Uniform Guidance and Grants Accounting Author: Mariel Diaz Office of Research

Compliance Supplement Uniform Guidance Compliance Supplement A "government-wide framework for grants management" – is an authoritative set of rules and requirements for Federal awards that synthesizes and supersedes guidance from earlier OMB circulars. The OMB A-133 Compliance Supplement is a large and extensive United States federal government guide created by the Office of Management and Budget (OMB) and used in auditing federal assistance and federal grant programs, as well as their respective recipients. Uniform Guidance (Link) Office of Research Compliance Supplement (Link)

Compliance Requirements – Areas of Audit Review Activities Allowed or Unallowed Cost Principles Cash Management Reserved (Davis-Bacon Act) Eligibility Equipment and Real Property Management Matching, Level of Effort and Earmarking Period of Performance Procurement and Suspension and Debarment Program Income Reserved (Real Property Acquisition and Relocation Assistance) Reporting Subrecipient Monitoring Special Tests and Provisions Office of Research

Key Focus Areas – Other Review Administrative Management Oversight of the sponsored program Program and fiscal coordination Policies, procedures and relevant manuals are available to staff Administrative meetings and minutes documentation Hiring of qualified staff and provide required training Adequate resources are available to sustain program operations Subcontract/consultant management protocols Fiscal Management Expenses align with budgets and burn rate for the period Appropriate procurement methods followed Expenses incurred within the period Personnel records – Time and effort Prior Approvals from sponsor obtained as applicable Internal controls and approvals Other special requirements and conditions as per guidelines Office of Research

Cost Principles Allowable Reasonable Allocable Consistently Treated Handout #1 Cost Principles Federal Regulations establish principles for determining costs applicable to Awards. The four main principles are: Allowable Reasonable Allocable Consistently Treated Office of Research

Internal Controls Means a process, implemented by a non-Federal entity, designed to provide reasonable assurance regarding the achievement of objectives in the following categories: Effectiveness and efficiency of operations Procedures Performance Metrics Training Reliability of reporting for internal and external use Financial Status Reports Regular Monitoring Financial Systems Data Entry and Standards Compliance with applicable laws and regulations Policies Appropriate Approvals Proper Documentation Justifications/Explanations Office of Research

Internal Controls - Grants and Contracts GCA supports adherence to the Uniform Guidance and Audit requirements as follows: Develop and implement Policies and Procedures Develop and implement forms with approval workflow Require support documentation, explanations and justifications as needed Secure proper financial management Monitor grant financial performance Office of Research

Examples of Non-Compliance Inappropriate reasons for bypassing purchasing protocols: Insufficient time left on the grant to put request through purchasing Purchased items to spend down balance since grant is ending soon Purchased on personal card without prior approval because wanted rush delivery Inappropriate Reasons for Cost Transfers Cost transfers solely for the purpose of transferring overruns or deficit balances Cost transfers solely for the purpose of utilizing unexpended funds of a sponsored award Cost transfers used as a cost management strategy Cost transfer for any other reasons of convenience Office of Research

Proactive Grant Management – Burn Rate Report A status summary of the grant portfolio by area which provides current spending and balances. This report is distributed monthly to Department Chairs, Deans and Office of Research Ambassadors. Review of these reports on a regular basis helps identify: Potential large balances due to unallocated expenses or budget planning revisions needed. May also highlight no cost extensions that are needed Potential accelerated spending that can lead to deficits Grants in deficit that need to be reconciled Grants that are ending in the next 90 to 30 days which need to start preparing for closeout including PO closures, subcontract invoicing, expense and labor reallocations to new funding sources, or employee terminations.

Proactive Grant Management – Burn Rate Report Sample Data Ambassadors can provide reports specific for your PI.

Institutional Policies Resources - Policies Federal Policies Institutional Policies Uniform Guidance Policy National Science Foundation Policy National Institute of Health eRA Commons– For NIH NGAs (agreement notice), Progress Reports and FFR submissions Office of Research Policies http://www.njit.edu/research/researchers/policies-forms.php Official University Policies https://www.njit.edu/policies/