College labor. Fabricated equipment valued machinery or tools and College labor. Fabricated equipment valued at $5,000 or more and having a useful life of one year or more shall at $5,000 or more and having a useful life of one year or more shall be capitalized and recorded on the College’s equipment inventory.be capitalized and recorded on the College’s equipment inventory.

Statement of Intent to Fabricate an Item form

Department must contact Department must contact Procurement Services (Fixed Assets (Fixed Assets Coordinator) when equipment is purchasedCoordinator) when equipment is purchased

No capital equipment may be purchased during the last 6 No capital equipment may be purchased during the last 6 months of a sponsored project.months of a sponsored project.

All equipment purchased using sponsored research funds is All equipment purchased using sponsored research funds is the property of Dartmouth Collegethe property of Dartmouth College

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Items Requiring Approval by PIItems Requiring Approval by PI

When involving a sponsored research accountWhen involving a sponsored research account Advance Account request form Request for issuance of a sub-award (or authorized (or authorized

designee)designee) Sub-award invoices Sub-award invoices Any invoice greater than $25,000Any invoice greater than $25,000 Consultant/Independent Contractor form Wage transfersWage transfers Cost transfersCost transfers Request for no-cost extension Request to carry over funds (when prior approval required Request to carry over funds (when prior approval required

by sponsor)by sponsor) Transferring residual funds Requesting re-budgeting of fundsRequesting re-budgeting of funds Any other items requiring prior approval from sponsorAny other items requiring prior approval from sponsor

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Items Requiring Approval by OSPItems Requiring Approval by OSP

When involving a sponsored research accountWhen involving a sponsored research account Advance Account request form Request for issuance of a sub award (or authorized designee)(or authorized designee) Sub-award invoices Sub-award invoices Consultant/independent contractor form regardless of Consultant/independent contractor form regardless of

amount and on invoices covered under an IC agreement if amount and on invoices covered under an IC agreement if over $5,000 over $5,000

Requests for payment (RFP) over $5,000Requests for payment (RFP) over $5,000 Miscellaneous Income Payment Vouchers (MIPV) over $5,000Miscellaneous Income Payment Vouchers (MIPV) over $5,000 Any invoice $5,000 or moreAny invoice $5,000 or more Wage transfersWage transfers Cost transfersCost transfers Journal entriesJournal entries Compensation Funding AgreementsCompensation Funding Agreements

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Changes Requiring Prior Approval from Changes Requiring Prior Approval from SponsorSponsorSponsor specific: Sponsor specific: Project relatednessProject relatedness Change of scope/salary allocationChange of scope/salary allocation Absence or change in key personnelAbsence or change in key personnel Change in grantee organizationChange in grantee organization Indirect cost rate adjustmentsIndirect cost rate adjustments Re-budgeting Re-budgeting CompensationCompensation EquipmentEquipment Foreign travelForeign travel Use of unspent balancesUse of unspent balances Stipends and tuition remissionStipends and tuition remission Sub-agreementsSub-agreements Pre-award costs Pre-award costs No-cost extension No-cost extension Capital expenditures involving buildings, landCapital expenditures involving buildings, land

Procedure for initiating changes requiring prior approvalProcedure for initiating changes requiring prior approval Request should be in writing and made “in advance” of changeRequest should be in writing and made “in advance” of change Signed by PISigned by PI Countersigned by OSPCountersigned by OSP

Windows User
I wonder if we should differentiate between federal awards under FDP and federal and non-federal awards that may require prior approval for rebudgeting, equipment, travel etc.? Actually, FDP slide is #24.
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Cost SharingCost Sharing

Cost sharing - project costs not paid for by the sponsorCost sharing - project costs not paid for by the sponsor

May be required by the sponsor (mandatory) or voluntarily offered by the grantee May be required by the sponsor (mandatory) or voluntarily offered by the grantee (voluntary)(voluntary)

Could include anything committed to in the narrative of the budget that will support the Could include anything committed to in the narrative of the budget that will support the project but is not paid for by the sponsorproject but is not paid for by the sponsor

Do not propose cost sharing if not required by the sponsor. Adding cost share to a Do not propose cost sharing if not required by the sponsor. Adding cost share to a proposal DOES NOT increase the probability of being awardedproposal DOES NOT increase the probability of being awarded

Once proposed and/or on the routing form but not in the Notice of Award it is still a Once proposed and/or on the routing form but not in the Notice of Award it is still a commitment and must be tracked accordinglycommitment and must be tracked accordingly

Signed off by fiscal office via routing form; GL account to be providedSigned off by fiscal office via routing form; GL account to be provided

Is a direct cost and is included in the research base for calculating federally approved Is a direct cost and is included in the research base for calculating federally approved F&A rateF&A rate

Most common types: Salary/fringe, equipment, F&AMost common types: Salary/fringe, equipment, F&A

Cost sharing is closely reviewed by auditorsCost sharing is closely reviewed by auditors

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Federal Demonstration Partnership (FDP)Federal Demonstration Partnership (FDP)

FDP allows:FDP allows: One time no-cost extension up to 12 months One time no-cost extension up to 12 months

PI submits request to OSP Sponsored Research Manager PI submits request to OSP Sponsored Research Manager at least 30 days prior to current end dateat least 30 days prior to current end date

Additional no-cost extensions on the same sponsored Additional no-cost extensions on the same sponsored research award require prior approval from the sponsorresearch award require prior approval from the sponsor

90 Day pre-award spending90 Day pre-award spending Rebudgeting within agency guidelinesRebudgeting within agency guidelines Automatic carryover Automatic carryover

Refer to agency for thresholds or Notice of Award for Refer to agency for thresholds or Notice of Award for restrictionsrestrictions

Expanded Authorities (EA)Expanded Authorities (EA) same terms and same terms and conditions as the Federal Demonstration Partnershipconditions as the Federal Demonstration Partnership

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Continuing the ProjectContinuing the Project

The PI has 3 options for extending a sponsored research project beyond the The PI has 3 options for extending a sponsored research project beyond the original date stipulated in the Notice of Award:original date stipulated in the Notice of Award:

Non-Competing ContinuationNon-Competing Continuation Competing ContinuationCompeting Continuation No=Cost Extension (NCE)No=Cost Extension (NCE)

No-Cost Extension under FDP:No-Cost Extension under FDP: First NCE (up to 12 months)-grantee approvedFirst NCE (up to 12 months)-grantee approved Subsequent NCE requests must be in writing and must include the following:Subsequent NCE requests must be in writing and must include the following:

Estimated balance in directs and indirectsEstimated balance in directs and indirects Explanation on why the additional time is needed Explanation on why the additional time is needed Explanation on how remaining money will be spentExplanation on how remaining money will be spent

The internal DC NCE form must be used/submitted for The internal DC NCE form must be used/submitted for allall requests requests Requests need to be sent to OSP 60 days in advance of end dateRequests need to be sent to OSP 60 days in advance of end date Requests to be countersigned and submitted to sponsor by OSPRequests to be countersigned and submitted to sponsor by OSP NCE is giving a PI more time to accomplish project goalsNCE is giving a PI more time to accomplish project goals NCE cannot be requested simply to use unspent fundsNCE cannot be requested simply to use unspent funds

*If the sponsor allows for an email to be sent, then draft letter should be sent to *If the sponsor allows for an email to be sent, then draft letter should be sent to OSP Sponsored Research Manager. OSP will review and then forward to the OSP Sponsored Research Manager. OSP will review and then forward to the Sponsor Sponsor

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Continuing the Project cont.Continuing the Project cont.

No-Cost Extension under No-Cost Extension under non-FDP/non-Expanded Authoritiesnon-FDP/non-Expanded Authorities

Review agency-specific guidelinesReview agency-specific guidelines PI must prepare detailed letter for all requests PI must prepare detailed letter for all requests

Estimated balance in directs and indirectsEstimated balance in directs and indirects

Explanation on why the additional time is needed Explanation on why the additional time is needed

Explanation on how remaining money will be spentExplanation on how remaining money will be spent The signed internal DC NCE form must accompany the detailed The signed internal DC NCE form must accompany the detailed

letterletter Requests need to be sent to OSP 60 days in advance of end dateRequests need to be sent to OSP 60 days in advance of end date Requests countersigned and submitted to sponsor by OSPRequests countersigned and submitted to sponsor by OSP NCE is giving a PI more time to accomplish project goalsNCE is giving a PI more time to accomplish project goals NCE cannot be requested simply to use unspent fundsNCE cannot be requested simply to use unspent funds

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PI Transfer/Change of InstitutionPI Transfer/Change of Institution

Contact appropriate institutional personnelContact appropriate institutional personnel Contact DC Sponsored Research Manager immediatelyContact DC Sponsored Research Manager immediately

Are grants to be transferred?Are grants to be transferred? If yes:If yes:

Obtain sponsor approvalObtain sponsor approval New institution/Personnel contactNew institution/Personnel contact Effective termination dateEffective termination date If equipment to be transferred refer to policiesIf equipment to be transferred refer to policies Relinquishing statementRelinquishing statement Fulfill all reporting requirementsFulfill all reporting requirements

If no:If no: Sponsor approval for PI replacementSponsor approval for PI replacement Effective termination dateEffective termination date Change in scope?Change in scope?

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Transferring Capital EquipmentTransferring Capital Equipment Required Procedure for Transferring Capital Equipment:Required Procedure for Transferring Capital Equipment:

Notify Fixed Assets Coordinator in Procurement Services Notify Fixed Assets Coordinator in Procurement Services to remove Equipment Item from Inventory Listto remove Equipment Item from Inventory List

A Letter formally requesting the transfer of capital A Letter formally requesting the transfer of capital equipment to another institution and must include:equipment to another institution and must include:

Current market valueCurrent market value Description of equipment (Name, Serial number, Description of equipment (Name, Serial number,

Dartmouth Asset Tag number)Dartmouth Asset Tag number) Signatures of PI, Department Chair, Director of Office Signatures of PI, Department Chair, Director of Office

of Sponsored Projectsof Sponsored Projects Carbon Copy to Fixed Assets CoordinatorCarbon Copy to Fixed Assets Coordinator Fully signed original must be sent OSP to be kept in Fully signed original must be sent OSP to be kept in

the sponsored research account filethe sponsored research account file

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CloseoutCloseout

PI must prepare and submit timely reports where required:PI must prepare and submit timely reports where required:

Technical/ProgressTechnical/Progress

InventionInvention

PropertyProperty

Federal-Mandatory submission of published works to Federal-Mandatory submission of published works to PubMed CentralPubMed Central

Work with Department Administrator/OSP to ensure timely Work with Department Administrator/OSP to ensure timely closeout processcloseout process

Late reporting may result in withheld funding for the PI and/or Late reporting may result in withheld funding for the PI and/or Dartmouth CollegeDartmouth College

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Closeout cont.Closeout cont.

RecordsRecords Dartmouth retains all original dataDartmouth retains all original data PIs are allowed to keep ‘copies’ of research notebooks when PIs are allowed to keep ‘copies’ of research notebooks when

leaving Dartmouth but the original must stay with the department.leaving Dartmouth but the original must stay with the department. How long should the records be saved?How long should the records be saved?

OMB Circular A-110 states (for federal) “generally” 3 years OMB Circular A-110 states (for federal) “generally” 3 years from the due date of the final report on the sponsored research from the due date of the final report on the sponsored research awardaward

Sponsor specificSponsor specific