business and fiscal officers meeting - 2/18/10 presented by: glen jones, director post-award...

BUSINESS AND FISCAL OFFICERSMEETING - 2 /18 /10

PRESENTED BY:GLEN JONES, DIRECTOR POST-AWARD

RESEARCH AND SPONSORED PROGRAMS

Federal Audit Compliance Overview of A-133 Audit Compliance Supplement

Compliance Requirements and Internal Control

Activities Allowable or UnallowableAllowable Costs/Cost PrinciplesCash ManagementDavis-Bacon ActEligibilityEquipment and Real Property ManagementMatching, Level of Effort, EarmarkingPeriod of Availability of Federal FundsProcurement and Suspension and Debarment

Compliance Requirements and Internal Control

Program IncomeReal Property Acquisition and Relocation

AssistanceReportingSubrecipient Monitoring

Activities Allowable or Unallowable

Activities allowed or unallowed are unique for each Federal Program and can be found in the following: Laws & Regulations

Program Legislation Federal Agency regulations

Provisions of the grant agreement Terms and Conditions of Award

A-133 Compliance Supplement Agency Program Requirements by CFDA#

Allowable Costs/Cost Principles

OMB Circular A-21, “Cost Principles for Educational Institutions” (2 CFR part 220) Selected Items of Cost (Direct and Indirect)

Selected Cost Item A-21 Section J

Advertising and public relations costs

(1) Allowable with restrictions

Advisory councils (2) Allowable with restrictions

Alcoholic Beverages (3) Unallowable

Alumni Activities (4) Unallowable

Audit Costs and Related Services (5) Allowable with restrictions

Bad Debts (6) Unallowable

Allowable Costs/Cost Principles (Cont)

Selected Cost Item (Cont) A-21 Section J (Cont)

Bonding Costs (7) Allowable with restrictions

Commencement and Convocation Costs

(8) Unallowable with exceptions

Communication Costs (9) Allowable

Compensation for Personal Services (CPS)

(10) Unique criteria for support

CPS – Organization Furnished Auto

(10.g) Unallowable for personal use part

CPS – Sabbatical Leave Costs (10.f(4)) Allowable with restrictions

CPS – Severance Pay (10.h.) Allowable with restrictions

Contingency Provisions (11) Unallowable with exceptions

Deans of Faculty and Graduate Schools

(12) Allowable

Defense of Criminal & Civil Claims (13) Allowable with restrictions

Depreciation and Use Allowance (14) Allowable with qualifications

Donations and Contributions (15) Unallowable if made by recipient



Employee Morale Costs (16) Allowable with restrictions

Entertainment Costs (17) Unallowable

Equipment & Other Capital Expenses

(18) Allowable based on requirements

Fines and Penalties (19) Unallowable with exception

Fundraising & Investment Mgmt Costs

(20) Unallowable with exceptions

Gains & Losses on Depreciable Assets


Goods and Services for Personal Use

(22) Unallowable

Housing & Personal Living Expenses

(23) Unallowable

Idle Facilities and Idle Capacity (24) Unallowable with exceptions

Insurance and Indemnification (25) Allowable with restrictions

Interest (26) Allowable with restrictions

Interest – Substantial Relocation (26.b(6) Possible adjustment



Labor Relations Costs (27) Allowable

Lobbying (28) Unallowable with exceptions

Lobbying – Executive Lobbying Costs

(28.h) Unallowable

Losses on other sponsored agreements

(29) Unallowable

Maintenance and Repair Cost (30) Allowable with restrictions

Materials and Supplies Costs (31) Allowable with restrictions

Meetings and Conferences (32) Allowable with restrictions

Memberships, Subscriptions, & Professional Activity Costs

(33) Unallowable for civic, community, or social organizations

Page Charges in Professional Journals

(39.b) Allowable with restrictions

Participant Support Costs Not specifically addressed

Patent Costs (34) Allowable with restrictions

Plant and Homeland Security Costs




Pre-Agreement Costs (36) Unallowable unless approved by the Federal Sponsoring Agency

Professional Services Costs (37) Allowable with restrictions

Proposal Costs (38) Allowable with restrictions

Publication and Printing Costs (39) Allowable with restrictions

Rearrangement and Alteration Costs

(40) Allowable with prior approval (special)

Reconversion Costs (41) Allowable with restrictions

Recruiting Costs (42) Allowable with restrictions

Relocation Costs (42.d) Allowable with restrictions

Rental Costs – Building & Equipment


Royalties and other costs for use of Patent


Scholarship and Student Aid Costs (45) Allowable with restrictions

Selling and Marketing Costs (46) Unallowable with exceptions



Specialized Services Facilities (47) Allowable with restrictions

Student Activity Costs (48) Unallowable unless specifically provided for in the sponsored agreement

Taxes (49) Allowable with restrictions

Termination Costs Applicable to Sponsored Agreements


Training Costs (51) Allowable for Employee Development

Transportation Costs (52) Allowable with restrictions

Travel Costs (53) Allowable with restrictions

Trustees (54) Allowable with restrictions


Basic Considerations to Determine Costs Reasonable and necessary (A-21, C.3) Conform with the allocability provisions (A-21, C.4) Consistent accounting treatment (A-21, C.10 & C.11)

Cost incurred for the same purpose, in like circumstances Treated as direct costs only, or Treated as indirect costs only

Conform with allowability of cost provision (A21, C.5) Be net of applicable credits (A-21, C.5) Be supported by appropriate documentation (A-21,

C.4) POs, receiving report, canceled checks, effort reports


Basic Considerations to Determine Costs (Cont) Be applied uniformly to Federal and non-Federal

activities Fringe benefit allocation

based on benefits received by different classes of employees

Direct Costs Identified specifically with a particular sponsored project Can be assigned to a project relatively easily and

accurately Indirect Costs (F&A)

Incurred for common or joint objectives cannot be identified readily and specifically with a

project Include both facilities and administrative costs (A-21, F.)


Basic Considerations to Determine Costs (Cont) Indirect Costs (F&A) (Cont)

Facilities – depreciation, interest associated with building debt, equipment, capital improvements, operation & maintenance, library expenses.

Administration – general and administrative expenses, departmental administration, sponsored projects administration, student administration and services, and other administrative costs

Cash Management

Compliance Requirements Cost reimbursement basis

Program costs must be paid before requesting reimbursement

Advanced funds Procedure to minimize time elapsed between receipt &

expense Appropriate assignment of responsibility of cash

drawdowns. Drawdowns are consistent with cash needs. Routine assessment of adequacy of subrecipient cash

needs.

Davis-Bacon Act

Construction Grants Only Wages for laborers and mechanics paid at prevailing

wage rates. Construction contracts should include Davis-Bacon

language. Contractors and Subcontractors should report weekly,

for each week the contract work is performed.

Eligibility

Eligibility is unique to each Federal Program Determine who can participate in program

Individuals Groups of individuals Subrecipients Consultants Employees

Equipment and Real Property Management

Equipment acquired with federal funds Title vests with the university in most cases Acquisition cost of $5,000 or more per unit. Use, manage, dispose of equipment per established procedure Property tags are placed on equipment Physical inventory periodically taken (at least every 2 years) Property records contain

Description Source (vendor) Who holds Title Acquisition date and cost Percentage of Federal participation in cost Location Condition Disposition Data

Matching, Level of Effort, Earmarking

Compliance Requirements Verifiable from the university’s records Do not include contributions from other federal

programs Are necessary and reasonable to accomplish project Are allowable under applicable cost principles (A-21) Are not paid by Federal Government under another

award Are provided for in the approved budget when

required Conform to applicable provisions in A-110, laws,

regulations and provisions of grant agreement.

Matching, Level of Effort, Earmarking

Matching, Level of Effort, Earmarking Defined: Matching (Cost Sharing) – non federal contributions

Specific amount or percentage Allowable non-federal costs incurred In-kind contributions

Level of Effort Specific level of service to be provided from period to period Specific level of expenditures maintained from period to period Federal funds to supplement not supplant non-Federal funding

Earmarking Minimum and/or maximum amount or percentage of the

program’s funding that must/may be used for specific activities, including funds provided to subrecipients

Period of Availability of Funds

Compliance Requirements All transactions must be incurred within the stated

period of performance (expensed or encumbered for goods and services) All unliquidated obligations (encumbrances) should be

liquidated within 90 days of the end of the grant. Timely communication of period of availability

requirements Grant close-out emails

Periodic reporting of unliquidated balances Burn rate report

Periodic review of expenditures before and after cut-off date

Procurement and Suspension and Debarment

Compliance Requirements Procurement

Provide reasonable assurance that procurement are made in compliance with the provisions in OMB Circular A-110

Procedures to verify vendors providing goods and services under a grant award have not been suspended or debarred. Requires staff to determine that entities receiving

subawards of any value and procurement contracts equal to or exceeding $25,000 are not suspended or debarred.• Checking the Excluded Parties Listing System (EPLS)• Obtaining a certification, or• Inserting a clause in the agreement

Program Income

Definition Program income is gross income received that is

directly generated by the federally funded project during the grant period.

Requirement To provide reasonable assurance that program income

is correctly earned, recorded, and used in accordance with the program requirements.

Program Income

Compliance Identify Program Income

Review grant award to see if program income is anticipated

Determine or assessing Program Income Properly determined and calculated and from allowable

sources Recording of Program Income

Properly recorded in accounting system Use of Program Income

Used in accordance with program requirements and A-110

Real Property Acquisition and Relocation Assistance

Requirement To provide reasonable assurance of compliance with

the real property acquisition, appraisal, negotiation, and relocation requirements. Uniform Relocation Assistance Act of 1970 Typically related to HUD grants

Reporting

Requirement To provide reasonable assurance that reports include

all activity of the reporting period, are supported by underlying accounting or performance records, and are fairly presented in accordance with program requirements.

Timely reportingFinancial ReportingPerformance ReportingSpecial Reporting

Subrecipient Monitoring

Requirements Award identification

Identify to subrecipient the federal award information (CFDA#)

During the award monitoring Reporting, site visits and regular contact with

subrecipient Subrecipient Audits

Audit confirmation from subrecipients verifying A-133 audit

Special Tests and Provisions

Compliance Requirement Unique to Federal Program

Program listed in compliance matrix by CFDA number Requirements listed in Part 4 and Part 5 of Supplement

Programs not listed in compliance matrix Review grant agreement for requirements

Common Audit Findings

Time and Effort ReportingCost Sharing and MatchingSubrecipient MonitoringCash Management

Findings in recent WSU audit related to reporting

??QUESTIONS??

business and fiscal officers meeting - 2/18/10 presented by: glen jones, director post-award...

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