Expected Im pact PIs, research/ lab techs, grad assistants, and other staff currently certify monthly for salaries charged to any sponsored or cost share accounts Under ATE, only the PI will certify project salaries and expenditures (rather than % effort) on an annual basis (rather than monthly) FY17: ~32,000 certifications Under ATE, expect more than 90% reduction in certifications This is expected to save thousands of hours for faculty and staff Faculty and staff reaction has been uniformly and overwhelmingly positive www.uga.edu
Questions UGA Cohort Contact Shawn Hill shawnh@uga.edu 706.542.9271 www.uga.edu
UCSF Approach to Compensation Compliance Under Uniform Guidance Award Verification Project MC Gaisbauer, Assistant Controller, Controller’s Office mc.gaisbauer@ucsf.edu March 6, 2018
UCSF Background Fiscal Year 2016‐17 Portfolio • Awards Setup: 7,930 • Cash Collected / Revenue Generated: $ 1,337 million • Federal: $ 695 million • State: $ 71 million • Local: $ 181 million • Private: $ 390 million • Compliance Audit Report Card: A • Financial Reports Filed: 1,626 • Effort Reports Generated / % Certified: 10,958 / 97% 37 Award Verification Project March 6, 2018
Agenda • UCSF Background • Journey to Project • Project Overview • High Level Pilot Project Timeline • Project Organization • Project Roles & Responsibilities • Current State and Technology Summary • Q&A 38 Award Verification Project March 6, 2018
Journey to Project An Opportunity to Improve • Under Uniform Guidance, UCSF has the opportunity to: • Eliminate administrative burden of effort reporting and costs associated with supporting the Effort Reporting System (ERS) • Replace separate project compliance tasks with one simplified, automated, and auditable task that verifies expense at the award level • Enable award management conversations between PI and RSA • Significantly improve the process and reduce time spent on compliance efforts by UCSF – PI, RSA, and Central Offices Opportunity statement: no certifications are required, and effort is no longer the focus. 39 Award Verification Project March 6, 2018
Journey to Project • Contracts and Grants Accounting, in collaboration with the Office of Sponsored Research, approached the academic leadership of UCSF Research Advisory Board RAB (June 2015) • Informal assessment of control environment • Joined the cohort (Oct 2016) • With concurrence of RAB leadership, the proposal was brought to the full RAB (Oct 2016) and executive committee was formed • Further concurrence to move forward was sought from UCSF campus financial leadership team (CPFO) (Jan 2017) • Executive Committee researched tools and approaches being used peers • In collaboration with the school financial leaders, pilot participating principal investigators were identified (June 2017) 40 Award Verification Project March 6, 2018
Journey to Project Current State: Effort Reporting and Other PI Responsibilities • Today, UCSF PIs are asked to perform many separate tasks: • Effort reporting • Twice a year based on the calendar • Subcontract invoice approval • As invoices are presented for payment by the subcontractor • General Ledger Verification (GLV) • Each accounting period • Financial Status Report / Final Invoices • Award budget period These tasks are in addition to the program tasks related to the award, such as progress reports 41 Award Verification Project March 6, 2018
Project Overview Vision: Through an on‐line tool that facilitates collaboration with the RSA, replace the multiple verifications and sign‐offs performed by the PI with a single verification of all expenses, payroll and other costs, that is performed on a cycle aligned with the other PI required activities of an award, such as progress reports. 42 Award Verification Project March 6, 2018
Project Overview Implement Award‐Based Verification Goal : Develop and implement a process and technical solution that leverages existing controls to verify all project expenses on an award in an efficient and transparent manner Objectives: • Reduce the administrative burden felt by PI and RSA • Retire the Effort Reporting System and expand verification beyond payroll expense • Meet compliance and audit requirements of Uniform Guidance • Leverage PI knowledge to validate expense on all projects across an award • Increase the effectiveness and rate of compliance with Uniform Guidance • Ensure appropriate integration with GLV process and leverage other UCSF systems 43 Award Verification Project March 6, 2018
March 6, 2018 9 Award Verification Project
High‐Level Pilot Project Timeline* March 6, 2018 45 Award Verification Project
Project Approach • Internal audit review and verification of internal controls over compensation • User‐based requirements gathering for new process and technology • Develop technical solution for an Award Verification system that provides transparency into the process for PI and RSA collaboration • Pilot and phased implementation of new process and technology • Retirement of the Effort Reporting System 46 Award Verification Project March 6, 2018
Payroll Process Controls COHORT INTERNAL ESTIMATE PAYROLL ADJUST PAYROLL CONTROL FRAMEWORK 6. Initial allocation 12. Reallocate estimates or of payroll charges 7. Allocation review 13. Cost Transfers of payroll and approval already reviewed for System Controls accuracy REVIEW PAYROLL 14. Cost Transfer over 90 days of 8. Reconciliations 1. IBS Policy: Pay Codes payroll determined accurate 9. Payroll Reports 2. 100% IBS is identifiable 15. Extra Compensation review 10. After‐the‐fact review 3. Allocation of 100% IBS sources and approval (charged estimates 4. Pay within Project Period determined accurate) 5. Cost Transfers identify earning period UCSF already had all 11. Individual payroll these existing controls, cross project no improvement needed UCSF already had all these existing controls, no coordination (if improvement needed necessary) Institutional Controls COMPLIANCE MONITORING ENFORCEMENT CONTROLS 22. Confirm controls work as 16. Cost Transfer restrictions if ADMINISTRATIVE (NON- intended or perform additional controls failed FINANCIAL CONTROLS) controls for higher risk 17. Spending restrictions for 18. Agency Salary-Cap processes non-compliance restrictions EDUCATION AND TRAINING 19. Committed Cost Sharing UCSF already had all 23. Responsibilities of individuals 20. Minimum devotion of time these existing controls, performing controls are no improvement needed 21. Reduction of 25% PI/PD time understood 47 Award Verification Project March 6, 2018 Cohort For Efficiencies in Research Administration, J. Forsberg, L. Mosley, D. Ngo
Cost Transfer Data Given the control environment, why the cost transfer volume? $100,000,000 1,000 545 547 $90,000,000 900 548 $80,000,000 800 $70,000,000 700 $60,000,000 600 $50,000,000 500 $40,000,000 400 $30,000,000 300 $20,000,000 200 $10,000,000 100 $‐ ‐ 9‐16 10‐1611‐1612‐16 1‐17 2‐17 3‐17 4‐17 5‐17 6‐17 7‐17 8‐17 9‐17 10‐1711‐1712‐17 1‐18 2‐18 3‐18 4‐18 5‐18 6‐18 7‐18 8‐18 48 Award Verification Project
Internal Audit Assessment of Sponsored Award Compensation Expense Controls Objective: Document current compensation process(es) and assess controls are sufficiently designed • Scope • Current (at January 1, 2018) compensation procedures for academic and staff employees • Compensation includes both salary and fringe benefits (2 CFR 200.430/431) • Excludes compensation based on contracts (personal services, etc.) where the contract serves as time and effort documentation • Procedures to be Performed • Document existing processes related to compensation (salary setting, timekeeping & payroll) • Conduct interviews and walk‐throughs of activity being conducted to assess adequacy of process controls • Assess internal controls using the COSO framework • Deliverables • Process flow map(s) • Process controls narrative and controls assessment matrix 49 Award Verification Project March 6, 2018
SAS 115 General Ledger Verification (GLV) • 2015 Internal Audit concluded that only 46% of departments were complying with the campus’s GLV policy • Main barrier to compliance was the manual process • 2016 project to create an online tool to streamline the GLV process was kicked off • It identifies the high risk transactions for verification • It easily shows the completion status of verification • High risk criteria examples • Abnormal account usage • Unallowable accounts • Unusual spending trends • Payroll allocation changes 50 Award Verification Project
Award Verification Design Provides an enhanced interface overlay, leveraging the GLV, to meet the PI’s requirements PI’s do not find the GLV interface intuitive – requested a dashboard view PI’s desire an interface that provided not just transparency into the staff’s reconciliations but the ability to collaborate about the data PI’s desire to see their entire portfolio: federal, non-federal, and non-sponsored 51 Award Verification Project March 6, 2018
Award Verification Process • After the fact review by project using dollars • No longer doing effort certification by individuals using % effort • Includes drill through views of 100% allocations of each person • After the fact review is complete by review quarterly • After monthly GL verifications of project expenses by finance staff • GL Verification process will highlight unallowable and high risk activity for review • GL Verification process will create Cost Transfers • Policy only applies to federal activity but tool includes all PI funds, even non‐sponsored 52 Award Verification Project March 6, 2018
Questions? 53 Award Verification Project March 6, 2018
General Ledger Verification Beta- Testing Snapshots 54 Award Verification Project March 6, 2018
GL Verification Demo GLV Dashboard Provides summary display of totals by Transaction Type of the items selected for GL Verification As transactions are reviewed and verified, the % GL Verification Items Completed provides a graphic indicator of the completion percent for each Transaction Type 55 Award Verification Project March 6, 2018
GL Verification Demo Transaction Report Shows the details within each transaction type of the amounts Not Verified by Source Code Drill through to Verify GLV Items report 56 Award Verification Project March 6, 2018
GL Verification Demo Verify GLV Items Report Allows the user to verify whether each transaction item was accurately recorded 57 Award Verification Project March 6, 2018
GL Verification Demo FTE & Salary Section of the Payroll Report Displays total monthly FTE and total monthly Salary expense for the last 12 months 58 Award Verification Project March 6, 2018
GL Verification Demo Payroll Expense Detail Section of the Payroll Report Displays 3 months of detail monthly pay and distribution data for each employee Employees with pay or distribution changes in the current month are noted in the Chg column, and the highlighted changes 59 Award Verification Project March 6, 2018
Award Verification Preliminary Mock-Up 60 Award Verification Project March 6, 2018
Award Verification Mock‐Up 61 Award Verification Project March 6, 2018
Award Verification Mock‐Up Project Dashboard 62 Award Verification Project March 6, 2018
Award Verification Mock‐Up Spend Drillthrough 63 Award Verification Project March 6, 2018
Break 65
Colorado State University Dave Schmidt David.Schmidt@colostate.edu Project Based Certification and Reporting
What We’ve Done, Where We’re Headed • Switched from paper certification to electronic system and moved to an alternative project based certification methodology • Evaluated options of: – Traditional Effort Certification – Project Confirmation – Hybrid Model (Effort for faculty, Project for staff) • Phase 1: Move from quarterly (based on fiscal year) effort certifications per person to effort confirmation by project for all employees – Reduced number or certifications per quarter by more than 1,000 – from over 2,700 to less than 1,700 – System went live in January 2018 On-time certification completion rate at end of initial period was 99.3%! • – Lessened administrative burden for PIs • PI certifies for all employees on a project at once • Reduced time r equired for PIs to complete certification • Provides more transparency and understanding of project expense activity • Easy-to-use resource to view personnel costs on each project; showing dollar amount and percent effort – Improved internal controls for OSP – Changes to effort trigger necessary cost transfers – Greater use of cost-share accounts and advance start accounts • Phase 2: Move to annual confirmation by budget year, with quarterly review
Project Confirmation Data Overview The ecrt system integrates with Colorado State University’s financial, payroll, HR and research administration systems to maximize compliance with documentation standards for personnel expenses as prescribed by federal regulation.
Implementation Timeline
PI Home Page The PI home page lists the PI’s statements that are ready for certification. In this example, the PI has 7 Project Statements and 2 Associated Project Statements. An Associated Project is part of the PI’s award but is led by a different PI. The Lead PI of that project is required to certify that statement.
Project Statement The project statement lists all individuals for the period of performance who have payroll or cost share effort. The PI is responsible for certifying/confirming the payroll charges on their specific project. The PI can view multiple project statements at a time and has access to notes, attachments and transaction history. To certify/confirm the statement, the PI would check off the Certify boxes , click Confirm and then I Agree on the ensuing attestation page.
Project Statement Hover Over The project statement hover over shows the 100% payroll breakdown for each employee charged to the project for the period. The hover over ensures that the PI is aware of all of their staff’s salary activity. Selecting the scroll icon displays the total funding for the employee.
Thank you
Research Finance Operations ALTERNATIVES TO EFFORT REPORTING TRACEY VOLZ TRACEY.VOLZ@NYUMC.ORG
Understanding the Possibilities 75
Traditional Effort Reporting vs Payroll Verification Method Description Effort Certification Payroll Verification (A-21 Circulars) (Uniform Guidance) Review Basis Individuals Grant/Contract (award) Certification/Review Cycle Fiscal Year – Once a Year Monthly payroll review Approver Individual/PIs/DAs Department and PIs Certification/Review Focus Individual’s percentage of All salaries/wages directly charged to the effort is reasonable based on award are reasonable based on work overall effort performed Type of Funds All sponsored funds All sponsored funds 76
Effort Certification Quick Guide Timeline: Effort Certification Process Oct. 2 nd to Oct. 13 th : DAs review and comment on efforts in the Professional Time Step 1 : Log into the Effort Reporting Tool using your and Effort Tool Kerberos ID and email password Oct 16 th to Nov. 17 th : Effort Certification Period Nov 20 th to Mid-Dec: RFO reviews all effort Step 2 : In the “Certification Section,” enter Actual Effort certifications Percentage in the “Actual Effort %” column and be sure the Mid-Dec: Time and Effort Reporting Tool column totals to 100% finalized and closed Step 3 : Review “Payroll Allocation %” for each account and determine if your actual effort over the reporting period was the same as the payroll percentage RFO Contacts for Questions: Step 4 : For each account, you can use the “Explanation/ Maria Shrestha – Comments” field to provide comments when necessary maria.shrestha@nyumc.org Step 5 : If a chartstring is missing, click “Add Chartfield” to enter 646-754-4678 the chartstring, payroll information and Actual Effort % Step 6 : Complete the certification process – check the “I certify” Tim Fitzsimmons – box and once you have done this, click the “Save Button” to timothy.fitzsimmons@nyumc.org complete the certification process 212-404-4285 Tracey Volz – Please keep in mind: Justine.volz@nyumc.org • NIH Cap: when calculating the effort on a federal grant, use the 646-754-5294 following calculation: Payroll Amount ($) /NIH Cap ($186,331**) = min % Effort Required at Cap Example: $37,400/$186,331 = 20.1% effort Professional Time and Effort Tool Link: • If effort was reported and no salary was charged to the grant, please https://toolsx.med.nyu.edu/ProfTimeAndEffort provide an explanation in the comments section **Note: $186,331 = the adjusted NIH salary cap for FY17 reporting period
Existing Internal Controls • Peoplesoft HCM – MSS Transactions – Payroll allocation % cannot exceed 100% – Shows payroll allocation across all funds • RFO Compliance Review of payroll adjustments that impact sponsored projects • Updated Cost Transfer Policy – Does not allow adjustments that impact a prior fiscal year 90 days after fiscal year ended • Payroll Suspense Account • Cost Sharing – Tracked using the companion account code for mandatory cost shares • Expired fund report to departments • SPA reviews Progress Reports with Department 78
Added Internal Controls • Monthly review of payroll charges by departments • Alternative to Effort Reporting payroll report shows employees on PI’s projects and the entire allocations for the employee • MSS retros – aligns with the cost transfer policy 79
Benchmarking – what other institutions have done 80
SUNY Buffalo • System Name: Payroll Review – Reflects an after‐the‐fact payroll review of payroll expenditures paid on an award to ensure it reflects the work performed – PI of a sponsored award confirms the payroll expenditures • Two reporting periods (based on a calendar year) • PI is required to review payroll charges and check an “Agree” or “Disagree” box to verify payroll charges are correct. Their payroll system also shows indirect and fringe • SUNY Buffalo also has a report that includes a Total Salary amount for the salary charges for all employees and total salary adjustments amount 81
Michigan Tech • Name: Project Payroll Certification Document (PPCD) (not a system) – PI and/or co‐PI of a sponsored project certifies annually for multi‐year projects, and upon completion of each project – Project Payroll Certification is annual based on the start date of the award and will also coincide with when progress reports may be due • Michigan Tech aligns this process with progress reports/financial reports • Michigan Tech provides monthly salary and wages reports to the PIs for review – this does not require certification • This applies to all sponsored projects 82
Pilot Workgroup • 6 Departments : Biochemistry and Pharmacology, Environmental Medicine, Orthopedic Surgery, Pathology, Pediatrics, and Medicine • Expectations: Each department in the pilot is expected to conduct a monthly review of payroll charges for each PI in their department and provide feedback on the process • Monthly payroll verification reports sent to each department to regularly review and verify that the payroll allocation is reflective of the work performed 83
NIH Steps to Enhanced Financial Integrity Cash Progress Unilateral Management Reports Closeout TIMELY VISIBILITY ACCURACY SUBMISSION • • Tracks Spend by • Submission of Estimated Balances Dollar Progress and & Projections Invention • Reported Effort & • Spend Rate by Reporting Spend to Actual Project • Non‐compliance • Justification for • Crosschecks impacts current balances greater Reported vs and future than 25% Actual Spend funding Increased Transparency from NIH
Payroll Verification Report 85
Process for Alternatives to Effort Reporting Monthly payroll verification report sent to departments Department reviews payroll allocation percentage to verify payroll amount PIs review payroll allocation on PIs grants is accurate and reasonable to work performed Pilot workgroup submits payroll adjustments immediately upon discovery of an incorrect payroll charge Monthly reviews aligns with the project’s budget period and applies to all sponsored projects 86
MSS Statistics Number of MSS transactions that are: Over 90 days, Retros Less Than 90 Days, and Proactives 400 351 350 316 308 303 300 250 200 150 90 100 49 45 40 41 50 37 29 16 0 Jul-17 Aug-17 Sep-17 Oct-17 Over 90 Days Retros Less Than 90 Days Proactives 87
Cost Transfer Statistics Number of Cost Transfers that are: Approved, Sent Back for Revisions 140 130 127 120 105 100 95 95 86 78 80 64 60 40 20 0 Jul-17 Aug-17 Sep-17 Oct-17 Approved Sent Back for Revisions 88
Benefits • Regular review of project expenses will decrease frequency of cost transfers and will increase timeliness of MSS changes • Increase accuracy of RPPRs: – Effort percentages align with payroll records – Expenses are already in ledger‐ decreasing incorrect expense projections 89
Ongoing Challenges • Annual Effort Certification vs Monthly Review and Recurring Reconciliation • System Solutions • Payroll Security • Perception of Added Busy Work • Fear of Accountability • Defining Cost Share • Change Management 90
THANK YOU! QUESTIONS? 91
THE NEW SCHOOL 92
David Ngo, Associate Provost The New School Provost’s Office - Research 00.00.2015
Mission: Research Support provides service to facilitate the advancement of The New School social research and sponsored activities, while ensuring the integrity of the institution's research enterprise through proper stewardship of extramural funding. Cohort For Efficiencies in Research Administration, J. Forsberg, L. Mosley, D. Ngo
Cohort For Efficiencies in Research Administration, J. Forsberg, L. Mosley, D. Ngo
Cohort For Efficiencies in Research Administration, J. Forsberg, L. Mosley, D. Ngo
Cohort For Efficiencies in Research Administration, J. Forsberg, L. Mosley, D. Ngo
Cohort For Efficiencies in Research Administration, J. Forsberg, L. Mosley, D. Ngo
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