Office of Research Administration

Faculty Forum September 26, 2007

Vision

To serve the campus community in its research initiatives in order to provide operational effectiveness of the research enterprise while maintaining regulatory compliance.

Office of Research Administration Recent changes in the Office of Research

Administration were made to: Enhance Customer Service to the research

community Change the “service culture” Reorganized staff to focus service for departments Reorganized staff to consolidate financial management

under ORA Ensure research compliance

Policies Procedures Training Other

Results Communication to research community E-mail updates Response time to inquiries Training and education to research community Monthly research reports to DHHD’s

One stop shopping

Streamline signature process for proposals and awards

Results

Productivity metrics for establishment of a fund.

Prior to Feb 07: 48% set up within 30 days of start date 34% set up within 14 days of start date 36% set up after 60 days of start date

After Feb 07: 69% set up within 30 days of start date 54% set up within 14 days of start date 12% set up after 60 days of start date

Research Compliance Currently in an environment of greater scrutiny by the

federal government on the compliance of the use of federal dollars

Areas of Compliance: Security and Biosafety

Select Agents Export Controls Foreign Nationals Publication restrictions Sensitive and Classified data

Technology Transfer Bayh-Dole Act

Human Subjects HIPAA

Research Compliance Areas of Compliance:

Financial Office of Management and Budget (OMB) Circulars:

A-21 A-110 A-133

Conflict of Interest Scientific Misconduct Animal Welfare State of Colorado

Contracts Fiscal Non-compete

Research Compliance Recent Federal government focus in the

financial compliance arena specific to the compliance of the OMB A-21 circular: Cost Sharing Effort Reporting Cost Transfers Administrative and Clerical Salaries Monitoring of Sub-recipients (OMB A-133

compliance supplement)

Research Compliance Inspector Generals (NIH, NSF, others)

performing subject target audits: NSF OIG found

U of Hawaii cost sharing certifications not supported NMHU cost sharing tracking system inadequate UPENN non compliant with effort reporting

processes: timeliness, and documented verification Georgia State University - $400,000 unallowed for

deficient sub recipient monitoring NIH OIG found:

Yale non compliant with cost transfers, effort reporting and cost allocations – resulted in disallowed funds

Research Compliance DOJ found

UConn non compliant with many research administration practices characterized as “sloppy recordkeeping and poor management of grants” – resulted in $2.5 million disallowed.

UConn instituted mandatory training program for all faculty and staff associated with research

ED disallowed $500,000 of funding to the Colorado Community College system due to deficiencies in effort reporting

HHS OIG inquiry to CSM on it’s findings indicated in the June 30, 2005 audit

EPA audit on CSM in FY2006. Disallowed expenses and found deficiencies in effort reporting

DOE inquiry to CSM about FY06 audit findings prior to award of grants

Research Compliance CSM Plan

Education and training for faculty and staff Guidance for the research community Policy review and development:

Sub Recipient Monitoring procedures (done 6/06) Cost Transfers (done 7/1/07) Tuition remission (done 9/1/07) Recharge Center rates (drafted) Effort Reporting Cost Sharing Direct vs. Indirect charges Allowable vs. Non-Allowable charges Export Controls Others

Working with the State on removing certain State requirements Immediate changes for known non-compliant matters

Audit Industry Focus

CSM is subject to various audits: Required annual audits

Financial – All activity Compliance (OMB A-133) – Sponsored activity Defense Contract Auditing Agency (DCAA) – F&A

and Fringe rates Others

OIGs Sponsors Internal State

Audit Industry Focus

Potential ramifications of having deficient audits:

Risk of loss of sponsor funding Risk of loss of state funding Increased audit scrutiny Increased state oversight

INTRODUCTION TO OMB CIRCULAR A-21 DEFINES AN "ALLOWABLE COST" . Available at

http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html

INSTRUCTIONS FOR THE UNIVERSITY TO ALLOCATE INDIRECT COSTS PROPERLY AND TO CALCULATE THE INDIRECT COST RATE

APPLIES TO PROJECT(Direct) COSTS REIMBURSED BY THE GOVERNMENT AND TO COST SHARING OR MATCHING FUNDS

GENERAL REQUIREMENTS: REASONABLE ALLOCABLE TO (BENEFITS) THE PROJECT SUPPORTED BY

THE GRANT OR CONTRACT TREATED CONSISTENTLY (INCLUDING CONSISTENT

TREATMENT AS EITHER A DIRECT OR INDIRECT COST

UNALLOWABLE COSTS

Advertising and public relations costs (with specific exceptions)

Alcoholic beverages Alumni activities Bad debts Institution-furnished automobiles Commencement costs Donations or contributions Entertainment Lobbying Fines and penalties Goods and services for personal use

UNALLOWABLE COSTS (cont’d)

Housing and personal living expenses Interest, fund raising and investment management

costs Membership in social, dining, country clubs, or civic

organizations Selling and marketing Student activities Airfare costs in excess of the lowest available

commercial discount airfare (with specific exceptions) Awards, prizes, trophies Flowers, gifts Parking tickets

DIRECT vs INDIRECT COSTS

What are direct costs? Identified specifically with a particular

sponsored agreement and incurred to advance the work under that agreement

Assigned to a sponsored agreement relatively easily and with a high degree of accuracy

DIRECT vs INDIRECT COSTS

What are F&A costs (Indirect costs)? Benefit common or joint activities Benefit numerous projects

Cannot readily be identified with a particular sponsored project

Cannot be proportioned to benefit a group of sponsored projects with relative ease or with a high degree of accuracy

NORMALLY Indirect costs Administrative and Clerical Salaries Office supplies, postage, dues and

memberships, local telephones(telephone equipment)

Computers – can be either an indirect cost or a direct cost depending on the scope of work of the project (Justification form)

A-21 Exhibit C provides for exceptions for charging normally indirect costs if the project is a major project

ORA

ORA is focused on serving the campus community in its research initiatives in order to provide operational effectiveness of the research enterprise while maintaining compliance.

Information available

ORA web site: http://www.is.mines.edu/ors/

Contact ORA staff

Questions

Thank you!