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Memo on Professional Services Contract Procedures

Time and Effort Reporting Policy

Subrecipient Monitoring Policy

Publication Page Charge and Reprints Cost Policy

Matching Funds Policy

Time and Effort Reporting Policy

The Office of Management and Budget Circular No. A-21 Cost Principles for Educational Institutions establishes principles for determining costs applicable to grants, contracts, and other agreements with educational institutions. Particularly, Section J (10)(c) requires that work performed directly on sponsored agreements and for other work allocable as F&A costs are identified and documented by the institution. Faculty and staff participating in active externally sponsored projects during the previous semester must complete the Time and Effort Report Form.

The Time and Effort Report serves two purposes:
  1. Certify that time paid to an individual from a grant was actual time spent working on that particular grant.
  2. Certify that time shown as cost sharing was actual time spent working on a particular grant but charged to another Cost Center.

Individuals are selected for the report in two ways:
  1. They are paid directly from a grant.
  2. There is a cost match commitment of time on at least one sponsored project. (Funds from a federal grant cannot be used as cost match to another federal grant.)

PIs, co-PIs, and other key project faculty and professional staff paid by project funds or whose research time is used as a match are required to complete and return this form to the RSSP office at the end of each semester. Each sponsored project worked on during the previous semester, and the percentage of time (% effort) that was committed to each project must be listed and confirmed on this form. This also assists in verification that “salaries and wages charged to sponsored agreements as direct charges, and to residual, F&A cost or other categories are reasonable in relation to work performed.” It is the responsibility of the PI of a grant to obtain all Time and Effort Reporting Forms for the individuals on his or her grant.

Please contact RSSP for the Time and Effort Form.

If in doubt, please contact Research Services to determine the need for a time and effort reporting form.

Revised: 11-12-2007

Subrecipient Monitoring Policy

McNeese State University is responsible for the programmatic and financial monitoring of its sponsored research award subrecipients. OMB Circular A-110 A.2 (gg) defines a subrecipient as “the legal entity to which a subaward is made and which is accountable to the recipient for the use of the funds provided.”

The following is provided to assist responsible faculty and staff in ensuring that subrecipients conduct their portions of research projects in compliance with laws, regulations and terms and conditions of awards and subawards and that project costs incurred by subrecipients are reasonable and allowable.

Roles and Responsibilities:
  1. It is the PI’s responsibility to closely monitor the progress and performance of subrecipients to ensure compliance with federal regulations and both prime and subrecipient award terms and conditions.
  2. It is Administrative Accounting’s responsibility for reviewing invoices from subrecipients and questioning expenditures if necessary and for monitoring and maintaining related financial reports.
  3. The Research Services and Sponsored Programs Office (RSSP) and the Vice President of Academic Affairs and the Vice President of Business Affairs have shared responsibility for ensuring that the University's subrecipient monitoring is compliant with federal and other applicable regulations and are consistent with sound business practices. RSSP will assist faculty in interpreting applicable regulations and subrecipient award terms and conditions and executing these guidelines. RSSP is also responsible for maintaining documentation of monitoring efforts.
  4. The University shall perform the following stewardship activities with regard to subrecipients of its sponsored awards:
    • Advise subrecipients of flow down provisions imposed on them by federal laws, regulations, and the provisions of contracts or grant agreements as well as any supplemental requirements imposed by the University dependent on level of risk as determined by the University.
    • The University shall provide the best information available to describe a federal award to each subrecipient including the Catalog of Federal Domestic Assistance (CFDA) title and number, award name and number, award year, if the award is R&D, and name of federal agency.
    • Monitor the activities of subrecipients to ensure that funding provided to the subrecipient is used for purposes authorized in the subaward agreement in compliance with laws and regulations, and that performance objectives in the agreement are achieved.
    • Ensure that subrecipients expending $500,000 (for fiscal years ending after December 31, 2003) or more in federal awards during the subrecipient’s fiscal year have met audit requirements.
    • If the subrecipient has audit findings, the University will review the findings and review the subrecipients corrective action plan to ensure appropriate and timely steps are taken to correct any problems.
    • Determine whether subrecipient audits necessitate adjustment of the University’s own records.
    • Require each subrecipient to permit the University and auditors to have access to the records and financial statements as necessary.
In addition to the general elements of compliance noted above, there may be additional sponsor- or program-specific requirements that mandate collecting and documenting other assurances (e.g. on lab animals, human subjects, biohazards, etc.) during the course of a project.

Pre-award Subrecipient Risk Assessment:

The following factors will be used to determine the level of risk a particular subrecipient presents with regards to the threat of improper stewardship.
  • Award complexity, extensiveness of the governing regulations;
  • Percentage passed through: (The larger the percentage of program awards passed through, the greater the need for subrecipient monitoring);
  • Subrecipient award size. Large awards (annual budgets >$500K) would receive substantial and frequent review and monitoring; mid-sized awards (annual budget $100K - $500K) would receive proportionately less substantial and less frequent monitoring; smaller awards (<$100K) would receive general review with the least frequent oversight;
  • Prior experience with the subrecipient:
    • A new subrecipient
    • An inexperienced subrecipient
    • Pre-award negotiation indicators
    • Financial/operational reporting accuracy and timeliness
    • Response to requests
    • Having new personnel
    • New or substantially changed systems
  • Whether the potential subrecipient is subject to an A-133 audit or other federal financial review;
  • Level of external oversight by auditors or sponsor agency.
  • Evidence of effective financial controls within the subrecipient's systems and administrative operations through review of the organization's audit reports, management letter, or other acceptable documentation;
  • Subrecipient location (remoteness from McNeese may mandate more oversight);
  • Subrecipient organization type (for profit /not-for-profit/ small business, etc.)

The frequency and scope of monitoring procedures should be determined by the responsible PI, financial accounting, and the RSSP Office. Initial monitoring decisions will be made based on the above review criteria. Risk assessment status can be subject to change pending findings during routine monitoring procedures. If it is determined that a subrecipient mandates closer scrutiny, appropriate measures will be taken to ensure compliance with subagreement performance, financial terms and conditions, and with all applicable federal rules and regulations. Administrators at such subrecipient sites may be asked to complete questionnaires (to be filed at McNeese) documenting their internal controls and grants management procedures.

This policy follows the practices recommended by the "Sponsored Research Administration's Guide to Effective Strategies and Recommended Practices" as well as the "Guidelines & Procedures for Monitoring Subrecipients" policy outlined by Harvard University.


Publication Page Charge and Reprints Cost Policy

The Office of Research Services and Sponsored Programs has been allocated a small amount of money to help MSU faculty pay for page charges required by journals in order to publish their research and/or the cost of reprints once their research has been published.

As long as the Page Charge and Reprints account has money, the Office of Research Services and Sponsored Programs will support these costs according to the following guidelines:

  • This is a first-come-first-served policy. Therefore, it is wise to plan ahead and always contact the Office of Research Services and Sponsored Programs to inquire about the status of the account before you commit yourselves to any costs that you may not be willing to pay out of your own pocket.
  • Requests from faculty members who have accumulated funds through indirect cost distributions will not be honored. The Office of Research Services and Sponsored Programs strongly recommends using indirect cost distribution funds to cover page charges and reprints costs.
  • The faculty member must request funding in writing and provide a copy of the publication supported with these funds.
  • An amount up to $350 may be requested per year to support page charges and/or reprints costs.
  • Every faculty member receiving such funds is obligated to work with the Office of Research Services and Sponsored Programs and submit at least one proposal requesting funding from an external agency within a calendar year from the time he/she received compensation for page charges and/or reprints costs. Future requests will not be honored unless a proposal is submitted.

Effective date: January 2, 2006

Matching Funds Policy

The Office of Research Services and Sponsored Programs has been allocated a small amount of money to provide matching funds for faculty/staff cash-match commitments in external proposals.

Guidelines towards the Distribution of Funds:
  • Eligible proposals must follow the Office of Research Services and Sponsored Programs grant submission procedure and timeline.
  • Funds will be distributed on a first-come-first-served basis.
  • The funding agency must explicitly state the need for matching funds.
  • The maximum award will be the smaller between $ 3,000 or 10% of the requested amount with the Director of Research Services having latitude to commit larger amounts on projects where the resulting funding enhances more than 1 department.
  • All requests must be approved by the Director of Research Services.
Effective: July 1, 2006

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