Part 3 - Comprehensive Standards
  

3.10.4  The institution maintains financial control over externally funded or sponsored research and programs. (Control of sponsored research/external funds)

Compliance
Partial Compliance
Non-Compliance

Narrative

The University of New Orleans (UNO) maintains both financial and non-financial compliance control over sponsored research funding from the proposal stage throughout the lifecycle of the award. Non-financial aspects of externally funded sponsored research programs are administered by the Office of Research and Sponsored Programs (ORSP), which reports to the Vice President for Research and Economic Development. Financial aspects of external funds are administered by Sponsored Programs Accounting (SPA), which reports to the Vice President for Business Affairs.

Controls at the Pre-Award Stage

Projects are to be approved by applicable departments as per AP-RE-01.2. To be eligible to submit a proposal, the individuals must meet the Principal Investigator eligibility guidelines listed in IMD 85.003. All proposals must be approved by the Principal Investigator’s Department head and Dean/Director; this is done through an electronic internal routing form. Chairs and Deans certify that the project is appropriate for the mission of the university and that the resources are available to accomplish the project.  Proposals submitted for external funding must be reviewed by a Research Administrator within the Office of Research and Sponsored Programs.  The Office of Research reviews the proposal and budget to ensure federal, state, university and sponsor guidelines are followed.  The budget is reviewed to ensure the correct fringe benefit and indirect cost rates are used, as per UNO negotiated rates and policy. Payroll amounts are examined to ensure the amounts are calculated correctly and follow UNO guidelines for summer pay and/or additional compensation. If cost share is included, it is reviewed to ensure it is necessary, meets the sponsor guidelines, and is approved by the appropriate party. 

As part of the routing form, the Conflict of Interest form is completed by the investigator as per UNO’s policy. Any reported financial interests are reviewed by the Vice President for Research and Economic Development to determine if further reviews and/or action needs to be completed prior to proposal submission. On the routing form, the investigator also certifies whether the proposed project involves human subjects, animals, additional compensation, export control issues, or controlled substances.  If applicable, the investigator is directed to appropriate departments for more information on the necessary compliance procedures. Capturing required compliance information at the proposal stage allows the award to be entered into the financial system with the proper protocols and facilitates compliance oversight at the award stage. Several members of ORSP staff serve on compliance committees to support compliance efforts.

Non-Financial Controls at the Post-Award Stage – Office of Research and Sponsored Programs

When an award notice is received from a sponsor, a Research Administrator in ORSP reviews the award document to ensure UNO can comply with the terms and conditions, or negotiates acceptable terms. Once award negotiations have been finalized and a contract is ready to be executed, it is forwarded to the Vice President for Business Affairs for review and signature. Only the Vice President for Business Affairs and the President of UNO are authorized to sign contracts.

Executed contracts are returned to ORSP and award data is entered in the Financial System by the Research Administrator. Award checklists are utilized to ensure processing consistency and that data is entered accurately and completely. There is a secondary review of the entered data because the award must be finalized in the system by the Executive Director (or designee). Once the award information is entered in the financial system, a request is forwarded to SPA for spending authorization via an internal account number. This request is completed via a standardized email template which includes the executed contract and other relevant award information; the principal investigator, co-principal investigators, and business managers are included in this email so they have electronic copies of the final documents.

Monitoring continues through the life cycle of the award and the Research Administrator enters reporting and compliance milestones in the UNO financial system. The financial system has been configured to automatically email the principal investigator, co-principal investigators, business manager, and the Office of Research when the report, expiration, or compliance milestone is coming due. Follow-up by the Office of Research is performed until each milestone is completed.

The ORSP website has information ranging from funding opportunities and proposal development to policies and procedures related to the proper management of externally sponsored projects.

Periodically modifications are made to an existing grant or contract.  Changes can include, but are not limited to, additional funding, no-cost extensions, principal investigator change, and budget adjustments.  Sponsors can send a grant modification to UNO without a request from the principal investigator.  An example of this would be the obligation of funding for the second, third, etc. funding periods.  Modifications can also be initiated by the Principal Investigator. 

All investigator requests are reviewed by an ORSP Research Administrator.  The administrator reviews the request to ensure it follows the modification request procedures in the grant guidelines or the contract.  If approved, the administrator usually will submit the request to the sponsor.  The grant guidelines may dictate an alternate submission procedure such as the submission of a request in the sponsor’s on-line system.  If the modification request is approved, the sponsor will either send an amendment to the contract or a change notice for a grant.  Contract amendments require at a minimum the signature from the Vice President for Business Affairs.  The Research Administrator will review the amendment prior to sending it for signature.

When a grant change notice or an executed contract amendment is received, the Research Administrator will process a modification in the PeopleSoft Grants Module and utilize an award modification checklist. Changes to milestones in PeopleSoft will be made as appropriate. After the modification is entered, the data entry will be reviewed by another Research Administrator to ensure accuracy.  Once it is reviewed, an email will be sent to SPA to notify the office of the change and request the change be made on the award profile in PeopleSoft.  ORSP will follow-up with SPA until the change is made.

Financial Controls at the Post-Award Stage – Sponsored Programs Accounting

SPA works closely with ORSP for the post award administration of sponsored awards. SPA and ORSP jointly oversee compliance with sponsored awards and maintain auditable records above and beyond the normal financial records for state appropriated funds.  SPA is responsible for the financial reporting on sponsored awards which includes, but is not limited to, billing, budget adjustments, drawdown of funds, cost transfers, personnel activity report certifications (PARS), agency specific financial status reports, and the approval of various proposed expenditures to funded awards.

Once SPA receives notification from ORSP that an award is ready for activation, SPA finalizes the award in the PeopleSoft Grants Management module according to the contract budget and generates an account code (speed key) to be used by the principal investigator (PI) for processing expenditures against the restricted project.  SPA sends a Notice of Grant Award (NOGA) to the PI and business manager which includes relevant award information such as beginning and end dates, budget setup, speedkey, contacts, etc.  The principal investigator is required to sign and return a copy of the Notice of Grant Award to SPA verifying the correctness of the budget setup and listed terms or conditions before being allowed to process expenditures against the award. 

SPA follows guidance from the Office of Management and Budget (OMB) circulars A-21 and A-110, university and state policies, sponsoring agencies, and the individual award documentation for determination of expenditure allowability. Externally funded awards are given the same level of scrutiny as state appropriated funds, but are also routed through SPA for an additional level of scrutiny.

SPA adheres to the reporting schedule in the award documentation to ensure timely submission of invoices and financial reports. As per OMB Circular A-21, SPA produces Personnel Activity Reports and has the Principal Investigator or his/her designee certify the percentage of effort performed on federal and federal pass-thru awards on a semester basis. 

Principal investigators and business managers have numerous methods available to assist with monitoring open awards. PeopleSoft has a delivered function called nVision which shows the annual budget for each award, by expense category and allows for drill downs which will provide detailed information for expenses that have posted on that award. ORSP created several easy to run reports that provide overviews in PeopleSoft that can be run for a department, Principal Investigator, or individual grant to aid with financial management. For those who would prefer to run queries and get more dynamic information, canned queries are available for PI’s and business managers. Professional Development in these PeopleSoft financial management techniques is offered by ORSP and there are also training materials available online.

Louisiana Legislative Auditors, under the Single Audit Act, audit all university accounts and have federal programs on a set schedule for review.

Supporting Documents

Document Description
Document IconAward_ChecklistAward Checklist
Document IconConflict_IntConflict of Interest Information Website
Document IconFringe_Ben_RateFringe Benefit Rate and Agreement
Document IconGrant_Con_MileGrant/Contract Milestone Checklist
Document IconGrant_Con_ModGrant/Contract Modification Checklist
Document IconInd_Rate_AgreeIndirect Rate Agreement
Document IconInt_Routing_FormSample Internal Routing Form
Document IconNotice_Grant_AwardNotice of Grant Award
Document IconOMB_Circular_A_110Office of Management and Budget Circular A-110 Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations
Document IconOMB_Circular_A_21Office of Management and Budget Circular A-21 Cost Principles for Educational Institutions
Document IconORSP_Online_TrainingOn-line Training Module
Document IconORSP_Pro_DevUniversity of New Orleans Office of Research and Sponsored Programs Professional Development
Document IconORSP_WebsiteUniversity of New Orleans Office of Research and Sponsored Programs Website
Document IconPAR_CertPersonnel Activity Report Post Certification
Document IconRecip_Fin_Sys_EmailRecipients (Notification roles) for Financial System Milestone Emails
Document IconSPA_Budget_AdjustBudget Adjustment Form
Document IconSPA_Cost_TransferCost Transfer Form
Document IconSpend_Author_TempSpending Authorization Email Template
Document IconUNO_Add_Comp_PolUniversity of New Orleans Policy AP- BA - 44.2 on Added Compensation
Document IconUNO_Dir_PI_EligibilityUniversity of New Orleans Directive on PI Eligibility
Document IconUNO_Grants_PolicyUniversity of New Orleans Administrative Policy on Grants and Contracts Evaluation and Approval Procedures
Document IconUNO_Neg_Indirect_Cost_RateUniversity of New Orleans Indirect Cost Rate Agreement