Documentation Transactions posted to sponsored funds Sponsored Programs Administration October 2012

Documentation o What do auditors want? o Best practices – at UNH? Please contribute! o Useful guidance and lessons learned from audits o Benefits of being prepared

What auditors want: Salary Appointment or employment letters, if applicable Support for pay rate in timeframe of selected cost Effort certification Timesheets for part-time hourly employees Description of the employees role in the project Work plan to support salary encumbrances Additional pay approval Stipend letters for graduate students

What auditors want: Travel costs Expense report showing request and payment Receipts and invoices Explanation of the purpose of the travel and relation to the project Support that the individual charging travel works on the project Airfare – support that its lowest reasonable cost S.P.A. approval for foreign travel

What auditors want: Consultants/Purchased Services Check request/other support showing request and payment Invoice Original consulting agreement Description of services and support for benefits to the project Vendor justification form and suspension and debarment verification for federal projects

What auditors want: Equipment, supplies, and other Requisition and PO Invoice Proof of delivery S.P.A. approval for equipment in federal projects Description and support for relationship to the project Vendor justification form and suspension and debarment verification for federal projects

What auditors want: PI approval Proof of any signature delegation Refer to the presentation by USNH Internal Audit at this forum winter 2010 by Jessica Wixson-Shaw on Your Signature

General Cost Allowability Criteria: clear in the documentation Allowable under A-21 and specific award terms Allocable – clear associated benefits to the project and the allocation methodology must be consistently applied, identified in advance, and never to use remaining unspent funds or that its this grants turn Reasonable – what a prudent person would do

Costs generally considered to be indirect costs in federal projects Administrative salaries, postage, local telephone, copier, general office supplies When direct costs must document Unlike circumstances – this project is different Costs are directly connected to the project Sponsor prior approval – see the budget narrative

Cost share/matching documentation Recorded cost share in 15C or 16C funds based on actual costs that are documented by the BSC. Memo accounting – 3 rd party and in-kind, e.g. volunteer time, with a form on the S.P.A. web page Proportionately and timely documented

Cost transfer documentation First – avoid cost transfers and record correctly the first time. Document the reasons even when not late. Be careful with the explanations that end up in official documentation since sometimes these are damaging or unclear. S.P.A. approval first for late transfers (over 90 days after the end of the month of the original transaction)

Subrecipients Documentation Agreements – in S.P.A. and Xtender Invoices – in Xtender Evidence of PI oversight and monitoring for performance and invoice approval Subrecipient audits – S.P.A. requests and reviews

Vendor/Subrecipient – Suspension & Debarment OMB Circular A-110 prohibits contracting with or making subawards to parties that are suspended or debarred Applies to all subawards (even those less than $25K) Applies to procurement contracts for goods or services paid by a grant or cooperative agreement expected to exceed $25K

Vendor/Subrecipient – Suspension & Debarment USNH Purchasing Procedures – communicated at this Forum by Denise Smith, Director of Purchasing on 5/26/11 All grant funded, non-personnel expenditures $25K or greater must go through the Requisition-to-PO process

Record Retention Federal requirements: 3 years from date of the final financial report or for contracts the final payment Applies to financial records, supporting documents, and all other records pertinent to an award Records for equipment purchases with federal funds – 3 years after disposition of the equipment

Record Retention Transaction Supporting Documents USNH Controllers Office requires 7 years Maintained by BSCs now mostly in BDMS Xtender

Documentation - Summary o Supporting documents for transactions recorded in sponsored projects must clearly demonstrate that the costs are allowable. o When documentation is unclear we spend additional time explaining the costs to auditors and risk questioned or disallowed costs.

Questions?