Management of Expenditures

Department

RMG

ICO Contracts 
(for Industrial Contracts excluding clinical trials)

OSR Contracts (for all other Contracts excluding clinical trials)

OSR Accounting

Manages PTA(s) associated with the award in accordance with sponsor’s policy, terms and conditions, University policy, and federal regulations.

When questions or issues arise, reviews award document, sponsor and University policies.  Consults Institutional Official in the Research Management Group (RMG), Office of Sponsored Research (OSR), or Industrial Contracts Office (ICO) for clarification.

Prepares detailed expense information for financial reports when needed and submits to OSR for review.

Provides guidance for award management and interprets issues that arise in accordance with grant terms and conditions, University policy, and federal regulations.

Contacts sponsor as the Institutional Official for additional clarification or guidance.

Reviews award terms and conditions and submits any interim and final financial reports required by sponsor.

PI

Department/Division

RMG

After the Research Administrator has completed his/her review,

the PI (Task Owner):

• on a quarterly basis, reviews the account details screen in eCertification for each sponsored project and cost sharing account
• ensures allocability and reasonableness of all expenses, including salaries
• requests clarification or corrections, if required
• certifies in a timely manner

The Research Administrator (RA), Division Manager, or DFA:

• on a monthly basis, reconciles and reviews the Account Details in eCertification
• on a quarterly basis, documents these monthly reviews in eCertification
• prepares financial projections for the entire grant period based on the rate of expenditure and anticipated needs of the project
• works with the PI to adjust the rate of spending or identify other funding sources to support any anticipated shortfall on the sponsored award (see Accelerated/ Delayed Spending)
• advises the Chair on the status of the department’s grants and contracts and solicits Chair support for problem resolution

Research Process Manager (RPM) and/or Research Financial Compliance Manager (RFCM):

• assists PI/Dept in interpreting sponsor and/or University policies
• advises PI/Dept on questions regarding allowability, allocability, and reasonableness

RFCM:

• reviews/approves requests for cost transfer that deviate from the Cost Transfer Policy.
• requests an early task guaranteed for 60 days by the School of Medicine (excluding Bioengineering) when the following conditions have been met:
  • NIH grants without automatic carryover in a non-competing continuation year (e.g. T32, P-series, U-series),
  • the progress report has been submitted to NIH, and
  • human subjects and/or animal protocol approvals are current at the time of request. 
• liaises between Office of Research Financial Policy and Compliance, Internal Audit and departments for all audit-related inquiries.

Topic

PI

Department

RMG

Tracking Effort and Other Support

Works with RA to maintain and update Other Support information to reflect changes in effort levels

Other Support Guidance

RPH Policy on PI effort commitment - 95% "rule"

Faculty Effort on Sponsored Research - FAQS

Managing PI Effort

SoM Policy on Sponsored Program Faculty Salary Support

PI Effort on NIH Clinical Trials

Charges and tracks effort in accordance with commitments made to the sponsor and terms of the award

Confirms effort reported to sponsors and adherence to any sponsor limitations, such as salary caps or minimum effort requirements (e.g., NIH K and DP awards)

Works with PI and RMG to adjust or resolve issues associated with bringing effort into compliance

Works with Department and PI to adjust or resolve issues associated with bringing effort into compliance

Reduction of Effort

For federal sponsors, notifies RA when PI  or key personnel specifically named in the notice of award plan to reduce effort devoted to the project by 25 percent or more from the level that was approved at the time of award. The notification should be made with sufficient time to submit the official request to the sponsor. Federal sponsors require the request to be made 30 days prior to the effort reduction.

For non-federal sponsors, coordinate with RA and RMG/ICO/OSR for changes in effort that require sponsor approval

For federal sponsors, notifies RMG if the PI or key personnel specifically named in the notice of award plan to reduce effort devoted to the project by 25 percent or more from the level that was approved at the time of award

For non-federal sponsors, coordinates with RMG/ICO/OSR for changes in effort that require sponsor approval

Reviews requests to reduce effort level(s), countersigns, and submits requests to sponsor as Institutional Official at least 30 days prior to the effort reduction.

Follows up with the sponsor until issue is resolved

Communicates resolution to PI/Dept. and other SU offices (as needed) via a revised Notice of Award or electronic mail

Working with Salary Caps

Informs RA of any changes in SU/VA /8ths

Utilizes Salary over the Cap worksheet to manage labor schedules for faculty (or staff) with salaries above the sponsor cap

DHHS agencies with Salary Caps

Other Sponsors with Salary Caps (not exhaustive list)

Uses the SU-VA worksheet  to manage effort for faculty with a joint SU-VA appointment.

NOTE: SoM Faculty Compensation adjusts any changes in parity pay for SU-VA faculty.  See FAQs under Other Considerations: VA Employment.

Requests a revised Memorandum of Understanding from Palo Alto Veterans Institute for Research (PAVIR) whenever PI receives new award or has a change in /8ths.

RFCM routinely performs review of faculty salary to ensure compliance with Salary over the Cap charges to 51190, and the 95% effort rule. 

Sabbaticals

As part of the MedLeave process, completes Attachment A and routes to RPM for review/approval at least 30-days in advance of planned sabbatical/leave

Works with RPM to obtain sponsor approval for the following:

1)     leave extending beyond the period allowed by sponsor policy, requiring an interim PI for the sabbatical/leave period

Note: Administrative duties, and any corresponding administrative supplement, are automatically discontinued during sabbatical unless an exception to policy is requested by the department. See Sabbatical/Professional Development Leave.

During PI sabbatical:

• Maintains labor schedule to reflect salary charged to the sabbatical pool and/or sponsored projects as appropriate

Note: When on sabbatical, PI administrative duties and the corresponding supplemental salary terminate

When PI returns from Sabbatical:

• Submits a recurring pay form to SoM Faculty Compensation group to request administrative supplements be charged/distributed to Labor Schedule.

Reviews MedLeave Attachment A, confirms PI will still be engaged on the projects, signs form and returns to PI/Department

Contacts/notifies sponsor of a reduction in effort or change in PI if a new PI needs to be named during the leave period

PI and/or Study Coordinator

Department

CT-RMG

OSR (SRM) 

Requests 98 account (SHC) or mnemonic (LPCH) account after PTA is provided by OSR.

Submits study subject enrollment information to PFS to ensure proper and timely billing of patient care costs.
Tracks enrollment and patient progress through the study protocol.

Reviews weekly reports of patient care expenses, ensuring that research costs are charged to the study (via the 98 account) and routine care costs are charged to insurance.

Based on payment schedule, enters completed tests or procedures in CRISP.  Sponsored Receivables Management (SRM) will used this request to generate the invoice.

Works with department financial analyst to monitor effort charged to the study, patient milestones, and payments received.

Responsible for all standard accounting procedures, including monitoring allocability and PI and staff effort charged to study.

Note:  Allocation of effort is based on enrollment, completion of milestone, or other activity as specified in the contract.

Monitors and reconciles the study expenditures monthly. 

Tracks cost sharing commitments.

Works with Study Coordinator to ensure all completed tests or procedures are invoiced thru Clinical Research Invoicing System for Participants (CRISP).

Reviews study receipts with Study Coordinator to insure that all funds due to Stanford have been received, and that all funds received have been earned. 

Works with OSR Accounts Receivable to ensure the invoice is sent to the sponsor timely.

Obtains PI certification quarterly.

CT Contract Officers: Negotiates any contract amendments. 

Obtains no-cost extensions to contracts as needed and requested by PI.

CT RPMs: Processes any needed corrections to the Clinical and Translational Research Planning (CTRP) Workbook that effect the budget and amends budget as needed. 

Receives and processes amendments as needed.

Sponsored Receivables Management (SRM) Group: Submits invoices to sponsor based on CRISP entries (Invoice Requests) and posts payments to the PTA.

Works with sponsor to collect outstanding receivables.

PI

Department/Division

RMG

After the Research Administrator has completed his/her review, the PI (Task Owner):

• on a quarterly basis, reviews the account details screen in eCertification for each sponsored project and cost sharing account
• ensures allocability and reasonableness of all expenses, including salaries
• requests clarification or corrections, if required
• certifies in a timely manner

• on a monthly basis, reconciles and reviews the Account Details in eCertification
• this review is documented quarterly by the RA in eCertification
• on a monthly basis, runs the BI Accounts Receivable History (Real-time) (formerly the RM3 235) report to verify that budget amounts reflects the cumulative receipts amount. If the amounts reflected do not match, contacts OSR accountant for resolution
• prepares financial projections for the entire project period based on the rate of expenditure and anticipated patient enrollment
• works with the PI to adjust the rate of spending
• advises the Chair on the status of the department's grants and contracts and solitics Chair support for problem resolution

CT RPM and/or RCFM:

• assists PI/Dept in interpreting sponsor and/or University policies
• advises PI/Dept on questions regarding allowability, allocability, and reasonableness

RFCM:

• reviews/approves requests for cost transfer that deviate from the Cost Transfer Policy.
• liaises between Office of Research Financial Policy and Compliance, Internal Audit and departments for all audit-related inquiries
• reviews and approves department request/justifications for transfers on remaining balances greater than 25% as part of the Close-out Process

Works with Department Administrator to maintain reflect changes in effort levels.

RPH Policy on PI effort commitment - 95% "rule"

Faculty Effort on Sponsored Research - FAQS

PI Effort on Industry Sponsored Clinical Trials

Industry Sponsored Clinical Post-Award FAQs

Using internal budget, charges and tracks effort in accordance with patient enrollment, milestone achievement and PI confirmation.

Note: On industry sponsored clinical trials, the effort is dependent on patient enrollment or completion of milestones.

As part of the MedLeave process, completes Attachment A and routes to CT-RPM for review/approval at least 30-days in advance of planned sabbatical/leave.

Works with CT-RPM to obtain sponsor approval for the following:

1) leave will extend beyond the period allowed by sponsor policy and an interim PI is needed for the sabbatical/leave priod

Note: When on sabbatical, the PI is relieved of all administrative duties and therefore the corresponding administrative supplement is discontinued.

When PI is on Sabbatical:

• Maintains labor schedule to reflect salary charged to the sabbatical pool and/or sponsored projects as appropriate.

When PI returns from Sabbatical:

Submits a recurring pay form to SoM faculty compensation group to request that the administrative supplements be charged/distributed to Labor Schedule. RFCM routinely performs review of faculty salary to ensure compliance with Salary over the Cap charges to 51190 and the 95% effort rule

Contacts/notifies sponsor of change in PI or if a new PI needs to be named during the leave period.