The mission of the Sponsored Programs and Accounts Receivable Office is to help the MCW community achieve its educational and research mission by providing efficient and effective post award management support for sponsored projects. This mission will be accomplished while maintaining responsible stewardship of sponsored projects as directed by the values of our office and the applicable federal, state, and agency regulations and policies. The Office ensures effective communications with appropriate College offices concerning grant reporting and oversight responsibilities, and strives to provide professional and quality customer support and services.
The Medical College of Wisconsin (MCW) receives funds from Federal and non-Federal sources as support for sponsored awards. There are legitimate instances when a Principal Investigator (PI) will need to incur costs associated with a sponsored award prior to official Notice of Award (NOA) receipt. Federal sponsors usually permit charges for up to 90 days before the start date and many industry sponsored clinical trials allow for start-up costs.
A pre-award start date can be in advance of the expected award start date if permitted by the award sponsor. All costs incurred on a pre-award account must be charged in accordance with the sponsoring agency agreement and/or guidelines. Rather than charging these expenses to an account not associated with the award and then having to process cost transfers after the award is officially accepted, the PI can request a pre-award account to be set up by the Office of Sponsored Programs. Contact the Office of Sponsored Programs by phone (414-955-8236) or email: firstname.lastname@example.org
As pre-award accounts and their associated costs can put the College at risk, the requesting PI/Department will be required to identify an alternate (unsponsored) funding source that has adequate funds to cover pre-award costs if problems arise with the funding of the official award prior to Sponsored Program’s approval of a pre-award account. PIs are responsible for ensuring that all costs incurred before the award is officially received are charged correctly to the pre-award account. The pre-award account will continue to be used for charging allowable expenses once the award is made.
The PI must work with their academic department to meet the obligations and responsibilities of managing funds. The PI’s responsibilities include:
Accounting for the spending of sponsored award funds with the assistance of the Department Administrator.
The Medical College of Wisconsin, as a recipient of federal funds, must comply with OMB Circular A-21 “Cost Principles for Educational Institutions”. A-21 incorporates Cost Accounting Standard (CAS) 501, which requires that the College’s methods for estimating costs in pricing a proposal be consistent with the College’s practices for accumulating and reporting costs in the accounting records.
The principal investigator and department are responsible for preparing the proposal budget in a manner that complies with OMB Circular A-21 and CAS 501 requirements, which includes submitting a proposal budget with line items that are consistent with the Expenditure Types available in the College’s accounting system and that represents the best estimate of actual costs to be incurred in performing the sponsored project.
Through the use of Expenditure Types the principal investigator and department administrative staff are responsible for recording expenditures in the College accounting system at a level which provides a meaningful comparison for any significant amount of estimated cost in the proposal budget.
Comply with all funding regulations and terms and conditions of each award
With the assistance of their Department Administrator and the Office of Sponsored Programs, the PI is required to stay in compliance with regulations on allowable expenditures, carryforward of unobligated balances, close out of funds, timely reporting and other terms and conditions set forth in the award.
Give special attention to monitoring the following:
The policy of the College is to include cost sharing in a proposal only when required by the funding agency or necessary to improve the proposal’s competitive position.
The principal investigator is responsible for insuring that Cost Sharing Commitment Forms from each contributing department are included in the proposal package submitted to the Office of Grants and Contracts. The Cost Sharing Commitment Forms require approval by the Department Chair or authorized designee.
Effort as defined by the federal government and the College is time an individual spends on an activity, expressed as a percentage of the total time an individual devotes to MCW compensated professional activity. Total effort cannot be more or less than 100% and is not based on a 40-hour workweek.
A person’s total percent effort includes effort committed to externally sponsored projects (including effort funded by the sponsor and effort supported by cost sharing), internally sponsored projects, teaching, patient care, community engagement, administrative activities, and/or other contributed effort.
Once the award is funded, a determination must be made as to whether the proposed level of effort commitment is appropriate and the salary distribution is consistent with the committed effort. If the level of effort for key personnel needs to be adjusted by more than 25% based on the percent effort indicated in the original accepted budget and noted in the NOA, the sponsor must be notified of the level of effort change. If the percent of effort devoted to the award is greater than the salary support contributed by the sponsor, a Cost Sharing Commitment Form must be completed. The percent total of all salary allocations for an employee must equal 100%.
The Medical College of Wisconsin, as a recipient of Federal funds, must comply with OMB Circular A-21, “Cost Principles for Educational Institutions.” These regulations incorporate Cost Accounting Standard (CAS) 502, which requires educational institutions to ensure that costs incurred for the same purpose in like circumstances are treated consistently. CAS 502 is intended to prevent the overcharging of costs to Federally sponsored projects.
The College has developed a policy for proper charging of sponsored award funds. Included in the policy is a discussion on Allowable costs, Unallowable costs, Normally direct costs, the Allocation of direct costs among multiple sponsored agreements, Normally indirect costs, and Charging normally indirect costs as direct costs. These rules are also referred to as Cost Accounting Standards.
Every department has a designated liaison with the Office of Sponsored Programs who will distribute information to all principal investigators. This liaison may be the Department Administrator or their designee.
Research investigators are also welcome to attend training sessions offered to administrative staff periodically by the Office of Sponsored Programs.
Funding agencies and College policies require that final project reports for sponsored research be submitted in a timely manner in order to allow close out of accounts. Sponsored accounts do not automatically close when the grant expires, funds are fully expended or the PI leaves the College. The academic department will coordinate the closing of specific fund accounts with the Office of Sponsored Programs once they have received the final project reports from the PI.
Investigators who have access to the MCW intranet site will find complete details by visiting the Sponsored Programs & Accounts Receivable site. On InfoScope, search for keywords “sponsored programs” and select the link for Sponsored Programs & Accounts Receivable.
There is general guidance on College procedures and policies for:
Direct and Indirect Costs
Proposal Budget Preparation
Time and Effort Reporting