FRA Financial Closeout slide show

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  • 1. FINANCIAL CLOSEOUT – POST AWARD FRA VII conference conference Financial Research Administration Conference Enhancing the Partnerships April 2-4, 2006 • La Quinta Resort & Club • La Quinta, CA • Palm Springs
  • 2. Session Presenters Tami Sadusky Director, Grant and Contract Accounting University of Washington Kim Garrison Associate Director, Research Services University of Pennsylvania
  • 3. Session Objectives
    • Identify central and departmental issues that delay preparation of financial reporting and closeout
    • Discuss best practices to minimize delays
    • Share examples of closeout procedures and documents
    • Discuss central and departmental best practices work plan that addresses closeout requirements
  • 4. The Closeout Process When should the closeout process begin? You should start while the grant is still active! Conduct regular review of account status!!
  • 5. Department Administrator Role
    • Assist PI in compliance with regulations and policies
    • Monitor expenditures of award funds
    • Obtain necessary signatures/approvals
    • Coordinate with central offices on reporting
    • Assist central administration with closeout and audit activities
  • 6. Common Departmental Issues
    • Untimely response to request for information & documentation
    • Incomplete documentation and approval
    • Misunderstanding of financial closeout requirements
    • Lack of regular communications between investigators and administrators
    • Not conducting timely (e.g., (monthly) review of project expenses
    • Lack of adequate cost share documentation
  • 7. Common Central Adm Issues - 1
    • Noncompliance with sponsor reporting requirements
    • Untimely processing of close-out adjustments
    • Lack of adherence to terms and conditions
    • Lack of timely response to departmental request for approvals, e.g., allowable costs, cost transfers, rebudgeting
  • 8. Common Central Adm Issues - 2
    • Delay in collection of receivables
    • Delay in requesting closeout documents
      • Termination Notices
      • Relinquishing Statements
      • Final Invention statements
      • Progress reports
      • Property reports
      • Subcontractors Release Forms
  • 9. Common Central Admin Issues - 3
    • Unusual reporting requirements
    • Unusual and very detailed expenditure reporting and documentation required
    • Types of reports required may not be clear
  • 10. Best Departmental Practices to Minimize Delays - 1
    • Communication
      • Begins at the proposal stage
      • Continues throughout the life of the project
      • Include:
        • Principal Investigators
        • Departmental Administrators
        • Pre and Post Award Administration Offices
        • Other Central Offices
        • Sponsors
  • 11. Best Departmental Practices to Minimize Delays - 2
    • Items to be communicated
      • Approvals for rebudgeting and carryover
      • Need for extensions and status of renewals
      • Issues such as overspending, non- compliance with budget or award terms
      • Delays in meeting deliverable or technical report deadlines
      • Change in scope or effort of key personnel
      • Issues concerning non payment of invoices
  • 12. Best Central Administration Practices to Minimize Delays - 1
    • Review agreements and sponsor policies and procedures thoroughly prior to sending department inquiries
    • Initiate communication prior to reporting or closeout deadlines
      • Checklist or email to departments with specific due date
      • Indicate course of action if non-compliant
  • 13. Best Central Administration Practices to Minimize Delays - 2
    • Review accounting transactions for allowability
    • Review accounting transactions for compliance
    • Review for proper signatures
    • Advise departments on financial matters
  • 14. Department/Central Administration Shared Responsibilities
    • Stewardship and accountability
    • Effective management of public and private funds
    • Understand each other’s roles and responsibilities
    • Use a team approach to resolve issues
  • 15. Grief Relief/Guilt Check - 1
    • What causes departments the most grief in preparation for closure?
    • Are these self inflicted problems and, if so, what can be done?
    • Examples:
      • Follow up on extensions/supplements requested and not yet received
      • Verify proper charging of trainee expenditures
      • Ensure patient care costs are appropriate
      • Follow up on final subcontract expenditure
  • 16. Grief Relief/Guilt Check - 2
    • More examples:
      • Reconcile travel advances
      • Ensure tuition charges are appropriate
      • Determine all participant support costs have been charged
      • Identify and reconcile all noted restricted budgeted categories
      • Review charges incurred after expiration date
      • Liquidate encumbrances as necessary
  • 17. Grief Relief/Guilt Check - 3
    • Even more examples:
      • Review and, if necessary, transfer outstanding obligations
      • Reconcile cost sharing & faculty effort
      • Determine program income revenue and expenditures are appropriate
      • Complete & submit statement of trainee appointment forms
      • Resolve deficits
      • Obtain information from other departments for interdisciplinary awards
  • 18. University of Washington Reconciliation & Closeout Process
    • Notice of Expiring Budget (See Attachment A)
    • Responding to the Notice of Expiration Letter (See Attachment B)
  • 19. University of Pennsylvania Central Office Reconciliation & Closeout Process
    • Run reports to identify reports due
    • Initiate courtesy email to responsible departmental administrator prior to financial report due date
    • Perform summary review of expense for allowability, allocability, & compliance with sponsor & university policies
    • Request information, documentation, verification, and indicate a response time
  • 20. University of Pennsylvania Departmental Reconciliation & Closeout Process
    • Maintain documentation for files
    • Run reports to identify interim and final due reports
    • Perform final review of expense for errors, allocability, allowability, reasonableness & relevant sponsor & university policies prior to end of reporting period
    • Initiate email to Central Office accountant regarding information, documentation, verification necessary for reporting & closeout
    • Indicate course of action and time frame
  • 21. Closeout Process Impact
    • Who else impacts the process?
      • Sponsors
      • Pre Award Office
      • Post Award Office
      • Accounting/Payroll
      • Accounts Payable
      • Service Centers
  • 22. Federal Demonstration Partnership FDP Update
    • Simplification of reporting
    • Examples:
      • Combining SF-269 and SF-272
      • Elimination of F&A detail
      • Elimination of cumulative cost sharing column
  • 23. Final Notes - 1
    • The end of a project does not mean the end of our responsibilities
    • Each institution has sponsor requirements to meet before a final closeout of the project is completed
    • Good project management during the active live of an award will assist in eliminating problems after the award has ended
  • 24. Final Notes - 2
    • Recommendations
      • On a regular basis review project expenses
      • Maintain proper documentation
      • Provide timely communication between PI’s, departments, sponsors, and central offices
      • Provide tools to assist in closeout review
      • Develop institutional sponsored projects policies to assist in communicating and enforcing closeout procedures
      • Provide compliance and closeout training for PI’s, central and departmental administrators
  • 25. Resources
    • NIH Grants Policy Statement http://grants.nih.gov/grants/policy/nihgps
    • NRSA Frequently asked questions http://grants.nih.gov/training/faq_training.html
    • NIH T32 announcement, NIH guide http://grants.nih.gov/training
    • OMB circular A-21(Cost Principles) http://www.whitehouse.gov/omb/circulars/a021/a21_2 004.html