VICE CHANCELLOR FOR RESEARCH, ECONOMIC DEVELOPMENT, AND ENGAGEMENT
Title
KEY PERFORMANCE INDICATORS – UNC BPCP
Classification
STANDARD OPERATING PROCEDURE
PRR Subject
POST AWARD SPONSORED PROJECTS ADMINISTRATION
Contact Info
Office of Grants & Contracts
, 252-328-9530
Office of Grants and Contracts
History: First Issued 07/2009. Latest update 12/2016.
1. PURPOSE
As part of the UNC Business Process Compliance Program (BPCP) (formerly known as Finance and Information Transformation, FIT) each UNC campus is to establish best practices for management of sponsored projects and other business functions. Key Performance Indicators (KPI) are established to help ensure that campus actions and activities meet best practice standards.
The following outlines ECU KPIs to ensure best practices related to financial and administrative oversight for sponsored projects. These standards are provided as general University requirements for processing accounting and reporting actions for sponsored projects. These standards apply to all awards (grants, contracts, cooperative agreements, and other appropriation mechanisms) that are processed through the Office of Sponsored Programs (OSP) and the Office of Grants & Contracts (OGC). For the purposes of this policy, the term “grant” may be used to denote any sponsored project regardless of award or appropriation type.
Specific awards/sponsors may have more restrictive requirements and timeline guidelines. Specific transactions may have more restrictive State/University requirements and timelines for processing. Where sponsor and University requirements are different, the most restrictive policy will be applied.
Any expenditure charged to a sponsored project must be in compliance with this procedure and, as appropriate, other sponsor and University business practices and audit requirements. All expenditures charged to a sponsored project must be incurred within the award period and prior to the budget end date of the award. All costs must be reasonable, allocable, allowable under sponsor and University guidelines, and necessary for completion of the project.
The Principal Investigator (PI) and the Departmental Administrator (DA) share duties/responsibilities to assure compliance with all grant terms/conditions and the University KPIs. Individual distribution of specific duties/tasks will vary by department.
PI/Departmental compliance with these standards is subject to review by UNC-GA under the UNC BPCP initiative and by internal and external auditors.
2. PAYROLL/SALARY PRACTICES AND DEADLINES
2.1. PCF/EPAF processing - For hiring or transferring employees, allocating salaries to Banner funds,
and adjusting payroll rates.
BEST PRACTICE – Before work/activity start date. (Mandatory for new hires.)
STANDARD – Within 30 days of start date (for active employees; not new hires)
MAXIMUM – Within 90 days of start date and/or before Effort Reporting System (ERS) closing due date, whichever is first, (for active employees; not new hires).
ACTION – PCF/EPAF may be denied if > 90 days of start date or less than 2 weeks before Effort Reporting System (ERS) closing due date. The charge to a grant fund will not be allowed.
2.2. Salary Distributions and Redistributions (corrections) - For ensuring the accuracy,
appropriateness, allowability, and completeness of correcting entries.
On an on-going basis, review each fund for correct amounts, correct individuals (named individual is working on the specific project), level of effort, and any missing individuals. A monthly post-review verification process should be documented. All necessary salary redistributions should be processed on a timely basis. Review of payroll and submission of corrections:
BEST PRACTICE – Within 30 days of pay period.
STANDARD – Within 60 days of pay period.
MAXIMUM – Correction must be processed within 90 days and must be processed prior to ERS certification requirements; whichever is first.
Some corrections may need to be processed sooner based on sponsor final FFR/invoice deadlines.
ACTION – Transfers > 90 days or outside of the ERS deadline or final FFR/invoice deadline may be denied. The charge to a grant fund will not be allowed. New debit transfers to a grant fund will not be allowed after submission of the final FFR/invoice.
Late transfer is a reportable condition under UNC BPCP guidelines and is subject to review by UNC-GA and internal and external auditors. All cost transfers have a high audit profile with both state and federal auditors.
3. EFFORT REPORTING SYSTEM (ERS) – For audit certification of effort on grant funds.
Applies to both paid and cost shared effort. Salary cannot be reported to the sponsor as either a direct expenditure or cost-share if not included within ERS.
STANDARD/MAXIMUM – Certification completed by published deadline (normally within 45 days of report distribution to department).
ACTION – Costs on a grant fund will be disallowed if the certification is not processed on a timely basis. Costs will be transferred to a non-sponsored fund and cannot be moved to a sponsored project.
Late certification is a reportable condition under UNC BPCP guidelines and is subject to review by UNC-GA and internal and external auditors.
3.1. Departmental effort review practices/steps – For completing payroll transactions and ERS
certifications.
STANDARD – Department maintains master of effort commitments and monitors all effort reporting requirements for compliance and timeliness.
ACTION – Costs may be disallowed if appropriate standards for salary review and effort certification are not documented and processed on a timely basis.
3.1. A. Upon receipt of award:
· Paid commitments noted, master maintained.
· EPAFs reviewed for action needed for paid commitments. PCFs/EPAFs processed, as needed.
· Cost share and other effort commitments noted on master for ERS periods.
· PI notified to contact Departmental Administrator for changes, additions, or deletions throughout the life of the award (30 days best practice).
3.1. B. Life of the award:
· All necessary corrections made on a timely basis.
· Monitor: Faculty cost share effort commitments - maximum 20% cumulative, all awards. At 25% or more, normally a buy-out (salary charged to grant), not cost share, should be processed. Cost share 25% or more must be preapproved by VC.
· Monitor: PI must show some level of effort, paid or cost share, for all awards (minimum 1-5%).
· Monitor: PI/Co-PI may not be paid 100% from sponsored projects (minimum 5% must be from non-sponsored funds).
· For federal awards: For PIs and Key Personnel - minimum 75% of committed effort requirement monitored. Contact OGC for additional action if 75% committed effort cannot or will not be met. Adjustments in level of effort will require sponsor approval. Individual awards may have more specific effort commitment restrictions.
· For federal awards: No clerical/secretarial/administrative salaries without sponsor approval or Uniform Guidance (UG) exception approval on file with OGC. (Also known as “A-21” exception.)
3.2. ERS Pre-Review
· Review queue: Notify ERS if any individuals should not be in the queue. Standard within first 2 weeks. OGC must adjust system.
· Review queue: Notify ERS if any individuals are missing from queue or that need to have certification created for cost share, etc. Standard within 2 weeks. OGC must adjust system.
· Review queue: For cross-departmental individuals and coordinate with other department prior to certification. Notify ERS if changes in departmental assignment for certification are necessary. OGC must adjust system.
· Verify review/certification system and processing set up.
o Pre-Reviewer and Certifier may not be the same individual.
o Faculty and Post Docs must certify their own effort.
o All employees normally must certify their own effort. Contact OGC for allowable exceptions under specific circumstances. The PI or immediate supervisor may certify for students/staff on an exception basis.
· Review ERS distributions with PIs and certifying individuals for accuracy and completeness (includes cost share). Make necessary adjustments prior to completing certification.
· PIs should review/verify all individuals paid on their awards. In most cases, this will be an off-line review/approval so that the paid individual can certify their own effort report.
3.3. Effort may not be changed after the effort certification has been processed.
· Salary may be removed from a grant fund after the certification period. The effort will remain the same as reported but will become cost share rather than a direct expenditure.
· No new or additional salary can be charged to a grant fund after completion of the effort certification. All necessary redistributions should be completed as part of the certification process.
· No new or additional cost share can be reported to a sponsored project after completion of the effort certification. All cost share should be completed as part of the certification process.
4. NON-SALARY EXPENDITURES – For ensuring accuracy and allowability of costs incurred.
BEST PRACTICE – Approval/verification prior to incurring cost or within 30 days of cost incurred.
STANDARD – Approval/verification within 60 days of cost incurred.
MAXIMUM – Approval/verification within 90 days of cost incurred or prior to final FFR/Invoice; whichever is first. 30 days from OGC notification of discovery or prior to final FFR/Invoice; whichever is first.
ACTION – Costs cannot be charged to a grant fund or may be disallowed.
· Federal Awards – Uniform Guidance (UG) Exception Approvals. (Also known as “A-21” exception.) No UG normally unallowable costs without sponsor approval or UG exception approval on file with OGC.
4.1. Travel Reimbursements
BEST PRACTICE – < 30 days from completion of travel.
STANDARD – 30 days from completion of travel.
MAXIMUM – 60 days from completion of travel or prior to final FFR/Invoice; whichever is first.
ACTION – Late reimbursement requests may be denied or disallowed. Late requests will require specific justification and may need additional approvals from Dean/VC.
4.2. Direct Pays or PORT (includes subagreement payments)
BEST PRACTICE – 30 days from cost incurred or invoice received.
STANDARD – < 60 days from cost incurred or invoice received.
MAXIMUM – 90 days or prior to final FFR/Invoice; whichever is first.
ACTION – Cost cannot be charged to a grant fund or may be disallowed.
4.3. Expenditure Distributions/Redistributions (non-salary)
Review accounting ledgers for accuracy, appropriateness, allowability, and completed corrections on at least a monthly basis. Review each fund for correct amounts/allocation, related to project activities, necessary for completion of project. PI approval and verification process should be documented. All necessary corrections should be submitted on a timely basis.
BEST PRACTICE – Review/approval prior to cost incurred. Post-review of accuracy on ledger 30 days.
STANDARD – 60 days from cost incurred.
MAXIMUM – to process corrections - 90 days from expenditure or prior to final FFR/Invoice; whichever is first.
ACTION – Costs cannot be charged to a grant fund or may be disallowed.
Service center or center-like distributions from a pool fund to specific funds should also follow these 30-60-90 day standards. At a minimum, pool distributions should be processed quarterly.
Late transfer/distribution is a reportable condition under UNC BPCP guidelines and is subject to review by UNC-GA and internal and external auditors. All cost transfers have a high audit profile with both state and federal auditors.
5. GENERAL FINANCIAL MANAGEMENT REVIEWS - OVERSIGHT
5.1. Expenditure rates/projected expenditures/budget balances – For monitoring general financial
health and progress of the project. To ensure conformance with prior approval requirements.
Some awards may have line-item rebudgeting restrictions that may require sponsor approval or OGC exception approval. Some sponsors have prior approval requirements for carryover of annual budget balances to the successor period. Some sponsors have prior approval requirements for time extensions.
BEST PRACTICE – Review balances and projections monthly/quarterly, in each budget year.
STANDARD – Review balances and projections at 6 months/50% of annual budget period. (<25% reportable)
MAXIMUM – Review balances and projections at 9 months/75% of annual budget period. (<50% reportable)
STANDARD – Any requests for rebudgeting or time extensions should be submitted to the sponsor at least 30 days prior to the budget end date. Some sponsors may require earlier submission. Some sponsors may not approve retroactive requests for rebudgeting or time extensions.
ACTION - Cost may be disallowed if not within approved budget categories. Also, some sponsors may not approve carryover requests if they were not notified of the potential need prior to the end date.
5.2. Expenditures in last quarter of budget period
BEST PRACTICE – All necessary expenditures booked and all necessary corrections processed prior to budget end date.
STANDARD – No equipment or large supply expenditures in last 90 days. Specific exceptions may apply for equipment-only or specialized projects – contact OGC for clarification/exception. No expenditures for the purpose of reducing budget balance. All costs must be necessary to complete the goals of the project. All goods must be received and used prior to the end date of the award. No stockpiling for future use.
MAXIMUM – No equipment in last 30 days. No large expenditures in last 30 days. All goods must be received and projected to be used prior to the end date of the award. No stockpiling for future use. No expenditures for the purpose of reducing budget balance. All costs must be necessary to complete the goals of the project.
STANDARD – All necessary redistributions must be completed within 30 days of the budget end date or prior to final FFR/Invoice; whichever is first.
ACTION – Late costs and costs not necessary for specific completion of the project cannot be charged to a grant fund or may be disallowed.
6. COST SHARE
All cost share must be documented in the accounting and/or effort reporting system or it cannot be reported to the sponsor to meet the cost share/match requirements. Cost share is subject to the same audit standards as costs charged directly to a sponsored project. State and University policies require that all cost share be minimized.
6.1. Cost share proposed
BEST PRACTICE – Do not propose cost share.
STANDARD – Cost share should be limited to projects where the sponsor has a mandatory cost share/match requirement or where the PI/Chair/Dean have determined there are benefits to the University and it is essential for the project. Cost share committed must be outlined in the approved proposal budget and justification.
MAXIMUM –
· Effort cost share should be limited to 20% cumulative, from all awards. Effort cost share of 25% or more (cumulative, from all awards), must have the prior approval of the appropriate Vice Chancellor.
· All cost share must have the prior approval of the appropriate Vice Chancellor/Dean; usually as part of the proposal review process. Additional Dean’s approval may be required if not originally included in the approved budget.