McGill Alert / Alerte de McGill

Updated: Fri, 07/12/2024 - 12:16

McGill Alert. The downtown campus will remain partially closed through the evening of Monday, July 15. See the Campus Safety site for details.

Alerte de McGill. Le campus du centre-ville restera partiellement fermé jusqu’au lundi 15 juillet, en soirée. Complément d’information : Direction de la protection et de la prévention

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U.S. Federal Awards Requirements

If you are the recipient of a U.S. federally funded award, you must adhere to specific compliance requirements.

US Federal Grants

US federally funded grants must adhere to specific compliance requirements. These grants include funding received directly from U.S. government agencies (e.g., NIH, NSF, DoE), as well as funding from other US government agencies that are passed through intermediate entities (e.g., NIH funding awarded to a lead institution (Arizona State University) and passed on to a sub-recipient institution (McGill University).

Annual Single Audit

US Federal grants are subject to an annual Single Audit. Any non-federal entity that expends $750,000 or more in federal award funds during the university’s fiscal year is subject to a Single Audit. An independent auditor performs the Single Audit.

The Single Audit provides assurance to the US Federal Government that McGill University has proper internal controls in place and is compliant with program requirements. The audit also determines that grants are being administered in accordance with the terms and conditions set forth in the agreements and the provisions of federal law and/or regulations.

For more detailed information click here: Single Audit

Time and Effort Reporting

Time and effort reporting is a requirement for US Federal grants and is subject to audit. It is mandatory to report Time and Effort, certifying the hours spent by individuals working on specific projects.

Research Financial Management Services (RFMS) will prepare an effort report reflecting the employees time charged to the grant(s). The Principal Investigator must review the report and certify that the effort allocated is accurate and return it to RFMS for audit purposes. The status effort report is prepared at the same time the claim(s) is due.

Cost Transfer

Journals to transfer expenses to US federally funded grants from other grants must identify the original invoice or expense source, and the expense(s) in question must be related to the research in the US federally funded grant.

Entries to simply transfer a deficit balance from one grant to another is not permitted on US Federal grants.

All transfer of expenses to US Federal grants must be accomplished within 90 days of the effective date of the original entry. The transfer must be supported by documentation that fully justifies the transfer of expense(s) in question. An explanation merely stating that a transfer was made "to correct an error" or "to transfer to correct project" is not sufficient.

Transfers of expenses must be processed within the same university fiscal year in which the expense was incurred.

Eligible Expenses

Expenses charged to US Federal grants must be:

  • Allowable under both the provisions of federal guidance AND the terms of a specific award.
  • Allocable: The expense expense must be associated to a project with a high degree of accuracy.
  • Reasonable: The cost reflects what a “prudent person” would pay in a similar circumstance.
  • Charged consistently as direct expense (versus an indirect cost).

An expense is a “direct cost” if that expense can be identified specifically with a particular sponsored project or other activity with a high degree of accuracy. “Indirect costs” (sometimes referred to as facilities and administrative (F&A) costs or overhead), are costs that benefit many activities (e.g., building operations and maintenance, IT expenses, security, administrative personnel such as grant managers, etc.). F&A costs are recovered through the federally negotiated rate. Costs incurred for the same purpose in like circumstances must be treated consistently as either direct expenses or indirect costs.

The Principal Investigator (PI) is responsible for the regular review of expenditures charged to the US Federal grant(s), to ensure that spending follows a plan and does not exceed available funds.

In situations where the PIs and/or departments have questions on specific expenses, they are addressed to the Financial Administrator (FA), RFMS. The FA determines the eligibility of such expenses.

For NIH policies that cover eligibility of expenditures, please review allowable costs here: NIH Allowability of Costs Activities.htm

Items to be mindful of for NIH grants:

  • Undergraduate and graduate students working on the project cannot be paid a stipend. They must be hired and paid as casual research assistants.
  • Foreign travel (excluding travel within North America) must comply with the Fly America Act (conducted on US flag carriers or under Open Skies Agreement). This should be taken into consideration before travel is booked. Foreign travel that does not comply with the Fly America Act would be deemed non-compliant for audit purposes and reimbursement may be requested. Guidance on the Fly America Act can be found here: Fly America Act
  • Equipment any equipment purchased with U.S. federal funds needs to be tracked and itemized and must be easily traceable (room location, date/method of disposal). When purchasing such items, please ensure to use the appropriate account code as this initiates the asset tracking process. Procurement Services contacts the PI to complete the asset tracking process. The PI must inform Procurement Services of any type of disposal of said equipment (sale, donation, relocation to another institution, decommissioning) prior to disposal.
    Equipment per NIH regulations is defined as an item having a shell life of greater than one year with a purchase cost greater than $5000 USD.
  • Inventory physical counts will be conducted by the PI's Department every two years and compared to the equipment listing. Procurement or RFMS will also conduct periodic confirmation of equipment purchases with the researcher.
  • More information on equipment can be found here: Equipment

Procurement Services

McGill University’s Procurement Policy applies to all procurement activities carried out at the university.  For more information, please review McGill Procurement Services Regulations and Policies.

Indirect Costs

Indirect costs of research are institutional costs that benefit and support research. These costs must be included in budget requests to external sponsors of research.

In case of NIH budgets, a rate of 8% is applied on total direct costs (excluding equipment over $5,000), which is in accordance with NIH Grants Policy Statement.

For non-NIH grants funded by the US government, McGill University’s negotiated F&A rates apply see McGill Indirect Costs Policy.

For more information on agency-specific overhead rates, visit McGill Indirect Costs Policy.

Budget & Re-Budgeting

Actual costs are compared to the approved budget to ensure that the Federal awards are expended within the funding limits and in accordance with the applicable cost principles.

Budget and re-budgeting authority is flexible, i.e., variances from one cost category to another are allowed without prior approval from NIH, OSR or RFMS. However, significant deviations in planned budget, especially to equipment or travel, could imply a change in scope of work. If re-budgeting is due to a significant change in the initial scope of the project, the Program Officer at NIH needs to be notified to discuss such changes.

McGill has system controls in place to prevent certain transactions from causing over-expenditures. Budget availability checking, abbreviated to BAVL, is a system feature used at McGill to ensure that an adequate balance exists on a fund charged at the time a transaction is originated online. An online transaction will be rejected by the system if it will create or contribute to an overspent fund.

Subrecipients

A subrecipient agreement, commonly known as a subaward, is a portion of a grant that is distributed to another institution by the recipient of the original award to conduct a portion of the research project work at the collaborating institution.

McGill University as the lead university in a project, awards a cost reimbursable sub-award to the Subrecipient. When a sub-award is signed by the Office of Sponsored Research (OSR), all terms and conditions of the prime award are applied to the subrecipient organization. McGill reimburses Subrecipients on a quarterly basis for actual costs incurred on the sub-award grants. The RFMS Financial Administrator reviews subrecipient invoices for eligibility of expenses, compares these expenses to the approved budgets and ensures compliance with the terms and conditions of the subaward agreement. All invoices are subject to adjustment within the total estimated cost before being submitted for payment. The backup documentation for questionable expenditures may be requested to support and justify such costs. In the event that such adjustments are necessary, the invoices are returned to the Subrecipients for corrections. Re-submitted invoices are reviewed again for requested adjustments.

All subrecipient invoices are submitted to the PI for final review and approval. Once approved by the PI, they are sent to Accounts Payable for payment.

McGill University also acts as a subrecipient when collaborating on a research project where another US Institution is the lead.

Reporting Requirements

US Federal Sponsors requires recipients to submit a variety of reports which are due at specific times during the life cycle of a grant award. All reports must be accurate, complete, and submitted on time.

The Project Leaders have access to query fund balances and transactions posted to their grants in Minerva (McGill’s Administrative System). They can review a list of expenses charged for each research grant using a Minerva statement that are automatically system generated on a monthly basis.

The InfoEd system is available which tracks all grants awarded to McGill University.

Post award management is a shared responsibility.

Research Financial Management Services (RFMS) is responsible for preparing all required financial reports/claims and the Principal Investigator (PI) is responsible for all technical reports required under the terms of an award in the form required by the sponsor.

The RFMS Financial Administrator (FA)’s main responsibilities are:

  • Performs all tasks related to the monitoring and approval of financial transactions
  • Prepares, reconciles and submits the financial claims/reports within the established agency deadlines
  • Ensures expenditures being processed are compliant with sponsor guidelines and policies and/or policies and procedures of the University
  • Closes the research fund ensuring all revenues have been received and financial reporting requirements have been met

The Principal Investigator (PI)’s main responsibilities are:

  • Complies with sponsors’ terms and regulations and meets all deliverables and timely submission of progress reports
  • Regularly reviews expenditures, budget vs actual variances
  • Certifies effort reporting
  • Reviews and approves invoices for payment

A written policy exists regarding McGill’s Research Administration Roles and Responsibilities.

McGill has several policies/regulations that document when it is appropriate for a Principal Investigator (PI) to delegate their signing authority and/or approval authority.

Period of Performance

NIH and other US Federal funding agencies do not release funds for the full period of performance. Notices of Awards are issued for each year of the grant or agreement.

Sponsored awards such as these are typically considered as cost reimbursable meaning that annual budgets are advanced or released to the PI (as per the agreement) to allow the charging of eligible expenses. These expenses are then submitted to the sponsor (via a claim or invoice) for McGill to collect payment (reimbursed).

After the end of each grant year (period of performance), the remaining unspent balance is subject to approval by the sponsor before being released back to the project for use.

Prior to the federal awards end date, RFMS works closely with the Principal Investigator to ensure that all project related costs have been charged and incurred by the project end date in order to be included in the final invoice submission for reimbursement within the established agency deadlines.

Extensions: US federal funds that are unspent at the award end date must be returned to the sponsor. RFMS will monitor and contact researchers as end dates approach, but it remains the researcher’s responsibility to cease spending, or to request an extension where required. NIH offers a maximum extension of up to one year after the expiration of the grant term provided that this is requested prior to the end date. Contact the Office of Sponsored Research (OSR) to initiate a request for extension.

The Unit to whom the Fund Financial Manager (Researcher) reports is responsible for the resolution of any unresolved over-expenditures.

Closeout Procedures

Grant closeout is the final phase of a project in which activities are finalized, funding stream ends and administrative tasks are completed.

Responsibility for ensuring compliance with sponsored awards’ terms and conditions is shared between the Principal Investigator, Research Financial Management Services (RFMS) and the Office of Sponsored Research (OSR).

RFMS Responsibilities: Prepares and submits the final invoice to the sponsoring agency. The closeout documentation and the time limits for submission are stated in the terms and conditions of the sponsored award. The general terms are as follows:

  • The final invoice must be submitted within 60 to 90 days after the award end date where McGill University is the prime recipient
  • For sub-awards where McGill University is the sub-recipient, the final invoice should be submitted to the prime grantee within 60 days after the award end date
  • McGill University must receive the final invoice from sub-recipients within 30 days of the award end date to allow for proper review and timely submission of the invoice to the sponsor
  • Follows up with the PI to ensure that all project costs have been charged and incurred by the project end date, and included in the final invoice
  • Closes the fund once the final payment is received from the sponsor

OSR Responsibilities:

  • Ensures PIs submit their final project report
  • Completes and submits final invention statement (even if negative report, submission still required)
  • Completes and submits other template formal reports as may be required from granting agency.

Principal Investigator's (departments') Responsibilities:

  • Ensure completion of deliverables, milestones, or tasks have been fulfilled as required by agency
  • Ensure completion of progress and scientific reports have been completed, submitted, and approved as required by agency
  • Confirm that all research related expenses have been charged to the fund
  • Confirm that all work at collaborating institutions is completed
  • All expected goods have been delivered and received
  • All outstanding PO's have been closed appropriately
  • Any research related activity requiring confirmation, completion, or resolution that is needed to close out project

Record Retention

Recipients must retain financial and programmatic records, supporting documents, statistical records, and all other records that are required by the terms of a grant, or may be considered pertinent to a grant, for a period of three years from the date the annual FFR (final financial report) is submitted.

Contact Us

Russell Ramoutar
Manager
Research Financial Management Services
Financial Services
SHERBROOKE 680
russell.ramoutar [at] mcgill.ca

Mirella Bino
Financial Administrator
Research Financial Management Services
Financial Services
SHERBROOKE 680
mirella.bino [at] mcgill.ca

Tina Marzilli
Financial Administrator
Research Financial Management Services
Financial Services
SHERBROOKE 680
tina.marzilli [at] mcgill.ca

 

Publication Date: June 4, 2024

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