Managing yourGrant Award

Fiscal Responsibilities of Post Award Administration

Provided byNKU Comptroller’s Office Grant Accounting

Staff

Grant vs. Internal Order Grant – is awarded to NKU by an external

source. Internal Order – is an award made by NKU to

an employee of NKU for an approved project. Community Partnership Faculty Projects SEM Awards

Good to know…

Funding Agencies make awards

to the University,

not to the

individual Principal Investigator (PI)

Overall PI RoleWhile the University is legally responsible for the stewardship of an award, thePI’s role is to manage the effort in compliance with:

applicable federal and state regulations

University policies/proceduresfunding agency’s agreement

Funding Sources Federal Government State Government Local Government Private Federal Flow Thru (federal awards made by a

state/local/private organization)

The Principle Investigator (PI)

While the PI may delegate tasks to others associated with the award, the accountability and overall responsibility always remain with the PI. The signature and/or approval authority remains with the PI. There are no exceptions.

If NKU and/or PI does not comply… Disallowed costs Reduction in grant funding Termination of grant award Return of grant funding Tainted reputation Jeopardize future grant funding

Time & Effort Non-Compliance Consequences (examples)Failure to meet requirements puts the University at

risk for audit disallowances resulting in significant financial penalties.

Northwestern University $5.5 million University of Southern Florida $4.1 million Johns Hopkins $2.6 million Harvard University $3.3 million University of Alabama Birmingham $3.39

million.*NSF OIG, Semiannual Report to Congress, March 2010

PI Key Responsibilities Managing overall grant award and any changes Authorizing and reconciling expenses Purchasing and equipment accountability Defining, hiring, and managing NKU personnel Managing external personnel (sub awards,

contractors) Managing travel Submitting progress/technical reports Keeping proper records/receipts

Managing grant award Executes as outlined in award agreement:

the deliverables, timeline/deadline, budget, and staffing.

The PI is the only NKU authorization for purchase requisitions, travel documents, interdepartmental bills, budget transfers request, Personnel Action Requests (PAR), and Time & Effort sheets, etc. Not the chair or dean.

Follows all NKU policies/procedures related to compliance (human subjects, recombinant DNA, animal care, biosafety, and financial).

Communicates research misconduct, misuse/abuse of funds, or fraud within NKU chain of command.

Grant Budgets If a budget revision is needed the PI must

e-mail Barb Smith with the budget transfer request.

If budget revision require sponsor approval, the PI should work with RG&C office.

Only the Comptroller’s Office can complete a budget transfer within a grant.

No funds can be moved into or out of a grant.

Expenditure Monitoring

Monitor cost spending to ensure it is necessary, allowable, and reasonable for awarded effort and is consistent with NKU’s policies, applicable state and federal regulations and per the sponsor agreement.

Keep all cost spending within funding period – do not stockpile costs near end of grant.

Ensures receipts and cost records are maintained. The PI understands cost share and/or third-party matching funds.

Ensures documentation is obtained, certified, and reported to Comptroller’s Office.

Attends training on use of NKU SAP PRISM system to manage grant spending. Then, monitors and reconciles SAP grant account monthly.

Expenses (cont.) Grants have a begin date and an end date.

No expense can occur before the begin date or after the end date; any items purchased for the grant must be received on NKU campus before the grant end date.

Do not wait until the end of the grant to make purchases.

Expenses (cont.) The completion date is the date on which all work

under the grant/contract agreement should be completed, or the date on the agreement on which sponsorship ends. All expenditures must meet a reasonable and necessary test to be allowable charges. It is extremely difficult to defend large or numerous expenditures in the final weeks of a project. Many times such costs are disallowed because the PI was trying to “spend all the money”. At times, written justification may be required for large expenses incurred or requested during the final weeks of a project.

Expenses (cont.) Use on-campus services (Printing Services,

Copy Center, and Food Services, etc). If necessary services are not available, Purchasing must approve before an outside vendor can be used.

Purchase Requisition University requisitions require approval for any

purchases over $1,000, but all grant purchases must be approved by the PI.

The more information that is included in the requisition the better. Use the comments section and attach documentation.

Grant PI will need to approve all purchase requisitions either in Universal Work List (UWL) or their SAP Workplace.

ProCard Required to be reconciled within 3 business

days of the 25th of the month. Can reconcile weekly.

Purchasing uploads the ProCard once a week.

If the grant purchases are not reconciled they will be charged to the PI’s department cost center.

Penalties for not reconciling the ProCard can be found on Purchasing website.

ProCard (cont.) Make sure the original receipt is kept with the

PI’s grant paperwork. Recode requests can be written by the

Academic Coordinator and sent to the PI. The PI should forward the e-mail and his approval of the recode to Tom Barnett and cc Barb Smith.

Recode requests should be sent within 60 days of the expense posting date.

Food Expense Food expense is an expense that is

scrutinized and sometimes disallowed Must be for a meeting or educational purpose Cannot be for entertainment purpose No alcohol

Meals and Entertainment Form is on the Purchasing website Fill out any time there is a food purchase on a

grant Attach to the detailed receipt and keep in the

grant file

Equipment Contact NKU Purchasing department before purchases (or

commitments to purchase) equipment greater than $5,000 from a vendor are made.

Coordinate all technology, PC, and software purchases through Purchasing/IT departments. If not, risks are: Jeopardize NKU security infrastructure NKU may already have a site license (enabling a cost savings) They may have contracts with Vendors that offer a better price

Do not use Procurement card for technology purchases! Seek support from NKU Purchasing department.

Equipment (continued) Recognize that any item ordered must be received on

NKU campus by the grant end date. Recognize that any equipment purchased becomes the

property of NKU.

NKU Personnel Adhere to signed NKU Conflict of Interest form as it relates to

hiring personnel. Work with NKU Human Resources to understand University

staffing policies on generating JAQ’s, hiring employees and preparing Personnel Action Requests (PAR) accurately and in a timely way.

Manage time and effort reporting for grant employees. Work with Office of Student Financial Assistance to correctly hire

and pay students. Work with Payroll Office to complete student research stipend

forms.

Time & Effort Certification Faculty and Staff exempt employees are

required to certify their time. Time certification is completed thru Employee

Self Serve within the MyNKU portal. Time certification can be done electronically

on a monthly basis. Time certification approval is completed

through the Universal Worklist within the MyNKU portal.

External Personnel Work with the Office of Student Financial Assistance if award

includes student or participant tuition. Procedures for grants with tuition are on the Comptroller’s Website Contact NKU Procurement department before contracting with an

individual or firm to perform any service/work.

The Procurement department will assist with creation of the Personal Services Contract, which is required by state law.

Note: There are social security charges on all student payroll during the summer and Christmas break(including student research stipends). There are no social security charges during the academic year if a student is taking a full load of classes.

Travel Ensure all travel charges include relevance to

project’s scope (what, where, who, how). Ensure travel on grants follow all NKU travel

policies. Travel must be the most economical for all

individuals traveling on the grant. Foreign Travel must be specifically allowed

by the grant or the PI must receive authorization from the sponsor.

Grant Unallowable CostOffice of Management and Budget CircularA21established the principles for determiningcosts applicable to grants, contracts and otheragreements with educational institutions. Theprinciples are designed to provide that the federalgovernment bear its fair share of the total cost,determined in accordance with generallyaccepted accounting principles, except whererestricted or prohibited by law.

Grant Unallowable Cost

The basic considerations for determining theallowability of costs are located at the linkbelow.

http://comptroller.nku.edu/grants/index.php

Reporting The PI is responsible for understanding

progress/technical reporting requirements as outlined in award. All progress/technical reports should be submitted on time using the specified format. A copy of any final reports should be sent to the Comptroller’s Office.

Understand that any requested financial information must be prepared by NKU Comptroller’s office.

Record/Receipt Keeping Assures integrity and safekeeping of all

related files (including & especially procard receipts, reports etc.) for time period stated in funding agency and NKU’s policies.

Comptroller’s Office sends a closing memo to PI’s approximately 90 days before the grant end date. The memo includes how long the grant documents/receipts should be kept.

Grant File The PI is responsible for maintaining the

grant file. If the PI leaves NKU employment the grant

file should be maintained by the Chair.

University account/grant account differences Grant period may differ from university fiscal

year (July 1 – June 30) Grant may have a different closeout date

than June 30. Grants may use different budget rules than

NKU. There can be different budget rules/pools for

each grant. The SAP reports for grants are different from

the University reports.

University account/grant account differences (cont.) Budget flexibility is not the same as for

University accounts Allowable/unallowable expenditures per NKU

may differ from grants Allowable/unallowable expenditures

permitted by funding agencies may differ No transfer of funds into or out of grant

accounts are allowed Budget transfers can only be completed by

the Comptroller’s Office

Grant SAP Coding Grant numbers are 7 digits (start with

4000xxx) Cost center numbers are 9 digits Match cost centers end in 50 Grant cost centers end in 55 or 65 Grant expenditures require a cost center and

a grant number.

SAP GUI Grant Reports ZGBC–Grant Budget Consumption report

The grant Budget Consumption report is the sponsor view report. With this report, you can check budget activity by sponsored class within the grants management view and check the available balance. The report displays internal match funding and external grant funds

ZGPC–Grant Project Consumption Report The Grant Project Consumption report is the NKU view

report. With the report, you can check expense activity by commitment item within the funds management view. The report displays both internal match funds and external grant fund expenditures combined. This report cannot be used for budget purposes.

SAP BW Grant Reports Grants Management Labor Distribution Grants Management PBC Payments Grants Management Recipients of Financial

Aid Grant Transaction List by Month

Help and Training Links myNKU website for SAP support information:

http://it.nku.edu/mynku/help.php

Grant SAP Training – to register for a SAP grant training course:http://pod.nku.edu/podreg/allevents.asp?sort=date

Post Award Grants & Contracts Administration Staff

TITLE NAME TELEPHONE E-MAIL DUTIES

Director of Research Foundation Accounting/ Grant Administration

Barb Smith (859) 572-6456 smithba@nku.edu

Setup/maintain grant master data, approve all Budget Entries, Journal Entries, PR Retros, invoices/financial reports, meet with PI’s, sub recipient monitoring, F&A, tuition, SAP grant enhancements

Grants & Contracts Manager

Lisa Burson (859) 572-7619 bursonl@nku.edu

Prepare federal cash draws and federal financial reports, grant close out, Time & Effort and final progress report tracking; review/approve Interdepartmental bills, NorseCo

Senior Grant Accountant Tom Barnett (859) 572-5614 barnettt@nku.edu

Review/approve purchase requisitions, travel & credit card transactions, review recode request, set up sponsor programs, Stream Corridor, WNKU

Senior Analyst, Budget & HR Integration

Tonya Smiley (859) 572-5264 smileyt@nku.edu

Grant payroll, review grant PAR’s, set up release/reassigned time, prepare PR retros/corrections, campus based programs, grant training

Grant Accountant Kim Peace (859) 572-1978 peacek2@nku.edu

Prepare invoices/financial reports, SAP entry of journal entries and budget entries, review departmental charges, credit balance report, maintain invoice/reporting calendar, deferred revenue, monitor accounts receivable

Grants & Contracts Administration Website

http://comptroller.nku.edu/grants/index.php

In summary When a grant award is made, the PI will be

invited to a “post award” meeting with NKU Comptroller’s Office and an RGC contact. The PI responsibilities will be reviewed in detail then.

When in doubt on anything related to your grant, ask any grant staff in the Comptroller’s Office.

Managing your award - fiscal responsibilities.Rev2.ppt 7/12/12