Key Compliance Issues in Research Award Management - August 2024 Update
Stay informed about recent audit findings and compliance issues in post-award fiscal management, including inadequately supported expenses, participant support misuse, and internal cost transfer policy compliance. Learn how to navigate these challenges effectively to ensure grant funding integrity.
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AUDIT AND COMPLIANCE HOT TOPICS MRAM August 2024 Matt Gardner Post Award Fiscal Compliance
Recent NSF Audits at Other Universities
Gift Cards > recipient charged $4,000 to the award for the purchase of 40 $100 gift cards. Although recipient provided documentation to support that 37 of the 40 gift cards were distributed to the award research participants, recipient did not provide documentation to support the remaining three, or $300. Unused gift cards cannot be charged to an award and the cost must be covered by non-sponsored funding. If unused cards are used to benefit a subsequent award, the cost of the cards can be transferred to that award. MRAM Matt Gardner PAFC
Participant Support > recipient inappropriately used $7,099 in participant support cost funds budgeted for the award to cover costs incurred to hire a consultant to host an award-related workshop. Because the consultant was not a conference participant and because recipient did not receive or request approval to rebudget participant support cost funding to cover consultant costs, these costs are unallowable. Participant support costs can only be used to support participants of a workshop, conference or training, not staff or other individuals hosting or providing the event. To use Participant Support costs for non-participants requires prior written approval from the sponsor. MRAM Matt Gardner PAFC
Compliance with Internal Cost Transfer Policy > recipient processed a cost transfer to move $3,048 in salary expenses to the award. However, recipient originally posted the expenses in September 2020, and it did not obtain the PI s approval to process the cost transfer, which occurred later than 90 days after the original transaction date. Universities must follow their own internal policies. Failure to follow internal policies can result in an audit finding from our sponsors. MRAM Matt Gardner PAFC
Inadequately Supported Expenses Outside Services > recipient charged the award for $2,823 in website development service expenses but did not provide a service agreement or other documentation to support the scope of services provided If it s not readily apparent from an agreement or contract how a cost benefits the award, additional justifications should be drafted to explain the necessity, scope, and cost of the service. MRAM Matt Gardner PAFC
Disposition of items Disposition of items purchased on purchased on Awards Awards
Scenario > During the course of an award, supplies were purchased that are no longer needed by the Department/PI after the end of the award. What should the Department do with the unwanted supplies? Can the items be given away? MRAM Matt Gardner PAFC
Disposition of Unwanted Items > All items purchased with sponsored funds are owned by either: The Sponsor, or The University of Washington > If the sponsor does not own the item, then the UW owns the item > Any UW-owned items must be disposed of in accordance with University policy and Washington state law This includes laptops! MRAM Matt Gardner PAFC
Disposition at the UW > UW Facilities provides guidance for disposal of unwanted items > By law, all unwanted University property must be surplused > Items cannot be given or thrown away https://facilities.uw.edu/catalog/surplus MRAM Matt Gardner PAFC
Budget Dates in Budget Dates in Workday Workday
Workday, Accounting Adjustments, and Budget Dates The Budget Date in Workday indicates the date the cost was incurred Workday will allow editing of the Budget Date for certain transaction types via an Accounting Adjustment This functionality should only be used to edit/change the Budget Date if that date is incorrect (i.e., does not correctly represent the date the cost was incurred) MRAM Matt Gardner PAFC
Things to remember with Budget Dates The Budget Date should represent the date the cost was incurred Costs incurred outside the start and end date of the award are not allocable to the award Sponsors will audit awards to ensure that the costs benefit the award Costs incurred after the award end date are unallowable and will be disallowed on an audit MRAM Matt Gardner PAFC
Resources > Cost Principles: https://finance.uw.edu/pafc/four-cost-principles > Expenditure Timing: https://finance.uw.edu/pafc/spending/expenditure- timing MRAM Matt Gardner PAFC
Questions > Post Award Fiscal Compliance (PAFC) effortreporting@uw.edu (Effort questions) gcafco@uw.edu (Cost share and all other compliance questions) https://finance.uw.edu/pafc/ > Matt Gardner mgard4@uw.edu 206-543-2610 > David Parks parksd2@uw.edu MRAM Matt Gardner PAFC
