E-Verify Julia Puntenney

E-VERIFY E-VERIFY Employment Eligibility Verification

E-VERIFY FAR Clause 52.222-54 Applicable only to federal and subfederal contracts Listed in contract terms and conditions

E-VERIFY Employees assigned to the contract. For each employee assigned to the contract, the Contractor shall initiate verification within 90 calendar days after date of contract award or within 30 days after assignment to the contract, whichever date is later.

E-VERIFY Employee assigned to the contract means an employee who was hired after November 6, 1986

E-VERIFY All UA employees who began work prior to November 6, 1986 are exempt UA E-Verifies all new and rehired employees since January 1, 2008 For employees that are assigned to contracts with FAR 52.222-54 and their hire date falls between 11/6/86 and 1/1/08 E-Verification is required

E-VERIFY SPCS reviews all new fed/subfed contracts for clause Flag Account Name Review personnel in budget /email Workforce Systems to request I-9s as needed Email Fiscal Officer Dear Fiscal Officer, The above referenced contract includes the E-Verify clause (FAR 52.222-54.)  When the E-Verify clause has been included in a contract, the University is required to E-Verify all employees assigned to the contract.  Sponsored Projects Services will perform an initial review of employees listed in the budget and a periodic review of employees paid from the account.  A list of employees who require E-Verify will be sent to Workforce Systems.  Workforce Systems will notify departments if an I-9 is required to perform the E-Verify.  Please provide I-9’s to Workforce Systems as soon as possible if you are contacted.  Additional information regarding E-Verify as it applies to federal contracts may be viewed at the U.S. Citizen and Immigration website: http://www.uscis.gov/e-verify/federal-contractors Thank you for your cooperation.  Please feel free to contact me with any questions.

E-VERIFY Please ensure E-verification for employees assigned to contracts that contain FAR 52.222-54 Can affect approval of: Salary Expense Transfers Effort Reports Supplemental Compensation Retro Pay

NSF Audit Lessons Learned Marcel Villalobos, Tara Gonzales, Tabatha Holan

Objectives Evaluating risk level of expenditures Understanding how to properly justify and document Being able to apply knowledge to real cases

Scope of Audit Purpose: Are costs charged to NSF projects allowable, allocable, reasonable, and in conformity with NSF and Federal terms and conditions? Period: 1/1/2012 to 12/31/2014 Total Cost: $140 million direct costs across 772 projects. Contracted Firm: Moss Adams We received the NSF OIGnotice on February 2015

Allowability Reasonable Allocable Conforms to terms Consistent Necessary Arm’s length bargaining: a transaction in which the buyers and sellers act independently of each other and have no relationship to each other. The prudent person test: a sound business decision made by a prudent person under the circumstance prevailing at the time. Allocable Incurred specifically for a project Chargeable or assignable to a project in proportion to the benefit received Reasonable allocation basis without undue effort or cost May not shift costs to eliminate deficit or for convenience Documentation Conform to limitations or exclusions set by laws, regulations, terms of an award, and policies. Consistently treated under similar circumstance

What is a High Risk Cost? OIG Methodology Data Analytics & Risk Based

Questioning of Costs Review of costs against NSF and Federal terms and conditions Evaluate justification in the proposal and/or purchase documentation Require additional justification from fiscal officer and investigator

Questioned Costs Overtime General Rebudgeting Late Cost Transfers > 120 Days After End Date Equipment not Budgeted Purchases near term Computers Equipment Relocation Costs Travel During a period with no payroll Allocated to multiple awards over long period Foreign Excessive PI travel to workshops/conferences

Lesson Learned Expenditures on Federal projects must be supported by a business purpose. It can either be in the proposal budget justification, or accompany the transaction in Financials. The level of documentation should scale with the level of risk of the cost.

Outcome 250 Transactions Nine Preliminary Findings, Down to Five Findings in Moss Adams audit report One Management Note {

Findings Compassionate leave Subaward without prior approval Pre-award costs outside of 90 days Travel charged to the wrong award Campus rec fees for student participants

How do we Compare? University of Southern California $639,479 University of Kansas Center for Research $172,030 Georgia Tech Research Corporation $62,009 University of Arizona $56,904 *Figures include direct and F&A costs

Thank You!