This article was derived from a live presentation given by Stephanie Lezotte, Director of Sponsored Programs at Rowan University, and Matty Gilreath, Evisions Professional Services Consultant, at the annual Evisions Research Conference on July 18th in Portland, OR.
We’d like to detail some best practices for audit-proofing your electronic Research Administration (eRA) world, from initial grant proposals to awards and financial closeouts. We’ll show some examples of how to use Cayuse SP (sponsored projects lifecycle management software, part of the Evisions Research Suite) to stay in compliance, especially during times of regulatory uncertainty and change.
Rowan University Overview:
Rowan University is a leading comprehensive public research university which has grown a great deal in recent years. Founded in 1923 as the Glassboro Normal School, transformed by a $100 million gift from Henry Rowan in 1992, the institution officially became Rowan University in 1997. Rowan opened the Cooper Medical School in 2012, and then unexpectedly acquired a second medical school, the School of Osteopathic Medicine (SOM), in 2013 when the New Jersey legislature dismantled the state-run health sciences institution. Today, Rowan University has over 13,000 undergraduates, 3,000 graduate & professional students, and 13 colleges and schools spread across 5 campuses in Southern New Jersey.
When Rowan acquired it, the SOM campus was just wrapping up a 5-year Corporate Integrity Agreement with the Federal government as a result of fraudulent billing, and was subject to higher compliance monitoring. This acquisition happened only one year after Rowan finished building its own MD-granting medical school! Rowan reorganized the campuses, which now report to a central Division of Research. Rowan was awarded a Robert Wood Johnson Foundation grant in 2014 to strengthen healthcare education in Southern New Jersey; a small portion was budgeted for the Evisions Research Suite: Cayuse 424 (Federal grant submission software) & Cayuse SP, along with the Cayuse Connect Modules: Data Connect, HR Connect & Finance Connect for Banner. Rowan went live with Cayuse 424 and SP in Spring of 2015.
Internal COSO audit:
Committee of Sponsored Organizations of the Treadway Commission (COSO) is a joint initiative of five private sector organizations that provides guidance on risk management, internal controls, and fraud deterrent. COSO best practices are recommended by the Federal government, but are not required. In the Fall of 2015, Rowan tested two units, the Office of Sponsored Programs (OSP) and Financial Aid, to prepare for future audits. Internal auditors used COSO best practices to check for OSP internal controls. The focus was on OSP’s ability to document adherence to internal controls, not just to have internal controls in place.
Key internal controls audited included:
- Internal Approvals
- Budget development
- Subaward Coordination
- Application assembly
- Journal entries
- Budget setup
- Cost transfers
- Award setup
- Financial reporting
- Award modifications
- Grant reconciliations
- Indirect distribution
- Database maintenance
- Responsible Conduct of Research
- Conflict of Interest
- Export Controls
- Effort Reporting
- Invention Disclosures
- Royalty Payments
Stephanie and her team created 25 process narratives, each documenting how Rowan’s OSP processes the items above. Although they had only gone live with Cayuse 424 and SP earlier that year, the eRA system was already becoming key to their business processes.
COSO audit findings:
Here’s what the Rowan audit testing found:
- Proposal Review: No evidence that a Proposal Specialist performed a proposal review before the OSP Director approved a Cayuse SP proposal record
- Budget Development: No evidence that a Proposal Specialist reviewed the budget
- Subaward Risk Assessment: Inadequate documentation
- Internal Approvals: How can we be sure the internal approval chain in Cayuse SP is correct and untampered?
- Account Review – No evidence of OSP Director checking account information set up in financial system
Rowan OSP Best Practices in Cayuse SP:
What Rowan’s OSP learned from the COSO audit changed their business processes for the better.
Pre-Award Budget Development:
Budget development: Rowan OSP used to delete all attached budgets except the “most final.” Now, they leave the draft versions in SP to show changes. They’re able to mark a document as “Final” in SP.
Pre-Award Proposal Review:
- Now a Proposal Specialist (PS) writes a non-deletable note in the Cayuse SP proposal record (see pic 1 below) to document their review of the entry/budget. (Example: “PS review complete, ready for OSP Director review/approval.) SP records the PS name and date stamps the note automatically.
- PS now completes and uploads to the Cayuse SP proposal record an internal Proposal Checklist before OSP Director review/approval, ensuring that each proposal undergoes standard, documented review. The OSP Director then reviews the Checklist in SP before approval.
Pre-Award Subaward Risk Assessment:
- Rowan created a proposal attachment type in SP, “Subaward Compliance” (see highlighted area in pic 2 below), to group and organize important compliance-related documents, including:
- Risk assessment checklist (internal)
- Screenshot of SAM.gov clearance
- A-133 audits and management plans
- F&A Rate agreement
- Subrecipient questionnaire
- Annual FFATA letters and reports
Pre-Award Internal Approvals:
- The auditors had asked OSP how they could be sure the electronic approvals in Cayuse SP were correct and untampered? Answer: the Cayuse SP electronic routing “chain”, a key feature, cannot be altered once the proposal entry has been submitted for internal departmental approvals. The record would first need to be rejected, and the institutional organizational hierarchy changed before re-routing; such changes would be documented. Simply put: there is almost no way to be sneaky with internal approvals in Cayuse SP.
Post-Award Account Review:
- Award Checklist: The PS completes an internal Award Checklist and uploads it into the newly-created SP award record (with updated award amount, as necessary).
- Documentation Review: The PS ensures the final, approved documents are uploaded and clearly marked in Cayuse SP for post-award staff.
- Handoff: Post-Award staff go into Cayuse for needed information. They match the budget in Cayuse SP to the Notice of Award before creating a fund.
- Evisions Finance Connect for Banner (now in implementation at Rowan) will soon be used to automatically feed basic SP award account setup data into the Rowan Banner financial system. This will create a secondary check point in OSP’s account review process. Finance Connect also reduces the chance of human data entry errors in Banner.
Based on the above changes, Rowan’s internal audit staff said the Division of Research was one of the most prepared, helpful, and productive units they have worked with. Rowan’s federal auditors also applauded Rowan’s effort to strengthen internal controls.
As Professional Service Consultants, we have some best practice ideas to add:
Organize documents in the Cayuse SP “cloud”:
- Upload everything: One of the key benefits of Cayuse SP is that it helps you organize your sponsored projects world, in an unlimited, protected, backed-up online cloud. So it should be used to upload and store all relevant project documents, for ease of reference/retrieval. (Before Rowan got SP, they had separate Access and Excel databases acting as primary records, which made auditing difficult.)
- Naming document types: Some of our clients (like Rowan) use the Cayuse SP attachment type “Subaward Compliance”, to tag a variety of possible docs. Other clients choose to be very specific, naming certain document types individually, like “Subrecipient A-133 compliance letters”. Either approach will work, and will benefit your online document organizing efforts.
- Where to put documents? In Cayuse SP, you can easily view all uploaded attachments from the highest Project level, and/or drill down into the related Proposal, Award, and Subcontract areas. Decide as a group where your staff should upload documents, and then make it part of your standard process.
- Why does this matter? Proper naming and placement of documents in Cayuse SP helps your end users find specific documents. No one wants to waste time opening up mystery documents uploaded as type “Other”, especially during a time-sensitive audit!
If you’re already a Cayuse SP client, it’s never too late to update your SP environment to keep in step with changing processes, regulations, and policies! Simply contact our Evisions Support team to request changes to the configurable areas of your Cayuse SP. If you are not yet a Cayuse SP client, please feel free to request a demo here. What other ways are you staying organized online (in your Cayuse SP or other eRA system), to prepare for audits? Tell us in the Comments section below.
About the author:
Stephanie Lezotte is the Director of Sponsored Programs at Rowan University in New Jersey. In 2003 she landed accidentally in the grant world and since has worked in both departmental and central settings, at both universities and nonprofits. She is a Certified Research Administrator, is active in the Delaware Valley Chapter of the Society of Research Administrators, International, and has previously presented at the National Council of University Research Administrators annual meeting and the Council for Advancement and Support of Education annual conference for Corporate and Foundation Relations Officers. She holds a bachelor’s from Lebanon Valley College and master’s from Rutgers University.
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