Controller’s Office Research Administration Town Hall Wednesday, October 29, 2014 10:00-12:00 PM...

Controller’s Office

Research Administration Town Hall

Wednesday, October 29, 201410:00-12:00 PM

HSW-301 w/ a live broadcast to Genentech Hall, Byers Auditorium at Mission Bay & Room 116 at the Fresno

Campus & Live Webcast

Contracts and Grants Accounting


Introduction of New AVC, Research Administration – Marge O’Halloran

Coverage Analysis – Eileen Kahaner and Jacquie Eichhorn

NOT-OD Updates – Joyce Abe Uniform Guidance Update – Nilo Mia Final Invoice Preparation – Dan Wikert Clinical Trial Post Award Topics – Michael Grafton Post Award Hot Topics – Michael Grafton and Jean

DeMartini Compliance Update – MC Gaisbauer CGA Survey and Contact Process – MC Gaisbauer

2

Agenda


Introduction of new AVC, Research Administration

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4

Update:Clinical Trial Coverage Analysis

UCSF Clinical Enterprise Compliance Program

(CECP)


Agenda

IntroductionsWhat is a Coverage Analysis (CA) and why is it

importantWho performs CAs at UCSFYour role

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UCSF Clinical Enterprise Compliance Program Mission

Promote a culture of compliance with applicable laws, rules, regulations

Provide oversight, guidance, and tools to detect, deter, and resolve non-compliant behavior

Establish an environment that empowers and expects individuals to address conduct that does not conform to the applicable standards

Support UCSF Mission by reducing organizational risk Scope

Clinical activities, including clinical research billing Tools

Training, address questions, review policies/SOPs Perform reviews Oversee corrective actions

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Process

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What is a Coverage Analysis?

Focused review of all clinical trial-related documents to determine who is financially responsible for all items and services provided to the research subjects over the course of the study

Process aligns the Protocol, Clinical Trial Agreement, Informed Consent (ICF), Budget

Creates a reference that all subsequent billing and invoicing decisions should use Study team, post-award, patient billing ICF costs section

UCSF CA mandate as of June 1, 2013

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Some Principles of CA Development

Coverage analysis is based on billing rules Medicare rules typically applied

More well defined Most commercial payors follow, even for pediatrics

Charging for an item does not necessarily mean that item is reimbursable

FDA approval does not guarantee reimbursement

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Why is the CA Important?Respond to government attention re CRB

Industry trials and federal grantsMore accurate assessment of trial costs

Improves budgeting UCSF cost recovery per OP mandate

Allows accurate ICF for expected costsAccurate billing to sponsor and payors

Single reference for study teams, post-award, billers Maintain sponsor and participant trust Reduces need for “back-end” corrections Demonstrates due diligence to bill accurately reducing

fines or penalties if mistakes are made

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Multiple Groups Perform CAs

CA owner depends on type of trial http://hub.ucsf.edu/ca-budget-billing CTBSC: [email protected] Center: [email protected] of Cardiology: [email protected]

Budgeting also performed by multiple partiesNon-industry Sponsored Clinical Trial - RMSIndustry Sponsored Clinical Trial - ITACancer Center - ITRDivision of Cardiology - Cardiology

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Your Role

Encourage study team to seek CA early in process – run in parallel with other activities

Do not finalize CTA without a formal CAAlert CECP to potential issues that

cannot be resolved through standard processes

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Questions?

Jacquie Eichhorn, Manager Clinical Research Billing Compliance [email protected] 415-514-2576

Eileen Kahaner, Director, CECP [email protected] 415-476-8642

CECP – 415-502-2790

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NOT-OD Updates

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Notable NIH Updates

NOT-OD-15-014NOT-OD-13-097NOT-OD-14-113NOT-OD-14-090NOT-OD-14-094NOT-OD-14-095

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Reminder: NOT-OD-15-014

http://grants.nih.gov/grants/guide/notice-files/NOT-OD-15-014.html

Guidance about NIH Type 5 Progress Reports (annual progress reports) • Implements Effective October 17, 2014 NIH requires that all type 5

progress reports be submitted using the Research Performance Progress Report (RPPR) module in eRA Commons

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Guidance about Graduate students/undergraduate students roles

participating on NIH-funded projects for one person month or more

• Implements Effective October 2014 NIH requires eRA Commons IDs for

all graduate and undergraduate student roles reported on annual progress reports (RPPRs)

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Guidance about Individual Development Plans (IDP) for graduate students

and postdoctoral researchers supported by NIH awards • Implements Effective October 1, 2014 Research Performance Progress

Report (RPPR) are required to include a report on the Use of IDPs in Section B, Question B.4.

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REMINDER: NOT-OD-14-113, continued

The Graduate Division has posted information on IDPs and template language for RPPRs on their website: You can get the information on IDPs at: https://career.ucsf.edu/grad-students-postdocs/myIDP

Template language for RPPRs is located at:

https://career.ucsf.edu/sites/career.ucsf.edu/files/PDF/Reporting%20Use%20of%20the%20IDP.pdf

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NOT-OD-14-090 and NOT-OD-14-133


Guidance about Update to PA-14-150 (F30) NRSA Individual Predoctoral

Dual-Doctoral Degree Fellowship• Implements Requirement to upload “Additional Educational

Information” under Other Attachments in the Other Project Information section of the application

Applications submitted without this attachment will be considered incomplete and rejected

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Guidance about Update to PA-14-147 (F31) NRSA Individual Predoctoral

Fellowship• Implements Requirement to upload “Additional Educational



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Guidance about Update to PA-14-148 (F31-Diversity) NRSA Individual

Predoctoral Fellowship to Promote Diversity in Health-Related Research

• Implements Requirement to upload “Additional Educational



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OMB Uniform Administrative

Requirements, Cost Principles, and Audit

Requirements forFederal Awards


Background – When, Why, Who? Fall 2009, Executive Order 13520 on reducing improper

payments and eliminating waste in Federal programs and Presidential memorandum on promoting administrative flexibility

Set in motion the single biggest regulatory change in the last 50 years of research administration

In the documents, President directed OMB to work with Executive Branch agencies and other key stakeholders to evaluate potential reforms to Federal grants policies

The Council on Financial Assistance Reform (COFAR) was established in October 2011 and has led efforts to improve delivery, management, coordination, and accountability of Federal grants and cooperative agreements, which includes the development of the uniform guidance

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Background – What Did COFAR Do ?

OMB Advance Notice – Spring of 2012Proposed guidance issued February 1, 2013Final guidance issued December 26, 2013Federal agencies had 6 months (to June 26,

2014) to submit THEIR draft(s) of “implementing regulations” to OMB

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Overview of UCSF Review and Campus Coordination Process

Meet every two/three weeks to review guidance and make initial assessment

Form UCSF position and stay connected with UCOP to share concerns and stay abreast of UCOP review process

Coordinate UCSF concerns with Council on Government Relations (COGR)

Establish and maintain communication plan with campus stakeholders

Vet concerns of Grant Reform Task Force with campus administrators and academic community

With stakeholders, establish campus priorities and develop implementation plans

Execute, track, and communicate status of implementation processes

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Parts of UG & Who Is Reviewing It

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Final Rule Section Title Champion DepartmentSubpart A – Acronyms and Definitions All AllSubpart B – General Provisions NM Budget & Resource Mgmt.Subpart C – Pre-Federal Award Requirements JR& MO Office of Sponsored ResearchSubpart D – Post Federal Award Requirements MC Controller’s OfficeSubpart E – Cost Principles NM Budget & Resource Mgmt.Subpart F – Audit Requirements MC/TP Controller’s Office/AuditAppendices

Notice of Funding Opportunity All All Contract Provisions

Research JR& MO Office of Sponsored F&A Costs…for Institutions of Higher

Education NM Budget & Resource Mgmt.

F&A Costs…for Nonprofit Organizations N/A State/Local Gov’t and Indian Tribe Service

Allocation N/A Public Assistance Cost Allocation Plans N/A States and Local Gov’t and Indian Tribe IDC N/A Nonprofit Orgs Exempted from Subpart E N/A Hospital Cost Principles N/A Data Collection Form (Form SF-SAC) MC Controller’s Office Compliance Supplement MC Controller’s Office


Review Timeline

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Calendar YearFiscal Year 2016

1.0 Administrative

1.1 Establish sub-committee

1.2 Set communication meetings every 2 weeks

1.3 Champions to develop review plan

1.4 Establish campus communication process

1.5 Send second announcement to campus (task force formed)

2.0 Review OMB Final Guidelines for campus impact

2.1 Form initial assessment

2.2 Review with sub-committee

2.3 Strategize / determine options/ priorities

2.4 Vet with stakeholders

2.5 Communicate to leadership on priorities by FYE 2014

3.0 Prioritize and create draft implementation plan schedule

4.0 Brief leadership on initial implementation plans

5.0 Revise campus communication process

6.0 Establish progress tracking process and check in with Costing Policy Group

7.0 UCSF Compliant with New Guidance

MAY

Adm

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and

Cos

t Pri

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Aud

it Re

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2015

Review and Implementation Process and Timeline

FEB

MAR

APR

MAY

JUN

2014 20152014

JUL

DEC

JUN

JUL

AUG

SEP

OCT

NO

V

JAN

FEB

MAR

APR


UC Approach to Uniform Guidance, Phase One (6 months) Identify major issues and areas where systemwide guidance or policy will

need to be updated Determine key issues/approaches to inform and engage local campus

constituencies Issue systemwide guidance, where appropriate, and/or begin work to

update policies, as needed

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Uniform Guidance Applicability

Applicability and Dates (200.110)Uniform implementation date of 12/26/14 for all Subparts, except Subpart F Subpart F, Audit Requirements, will be effective the first FY beginning after 12/26/14; for UCSF, this will be FY 2016 (July 1, 2015 – June 30, 2016)The UG will be applicable to all NEW AWARDS and extensions / additions to EXISTING AWARDS with award dates on or after 12/26/14

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Uniform Guidance Applicability Question: Will the Uniform Guidance changes apply

ONLY to awards made after the effective date (December 26, 2014), or do the changes apply to awards made earlier?

Answer: Once the Uniform Guidance goes into effect, it will APPLY TO AWARDS or FUNDING INCREMENTS AFTER THAT DATE (December 26, 2014); it will NOT retroactively change the terms and the conditions for funds (awards) already received

Note: Existing federal awards will continue to be governed by the terms and conditions of that Federal award

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Some Top Highlights and Key Issues 200.112 Conflict of Interest 200.301 Performance Management

Researchers must relate Financial Data to Performance Accomplishments of the federal award

Researchers MUST provide COST INFORMATION to demonstrate COST EFFECTIVE PRACTICES (e.g. – unit cost data); objective is to improve program outcomes, share lessons learned, and spread adoption of best practices

Higher reporting bar overall for Federal contracts Stronger certification language reminds signers of statutory penalties for false

certifications

NOTE: Alert your PI’s now of these requirements…

200.303 Internal Controls Strong emphasis on IA as well as understanding “must” versus “should” Requires recipients to have strong internal controls; should be in compliance with…

Internal Control Integrated Framework (COSO) The Federal “Green Book” – Protecting Personally Identifiable Information Federal statutes, regulations and conditions (Comptroller General of the U.S.)

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Some Top Highlights and Key Issues 200.306 Cost Sharing

Voluntary committed cost-sharing is not expected in Federal research proposals

Cost-sharing obligations must be included in FOA’s (Funding Opportunity Announcements)

Cost-sharing may not be used as a factor in the merit review of applications or proposals

200.307 Program Income 200-313 Equipment

“Conditional Title” is new; not a new concept, but designed to clarify, among other things, Federal equipment should move with the PI if they transfer between Universities; also clarifies that conditional title is calculated using project costs including mandatory cost sharing

“Percentage of Federal participation in the project costs” (A-110 required the “percentage of Federal participation in the cost of the equipment”) and “use and condition” (“use” is not included in A-110) are new; preliminary assessment is that the subtle changes in terminology will NOT require systems changes to the institution’s equipment inventory system

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Some Top Highlights and Key Issues 200.317-326 Procurement Standards

Effective July 1, 2016 (or FY17), but work ahead One year grace period before implementation

200.330 Sub-recipient and Contractor Determinations New option for each Federal agency to require us to document

how we decided each transaction is either a Subrecipient versus a Contractor

Characteristics of a Subrecipient / Contractor have not changed In new agreements with Subrecipients, be certain to reference

the terms and conditions found in the new “Uniform Guidance”, effective December 26, 2014

If you want reports from your “subrecipient”, you must include that requirement in your sub-award documentation

The provisions of the prime sponsor usually flow through to the “sub-awardee”; additional provisions may be added by the awardee

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Some Top Highlights and Key Issues200.331 Requirements for Pass-through Entities

Subrecipients must be monitored to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward

The Uniform Guidance provides recommendations, but does not specify how the pass-through entity should conduct that monitoring

Any monitoring would need to comply with the overall need for sufficient internal controls to meet the requirements in this section

Pass-through entities must honor subrecipient negotiated F&A rate or use 10% de minimis rate, or negotiate one with the subrecipient

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Some Top Highlights and Key Issues 200.332 Fixed Amount Subawards

The uniform guidance allows for the use of fixed amount (fixed-price) subawards but:

– Only with the prior approval of the Federal awarding agency– Only up to the Simplified Acquisition Threshold ($150,000)

Prior approval may be inferred if the intent is included in a proposal submission and awarded

The $150,000 cap may be problematic for some projects 200.343 Closeouts

Campuses must complete final reporting, invoicing, and cash draws within 90 days of the end of the performance period or risk not being able to recover funds expended

Although this requirement is not new, the Uniform Guidance codifies it and imposes a hard stop to adjustments

This could prove challenging in the management of subawards

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Some Top Highlights and Key Issues

200.413 Direct Costs – Clerical & Administrative The Uniform Guidance allows for the direct charging of administrative

and clerical salaries, so long as certain conditions are met: Administrative or clerical services are integral to a project or activity Individuals involved can be specifically identified with the project or

activity Such costs are explicitly included in the budget or have the prior written

approval of the Federal awarding agency The costs are not also recovered as indirect costs

A justification should be included in proposals that addresses the criteria above to facilitate the required agency approval for these charges

Any post-award addition of administrative salaries to a budget would require prior written approval of the funding agency

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Some Top Highlights and Key Issues 200.414 Indirect Costs

4-year extension, 1.3% UCA 200.419 Cost Accounting Standards and DS-2

11th hour push and cautious optimism 200.430 Compensation – personal services

Opportunities and challenges 200.456 Participant Support Costs

Now a federal-wide concept Are defined as direct costs for items such as stipends or

subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training projects

Participant support costs will be an exclusion in the MTDC base

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Some Top Highlights And Key Issues

200.461 Publication and Printing Costs The Uniform Guidance provides institutions

additional flexibility to charge Federal awards after the performance period for page charges in professional journals

This may require a system/procedure change to allow costs to post to an award after the performance period Late charges can create issues for meeting 90 day

closeout requirement for Federal awards

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What’s next?Phase One (Jan – Dec 2014)

Assess & analyze the Uniform Guidance Inform the campus and discuss approaches Issue interim guidance, as needed Issue Assessment document

Phase Two (Jan – June 2015) Update guidance & policies as needed Update DS2s (?) Update training & support, as needed

Phase Three (Jul – ~Dec 2015) Update support systems, as needed Other long-horizon actions needed

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Thoughts on Implementation Planning

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Primary UCSF Grant Reform Task Force Contacts

Nilo Mia - Budget and Resource Management Office

MC Gaisbauer - Controller’s Office Marge O’Halloran - Research Management

Services, Office of Sponsored Research John Radkowski - Government and Business

Contracts, Office of Sponsored Research

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Key Websites

Uniform Guidance, Title II CFR Part 200www.ecfr.gov

Federal Register Notice with Preamblehttps://federalregister.gov/a/2013-30465

Council on Financial Assistance Reformwww.cfo.gov/cofar

Questions and Concerns about the [email protected]

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OMB Circulars Consolidated Into UG A–21, ''Cost Principles for Educational Institutions'' (2 CFR Part 220) A–87, ''Cost Principles for State, Local and Indian Tribal

Governments'' (2 CFR Part 225) and also Federal Register notice 51 FR 552 (January 6, 1986)

A–89, ''Federal Domestic Assistance Program Information'' A–102, ''Grant Awards and Cooperative Agreements with State and

Local Governments'' A–110, ''Uniform Administrative Requirements for Awards and

Other Agreements with Institutions of Higher Education, Hospitals, and Other Nonprofit Organizations'' (codified at 2CFR 215)

A–122, ''Cost Principles for Non-Profit Organizations'' (2 CFR Part 230)

A–133, ''Audits of States, Local Governments and Non-Profit Organizations,''

Those sections of A–50 related to audits performed under Subpart F— Audit Requirements of this Part

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Final Invoice Preparation

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CGA Billing Team ResponsibilitiesContract & Grants Accounting (CGA) is responsible for

billing and payment processes for sponsored projectsKey billing functions:

Prepare timely and accurate invoices in accordance with award documents, University and sponsor policy

Submit invoices to sponsors Exception: Clinical trials invoicing initiated by departments (copy

CGA)Cost Reimbursable - CGA generates invoices based on

actual expenses incurred and posted to the General Ledger up to the authorized spending limit (appropriation)

Exception: approved PETs, submitted / approved journals for a final invoice or a late award set-up

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Departmental Administrator’s Role in the Final Billing Process

Review and ensure that all appropriate project expenses are reflected in the General Ledger prior to termination date

Submit any pending cost transfer requests so that they can be received and processed prior to the award end date or activity period end date

Review any open requisitions, purchase orders and contact Accounts Payables attempting to close immediately

For subcontracts, including those with other University of California campuses (intercampus), ensure final invoices have been submitted and paid

Determine if a carryover justification is required to move the unexpended balance from one activity period to the next

Determine if a no-cost extension (NCE) is required for the award and submit a request for an extension prior to award or activity period end date

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Final Invoices Continued… If UCSF is the subcontractor and another institution is

prime, ensure all services provided have been paid in full

If this is the final year, contact all recharge departments to terminate or change chartstring for any toll charges, phone lines and other UCSF Services such as animal care, storage etc

Review and remove unallowable costs per the office of Management and Budget (OMB) Circular A-21 and UCSF charging practices

For additional requirements, refer to the contract/agreement terms and conditions as well as University policies to fully comply with regulation and sponsor requirements for closing out an award

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Final Invoices Continued…

After the final invoice filed, clear overdraft or deficit within 90 days of the activity period or award end date Overdraft Represents the amount that spending exceeds the

award budget Deficit Represents the amount the total expense exceeds

total revenue

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Clinical Trial Post Award Topics

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Set Up of Clinical TrialsPrivate Industry Clinical Trials

Fund number 4400 is used Award purpose on award profile page is CLIN Award must be registered in www.clinicaltrials.gov by

UCSF Facilities and administration (F&A) is assessed on

gross receipts, not only an expenditure basis Base code is M

The assessment is based upon a “substitution” equation 1 – 1/(1+Rate)

The substitution rate is rounded to one decimal point The rate for clinical trials is negotiated at 33.0% of

total direct costs; the “substitution” rate is 24.8% of gross receipts.

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Set Up of Clinical Trials, continued

Private Industry Clinical Trials The rate for off-campus clinical trials is negotiated at

26.0% of total direct costs; the “substitution” rate is 20.6% of gross receipts

Department is responsible for sending the invoice to the sponsor; the department must also send a copy of all invoices to the Contracts and Grants Accounting unit, so that the invoice can be tracked for payment in the RAS accounts receivable module

The appropriation is done at the time of invoicing or time of sponsor payment, whichever comes first

52



Flow-Through Clinical Trials Fund number 4301 is used Award purpose on award profile page is CLINO Award must be registered in www.clinicaltrials.gov

by the sponsor Facilities and administration (F&A) is assessed on

expenditures, not gross receipts Base code is either C for total direct costs or A for

modified total direct costs The rate for clinical trials is negotiated at 34.0% of

total direct costs or modified total direct costs

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Flow-Through Clinical Trials The rate for off-campus clinical trials is negotiated

at 26.0% of total direct costs or modified total direct costs

Department is responsible for providing information to the Contracts and Grants Accounting unit, so that it can create an invoice that will be tracked for payment in the RAS accounts receivable module

The appropriation is done at the time of the award activation and subsequent award modifications

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Pending Matters The definition of clinical trial is going through a

review, to treat all agreements registered in www.clinicaltrials.gov consistently

We are reviewing whether an intercampus clinical trial falls under CLIN and assigned to fund 4400, or CLINO and assigned to fund 4301

Treatment of pre-clinical administrative costs has not been finalized by the campus Costing Policy Group. This oncludes both start-ups costs for a specific clinical trail, and set-up costs prior to proposal for a specific study, such as CHR protocol.

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Post Award Hot Topics

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Post Award Topics

Advances GAEL RSA updates STIP Record Retention SAM Registration T32 Management Surplus Transfers

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AdvancesWhy do we need an advance?

Funding for a subsequent year can be delayed for a number of reasons; an advance allows the Department to spend on the award while the negotiation process is being concluded

What is the benefit of getting an advance? Ensures that costs can be placed on the correct

award/project in the General Ledger Ensures that cost transfers are minimalized and that late

cost transfers are avoided Documents financial responsibility should the contract not

be awarded Ensures that compliance concerns are addressed prior to

the initiation/continuation of work on the project

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Advance, continued

What is the process to request an advance? Please consult with your Research

Management Services (RMS) contact early to ensure that the fund advance is completed and sent to CGA in a timely manner

The Award Advance Request Form and Award Activity Period Advance Request can be found on the Office of Sponsored Research website http://osr.ucsf.edu/forms

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GAEL GAEL refers to the General, Automobile, and Employee

Liability (GAEL) assessment The GAEL assessment is tied to the distribution of payroll

expense ledgers for all regular salary lines (HRG, HST), but is NOT an employee benefit

The GAEL assessment posts monthly at the time that the distribution of payroll expense subsidiary ledger is migrated to the general ledger

In the new chart of accounts, the account number is 57400 In the prior chart of accounts, the expenditure NCA code is

437970 The GAEL assessment is exempt from federal or federal flow

through funds with a 100% federal share On sponsored project awards, the GAEL assessment is subject to

the facilities and administration (F&A) base and rate of the project that posts the payroll

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GAEL If an award is coded as a federal flow through with a 100% share

from the federal government, the award will be coded as federal flow through code 3 in the Award Details link Steps to Exempt GAEL from 100% Federal Flow Through Secure proof that the award is 100% federal; there might be an

overlooked section of the award with a pertinent clause, or perhaps a sponsor e-mail will attest to the 100% flow through status

Once proof of 100% federal funding is available, send a request to the Contracts and Grants Accounting service desk to have the award updated and the general ledger reflect the reversal of GAEL entries to date [email protected]

The federal flow through code on the Award Details link will be updated 3, and the prime sponsor agency will be added; any award that is updated to 3 where the prime sponsor is an agency of the Public Health Service will be subject to the federal salary cap

Contracts and Grants Accounting will reverse the cumulative GAEL assessment on the award with a 535 financial journal

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GAELSAMPLE PROOF OF 100% FEDERAL FUND FLOW

From: Hax, John R@DOR [[email protected]]Sent: Tuesday, September 30, 2014 12:10 PMTo:Cc:Subject: RE: Contract #28838 (CFDA #84. 126A) Award A121902

Hi : 100% of the funds you receive as payment on your 801B service invoices are ‘federal’ funds. Once your match is received and the federal draw down funds are received from the federal Rehabilitation Services Administration, all funds are to be identified as ‘federal’ funds. Hope this helps. John R. Hax, Program SpecialistCollaborative Services SectionCA Department of Rehabilitation(916) 558-5438 CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication.

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GAEL

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GAEL

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GAEL

If an award is a non-federal or non-federal flow through, and the sponsor disallows the GAEL assessment, the department will be required to cover the assessment In the case of non-federal GAEL disallowances, the

GAEL will not be reversedDepartments will be required to transfer the

cumulative GAEL accrued on account 57400, at the project level, from the sponsored award to a discretionary fund, using a 535 financial journal

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STIPThe University defines STIP as a general resource

available to the department head to invest in strategic plans as he/she best determines. Therefore, the intradepartmental allocation of STIP is not considered necessary, except where an external sponsor requires the allocation of STIP to the award

If the department head determines an intradepartmental allocation of STIP is necessary to meet the department's strategic objectives, the intradepartmental allocation may not cross fund families

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STIP, continuedWhen the sponsor mandates that STIP be

allocated to the award, the Department is responsible for transferring all reportable STIP onto the award throughout its life

Department must request budget entry through [email protected]

CGA will monitor for compliance with the award terms during the generation of the FSR and at the time of closeout

Information on this policy: Job Aid – to come Contact - Denis Nepveu, Director - Resource Planning

[email protected]

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Record Retention

A records retention schedule defines the period of time that records should be retained and when they should be destroyed Various requirements based in law and university policy

govern the retention of administrative records A retention schedule is critical for promoting responsible

records management, mitigating risk, and ensuring consistent compliance across UC

Record retention resources are as follows: Records Retention and Management Policy 050-19 located at

http://policies.ucsf.edu/policy/050-19 UC Records Retention Schedule located at:

http://recordsretention.ucop.edu/ Campus Records Management Coordinator: Brenda Gee DePeralta

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System for Award Management (SAM)

SAM, launched in 2012, integrated 8 federal procurement systems (including the old CCR) into a single streamlined system

Provides federal government with details of management, performance, representations, certifications, etc.

Registration is updated annually (next due date 3/5/15)

Awards/subcontracts may request UCSF to provide SAM status or expiration date

https://www.sam.gov/portal/SAM/#1

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System for Award Management (SAM)

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T32 ManagementAppointments

Appointment forms must be submitted through xTrain before the start of the trainee’s appointment or reappointment

Must correlate to the trainees identified and stipend charged to the general ledger

Stipend levels detailed at: http://grants.nih.gov/training/nrsa.htm

Generally appointments are for a full-time, 12 month period

Termination Notices PD/PI is responsible for submitting, via xTrain, within 30

days of the end of period of support xTrain – Business Officer is Freddie Robinson

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Surplus Transfers

A surplus may result at the expiration of a fixed priced award/activity period

Sponsor agreements may require that surplus amounts be returned to the sponsor, or may be retained by the University

Surplus transfers, within the University, should be recorded on a 78% account number The amount transferred should consider the IDC

impact Any questions should be directed to the CGA

Award Closeout Team73


Compliance Update

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Compliance Update

Transition Initiated search for Compliance Manager Rick Blair will serve as interim Compliance

Manager Key Initiatives

Effort Reporting – period closes 10/31/14 T32 Policy Change Audit Status Updates

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Effort Reporting ConsiderationsRoles

ERC role is to facilitate process, organize and communicate with PI

PI role is to review and certifyFunction – PI is certifying based on first hand

knowledge of effort If a PI has already certified an entire report for

another faculty member, there are two possible solutions If the effort certification is correct, the faculty member

should add a comment to their effort report stating concurrence with the certified percentages; comments may be added after certification by using the Comments tab

If incorrect, the report should be recertified

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T32 Award Policy Change The NIH Grants Policy Statement changed the allowability of Training Related

Expenses in 2014 – for this to be applicable at UCSF, we must adopt a new charging policy and update our payroll system

http://grants.nih.gov/grants/policy/nihgps_2013/nihgps_ch11.htm#_Toc271265131 11.3.8.4 Training-Related Expenses

Our goal is to have the new campus policy in place and the payroll system modified by the end of the year - the final implementation date will be announced in an upcoming newsletter

The new campus policy will allow for the charging of Health benefits (medical, dental and vision) ▪ Tuition and fee Leave rights ▪ Travel Malpractice insurance - if the research training experience involves direct contact with

patients or human subjects The following items will continue not to be chargeable to grant:

Disability insurance ▪ Life insurance Union dues ▪ Unemployment insurance Workers’ Compensation ▪ FICA GAEL (General, Auto, and Employment Liability)

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Audit Status Updates

Audit status Annual Financial Statement Audit A-133 Audit Compliance Reviews – Administrative Expenses

Thank you for your assistance during the audit process and your diligence during the year

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QUESTIONS?

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We Are Here To Serve You

Research Management Services (RMS) for federal grants, fellowships, cooperative agreements and all non-profit sponsors

http://osr.ucsf.edu/find-my-osr-staff Government and Business Contracts (GBC) for federal contracts and

all state, city, county, and foreign government/organization sponsors

http://osr.ucsf.edu/content/gbc-contact-information Industry Contracts Division (ICD) for all industry sponsors (industry

is the prime sponsor)http://ita.ucsf.edu/about/staff CGA Service Desk for post-award issues [email protected] Also a CGA service quality survey at https://ucsf.co1.qualtrics.com/SE/?SID=SV_cuSKJUDE6sZTnjT

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