WHO KNOWS WHAT LURKS IN THE PI MIND - WE DO

ONLY THE SHADOW (SYSTEM) KNOWSRandi Wasik, MBA,

Director of Administration and Finance, University of Washington

THE AWARD LIFE CYCLEFind &

Prepare ProposalInstitutional

Review & Submittal

SponsorReview & Award

Award Negotiation

Award Set-Up

Award Administration& Compliance

Award Closeout

• Reasonable, Allowable, Allocable – the grant management holy grail

• Put the correct charges on the correct fund right from the start.

• Undue cost transfers are a compliance issue.

• Reconcile fund activity monthly. • Process all corrections as quickly as possible.• Communicate with PI or designee monthly to review

past expenditures and future projections. • Do projections / burn rate and include IDCs!

AWARD ADMINISTRATION

Plan – they should serve both you and your faculty - transparency

Model so they can accomplish multiple goals Be consistent Do regularly Get up and meet with your faculty to review

and discuss Have the faculty sign the reports More than one set of eyes Use electronic tools

SHADOW SYSTEMS

• Transfer of cost from one institutional account to another

• Cost transfers can occur between:o two sponsored accountso from a non-sponsored account

to a sponsored account, o from a sponsored account to a

non-sponsored account,o between two non-sponsored accounts

COST TRANSFER DEFINITION

• Federal regulations require that the effort of all individuals compensated or contributing effort to a federal project is verified.

• Effort is percent of total time an individual spends on all work-related activities (research, teaching, patient care, administration, etc.) within their institution.

• Cannot exceed 100%.• Not based on 40 hour work week.• Effort reporting certifies to the

sponsors that effort committed to a project was completed.

EFFORT REPORTING

• Institutions are responsible for programmatic, administrative and financial monitoring of all awards made to sub-recipients under sponsored projects.    

• Institutions have an obligation to monitor the sub recipients activities throughout the life of the award.    

•  Responsibilities include - PI, Department and  Institution.

SUB RECIPIENT MONITORING

Equipment IRB IACUC Invoicing and Accounts Receivable Scheduled Payments Use for future budgeting and forecasting Plan, forecast and account

OTHER TRACKING NEEDS

Financial Reports:◦ All expenditures posted?◦ All expenditures appropriate?

Equipment reports◦ Who owns the property now: Institution or

Sponsor?◦ What is its distribution?◦ Is it still being used?

REPORTING

• Releases (Normally for Contracts) Payment linked to timing or milestones/deliverables

• Deficit Balances (Overruns)oCannot be shifted to other awardsoCannot be included in F&A cost pools

• SurplusesoCost Reimbursement Agreements – Returned

to SponsoroFixed Price Agreements (including Clinical

Trials) – Retained by Institution

REPORTING, CONTINUED

• Anticipate the project will be audited. • Manage the award correctly from the beginning.• Audits often take place several years after the

project is completed. • Organized Files• Documentation for expenses including

explanations of why items were charged• Appropriate Approvals• Audit Trails

AUDITS

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Conduct of ResearchPrinciple: Ensures validity of results & maximizes return

on public investment.Conflict of Interest, Research

Integrity, Data, Resource Sharing, Cyber Security, Public access to

Publications, Conflict of Commitment

Public Policy Principle: Meets national

social, economic, & security interests.SEVIS/Visas, Export controls Race, Gender, & Handicap

Equality & Education, Lobbying, Debarment,

Drug Use, USA Patriot Act

Protections/SafeguardsPrinciple: Provides for welfare of

researchers, subjects, & environment.Human Subjects, Animal Welfare,HIPAA, Select Agents, Radiation, Environmental Health & Safety, Hazardous Materials, Radiation, Recombinant DNA, Lab safety

Cost Policy and Financial ManagementPrinciple: Ensures fair and

reasonable costs to the Government.Reasonable Allocation of Costs, Effort Reporting, Sub-recipient

Monitoring, Cost Transfers, Indirect Costs, Cost Sharing

Research Stewardship and Compliance: Principles and

Responsibilities

Originally Created by Geoff Grant, Partners Health Care

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Impact of Non-Compliance

Significant Audits

& Settlements

Johns Hopkins Univ.Effort Certification

$2.7 million

University of MinnesotaMisuse of federal funds

$32 million

New York University Medical Center

Inflated Research Grant Costs$15.5 million

Mayo FoundationMischarging Federal

Grants$6.5 million

Harvard/BIDMCCosting Issues(Self-Reported)

$3.25 million

Northwestern University

Committed Time/Effort$5 million

Univ Alabama, Birmingham

Effort Certification & Clinical Research Billing

$3.4 million

East Carolina Univ Questioned Costs

HHS/OIG Audit $2.4 million

Univ. of Southern California Questioned Costs

HHS/OIG Audit $400,000

Florida International Univ.Effort Certification

& Direct Costs $11.5 million

Univ. California, San FranciscoAnimal Care Allegations

$92,500 fine

Cornell Medical Clinical Research

Issues $4.4 million

DISCUSSION and QUESTIONS