Fiscal Compliance Corner Recent Happenings, etc. MRAM October 2014 Nathaniel Clark for Ted Mordhorst Assistant Director for Post Award Financial Compliance Research Accounting & Analysis

Audit News Internal audit of allowable costs on federal awards Significant items Administrative and Clerical costs – Justification did not show unlike circumstances. Off-Campus projects still require justification as unlike circumstance. Travel per diem rates – Justification for over-per diem unfounded. Hosted Conferences – need site bill that is itemized for meeting rooms, meals and lodging rooms.

Audit News Internal audit of allowable costs on federal awards Significant items Cost Transfers – inadequate justification, significant number of transfers over 120 days. Salary transfers not tracked to GCCRs for correction and re-certification. Inadequate justification. Significant number processed over 120 days from transaction date.

Technology Recharge Fee  Can the Technology Recharge Fee be charged directly to grants and contracts?  The Technology Recharge Fee cannot be charged directly to federal (or federal flow ‐ through) grants or contracts, but it can be charged to non ‐ federal grants or contracts if the sponsor does not specifically disapprove the cost in the award or in other notices it gives to the University.  TRFFAQs.pdf TRFFAQs.pdf

Grant Control Flags  Grant Control Flag #2 (Administrative & Clerical Salaries) has been discontinued  First announced at a QRAM several years ago  Why discontinued?  Inconsistent application  Subject to human error  Does little to guide campus on what is allowable or not allowable  Does not contribute to compliance  Exposure to audit findings for inconsistency

Grant Control Flags  Departments are responsible for knowing what types of costs are allowable on their awards.  Central offices are available to assist in interpreting and applying sponsor terms and conditions. Reference GIM 2