SOP-XXIV: PROJECT PARTICIPANT PARTICIPATION IN STCU PROJECTS

PURPOSE:

To provide a written policy and procedure establishing and maintaining financial control over payments of grants made by the STCU to individual project participants. This policy defines the STCU’s allowable days and percentage of days worked on STCU regular projects, governmental partner projects, and non-governmental partner projects, as well as any combination of these projects. Finally, in preparation for conducting joint ISTC/STCU projects, this policy will also align STCU’s policy towards individual project participation into line with that of the ISTC’s (see ISTC FOP-XIII).

BACKGROUND:

As per the recommendation of Observation #5 of the management letter issued by Lubbock Fine Chartered Accountants for the year ended December 31, 2003, the STCU was requested to provide a written policy and procedure defining allowable hours and percentage of hours worked on STCU regular projects, governmental partner projects, and non-governmental partner projects, as well as any combination of these projects.

Clarification of the allowable hours and percentage of hours worked was also needed as a result of the decision of the 17th STCU Governing Board meeting to approve a new non-governmental partner model project agreement. Within these new model agreements, grantees working on non-governmental partner projects from that date forward were allowed to work an unlimited amount of days and percentage of days worked. The 220-day restriction, and the restriction on institute director and Project Manager percentage of participation, applicable to regular and governmental partner projects, was no longer applicable to non-governmental partner projects as of that date.

In December 2009, the Mid-Term Recipient Audit Report on STCU, by the Office of the Inspector General, Department of Foreign Affairs and International Trade Canada (Recommendation 9, Page 28) made the following recommendation:

The Executive Director of the STCU along with the Chief Financial Officer should present the proposal of increasing the limit that project participants can charge to a project from the current 220 days to 250 days to an upcoming Governing Board meeting for approval. If approved by the Governing Board, any scientist who wants to charge more than 250 days to a project should first receive the approval of both the Senior Specialist and the donor nation which funds the project. A list of scientists who work more than 250 days a year should be made by the CFO’s Office and shared with the Executive Director, Deputy Executive Directors and the donor nations on a quarterly basis.

At the 32nd STCU Governing Board, the STCU presented the above recommendation, and the Governing Board made the following decision (see 32nd Record of Decisions):

Approved increase in the project work-day limitation from the current 220 days to 250 days, as well as eliminate the limit of 66 working days in one quarter, in order to accommodate the raised annual limit. Any project participant needing to work more than 250 days (collectively) on STCU projects must receive written approval from the STCU Senior Specialist.

The Governing Board only partially enacted the recommendation of the Canadian auditors, and this policy was rewritten to accommodate this decision.

PROJECT PARTICIPATION LIMITS

1. Definitions

   • 100% participation - 250 working days (working day is defined as 8 hours) in one rolling calendar year. This floating approach to setting a time period is necessary because different STCU projects have varying months as operative commencement months.
     The actual duration of a work day may be more than 8 hours, but the calculation of what is counted as 1 work day is based on 1 work day equalling 8 hours. For example, a project participant that works a 12 hour day is considered to have worked 1.5 work days by the STCU. The project participant should record in his time card the actual duration of his work day even if it is more than 8 hours. As per STCU procedure, timecards are required to be completed for actual hours worked.
   • Regular project - those projects funded by the STCU Funding Party Countries' (USA, EU, and Canada) that utilize the regular model project agreement approved by the STCU Board of Governors.
   • Government Partner Project - those projects funded by the STCU Funding Party Countries' (USA, EU, and Canada) governmental agencies, that receive approval as partners by the STCU Governing Board and that utilize the government partner model project agreement approved by the STCU Board of Governors.
   • Non-Government Partner Project - those projects funded by other non-governmental funding entities resident in the territories of the Funding Party Countries' (USA, EU, and Canada), that receive approval as partners by the STCU Governing Board, and that utilize the non-government partner model project agreement approved by the STCU Governing Board. These projects are usually with private sector or non-government organizations.
   • Recipient Signatories - Institute Directors, Rectors, etc.
   • Deputy Recipient Signatories - Deputy Institute Directors, Deputy Rectors, etc.
   • Recipient Signatories and Deputy Recipient Signatories - (also known as institution top management) - Institute Director, Rector, etc.. Deputy Recipient Signatories are defined as Deputy Institute Director, Vice Rector, etc.
   • Non-Recipient Signatories and Non-Deputy Recipient Signatories - Project Managers and project participants.


2. Participation in Regular or Government Partner Projects by Non-Recipient Signatories and Non-Deputy Recipient Signatories
   
   
   • Participation in STCU regular or government partner projects (unless written exception is received from the government partner) is limited to 250 days a year (calculated on a rolling calendar-year basis at the time of quarterly report submission).
   • Participation by STCU regular or government partner Project Managers is also required to be not less than 45% in the project(s) that they manage (unless written exception is received from the government partner).
   • The number of regular and government partner projects on which a project participant works is not limited, but the amount of days collectively worked on said projects is limited to 250 days per year, as stated above.
   • Regular or government partner participation may be increased from 250 days with written permission (e-mails are acceptable forms of written permission) from the Senior Specialist in charge of the project. Any project participant that works more than 250 days and does not receive approval from the responsible Senior Specialist will not be paid for the time in excess of 250 work days.
   • Verifying the amount of time a project participant works on regular or government partner projects is monitored by the STCU financial system (MS-Navision). Prior to making a grant payment, the financial system calculates number of workdays previously claimed for compensation, and generates a report for the STCU Project Accountant to verify during the processing of the project’s quarterly financial report. Only after the results of verification are less than 250 days, is the request for grant payment processed. If the result of the verification procedure indicates that the total number of days claimed for compensation is in excess of 250 days, then the following actions are initiated:
     
     
     • The payment against the quarterly financial report is released for all grantees except for those with a number of days in excess of 250 days.
     • For those grantees who claim more than 250 days, the Project Accountant in charge of the project prepares a written notice of grant withholding (e-mails are sufficient written notice of grant withholding) and sends it to the Senior Specialist.
     • For the execution of the compensation in excess of 250 days, the responsible Senior Specialist presents written authorization (e-mails are sufficient written authorization) to the responsible Project Accountant based on justification received from the Project Manager.
     • If the Project Manager disagrees with the Senior Specialist's decision, then the Project Manager shall provide written notification (e-mails are sufficient written notification) to the Executive Director, responsible Deputy Executive Director, CFO, responsible NGP or GP Manager, Deputy CFO, and Senior Specialist for final decision.



3. Participation in Regular or Government Partner Projects by Recipient Signatories and Deputy Recipient Signatories
   
   
   1. Participation in STCU projects by Recipient Signatories and Deputy Recipient Signatories may not exceed 10% in any single regular or government partner project, nor a cumulative amount of 30% in all STCU regular and government partner projects. Participation may be increased as exceptions if the following conditions apply:
      
      
      1. Organizations with number of employees (number of employees includes everyone on the payroll of the organization) is less than or equal to 20 - Participation of the Recipient Signatories (i.e. Institute Director, Rector, etc.) and Deputy Recipient Signatories (i.e. Deputy Institute Director, Vice Rector, etc.) in individual regular or governmental partner projects may be increased to 20%, and/or cumulative participation of the Recipient Signatories and Deputy Recipient Signatories in STCU regular and parnter projects may be increased to 100% after validation and written approval by the appropriate STCU Deputy Executive Director. Any participation above those percentage levels requires the written approval of the Executive Director.
      2. Organizations with number of employees (number of employees includes everyone on the payroll of the organization) greater than 20 - Participation of the Recipient Signatories (i.e. Institute Director, Rector, etc.) and Deputy Recipient Signatories (i.e. Deputy Institute Director, Vice Rector, etc.) in individual regular or governmental partner projects may be increased to 15%, and/or cumulative participation of the Recipient Signatories and Deputy Recipient Signatories in STCU regular and government partner projects may be increased to 75% after validation and written approval by the appropriate STCU Deputy Executive Director. Any participation above those percentage levels requires the written approval of the Executive Director.
   
   
   2. Participation in Regular or Government Partner Projects by Recipient Signatories and Deputy Recipient Signatories is also subject to all of the terms outlined in section B above as well as those outlined in this section, with the exception of the term above pertaining to Project Managers (minimum 45%).


4. Participation in Non-Government Partner Projects by Recipient Signatories, Deputy Recipient Signatories, Non-Recipient Signatories and Non-Deputy Recipient Signatories
   
   None of the conditions outlined in either B or C apply.


5. Simultaneous Participation by Recipient Signatories, Deputy Recipient Signatories, Non-Recipient Signatories and Non-Deputy Recipient Signatories in Non-Governmental Partner Projects and, Regular Projects or Governmental Partner Projects ("weakest link in the chain" rule)
   
   If a project participant participates in a regular project or governmental partner project simultaneously with a non-governmental partner project, then the project participant is governed by Sections B and C above, and NOT governed by Section D alone.
   
   This section may be illustrated with the use of a chain as an analogy. A chain is only as strong as its weakest link. If a project participant works on a number of projects (chain of projects), and one of the projects (e.g., regular project) has the requirement of 250 days (the weak link in the chain), then the weakest link determines the upper limit on the chain.
   
   In short, if a project participant wants to work more than 250 days (without receiving permission to exceed 250 days from the Senior Specialist as outlined above in Section B), all of the projects that he or she works on must NOT have the 250 day limit. If one of the projects does impose the 250 day limit, then the project participant is limited to a total of 250 days of STCU project-related work, to be calculated cumulatively across all the STCU projects he works on. The participant is also subject to the other limits outlined in Sections C and D above.

6. Work on Weekends and Holidays

   
   STCU project work may be carried out on any day of the week provided it is convenient for project participants, and is required for success of the project. The STCU charges the Project Manager and project participants with using their own judgment as to which days of the week are required for the success of the project. The STCU understands that sometimes for a project to be successful, project participants may be asked to work weekends and/or holidays. But any days worked on a project, including work performed on weekends and holidays, is to be counted as a work-days on the project and must be recorded in the project timecards.


7. Limitation of this Policy
   
   As pointed out by Lubbock Fine Chartered Accountants in Observation #5 of the 2003 Management Letter, the STCU has no mechanism for preventing scientists on regular and government partner projects from working more than 250 work day in a year. The only mechanism currently available to the STCU, is to implement this requirement retroactively. The STCU will continue to investigate methods for enforcing project participation preventively; however, at time there is none available.

EFFECTIVITY:

• Andrew A. Hood
• Executive Director