· To establish a standard operating procedure to best handle and
respond to requests to unfreeze grants after the adjustment period end date
to ensure that all adjustments are allocable and allowable and are made
prior to the report date of the grant.
· While the sponsor agency policy states the PI is solely responsible,
it is the policy of the School of Medicine that it is the joint responsibility
of the Principal Investigator and the department as well as the School
of Medicine and Research Services to ensure the accuracy of all costs
to be reported to the sponsor. A request to unfreeze represents the final
opportunity to make accounting adjustments and/or corrections for the
fund to be reported. These instances should be rare since the department,
center or institute have, in most cases, a 60 day adjustment period for
making necessary adjustments. Specifically, after the adjustment period,
ORS will proceed under the working assumption that the grant is ready
to be reported to the sponsor.
ORS will submit the FSR no later than 90 days (or other required timeframe)
after termination date of the award.
REASON FOR PROCEDURE
· To provide timely and accurate reporting to sponsors
· To ensure that transactions posted after the project end
date are consistent with university and sponsor policies for allowability,
allocability and reasonableness.
· To allow for a preliminary review by the Office of
Research Support Services (ORSS), and assist ORS in receiving unfreeze
requests that contain all necessary information.
· To reduce the number of requests and/or multiple requests
to unfreeze the same fund made to Penn Research Services (ORS).
WHO SHOULD KNOW THIS PROCEDURE
· School of Medicine Administration
· Departmental Chairs, Center and Institute Directors
· School of Medicine Faculty/Investigators
· Business Administrators
· Office of Research Support Services
· Office of Research Services
· Accounts Payable
· It is imperative to work with your designated research accountant
to be sure that the final report is accurate and on time and that the
department and investigator agree with the number to be reported.
· The department will be held accountable for any unposted adjustments.
Be sure to verify that all corrections have properly posted to the fund
by the designated refreeze date.
· Although ORS prepares the Summary Financial Reports, it is the
departments and School of Medicine's responsibility to ensure the accuracy
of all costs to be reported.
· New POs: The fund freezes for new POs on the date the project
ends, and no new POs can be created on the fund beyond the account end
date. This freeze is irrevocable unless the project end date is extended.
· The fund becomes fully frozen automatically only after the adjustment
period has ended.
· Who should request Unfreeze:
The request to unfreeze should be made by the Responsible ORG only to
ensure the RESP ORG is aware of the changes to be made on their fund.
An exception for this is when the RESP ORG is outside the School of Medicine
and you are trying to remove wayward transactions.
· Who to notify of request to Unfreeze:
Submit requests to unfreeze to your ORSS research
manager. Once approved, ORSS will send the approved request to ORS and
all parties will be copied on the email. ORS will notify all parties when
the grant has been unfrozen and specify when the grant will refreeze.
A response should be expected within two business days. Unfreeze actions
last for 5 calendar days (to accommodate Payroll unfreeze requests, ORS
will always automatically update for a refreeze to occur on the Tuesday
eight days after the payroll run).
· What to include in the email request:
Subject line of the email should read "Unfreeze [fund #], [P.I.],
[Sponsor I.D.]" to ensure that the fund # has been typed correctly.
There should be one email for each fund unfreeze request.
The body of the email request should specify the following:
· Type of unfreeze needed (manual journals, payroll, C forms,
· An indication that you have attached a spreadsheet reconciling
all expenditures, including current total expense (direct and indirect),
adjustments and related employee benefits and F&A costs, and final
expense to be reported (direct and indirect). If an EB or F&A adjustment
is necessary, specify that clearly in your e-mail. Otherwise adjustments
will always default to whatever the current rates are. Do not round to
whole dollars when reconciling the fund. ORS will need to report to the
· On the spreadsheet when listing adjustments, specify which fund(s)
are to be credited and which fund(s) are to be debited.
· Payroll reallocations need to be identified by pay end date in
order for the employee benefits to be reconciled using the correct EB
rate. (see bullet 3 above)
· The final balance to be reported must match the final balance
on your reconciliation worksheet.
· The Unfreeze request should be accompanied by a closeout package,
including all necessary supporting closeout documentation, which varies
by sponsor and award type. Refer to Closeout SOP.
Remember that when Research Services notifies you that the fund has been
unfrozen, it is a manual process and should be verified by checking View
Grant Attributes that the unfreeze has taken effect.
Also if requesting an unfreeze to make payroll adjustments, it is best
to request the unfreeze on Wednesdays since Payroll is a day behind FinMIS
in terms of "knowing" about the unfreeze/freeze status of a
grant. In order for Payroll to "know" on Monday (when Payroll
generates transactions) that an account is unfrozen/frozen, it must be
unfrozen/frozen in FinMIS by the preceding Friday.
Payments to be made after termination for goods received or services
rendered during the project period, (for which funds are not encumbered),
can be made via C form.
Remember if your grant has a subcontract and the final invoice will not
be received in time for adjustment and close-out and reporting, relieve
the remaining encumbrance and once the invoice is received pay on a C-368
form on the next year's fund number. (Research Services will have reported
that remaining amount as unliquidated obligations and the dollars will
have been carried over to the next year's fund number.) However, every
effort should be made to ensure that the final invoice has been received
and processed for payment prior to the end of the adjustment period.
Tuition adjustments need to be coordinated with Associate Director of
Finance & Data Management in the Biomedical Graduate (usually need
approximately 2 weeks). Tuition payments entered into the SAM system update
every Friday evening. Payments are posted to the student's account in
the Bursar system the following Tuesday, and post to the fund being charged
the next Tuesday. So it takes 7 working days from any given Friday before
the tuition charge appears on the fund. In the case of grants specifically
unfrozen for tuition payments to be posted, the grant should be unfrozen
on a Friday, with the tuition payments being processed into the system
the same day. The grant would then need to remain unfrozen for 12 calendar
days including the Friday it was first unfrozen.
· When unfreeze requests are NOT necessary:
o To prepare budget journals, even after the project has ended
o To pay encumbered amounts
o To relieve encumbrances (address these requests to apsup@pobox) unless
the PO has finally closed, in which case a request to unfreeze Manual
Journals must be made, and a manual encumbrance journal created. Refer
to Encumbrance SOP.
After the account has been unfrozen and you have made the necessary reallocations
and journal entries, you MUST verify that the adjustments have been posted
To verify that payroll reallocations have been processed: Access the
on-line payroll system and view reallocations from the browse reallocations
screen. If none appear, then the reallocations have been processed. If
reallocations appear in the browse screen, contact Payroll to determine
To verify that payroll reallocations have posted to the correct fund(s),
use on-line account detail inquiry, or run an account detail salary management
· Departmental Business Administrators
· Office of Research Support Services
· Office of Research Services
· Biomedical Graduate Studies
· Accounts Payable
· Payroll Department
· Office of the Comptroller
FORMS AND ATTACHMENTS
· Sample spreadsheet
Refer to Freeze grants SOP
Refer to Closeout SOP
Refer to Cost Transfers SOP
Refer to Payroll Reallocations SOP
Refer to Wayward Transactions SOP
Refer to Encumbrance SOP
Refer to Effort Reporting SOP
Refer to Revision of FSR SOP