Exchanging Talents Through Guidance

Transcription

1 National Council of University Research Administrators Keys to Success! Cost Transfers The Good, The Bad, and All Preventable Exchanging Talents Through Guidance NCURA Region IV Spring Meeting May NCURA 1 4, 2016 Region IV Indianapolis, Indiana April 27 30, 2014

2 NCURA NCURA Region IV Region Spring IV Spring Meeting Meeting April 27 30, 2014 Elena Semyonova Smith, CRA Manager, Post Award Services University of Kansas, Office of Research Anita Abel Associate Director, Post Award Services University of Kansas, Office of Research

3 NCURA Region IV Spring Meeting A Cost Transfer is an after the fact reallocation of costs

4 NCURA Region IV Spring Meeting A Cost transfer can be: Non Payroll Payroll

5 NCURA Region IV Spring Meeting Why we are concerned about Cost Transfers? Cost (in Cost Transfer) = expense you certified Cost Transfer = a journal to the general ledger (GL)

6 NCURA Region IV Spring Meeting Why we are concerned about Cost Transfers? Think: Audit! GL is the first place where auditors look Think: Uniform Guidance. Frequent cost transfers = poor accounting systems and internal controls

7 Uniform Guidance Circular 2 CFR 220 (former A 21): "Any costs allocable to a particular sponsored agreement [ ] may not be shifted to other sponsored agreements in order to meet deficiencies caused by overruns or other fund considerations, to avoid restrictions imposed by law or by terms of the sponsored agreement, or for other reasons of convenience."

8 NCURA Region IV Spring Meeting The Question of the day: Do All Cost Transfers Bring Bad Karma?

9 [Potentially] OK: Well documented transfers of project costs that were charged elsewhere Infrequent data entry errors Transfers between projects supporting closely related bodies of work with the same PI

10 Really Bad Idea: Not Allowable? Not a Problem! Let s Park it Here for Now Overrun Here + Balance There It s Convenient [for Now]

11 NCURA Region IV Spring Meeting Prevent It? Fix It?

12 Preventing Cost Transfers NCURA Region IV Spring Meeting

13 NCURA Region IV Spring Meeting Educate: Training is the Key! Ideal world I ll train everyone Reality I ll train everyone I can

14 NCURA Region IV Spring Meeting Educate: Look for trends: Recurring Problems Frequent errors = need for improvements in the department's grant management system Transfers near the project end date Missing or inadequate documentation

15 NCURA Region IV Spring Meeting Be proactive: Do not park expenses on an expired project or other sponsored projects Policies & Procedure are the key Monitor your projects Request a provisional account

16 Provisional Accounts What do YOU call a provisional? [Few] Reasons to request a Provisional: Changes in funding Time Change of PI Adding equipment category Use the provisional accounts that you requested!!!

17 Communicate: Principal Investigator + Department Res. Admin + Central Research Admin = Success

18 It takes a village PI and departmental staff Written cost transfer request & supporting documentation. Departmental Leadership Approve Provisionals wisely and timely. Create a culture of collaboration, accountability and compliance.

19 Yes, an entire village Central research admin realistic proposals. Oversight of cost transfer procedures & processes. Leadership Policies. Culture of compliance & collaboration. Investment in era systems.

20 Invest in Systems Cost Transfer = Expense Helps everyone track expenses better Provides electronic workflow to move things through faster

21 Reality Check Cost Transfers happen If you cannot prevent them do them right. Allowability Necessity Forms Timing

22 Cost Transfer = Expense Transferred Costs must be allowable under 2 CFR 220 (A 21) on a destination project. Allocable Reasonable Consistent

23 NCURA Region IV Spring Meeting Is really necessary? [cost transfer] Yes?!!! OK.. If you must. Use a Standard Cost Transfer form

24 Cost Transfer Forms: Why Require the Form? Compliance with 2 CFR 220 (A21) Documents timeliness of correction All responsible parties signed the form No surprises in a future audit Documentation of reasons for transfer Management plans for corrective action

25 NCURA Region IV Spring Meeting Cost Transfer Forms: What s the right form? What? Why? How? What lesson(s) did we learn?

26 Timing is everything UG 90 days Audit Final Reports

27 NCURA Region IV Spring Meeting Prevent It Fix It?

28 NCURA Region IV Spring Meeting Better to prevent than to correct (or explain in an audit) Training & Collaboration are paramount Good systems = good audits Policies and culture are golden

29 NCURA Region IV Spring Meeting Questions

30 NCURA Region IV Spring Meeting Cost Transfers The Good, The Bad, and All Preventable Presenters Contact Information: Anita Abel Elena Semyonova Smith elenas Images from Getty image collection, literary exploration.com