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SPA Newsletter - Spring 2017

SPA NEWS

Greetings from SPA/OSP/CGA!

Updates from SPA/OSP/CGA*:

Welcome to the Spring SPA News. In addition to the many articles full of tips and updates, I want to share some new developments with you.

Research Administration (RA) System, Kuali Coeus (KC): MSU will be going live with the proposal and conflict of interest modules of KC April 24, 2017. An article with additional information on the implementation is included in this issue, but here I would like to recognize by group, the many people that were involved in the project. My appreciation and thanks to:

  • The RA Project Team that led the efforts and worked on the project full-time,
  • The collegiate and departmental representatives that participated in solution-oriented sessions as part of RASIC** and the sub-group that were also involved in training,
  • The faculty and administrators that participated in the Pilot to test the system,
  • The SPA/OSP/CGA, Business-CONNECT and Conflict of Interest Office staff that teamed with the RA Project Team to support development, data conversion, business determinations, and creation of resources and training efforts,
  • The many central offices that provided resources, particularly the Controller's Office, Office of Planning and Budget, and Information Technology Services,
  • The many committees that were actively engaged and provided input, and
  • The RA Executive Committee that provided direction and oversight to the project.

Changes in CGA: After almost four decades with MSU, CGA Director Dan Evon, has announced his decision to retire effective July 3, 2017. I want to thank Dan for his dedication, his many years of leadership and service and the valuable contributions he has made to MSU. We wish Dan the very best in retirement.

Through an open and national search process, I am happy to announce that Evonne Pedawi has accepted the position of CGA Director.  She will officially assume the role July 5 after Dan’s retirement. Evonne is a MSU graduate with dual degrees in Mathematics and Chemical Engineering. She began her MSU career in CGA 12 years ago, progressively taking on more responsibility including seven years as the CGA Assistant Director. Evonne will pursue the new assignment with strong leadership and a commitment to quality and to MSU. I look forward to working with her. The recruitment for the new CGA Assistant Director is expected to begin the end of April.

Office Values: As part of our strategic planning process and with input from the staff and the MSU core values, we recently developed our SPA/OSP/CGA* values: Quality, Fairness, Integrity, Respect, Service, and Teamwork, i.e., the tagline is "Quality FIRST". These values will be the framework for what we do and the bedrock of our Newsletters.

For suggestions for future content or feedback on this issue, please contact Jennifer Lafferty, stumpje1@osp.msu.edu or me, reighley@osp.msu.edu. Authors or contact information have been included in each article for topic-specific questions. Thank you for spending a few minutes to review the Newsletter.

Twila Fisher Reighley, Assistant Vice President for Research and Graduate Studies

Updates on International Sponsored Awards
Tools & Resources
by Twila Reighley & Katie Winkler, SPA

Homepage for International Tools & Resources

In Phase 1, the International Sponsored Awards Workgroup (ISAW) provided input to the development of a webpage focused on international sponsored awards. A description of the process and resources is at: Fall 2016 Newsletter

ISAW started Phase 2 in the Fall 2016 and is supporting great progress on creating more tools and resources. Some have been identified below:

  • Global Research Administrator Network and Development (GRAND) Forum – In December 2016, SPA/OSP/CGA hosted the first GRAND Forum for those who are supporting or who are interested in supporting international sponsored projects to learn and collaborate. The next GRAND Forum is scheduled for May 9, 2017. You can register here.
  • Subaward Videos – with department/college input, several OSP and SPA members have created videos to assist subawardees with pre-award activities. Please see the article in this issue of the SPA Newsletter for links to the videos! We anticipate that there will be six videos published by June 2017 and three more by Fall 2017.
  • Subaward Processing Data – OSP drafts and executes subaward documents for agencies that do not participate with the Federal Demonstration Partnership (FDP) model agreement, which applies to the majority of international subawards. To further explore how to best decrease the amount of time it takes to write and negotiate a subaward, we analyzed international subaward processing time in OSP. For the year ending September 2016, OSP processed over 160 new international subawards and modifications with an average processing time for signed agreement in OSP of 9 calendar days and overall processing time including others (subawardee, department/unit, PI, or with other offices) of 32 calendar days. The data suggests that there may be opportunities outside of OSP to improve processing time and we will consider options further.
  • How to Pay for International Activities – the Controller's Office developed with input and support from SPA, CGA, and ISAW a table to show methods of payment available at MSU for international activities payments. The tables on the Accounting Office webpage includes information for "Payroll, Purchasing, Services and Travel", "Direct Deposit" for employee salaries and employee expense reimbursement, "MSU Check and Foreign Currency Draft", and "Wire Transfer."
  • Budgeting for Project Manager – new guidance has been included in our Budgeting Preparation Considerations section of the international webpage: For medium to large projects, budgeting for a Project Manager is encouraged to leverage the faculty members' time and increase resource management which could include managing budgets, personnel, other resources, and subawardees, monitoring and complying with performance schedules and completing reports, plus understanding a myriad of systems.
  • Subrecipient Expenditure Invoice Template for standard subrecipients. To maintain consistency, MSU is using the template created by the Federal Demonstration Partnership. The templates are updated annually and revised versions are posted if changes warranted to address Federal requirements.

Phase 2 is expected to end May 2017. As a campus, we should continue to pursue opportunities to increase MSU’s capacity and improve processes to manage financial and contractual/grant obligations for international sponsored projects.

If you have any questions about ISAW or the webpage, please contact Katie Winkler (ashbau10@osp.msu.edu) or Twila Reighley (reighley@osp.msu.edu).

Updated OSP Budget Development Guidelinesby Craig O'Neill, OSP

OSP has posted updates to our Budget Development Guidelines which provides guidance on the standard budget categories, budget justification, and Frequently Asked Questions. A summary of changes follows:

  • In case you missed it, helpful information and tools for international projects can be found at the following link: https://osp.msu.edu/PL/Portal/DocumentViewer.aspx?cga=aQBkAD0ANAAyADEA
  • Update – Research Associate (i.e. postdoc) Salaries: Per the memo issued by Provost Youatt on December 21, 2016, the minimum salary for research associates has been raised to $42,500 (AN) / $34,772 (AY) with the intent to raise all research associates salaries to $47,484 by July 2018. Therefore, all new proposals going forward are to budget at a minimum of $42,500 now and $47,484 by July 2018. Inflationary increases after July 2018 follows the standard 2-4% range.
  • New Clarification – Intra-Institution of Higher Education (IHE) Consulting (also referred to as Overload) by faculty is assumed to be undertaken as part of their normal duties requiring no additional compensation to their Institutional Base Salary (IBS). However, in unusual cases where consultation is across departmental lines [different last 3 digits in the CUC code] or involves a separate or remote operation, and the work performed by the faculty member is in addition to his or her regular responsibilities, additional compensation above their IBS may be allowable with sponsor approval. The IHE consulting arrangements must be included in the Budget Justification, with the name of the individual receiving the IHE consulting payment specified. The IHE consulting rate should be budgeted at the faculty member's estimated hourly rate with 7.65% for fringe benefits.
  • New Clarification – Institutional Review Board (IRB) fees are only budgeted on non-governmental sponsored projects. See MSU HRPP Manual for more detail.
  • NEW FAQ – Q: If an RFA indicates that the project could be funded by a different Federal agency (e.g. "an interagency partnership between NSF and USDA/NIFA"), what applicable F&A rate should be used? A: The full F&A rate should be used unless the RFA states otherwise. If considered for funding by another agency, normally the PI will be instructed by the agency to withdraw their original pro-posal and resubmit it in accordance with instructions provided by the applicable agency’s Program Officer. This frequently happens with USDA/NIFA funding since their F&A reimbursement might be limited by legislation and the budget may need revision to be compliant.

Tips: Completing the Subrecipient Commitment Form
by James Bliss & Adam Stone, OSP

MSU's "Office of Sponsored Programs Subrecipient Commitment Form" (Form) is an effective tool for performing due diligence before executing a subaward. We have put together some tips for completing the form to help expedite your project’s subaward set-up. *Please Note: Due to the FDP Expanded Clearinghouse initiative, we will soon issue a revised Subrecipient Commitment form. The information below will still be applicable.

Supplemental Pages are Important

If a Subrecipient's budget includes a Fringe Benefit rate or Facilities and Administrative Cost (F&A) rate other than a federally negotiated rate or de minimis rate, it is important that the Subrecipient provides a description of the basis on which the rates were calculated. A well-written description can help expedite MSU’s determination of the allowability of the Fringe Benefit and F&A rates requested by the Subrecipient organization.

Don't Forget the FWA & AWA Numbers

When a Subrecipient's work will involve Human Subjects, a Federal Wide Assurance (FWA) number is required. Through the FWA, an institution commits to the U.S. Department of Health and Human Services (HHS) that it will comply with the requirements in the HHS Protection of Human Subjects regulations at 45 CFR Part 46. If the Subrecipient organization does not yet have an FWA number, one may be obtained through the U.S. Department of Health & Human Services website. Likewise, when a Subrecipient’s work will involve the use of animals, a Public Health Service Animal Welfare Assurance (AWA) number is required. The AWA confirms that a Subrecipient has committed to complying with the U.S. Public Health Service Policy, with the Guide for the Care and Use of Laboratory Animals, and with the Animal Welfare Act and Regulations. If the Subrecipient organization does not yet have an AWA number please visit the National Institutes of Health website or call 1-301-496-7163 for information on how to obtain one.

DUNS Number

A DUNS number is a nine-digit number used to identify an organization. It is required by the U.S. Government for recipients (including subrecipients) of federal funding. If the Subrecipient organization does not have a DUNS number, it will need to register for one by visiting the Dun & Bradstreet (D&B) website or calling 1-866-705-5711. Registering is free and it only takes 1-2 business days to receive the number.

If you have any questions about the Subrecipient Commitment Form or suggestions for how to improve it, please feel free to contact Adam Stone (stonead@osp.msu.edu) or James Bliss (blissjam@osp.msu.edu).

Subrecipient Monitoringby Kristy Smith, CGA & Diane Cox, OSP

The Office of Sponsored Programs (OSP) and Contract and Grant Administration (CGA) recently revised the Subrecipient Monitoring Policy which applies to all subawards issued on RC accounts. The full policy can be found at https://cga.msu.edu/PL/Portal/DocumentViewer.aspx?cga=aQBkAD0ANQAxADEA, and a summary is posted below.

Who do we monitor and who does the monitoring?

  • When MSU uses project funds to work with another entity (via a subaward), we are required to monitor the activities of that entity (called a subrecipient). The Subrecipient Monitoring Policy applies to all subawards issued on RC accounts, regardless of funding source (federal or non-federal), amount or award type (grant, contract, etc).
  • The Principal Investigator (PI) has oversight of all subrecipient activities including programmatic performance, while department administrators initiate payments and act as the liaison between the subrecipient and MSU’s central offices. OSP and/or CGA reviews subrecipient budgets, drafts and executes subaward documents, reviews subrecipient payment requests for compliance, interfaces with sponsor administrative contact if needed, and performs risk assessments and debarment checks.

What do we monitor?

  • MSU is responsible for monitoring all subrecipient activities related to a subaward. Programmatic activities are monitored by the PI with support from the department administrator. To monitor financial compliance, OSP/CGA typically evaluates each subrecipient annually. As part of that process, a risk assessment is completed based on a subrecipient’s financial stability and organizational information. OSP/CGA uses the risk assessment, as well as project specific information to draft subaward terms and conditions.

Why do we monitor?

  • The federal government requires MSU to monitor subrecipients to ensure that federal funds are being properly used when we act as a pass through entity. MSU extended the monitoring requirements to non-federal projects to support stewardship and maintain consistency.

When do we monitor?

  • Subrecipients are monitored throughout the life of the subaward. OSP/CGA uses the subrecipient’s risk assessment to establish the subaward terms and conditions and monitors financial compliance in collaboration with the PI as payments are processed and/or modifications are executed.

Where do we monitor?

  • Typically, MSU monitors subrecipients from the comfort of our campus. We utilize email and other forms of communication to obtain the necessary information, review compliance documents, and track the progress of subawards.
  •  MSU may conduct site visits to review programmatic and/or financial compliance depending on the project and subaward.

Questions regarding subrecipient monitoring can be directed to Kristy Smith in CGA (smith@cga.msu.edu) or Diane Cox in OSP (coxd@osp.msu.edu).

Client Feedback Surveysby Erin Schlicher, SPA

SPA/OSP/CGA strives to provide excellent customer service in all stages of research administration, from proposal development to the final closeout of an award. Client surveys solicit feedback on our proposal, award, and post-award processes. In addition to the ratings responses, the surveys include an area for open ended comments to collect additional input. This feedback is useful to management in helping assess the level of client support and providing ideas and encouragement to improve services to the campus community.

Award Negotiation & Account Setup Survey

Between July 1, 2016 and March 31, 2017, we received 142 unique responses from participants interacting with personnel from the OSP and CGA on award negotiation and account setup activities. Due to the KC implementation, we temporarily suspended this survey between August 12, 2016 and October 11, 2016, resulting in a decrease in the total number of responses received. Overall, 89 percent of responses indicated satisfaction with the award negotiation and account setup processes.

Negotiation and Award Survey Report Metrics

For the award negotiation portion of the survey:

  • 92% were kept informed during the award negotiation process
  • 96% were treated courteously by staff involved in negotiations
  • 91% were satisfied with the negotiation and agreement execution

For the Account Setup portion of the survey:

  • 80% agreed that the account setup and availability of funds was handled in a timely manner
  • 91% were treated courteously by staff involved in the account setup
  • 86% were satisfied with the account setup

CGA Survey

Between July 1, 2016 and March 31, 2017, we received responses from 77 individuals who worked with CGA on post award services. The results show a high level of satisfaction with CGA's post-award services.

CGA Survey Report Metrics
  • 90% received a response from CGA in a timely manner
  • 89% were satisfied with CGA's turnaround time to complete the post-award tasks
  • 90% received a clear explanation from CGA regarding compliance with the award
  • 96% were treated courteously by CGA staff

In addition, respondents were asked to rate their overall satisfaction with CGA’s post-award services. 95% of individuals that responded indicated that they were either extremely satisfied or somewhat satisfied with CGA’s services.

CGA Survey - Overall Satisfaction

Thank you to all who participated in the surveys! We appreciate your input and will continue to use your responses and comments to improve our services to the campus community.

Audit Cornerby Dan Evon, CGA

It’s time to return to the basics, so let’s review how MSU can continue its long-standing track record of clean audits.

Do audits actually occur? Yes they occur and probably, more often than you might think. Last May I made a presentation about MSU sponsored program audits to the MSU Board of Trustees’, Audit Committee. The following data is from that presentation (with the addition of the 2015-16 data) and shows the number of external audits of MSU sponsored programs conducted each fiscal year:

FY 2012-13 FY 2013-14 FY 2014-15 FY 2015-16
42 46 30 23

What is an audit, and are they all similar? Audits are a way for the sponsoring agency to verify that we are performing the project according to their regulations. Audits can be focused on performance (technical/scientific) issues, financial issues, or they can be specific investigations as a result of hotline or whistleblower calls.

What should you do if you learn that an agency plans to conduct an audit? Contact CGA immediately! Since we are involved in a lot of audits, we have developed responses to questions that will save you time, and we speak the official language of auditors, e.g., debits and credits, allowability, allocablility, and reasonableness (oh my)!

Why is it important to have clean audits (without findings)?

  • To avoid the financial impact of returning money to the federal government. In the Big Ten alone, a couple of substantial past audit settlements have resulted in paybacks of $5,500,000 and $32,000,000.
  • To avoid negative publicity. Many of us view MSU as a reputation-based corporation, therefore, anything that reflects MSU in a negative light is to be avoided, whenever possible. From the PI’s perspective, why risk turning a scientifically successful project into a negative, due to accounting rules, not to mention the many hours spent on finding documentation and defending purchasing decisions that occurred years in the past? Record retention is generally 3 years from the date of final report, so records must be available for long periods of time.
  • Finally, so that granting agencies have the confidence that awards to MSU will be performed according to the rules specified by the granting agency. While the overwhelming majority of sponsored project awards made to our PIs are based on the excellent science proposed, there are some projects that are so grand, that a critical evaluation factor is the ability of the institution to provide an internal-control structure, to ensure adherence to agency policies.

What do I need to know to successfully pass an audit?

  • Spend RC account money only for project activities that are within the scope of work approved by the sponsor. Don't be tempted to use project funds to cover non-project related expenses.
  • Know the rules and limitations the sponsor has placed on your award (Fly America Act, salary limits, travel restrictions, food while not in travel status, etc.). Irrespective of how unusual a particular rule might seem, it’s the right of the sponsor to set the rules. It’s also our right to decide to accept the award. Once accepted, we need to honor the established rules.
  • Know the most important question to ask when considering a non-standard purchase: “What is the benefit to the project?” If you can document the direct benefit to the project, the costs are proportionately charged, and it’s not explicitly listed as unallowable, i.e., entertainment, fines and penalties, lobbying, etc., the transaction should pass audit. When in doubt, ask CGA!
  • What does “documentation” mean? Documentation simply is a method to record why an expense was initiated, and depending on how unusual the type of expense is, how that expense benefits the project. Documentation can take many forms. For example: email, written note from the PI, or written note of a conversation with the PI. This correspondence should be included in the documentation attached in KFS.
  • Who is responsible to ensure the project is performed both scientifically and financially? The Principal Investigator (PI). However, the PI has lots of assistance in the form of departmental, college, and central (payroll, purchasing, accounting, CGA) level administrators.
  • Who is responsible for repaying expenses that have been disallowed as a result of an audit? The primary responsibility rests with the department. However, depending on the size of the disallowance, it might be shared by the college and, in unusual instances, by central administration.
  • Who is responsible for repaying expenses that were reviewed and approved by CGA? CGA relies on prior audit experience to make a judgement about if an expense is likely to be allowable. However, final allowability is determined through the audit process. Since CGA received no benefit from the expense, the disallowance remains the responsibly of the PI’s department.
  • Charge expenses to the correct project as they occur. Auditors automatically consider untimely charging of expenses, or expenses that were initially charged to other accounts, as high risk. Auditors also more closely review expenses incurred close to the end of a project to be sure these were truly needed, received and used during the project period.
  • Other areas where MSU has experienced audit attention include:
    • Proof of attendance at conferences. Some auditors expect sign-in sheets, but we have used group pictures as documentation of participation.
    • Travel items. Does the purpose of the trip (on the travel voucher) include enough information to support the benefit to the project? Was the rental car necessary? Is the hotel cost reasonable considering the location? Did you include documentation to support the allocation of expenses to the project if the trip includes additional costs related to non-grant or personal segments? If international travel, do you have the appropriate authorizations?
    • Monitoring of our subrecipients, and P-card documentation.

While the above might seem like a long list, it’s important that when given the opportunity to perform sponsored research, we respect the wishes and limitations of those providing the funding.

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