Fiscal Compliance CornerRecent Happenings, etc.

MRAM September 2014

Ted MordhorstAssistant Director for Post Award Financial ComplianceResearch Accounting & Analysis

Audit News

Audits from NIH OIG, NASA and NSF.

Significant items

NASA – No questioned cost but cited weaknesses in internal controls that led to cost over-runs and delayed receivables

NSF – Findings related to “senior project personnel” salary charges exceeding the 2 month limit.

NIH – Institutional policies were not followed

Cost Transfers University Policy: GIM 15

Indicator of adequate internal controls Frequency Timing justification

Cost Transfers Frequency

A high volume of cost transfers necessary to correct costing errors may be an indication of poor internal controls.

Review your procedures used to detect errors.

Procedures should be established to detect coding errors in a timely manner.

Cost Transfers Timing

Transfers should be processed within 90 days of when the error occurred.

Additional explanation required for transfers 120 days or more after the transaction posted.

This explanation should include steps taken to detect errors and make corrections in a more timely manner.

Cost Transfers Justification

Two parts How the error occurred in the first place and what steps

are being taken to prevent the error from occurring in the future.

Explain the allocability or benefit to the budget being charged. Be specific. If a portion of a cost, explain how the correct portion was

determined.

Cost Transfers Final comments

Whenever possible avoid having one person prepare and submit cost transfers.Attach notes and/or emails from faculty or other staff when available.Document departmental internal control procedures so everyone knows what is expected.

Never, ever use “availability of funds”, or lack thereof as a justification for transferring a cost to a sponsored project.