we are all in this together: close out issues researchers, administration teams and sponsored...
Post on 19-Dec-2015
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We Are All in This Together:
Close Out Issues
Researchers, Administration Teams and Sponsored
Projects StaffArriving Together at the
End of a Sponsored Project
Team
• Primary Investigator
• Research Administrators
• Sponsored Projects Office
• Grant and Contract Accounting
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• Understanding no matter what our responsibilities are during the life of a project, they can ultimately effect the closeout
Objectives
Closeout Starts With Proposal Submission
• The Investigator and/or Team• Your institution’s guidelines• The sponsor’s regulations & references• Award Requirements
Review ItemsComplex Projects
• Incrementally funded, multi-year
• Contains Subcontracts
• Excessive Cost Share
• Multi-disciplinary,
• Complex financial reporting (e.g., by task)
CAS Exceptions Requested
• CAS exceptions must be:
– allowable, allocable, reasonable, identifiable with a sponsored work and approved by the sponsor,
• Typical CAS exceptions are– e.g., Office supplies, clerical salaries,
postage, local phone calls
Subcontract
A contract that assigns some of the obligations of an existing contract to another party.
When the Award Arrives
• Congratulate the researcher!
• Setup Team Meeting to:
– Verify the budget
– Verify the cost-share
– Schedule reports
– Setup Internal Financial Tracking System
– Other items as needed
Final Closeout Checklist
Start with This in Mind
• Final Deliverables
• Money Out = Money In
• Documentation
During the Life of the Project
• Keep on top of it• Cost Share – On schedule? On
target? Documented• Reinforcements
• Anything not routine
• Complex Projects
• Unspent funds (FP)
• Excessive Spending
Post Award Issues That Effect Closeouts
Review For Project Changes
• A significant delay in project
• Conflict of interest that cannot be resolved
• Change in scope of work
• Addition of a sub contract.
Review for Non- Compliance
• Review for Non-compliance with Award Restrictions –Budget restrictions / limitations–re-budgeting between categories–prior approvals for equipment
• Unallowable Costs• Other
Review Items That Need Special Monitoring
Special Monitoring
Purchasing cards Cost Share
Cash Advances Cost Transfers
Encumbrances Subcontractors
Hourly-paid Staff and/or Students
Purchasing Cards
All Purchasing Card costs on sponsored accounts MUST be directly related to the project and documented
Cost Share Documentation
• Audit Purposes• Mandatory reporting to sponsor• Voluntary Committed verified &
Documented• Consequences of Under-reported Cost
Share
Cash Advance
• Use sparingly
• Not a “petty cash” fund
• Costs must be directly related to
the project
• Mostly for field work
Cost Transfers OMB Circular A-21 prohibition makes cost
shifting audit sensitive
• Post Term Charges
–Largely unallowable (Final report costs only exception)
Unallowable Costs–Costs that do not meet the criteria for
A 21 Allocable costs.
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Review Subcontracts
• Activate Subcontract
• All payments/financial reports being submitted in a timely manner
• All deliverables, progress reports being submitted
Date Of Completion
• “Date of completion means the date on which all work…is completed or the date… on which Federal or Non Federal sponsorship ends.”
At the End of the Project
• Should be no surprises
• Use your checklist
• Project deliverables are the responsibility of the Investigator
Final Closeout Review
Purchasing Card Expenditures Documented
Cost Share Documentation CompletedSubcontracts Closed
Refund to Sponsor Cleared
Final Closeout Review
Residual Transfers Completed (FP)
Cash Advances Cleared
Encumbrances Cleared
All Cost Transfers Completed
Other
Final Closeout Review
Final Deliverables Submitted Patents, Technical, Equipment, Inventory Final Financials, Others as required
Revenue = Expenditures
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Records Retention & Access System
• Retention required for three years after last action
• Other standards may apply• Government requires timely and
unrestricted access