New requirements for research funds: authorization of expenses by PIs and record retention
Memorandum
Rose Goldstein
Michael Di Grappa
Date: May 5, 2014
To: McGill researchers and staff
颁肠:听Suzanne Fortier, Principal and Vice-Chancellor,听Anthony C. Masi, Provost,听Senior Administration,听Academic Leadership
Subject: New requirements for research funds: authorization of expenses by PIs and record retention
Dear Colleagues,
In November 2012,听we informed you听of the need to improve our practices and procedures in the management of research grants, following recommendations resulting from the 2010 Tri鈥怉gency monitoring visit.
Two significant findings stemmed from difficulties in confirming that:
- Principal Investigators had authorized signing authority to delegates, and
- Principal Investigators or authorized delegates had approved, prior to incurrence, each expense charged to their research grants.
To address the first concern, a new online听Delegation of Temporary Signing Authority听application was implemented in May 2013 to better capture and document authorized delegates on research grants. Take note that this is now the only valid method for delegating authority on such funds.
To ensure compliance with the second Tri鈥怉gency requirement, we wish to remind you that it is critical that Principal Investigators (PIs) or their delegates authorize all expenses allocated to their research funds. While certain transaction categories have built鈥恑n mechanisms that document such approvals, for example expense reports and purchases made via McGill Marketplace, authorization for other transaction categories is captured and retained at the unit level.
The transaction streams which require greater diligence include:
Payroll:
- PIs must sign offer letters and timesheets for hourly鈥恮orkers (revised timesheets were released in December 2013) and student stipend payment authorization forms (BSA).
- They must also authorize, either by signature on printed payroll forms or by email, all payroll distributions (% effort charged to research funds), or any changes thereof, prior to submission of payroll appointment forms via Minerva or retro adjustments.
Procurement Card (PCard):听As stated in the PCard policy, all receipts must be retained and be easily accessible, even in the absence of the cardholder.
Journal entries to correct/reallocate expenses (commonly referred to as JE16s):听if initiated by Unit staff, PI鈥檚 approval must be obtained in writing (either via memo or email).
UPrint:听authorization from the PI must be obtained prior to granting students or staff printing privileges and assigning a FOAPAL via the Minerva UPrint menu.
Record Retention Requirements
Consistent with Tri鈥怉gency practices, lack of supporting documentation evidencing PI or delegate authorization will be deemed non鈥恈ompliant. In addition, expenses approved by an individual, other than the Principal Investigator, authorized to do so via the Delegation of Temporary Signing Authority menu will also be deemed non鈥恈ompliant. We acknowledge that in many instances, Principal Investigator or authorized delegate approvals are already being obtained on these types of expense categories. However, inadequate record retention practices have made it, at times, difficult to retrieve supporting documents proving authorization.
The听appended table听provides guidance on documentation and record retention requirements. Documents evidencing appropriate authorization must be retained by the Faculty/Department/Unit, either in electronic format or hardcopy, in shared folders, easily accessible and retrievable upon request by sponsoring agencies. While scanning original, signed documents is an acceptable means of preserving files, please be advised that the use of digital electronic signatures or images of a hand鈥恮ritten signature is not accepted as proof of PI or delegate approval.
Faculties must therefore review record retention and PI/delegate authorization processes and promptly implement improvements as needed.听Record retention best practices were introduced to Faculty Financial Officers in December 2013 and representatives from Financial Services have had ongoing meetings with Faculty representatives to discuss this initiative. Ongoing monitoring and compliance testing by Research Financial Management Service (RFMS) will verify conformity with these requirements.
We rely on each Faculty, with assistance from Departments and Centres, to ensure unit鈥恠pecific implementation. If you have any questions or concerns, please contact your Faculty Financial Officer or Financial Services Team. They will convey any difficulties in meeting these requirements to our respective offices.
Please be advised that authentication of Principal Investigators鈥� or delegates鈥� approval of expenses resulting from shared resources, as well as internal stores and service providers, continues to pose challenges. Solutions will be communicated as they are implemented.
We thank you in advance for making every effort to implement these new practices. You are vital to ensuring compliance with granting Agencies requirements and safeguarding our good standing as stewards of public funds.
Rose Goldstein
Vice Principal, Research and International Relations
Member of Tri-Agency Steering Committee
Michael Di Grappa听
Vice Principal, Administration and Finance
Member of Tri-Agency Steering Committee
[Message sent out on the FIS listserv May 12, 2014]