Research Management Group– (RMG)

Quarterly Post Award Reporting Policy and Procedure

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1. Policy

It is Stanford University's policy to comply with all applicable accounting and cost principles contractually or legally required by parties for which sponsored research is performed.

The School of Medicine's practices, monitored through the Research Management Group (RMG), must ensure that expenditures are consistent with the intent of the awards as well as any contractual requirements and governmental regulations that govern the use of such funds.

The University and the School are responsible to granting agencies for proper management of sponsored projects. The individual department is responsible for implementing a framework of sound fiscal controls within which the institutional responsibilities can be accomplished. The overall responsibility for management of a sponsored project within funding limitations rests with the Principal Investigator (PI). The department's Director of Finance and Administration (DFA) and/or the Division Administrator must assist with the control and monitoring of the project from a financial perspective.

 

 

ProcedureS


2. Procedures

 

    • 2.1    Apply for and Receive Awards in Accordance with Existing Procedures

      • 2.1.1 The PI and the RMG Research Process Manager (RPM) develop the budget and apply for the new, competing or continuation award in accordance with existing Stanford University policies and procedures, and the requirements of the respective funding parties.


  • 2.2   The award is received, and PTA's set-up in accordance with existing Stanford University policies and procedures.



  • 2.3    Monitor Financial Aspects of the Grants and Contracts at the Department/Division Level
  • 2.3.1 The DFA or Division Administrator reconciles the actual expenditures on the expenditure statement to his/her own records on a monthly basis.

  • 2.3.2 The DFA or Division Administrator reviews rates of expenditures with the PI and obtains PI certification of all expenses, including salaries, charged to the project on a quarterly basis.

  • 2.3.3  At least quarterly, the DFA or Division Administrator projects the total expenditures for the grant year based on current rates of expenditure and other known factors and compares the projection to the awarded budget. If a problem is noted, the DFA or Division Administrator works with the PI with assistance from the RPM to adjust the rate of spending or identify other funding sources to support the project, giving consideration to the availability of discretionary accounts to be used as "guarantee" accounts.



  • 2.4    Monitor Financial Aspects of the Grants
    • 2.4.1 The Research Management Group (RMG) serves as the School's facilitating and monitoring unit and as a mediator/problem solver. The Research Process Manager (RPM) works with their assigned departments as needed to coordinate financial plans to ensure the scope of the project is not jeopardized and that the risks to the University are minimized. The RPM may assist in coordinating a financial plan to stabilize the grant.
    • 2.4.2 The PI Quarterly Certification is tracked through the eCertification Tracking System>>. The DFA or designee verifies the certification status for all of the sponsored PTAs within his/her department/division. The deadline for the PI certification is 60 days after each of academic quarter. The deadline to update the eCertification Tracking System is 67 days after each academic quarter. The rate of expenditure is also reviewed through the PI quarterly certification. From the eCertification Tracking System, the DFA or designee is required to explain awards that have problems.
    • 2.4.3 Awards that appear to have accelerated or slow spending patterns require an explanation in the comments section of the eCertification tracking system>>. Issues that require an explanation are when:
      a PTA has an overdraft of >25% of the next year’s budget; or the PTA shows a surplus/uncommitted balance of the lesser of $75,000 or 50% of total costs awarded for the year and is within one quarter of the budget period end.
    • 2.4.4 The DFA may report on any PTA's about which concerns exist regardless of whether they require an explanation under the above criteria.
    • 2.4.5 The DFA indicates for each PTA on the eCertification Tracking system>> the following classifications as appropriate:
      • no issue-the PTA is not anticipated to be in overdraft;
      • issues handled- the PTA has some problems, but they will be addressed at the department level (brief description of problem, its cause, and expected resolution must be noted);
      • issues require help-the PTA has problems and the department needs help (brief description of problem and its cause required; department should have previously reviewed all its resources);
      • spending pattern- current spending pattern indicates a surplus/uncommitted balance exceeding $75,000 or 50% of total costs awarded for the year may exist (brief description of proposed action to be taken required)
    • 2.4.6 The RMG Compliance Analyst reviews the completed entries along with the comments provided on the eCertification Tracking System>>. The RMG Compliance Analyst confers with the RMG Director on “problem PTAs” as defined above. When the rate of expenditure of an award is not adequately addressed in the eCertification Tracking System, the RMG Director and Compliance Analyst send a memo to the Department DFA requesting he/she provide a management plan that outlines how the PTA spending pattern will be brought in line with the award budget.
    • 2.4.7 The RMG Compliance Analyst performs periodic verification of the accuracy of PI certification information reported by the Divisions/Departments.

 

 

  • 2.5 Review of Grants and Contracts by Internal Audit Department

 

  • 2.5.1 Periodically, the Internal Audit Department performs University-wide A-133 audit testing and audits of Departments or specific grant and contracts during which individual transactions will be tested for compliance with applicable governmental accounting and cost regulations and sponsor contractual accounting requirements including a consideration of allowability, allocability and reasonableness.
  • 2.5.2 The Internal Audit Department will also review the PI certification through the eCertification system>>. Departments/Divisions will be reviewed on a rotating/random basis. Auditors will review the Department/Division's files to determine that the awarded budgets have been compared to actual expenditures. Auditors will review the comments from the eCertification Tracking system--particularly items considered when overdrafts were expected. They will determine whether information has been appropriately reviewed and forwarded to RMG and will review the actions taken by RMG.

 



Responsibilities

 

3. Responsibilities

3.1    Principal Investigator

    • 3.1.1 Work with the Research Process Manager to prepare the budgets for award applications
    • 3.1.2 Review the Expenditure Statements quarterly for reasonableness, initiating corrections if required and timely signing to certify the reasonableness of all expenses, including salaries, charged to the project.
    • 3.1.3 Work with the DFA/Division Administrator and/or RPM to develop a financial plan to stabilize the grant/contract when problems arise.



3.2   DFA/Division Administrator

 

    • 3.2.1 Review the monthly Expenditure Statement for reasonableness and reconcile it to his/her own records.
    • 3.2.2 Obtain the signature from the Principal Investigator prior to the certification deadline.
    • 3.2.3 Update the eCertification Tracking System by the deadline.
    • 3.2.4 Work with the PI and/or RMG to develop a financial plan to stabilize the grant/contract when problems arise.
    • 3.2.5 Advise the Department Chair on the status of the Department's grants and contracts and solicit Chair's support for resolution of problems.
    • 3.2.6 Bring discrepancies in system-generated data to the attention of RMG.


 

3.3    The Research Management Group (RMG)

    • 3.3.1 The RMG Compliance Analyst reviews the rate of expenditure on each PTA and the comments entered by the Department DFA in the eCertification Tracking System>>.
    • 3.3.2 Work with the PI, Division Administrator and DFA to develop a financial plan to stabilize the grant/contract when problems arise.
    • 3.3.3 The RMG Compliance Analyst will perform an annual random audit of PI certification.


 

3.4 Internal Audit

    • 3.4.1 Perform or supervise University-wide A-133 audit testing, and audits of Departments or specific grants or contracts, considering allowability, allocability and reasonableness.
    • 3.4.2 Randomly review Department/Division's files to determine that the awarded budgets have been compared to actual expenditures. Auditors will review the documentation supporting the Quarterly Reports, particularly items considered when overdrafts were expected. They will determine whether information has been appropriately reviewed and forwarded to RMG.
    • 3.4.3 Review the actions taken by RMG.








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