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MANAGING SPONSORED PROJECTS FINANCIAL COMPLIANCE
 

MANAGING SPONSORED PROJECTS FINANCIAL COMPLIANCE

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    MANAGING SPONSORED PROJECTS FINANCIAL COMPLIANCE MANAGING SPONSORED PROJECTS FINANCIAL COMPLIANCE Presentation Transcript

    • MANAGING SPONSORED PROJECTS FINANCIAL COMPLIANCE May 1, 2008 Office of Grants &Contracts Accounting
    • FINANCIAL COMPLIANCE
      • You Should Understand:
      • Key Areas of Risk
      • Your Responsibilities
      • Resources and Tools Available
    • FINANCIAL COMPLIANCE What are the Risks Related to Grant Awards?
      • Misuse of funds (purchasing cards, fraud)
      • Improper cost allocation (multiple projects)
      • Accelerated expenditures
      • Unobligated balances
      • Cost transfers
      • Restrictions on Notice of Award
      • Financial conflict of interest
      • Time and effort reporting
      • Unallowable costs
    • FINANCIAL COMPLIANCE Why All The Fuss?
      • Because of Potential
      • Impact on MUSC
        • Shutdown of Operations
        • Fines and Penalties
        • Damage to University’s Reputation
        • Susceptibility to False Claims Allegations
    • FINANCIAL COMPLIANCE Why All The Fuss?
      • Because of Potential
      • Impact on You
        • Loss of PI Status
        • Debarment
        • Possible Criminal and Civil Charges
      • Remember: One of our primary goals in GCA is to safeguard the University and you
    • FINANCIAL COMPLIANCE Who is Responsible?
      • Institution?
      • Principal Investigator (PI)?
      • Departmental Administrator?
      • Central Administration?
    • FINANCIAL COMPLIANCE Who is Responsible?
      • As PI, you:
      • Make the budgetary decisions
      • Approve expenditures
      • Should know special terms and conditions
      • Approve final Financial Status Reports (FSRs)
    • FINANCIAL COMPLIANCE Who is Responsible?
      • Tips:
      • Always remember that the financial aspects of your grant are just as important as the science
      • Don’t ever hesitate to question an expense on your grant
    • FINANCIAL COMPLIANCE Training
      • What would your responses to the following questions be?
        • What training have you attended in the past 18 months?
        • Who sponsored this training?
        • What training programs are provided by the University?
        • Does MUSC have policies and procedures to ensure compliance with federal regulations?
      • Make every effort to attend training
    • FINANCIAL COMPLIANCE Understanding Direct Costs vs. F&A Costs
      • DIRECT COSTS
        • Federal Definition (OMB Circular A-21, Section D)
      • F&A COSTS
        • Federal Definition (OMB Circular A-21, Section E)
      • It is a Direct Cost, but is the cost allowable?
      • Does the cost meet the following criteria?
        • Reasonable
        • Allocable
        • Allowable
        • Consistently Treated
    • FINANCIAL COMPLIANCE Avoiding the Pitfalls Allowable/Unallowable Expenditures
      • Know what charges are not applicable to your grant
      • If you have concerns of allowabilty or allocability question your Departmental Administrators
      • Become familiar with costs that can and cannot be charged direct to your grant
    • FINANCIAL COMPLIANCE Avoiding the Pitfalls Cost Transfers
      • Try to avoid having frequent transfers
      • Understand the University’s Cost Transfer Policy
      • Be aware of the NIH Cost Transfer Policy
      • Question transfers off and onto your grant
      • Make sure cost transfers are adequately justified and well documented
      • Avoid transfers at the end of a grant spending period
    • FINANCIAL COMPLIANCE Avoiding the Pitfalls Activity Reporting
      • Be aware of the University’s policies and understand them
      • Submit Activity Reports on time
      • Be able to reasonably explain how you track the amount of time spent on an award
            • By You
            • By a Trainee or Post Doc
      • Know who your Department Coordinator is
      • Understand how activity is reported, to whom, and how often
      • Understand how your activity is approved
      • Know who maintains the Activity Reports
      • Make sure that you account for all of your activity
    • FINANCIAL COMPLIANCE Most Common Direct Costs
      • Salaries & Fringe Benefits
      • Equipment
      • Supplies
      • Patient Care Cost
      • Travel
      • Subrecipient Agreements
    • FINANCIAL COMPLIANCE Salaries & Fringe
      • Combined Salary
      • NIH Salary Cap
      • Affiliate Salary Worksheet
      • (Affiliate Salary - Policy/Procedure 4-3.07)
      • Fringe Benefits – rates negotiated only for grants
      • MUSC Online Activity Reporting https:// appserve.musc.edu /effort
    • FINANCIAL COMPLIANCE Equipment
      • Definition
          • Special purpose equipment
          • General purpose equipment
      • Excluded from the F&A Calculation on federal awards
      • Rebudgeting may require prior approval from the sponsor
    • FINANCIAL COMPLIANCE Supplies
      • Materials & Supplies
        • Expendable items
        • Medical/scientific/laboratory supplies
        • Equipment under $5000 or a useful life > 1 yr.
      • Office Supplies
        • Normally unallowable as a direct cost on federal awards
    • FINANCIAL COMPLIANCE Patient Care Costs
      • Account Code
        • Most commonly used chart of accounts
      • Inpatient and outpatient expenses
      • Rebudgeting
      • Excluded from F&A Cost Calculation for Federal Awards
    • FINANCIAL COMPLIANCE Travel
      • Who can travel?
      • Contact GCA for further assistance prior to incurring travel expenditures.
      • Travel expenses incurred by consultants & private entities are subject to the Federal Travel Regulations http:// www.gsa.gov/Portal/gsa/ep/contentView.do?contentId =17943&contentType=GSA_BASIC
    • FINANCIAL COMPLIANCE Subrecipient Agreements
      • Definition
      • Prior approval
      • Applicable F&A
      • Subrecipient invoice approvals