About Award Verification
What is award verification?
Award verification is UCSF's procedure to support Principal Investigators (PIs) in meeting the requirements of the Uniform Guidance for federal awards. One of the key goals of award verification is to reduce the time required of PIs for compliance activities. PIs will cease certifying effort using the Effort Reporting System and will use a new online tool for award verification.
How will award verification work at UCSF?
Award verification is part of a set of controls and practices intended to ensure proper stewardship of the University's resources including sponsored awards. UCSF's award verification procedure has two components.
1. Documenting General Ledger (GL) verification using the GL Verification Online Tool
General Ledger (GL) verification is a key control of UCSF and is a requirement per Campus Administrative Policies. Each department is responsible for ensuring that financial transactions recorded in the general ledger (including sponsored award transactions) are in accordance with all relevant policies, regulations, and sponsor or donor terms and conditions. This is accomplished through the combination of following campuswide policies and procedures for financial transactions, and GL verification.
GL verification activities are conducted and documented using the GL Verification Online Tool.
- The GL Verification Tool systematically selects a subset of transaction lines requiring verification, including "high risk" transactions and transactions with significant policy and/or sponsor or donor sensitivity.
- Verifiers review the selected transactions, identify any errors, and initiate corrections. The monthly status of this activity is displayed in the Award Verification Tool.
- The department Verifier or Approver also reviews the Monthly Report for deviations from anticipated results or historical patterns that may indicate transactions requiring further investigation.
- Approvers attest that verification activities are complete, identified errors have been corrected, and, to the best of their knowledge, the selected department transactions are accurately recorded.
Departments must complete the GL verification process within 30 days of the previous month-end close. GL verification should be completed for sponsored awards prior to award verification.
2. Documenting Award Verification using the Award Verification Tool
Award verification activities are conducted and documented using the Award Verification Tool. The Award Principal Investigator must verify at least quarterly that payroll and other expenses for each of their sponsored awards (including privately funded sponsored awards) are allowable, allocable and reasonable.
- The Award Verification Tool lists the sponsored awards that require verification.
- All Award Verification Tool users can examine award and project information provided by drill down, graphs, status displays, and reports.
- Award PIs are responsible for verification of sponsored awards and cannot delegate this responsibility.
- PI verification should generally be performed after both GL verification, and Project PI and/or Program Manager review.
Other features available in the Award Verification Tool are optional and can be adopted depending on department, division, and Control Point requirements; complexity of each PI's portfolio; and communication and meeting schedules. These features include:
- Review of sponsored and non-sponsored projects by Project Principal Investigators and Program Managers.
- Recording of comments by PIs, including Multiple PIs, Program Managers, and RSAs.
See Using the Award Verification Tool for additional details and instructions, and Get Ready for Award Verification for sample process diagrams and steps you can take to prepare for award verification.
Who will use the Award Verification Tool?
Access to the Award Verification Tool is linked to data in the Research Administration System (RAS) and MyReports, and all roles are automatically provisioned. Award PI and Project PI assignments are refreshed with the monthly data load. Role assignments for Program Managers, Multiple PIs, RSAs, and viewers are refreshed nightly.
|Role||View All Data||Enter Comments||Review Projects||Verify Awards||Source|
|Award Principal Investigator||Yes||Yes||Yes||Yes||RAS - Award Owner|
|Project Principal Investigator||Yes||Yes||Yes||No||RAS - Project Owner|
|Multiple Principal Investigator||Yes||Yes||No||No||RAS - Multi-PI|
|Program Manager||Yes||Yes||Yes||No||RAS - Program Manager|
|Research Services Analyst (RSA)||Yes||Yes||No||No||RAS - RSA|
|Viewer||Yes||No||No||No||MyReports - Financial Role|
Refer to Award Verification Tool System Information for more details about roles and access, including how to assign Program Managers and RSAs in RAS and request the MyReports financial role.
When will we begin using the Award Verification Tool?
Pilot: December 1, 2020
Full implementation: April 12, 2021
When are verifications due?
At April Implementation
At implementation in April 2021, the Award Verification Tool will display all active sponsored awards, as well as inactive sponsored awards with expense activity from May 2020 through March 2021. Verifying all these awards is necessary to "catch up" compliance activities from the final UCSF effort reporting certification cycle which covered the period from January 1 to May 2, 2020. All displayed sponsored awards (except those that began in February or March 2021) will have a verification status of "Due This Month" and the deadline for verification is no later than 10 p.m. on May 11 .
Verification Due Dates
Each sponsored award must be verified at least once per quarter (once every three months). The quarter for an award starts in the month following the last verification (or the start date for new awards). A "month" in the Award Verification Tool starts on the date of the current data load and ends the day before the next data load. For example:
|Tool Data Through||Last Verified||Verification Status||Next Verification Due||Considerations|
|July 2021||June or July 2021||Not Yet Due (green)||September or October 2021||Can be verified prior to due date; early verification will reset the beginning of next quarter and next due date|
|July 2021||May 2021||Due This Month (yellow)||before August 2021 data loads||If not verified before August 2021 data loads, will become overdue when August 2021 data becomes available|
|July 2021||April 2021 or earlier||Overdue (red)||overdue||Verify as soon as possible|
Verification Timing Flexibility
As long as each sponsored award is verified at least quarterly, Award Principal Investigators and departments will have some flexibility to choose when to verify their sponsored awards. They can choose to verify all sponsored awards in the same month, or spread out verification of awards over several months.
- PIs with a small number of sponsored awards or less complex portfolios may find it easier to conduct all verifications in the same month.
- PIs with a larger number of sponsored awards or very complex portfolios that include multiple Project PIs, program managers, or matching funds may want to verify a portion of their sponsored awards each month.
- Local practices may dictate a specific verification schedule.
To spread out verifications over several months
The quarterly calendar "clock" for an award verification due date is started by the award start date or last verification. If a PI or department has many award verifications due in the same month and wishes to spread out verifications, the PI will need to verify some sponsored awards early the first time to reset the "start" of the quarterly calendar clock. Example:
|Last Verified||Next Verification Due||Number of Awards Due||Verify DURING||Considerations|
|July||October||30||All 30 awards in October||Next verification for all 30 awards is due in January|
|July||October||30||10 awards in August
10 awards in September
10 awards in October
|Next verification for these 10 awards is due in November
Next verification for these 10 awards is due in December
Next verification for these 10 awards is due in January
To align verifications in one month
Conversely, if a PI or department wants to synchronize all sponsored awards for verification in the same month of the quarter, they may need to verify some sponsored awards before they are "due". Example:
|Last Verified||Next Verification Due||Number of Awards Due||Verify DURING||Considerations|
|July||October||15||as due in October||Next verification for all 15 awards is due in January|
|August||November||5||all 5 awards in October||Next verification for these 5 awards is also due in January; total 20 awards to verify in January|
|New award||December||1||verify in October||Next verification is also due in January; total 21 awards to verify in January|
What will happen if a sponsored award is not verified?
To comply with University and Federal guidelines and policies, award verification of sponsored awards must be completed at least quarterly by the award Principal Investigator (PI). Each department is responsible for establishing a business process to verify awards in a timely manner. If verification is past due, department administrators must follow up with their PIs to ensure that delinquent award verifications are completed as quickly as possible.
UCOP Contract and Grant Manual, Chapter 7-330 Confirmation of Personal Services, requires a timely review and confirmation of personal services. Late verifications may result in increased questions about expenses and could result in a negative audit finding. Failure to complete award verifications at least quarterly will result in an escalation of past due award verifications (see table below). The lack of completed verifications may jeopardize the submission of future proposals, cause a proposal to be withdrawn, and/or result in the transfer of personal services and other unverified expense activity to an unrestricted fund.
Research Services Analysts (RSAs), department financial and administrative staff, and Contracts and Grants Accounting (CGA) staff will work with PIs toward full compliance. CGA will provide the following escalation notifications for those awards that are out of compliance with federal regulations and University policy:
|Award Verification Escalation Table|
|One month late||Notify Award PI and RSA|
|Two months late||Notify Department Financial Administrator (DFA) with copy to Award PI and RSA|
|Three months late||Notify Department Chair with copy to DFA, Award PI and RSA|
|Four months late||
CGA will move the charges associated with all unverified awards that have not been granted an extension by CGA following the CGA Default Discretionary Journal Procedure, and
When is data available in the Award Verification Tool?
Data becomes available in the Award Verification Tool once per month after monthly close. Principal Investigators, Program Managers and RSAs will receive an email when data is available each month. The Award Verification Tool will not be available during the data load beginning at 10 p.m. the night before until 7 a.m. the day data becomes available.
Refer to Award Verification Tool System Information for a table of data availability dates.
Why are we implementing award verification?
Awards from the federal government must be spent in accordance with federal laws, rules, guidance, and statutes.
On December 26, 2013, the White House Office of Management and Budget (OMB) issued final guidance entitled Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). This guidance superseded and streamlined the eight previous OMB Circulars including A-21, Cost Principles for Educational Institutions and A-110, Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations. This guidance, along with the Council on Financial Assistance Reform (COFAR) reformed guidance of 2014, reformed federal government procedures for assistance awards (e.g., grants and cooperative agreements) with the goal to increase accountability and transparency while reducing the administrative burden on award recipients.
These changes provided UCSF with the opportunity to review the internal controls in place for awards and to consider changing or replacing current practices. As a result, UCSF decided to develop and implement a new award verification procedure that leverages current risk control practices (including GL verification) and includes a new custom-built tool (Award Verification Tool) for the UCSF research community to meet the requirements of federal awards. The new Award Verification Tool:
- Replaces separate project compliance tasks with one simplified, automated, auditable, and traceable task that verifies expense at the award level.
- Eliminates the administrative burden of effort reporting, and the costs associated with supporting the Effort Reporting System (ERS).
- Enables and documents award management conversations between Principal Investigators (PIs), Program Managers, and RSAs.
- Significantly reduces time PIs must spend on compliance efforts.
- Meets the compliance and audit requirements of the Uniform Guidance.
Watch the recorded webinar Compensation Compliance under Uniform Guidance to learn about alternatives to effort reporting under Uniform Guidance and how the award verification procedures being implemented at UCSF will leverage new and existing controls to meet the requirements of federal awards.
What are the key changes?
- Eliminates effort reporting and retires the Effort Reporting System (ERS).
- Leverages existing processes and systems to streamline work and avoid duplication including:
- Local department teams and work procedures that support each PI
- Monthly General Ledger Verification process already performed by local department RSAs and financial analysts
- Award and project information from RAS
- Reports and data from MyReports, UCSF's campuswide reporting system
- Award PIs must verify each of their sponsored awards at least quarterly. Effort reporting was required twice per year.
- Responsibility for verification cannot be delegated.
- Uses the new Award Verification Tool:
- Award PIs can view their full portfolio of awards and funds, both sponsored and non-sponsored, in one location
- Includes a graphical representation of spending
- Drill down on awards to see projects, personnel, and other expenses
- View payroll summary data by award or project
- View current status of General Ledger verification and Program Manager/Project PI reviews
- Supports and records award management collaboration between Award PI, Project PIs, Program Managers, and RSAs
- Available via MyAccess.
How can I learn more about award verification?
- Watch this short video for a brief introduction on what to expect when mandatory award verification begins in April 2021.
- Review instructions for Using the Award Verification Tool.
- Read about things you should be considering to develop your local award verification practices in advance of implementation in April 2021.
- Bookmark the Award Verification page for future reference.
- Review a list of frequently asked questions and answers.
- If you are a Principal Investigator, Program Manager or RSA, read the email communications you received about award verification.
- Other employees with finance, research, and administrative roles can look for communications in ReSearch Resource Newsletter, Office of Sponsored Research Announcements, and the Controller's Office Newsletter.