“Behind the Scene” Research Administration Day 2015 Research Services Office Together we make it happen Research Administration Day May 27, 2015 Expenditure Testing and Tri-Agency/University Expense Eligibility and Compliance Pat Jones, Research Facilitator, Research Services Office Faculties of Nursing, Rehabilitation Medicine, Pharmacy and Pharmaceutical Sciences, School of Public Health FoMD: Departments of Biochemistry, Cell Biology, Medical Microbiology and Immunology, Pharmacology and Physiology 1 RAD 102
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Expenditure Testing andTri-Agency/University Expense Eligibility and CompliancePat Jones, Research Facilitator, Research Services OfficeFaculties of Nursing, Rehabilitation Medicine, Pharmacy and Pharmaceutical Sciences, School of Public Health FoMD: Departments of Biochemistry, Cell Biology, Medical Microbiology and Immunology, Pharmacology and Physiology
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RAD 102
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Research Services OfficeTogether we make it happen Research Administration Day May 27, 2015
• This introductory session on eligible and ineligible expenses will use the most recent Tri-Agency Financial Administration Guide and the University of Alberta Policies and Procedures Online (UAPPOL) website as the main sources of information.
• Attendees will be made aware of the most common expenses that are eligible to be charged to research grants at the University of Alberta as well as the most common ineligible expenses.
• An explanation will be provided to help attendees understand the difference between eligible/ineligible expenses and compliant/non-compliant expenses.
• Attendees will be provided with a behind the scenes look at what is involved with expenditure testing, why it is performed and what results are received.
Sources of information
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• The Agencies worked to simplify and streamline the former Memorandum of Understanding (MOU).
• Renamed the Agreement on the Administration of Agency Grants and Awards by Research Institutions, the new agreement can be found at http://science.gc.ca/default.asp?lang=En&n=56B87BE5-1.
• This Agreement was posted on December 31st and is effective from January 1, 2013 to March 31, 2018.
Research Services OfficeTogether we make it happen Research Administration Day May 27, 2015
• CIHR: Canadian Institutes of Health Research
• NSERC: Natural Sciences and Engineering Research Council of Canada
• RSO: Research Services Office
• SSHRC: Social Sciences and Humanities Research Council of Canada
• UAPPOL: University of Alberta Policies and Procedures Online
• U of A: University of Alberta
Acronyms
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Research Services OfficeTogether we make it happen Research Administration Day May 27, 2015
• Every sponsor has their own definition of “eligible!”• The best source of information for eligible (and ineligible)
expenditures is documentation from the sponsor (e.g., the contract/agreement, the application guidelines, sponsor websites, etc.).
• This applies equally to internal (department, faculty or university) and external (donor or sponsoring Agency) funding.
Definition of “Eligible”
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Eligible expenses are those expenses that are:• associated with the project or program for which the award is
made;• eligible in accordance with the terms and conditions of the
agreement;• necessary to the research endeavour being undertaken;• reasonable and conform with the financial guidelines of the
sponsor and the U of A; and• incurred within the eligible dates of the agreement.
Eligible Expenses
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Research Services OfficeTogether we make it happen Research Administration Day May 27, 2015
On the other hand, ineligible expenses are those expenses that are:• not associated with the project or program for which the award
is made;• not incurred within the eligible dates of the agreement;• not directly related to the research endeavour being undertaken;• not eligible in accordance with the terms and conditions of the
agreement; and• unreasonable and do not conform with the financial guidelines
of the sponsor and the U of A.
Ineligible Expenses
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Research Services OfficeTogether we make it happen Research Administration Day May 27, 2015
• Eligible expenses with proper supporting documentation are deemed to be compliant with Agency guidelines.
• The Tri-Agency Financial Administration Guide states the following:
“For each grant, the institution and/or the grantee must keep complete and accurate records on the use of Agency funding, including verifiable audit trails with complete supporting documentation for each transaction, for a minimum of seven years. The grantee is responsible for authorizing expenditures from his/her grant account in accordance with the Agency's requirements and conditions of grants and with the institution's policies. No other party may initiate or authorize expenditures from an Agency's grant account without the grantee's written delegated authority. All claims must have the grantee or delegate's signature.”
Link: Reporting and Supporting Evidence
• Grantees must be able to provide supporting documentation for all expenditures charged to their grant accounts.
Research Services OfficeTogether we make it happen Research Administration Day May 27, 2015
Some examples of supporting documentation include:• For salaries or stipends paid to research personnel: • signed records regarding personnel paid from grant funds, including
names, categories, salary levels, affiliation to the grant;• length of time supported in each case; and• details of employee benefits charged and relevant calculations.
• For internal expense allocations or shared expenditures: • documentation indicating the exact charge made;• the method of calculation or attribution; and• the grantee’s authorization for those assigned to the Agency
account.
What is considered “complete supporting documentation?”
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The travel claim must include the following information: • purpose of trip;• dates and destinations (person or location visited);• official supporting documentation (e.g., prospectus or program,
indicating the dates of conferences and workshops);• details of daily claims for expenditures relating to those visits;• details of any vehicle used;• original receipts, such as hotel invoices and car rental
agreements (credit cards slips are not valid receipts); and• original air travel ticket receipts and boarding passes (if
available) or any other evidence that supports travel expenses claimed (e.g., a written attestation from the grant holder).
Travel Claims on Tri-Agency Grants
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Eligible expenses lacking proper supporting documentation would be deemed to be non-compliant.• Some examples of deficiencies in supporting documents are
invoices that are paid without an authorized approver’s signature, travel claims lacking a detailed receipt for a meal, claims for networking/hosting events lacking a list of attendees, orders placed (financial commitments made) without prior written authorization from grant holder.
• Depending on the grant these expenses could be eligible, but if the proper supporting documentation is unavailable the expense would be non-compliant.
Non-compliant Transactions
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Research Services OfficeTogether we make it happen Research Administration Day May 27, 2015
• The U of A began regular expenditure testing after the Tri-Council monitoring visit in 2010 . Why? Testing is done as part of best practices and the U of A Internal Audit requires RSO’s report.
• Expenditure testing at the U of A involves:• Random sampling of research accounts chosen from a pool of federally
and provincially funded research grants as well as a broad assortment of other funding agencies’ grants.
• Individual expenses are identified and the grant holder or administrator/department is contacted and asked to provide back up documentation.
• Some expenses are ineligible and must be removed from the grant.• Some expenses are eligible but, lacking proper supporting
documentation, they are deemed to be non-compliant. This is an opportunity for training to be provided to the holder/administrator/ department.
Expenditure Testing
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Research Services OfficeTogether we make it happen Research Administration Day May 27, 2015
• Some expense are both eligible and compliant. Bravo!!• Expenditure testing reveals very very few ineligible expenses. • Expenditure testing reveals more instances of non-compliance.• Non-compliant expenses are otherwise eligible expenses that
are lacking the necessary, required supporting documentation.
Expenditure Testing cont’d
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• If the sponsor guidelines are silent on a particular expense, then the U of A guidelines are followed.
• For example, if the sponsor guidelines do not address the eligibility of hospitality expenses, then the U of A guidelines found on UAPPOL will determine whether or not hospitality expenses can be charged to the grant.• https://policiesonline.ualberta.ca/pages/results.aspx?k=hospitality
Research Services OfficeTogether we make it happen Research Administration Day May 27, 2015
Per Tri-Agency Financial Administration Guide• Costs associated with thesis examination or defense, including
external examiner fees.• Cell phone or PDA purchase or rental unless they are necessary
for data collection (purchase of iPads ineligible).• Telephone equipment and line rental.• Infrastructure costs, administrative (or management) fees.• Passport and immigration fees.• Commuting costs for grantees and associated research
personnel.• Office and stationery supplies (certain exceptions apply).• http://www.nserc-crsng.gc.ca/_doc/Professors-Professeurs/ExpenseSupplie
Research Services OfficeTogether we make it happen Research Administration Day May 27, 2015
• Costs of entertainment, hospitality and gifts.• Costs associated with regulatory compliance, including ethical
review, biohazard or radiation safety, environmental assessments, or provincial or municipal regulations and by-laws.
• Costs of moving a lab.• Sales taxes to which an exemption or rebate applies.• Costs related to professional training or development, such as
computer and language training.• Any part of the salary, or consulting fee, to the grantee or to
other persons whose status would make them eligible to apply for grants.
• Costs related to staff awards and recognition.
Examples of Ineligible Expenses cont’d
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• The grantee must apply in writing to the sponsoring Agency and request written authorization. If the Agency agrees that the cell phone is necessary for data collection and has been supplied with adequate justification by the grantee, the request may be approved. Written authorization from the sponsor must be kept on file by the grantee in the event of an audit.
Research Services OfficeTogether we make it happen Research Administration Day May 27, 2015
• In some cases the ineligible expense will come to the attention of the RSO during the preparation of the financial statement for the sponsoring Agency. In other cases the expense will appear on the expenditure testing report. Other instances may come to light when a report is run to capture the use of ineligible expenditure codes.
• If this occurs, the grantee will be informed that he/she must transfer the expense to another grant or use some other source of funds to cover the expense.
• The exact procedure to be followed will depend upon the department in which the grantee holds his/her grant.
What happens if an ineligible expense is charged to a grant?
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Research Services OfficeTogether we make it happen Research Administration Day May 27, 2015
• In other cases, the ineligible expense will be noticed during the monthly reconciliation performed by the grantee or his/her support staff. At this time the grantee must transfer the expense.
• Finally, the expense may be flagged during an Agency or an internal audit. The result is the same … the expense must be moved.
What happens if an ineligible expense is charged to a grant? cont’d
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• In most cases, the grantee must request written authorization from the sponsor, first, to have the expense posted to the grant after the end date. This may be permitted as long as the expense was incurred during the life of the grant and the item was received and used during the life of the grant.
• Second, the grantee must request permission from the sponsor to submit two financial statements: one statement that would cover the life of the grant and all revenue and expenditures posted to the grant prior to the end date, and a second statement that would cover the period during which the “late” expense was posted.
What if an invoice is submitted for payment after the end date of the grant?
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• Each sponsor has their own guidelines. Depending on the percentage of the annual budget that remains unused at the end of the award period, it may be necessary to request written authorization from the sponsor to carry those funds forward to the next award period. Sponsor guidelines must be followed.
• Tri-Agency guidelines permit some latitude with the budget; however, “The Agency reserves the right to defer or suspend subsequent installments if the need for funds is not demonstrated.” (CIHR reprofiling)
What if I don’t use all the money I was awarded during the expected fiscal period?
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• Each sponsor has their own guidelines for the use of funds after the end date. For example, CIHR and NSERC permit an automatic one-year grace period for many programs during which a grantee may continue to spend the funds which were awarded. In most cases, CIHR will not approve additional extensions beyond the one-year grace period.
• NSERC and SSHRC will permit a one-year grace period for many programs. NSERC will often approve an extension beyond the one-year grace period given adequate justification.
• If you are unable to find information on the Agency website regarding the specific expense you are questioning, please contact the Research Facilitator assigned to your Faculty:• http://www.rso.ualberta.ca/en/ContactRSO/RFOs.aspx
Where can I find information about sponsor guidelines?
