Compliance Certification Report

3.10.5
The institution maintains financial control over externally funded or sponsored research and programs. (Control of Sponsored Research/External Funds)
√ Compliant
Partially Compliant
Non-Compliant
Narrative:
Systems and processes are in place at The University of Texas Medical Branch at Galveston (UTMB) to maintain financial control over externally funded and sponsored research programs through the Office of the Associate Dean for Research Administration and the Office of the Vice President for Finance.

The Associate Dean for Research Services Administration, Mr. William New, heads the Office of Research Services. This office reports to the dean of medicine (1). Mr. William New is an experienced research administrator and oversees the administrative function from pre-award submission through post-award financial reporting (2).

As an institution affiliated with The University of Texas System, UTMB follows common reporting and budget guidelines established by the UT System Board of Regents and are all subject to the same audit standards. Operating budgets for all the institutions in the UT System are approved annually by the Board of Regents within the budget estimates of income prepared by the chief business officer and the president of an institution and approved by the Executive Vice Chancellor for Health Affairs, the Executive Vice Chancellor for Academic Affairs, the Vice Chancellor for Business Affairs, and the Chancellor (3). UTMB uses the PeopleSoft financial system, including the grants module, to account for externally funded or sponsored programs.

The Associate Dean for Research Administration is responsible for the operations of pre- and post-award administration of extramural funds through the Office of Sponsored Programs (OSP). OSP provides support to UTMB staff and faculty who are seeking or who have obtained external funding for sponsored projects and assists with the acquisition and maintenance of grant and contract funding for UTMB research, education, and training. Research Services maintains a web site with links to Sponsored Programs, Research Facilities, and The Yellow Sheet (4) (a weekly newsletter), in addition to extensive information regarding funding sources, proposal help, accounts, resources, and policy and guidance (5).

Pre-Award Functions The Office of Sponsored Programsí Pre-Award and Development Division directs the day-to-day pre-award administration and is the primary office responsible for ensuring compliance with the policies of UTMB and the sponsor when assisting in proposal development. This responsibility includes the review of the proposed budget, review of the proposal to assure compliance with sponsor and institution guidelines, approval, and submission of proposals and subsequent negotiation of funded awards. The Project Setup Division is responsible for financial setup of accounts upon receipt of grant award and the Contracts Division oversees the negotiation and execution of contracts and clinical trial agreements and insures that contracts are executed following the guidelines of the UT System and the State of Texas.

Post-Award Functions The Office of Post-Award and Finance is responsible for serving as the official UTMB representative in deliberation with funding organizations to meet their financial and administrative requirements; establishing, updating, and closing-out account numbers and budgets for grants and contracts; monitoring sponsored project activities and informing principal investigators of sponsor-specified expenditure restrictions; developing, approving, and obtaining signature on subcontract documents as necessary to perform grant and contract scopes of work; and providing oversight for cash management of all grants and contracts, including the preparation of billings, financial reports, and letters-of-credit, and the deposit of all grant and contract payments. Divisions within the office include Financial Reporting, Accounts Receivable and Billing, and Indirect Costs.

Audits UTMB, as a public institution within the State of Texas, has its audit of federal awards programs conducted by the Texas State Auditorís Office (SAO) as part of the statewide audit in accordance with the Office of Management and Budget's (OMB) circular A-133, "Audits of States, Local Governments, and Nonprofit Organizations." The SAO Report on Federal Awards for the year ended August 31, 2005 reported a material controls weakness and three reportable control weaknesses, that resulted in $0 questioned costs (6). Total federally funded expenditures for the Research and Development Cluster were $129,600,257 for the year ended August 31, 2005 (7).

UTMB has taken appropriate corrective action to address the identified weaknesses (8). Specifically, UTMB has implemented the following actions:
  • A complete reconciliation of all effort reports to salary charges for all faculty earning in excess of the NIH Salary cap was performed for the year ended August 31, 2005 and all salary charges in excess of the cap amount that had been charged to grants in error were transferred to appropriate sources. A final report of the results was submitted to NIH.

  • UTMB implemented a 100% reconciliation of salary charges to effort reported and all charges in excess of certified effort are transferred to an appropriate source. UTMB is in the process of implementing a new time and effort reporting system licensed from a major vendor which will provide improved controls over the effort reporting process.

  • A reconciliation of 388 active federal awards was performed by an external consultant and of 280 expired awards was performed by UTMB. The reconciliations resulted in the recognition of additional revenue that previously had been stopped by the accounting system supporting the fact that sponsors had not been overcharged. The reconciliation of expired awards is an ongoing project.

  • Quarterly reconciliation of the Payment Management System 272 reports to the general ledger ensures that expenditures in excess of the authorized are not reported and cash is not drawn.

  • QA reports have been operationalized to ensure that any transactions that are held by the system are reviewed and appropriate steps are taken in a timely manner to resolve all problems. All processes receive ongoing evaluation to provide assurance that systems are working as expected and sponsors are billed appropriately. Controls have been put in place to ensure that equipment purchased with federal funds and for which title vests with federal government are inventoried and identified separately from UTMB equipment.

  • The procedures were put into place to ensure that procurement transactions in excess of $25,000 do not occur with vendors who have been suspended, debarred, or otherwise excluded from federal procurement activity.

  • A robust subrecipient monitoring program has been put into place.
  • #
    Source
    1
    UTMB Research Services Organization Chart
    Hard copy located in the Office of Institutional Effectiveness
    2
    Curriculum Vitae for William New
    Hard copy located in the Office of Institutional Effectiveness
    3
    Regents' Rules and Regulations, Series 20501, Accounting, Operating Budget, and Legislative Appropriation Requests, Rule and Regulation, Section 3, Approval of Budgets
    http://www.utsystem.edu/bor/rules/20000Series/20501%202004%2012%2010%2001.pdf
    4
    The Yellow Sheet (sample)
    http://research.utmb.edu/research/yellowsheet/ysonline.htm
    5
    UTMB Research Services
    http://research.utmb.edu
    6
    State Auditor Office Report on Federal Awards for Year Ending August 31, 2005, pp. 193-197
    http://www.sao.state.tx.us/reports/main/06-325.pdf
    7
    State Auditor Office Report on Federal Awards for Year Ending August 31, 2005, p. 194
    http://www.sao.state.tx.us/reports/main/06-325.pdf
    8
    State Auditor Office Report on Federal Awards for Year Ending August 31, 2005, pp. 194, 195, 196, 197 http://www.sao.state.tx.us/reports/main/06-325.pdf