Circular A-110 Everything You Didn’t Want to Know

Purpose of A-110 Subpart C- Post Award Establishes uniform administrative requirements for Federal grants and agreements awarded to institutions of higher ed, hospitals, and other non-profit organizations. Establishes uniform administrative requirements for Federal grants and agreements awarded to institutions of higher ed, hospitals, and other non-profit organizations.

Post Award Requirements A-110 Subpart C - Sets standards for financial and program management of sponsored research awards in: A-110 Subpart C - Sets standards for financial and program management of sponsored research awards in: FINANCIAL & PROGRAM MANAGEMENT –Methods for making payments –Cost sharing and matching requirements –Accounting for program income –Budget Revisions –Audits –Allowability of Costs –Establishing Fund availability

Standards for financial management systems Relate financial data to performance data Relate financial data to performance data Financial system must provide: Financial system must provide: –Financial results of each project –Identification of source & application of funds –Control & accountability over all funds, property & other assets –Comparison of outlays to budget amounts

Standards (cont.) Procedures to minimize time between transfer of funds and disbursement of funds Procedures to minimize time between transfer of funds and disbursement of funds Procedures to determine reasonableness, allocability, and allowability of costs Procedures to determine reasonableness, allocability, and allowability of costs Accounting records supported by source documentation Accounting records supported by source documentation

Cost Sharing/Matching Funds

Definitions of Cost Sharing (Matching Funds) A commitment made by WSU to fund a portion of the total cost of a sponsored agreement. The commitment may be for direct and/or indirect costs, and may consist of WSU funds or funds from outside sources. Matching may either be classified as voluntary or mandatory. Either form is a true commitment and must be fully documented. A commitment made by WSU to fund a portion of the total cost of a sponsored agreement. The commitment may be for direct and/or indirect costs, and may consist of WSU funds or funds from outside sources. Matching may either be classified as voluntary or mandatory. Either form is a true commitment and must be fully documented.

Cost Sharing (Match) must meet all of the following criteria: In general, same requirements apply to Non-Federal Share as apply to the Federal Share Verifiable from recipient’s records Verifiable from recipient’s records Not included as Match for any other federally funded program Not included as Match for any other federally funded program Necessary and reasonable Necessary and reasonable Allowable under the applicable Cost Principles Allowable under the applicable Cost Principles Not paid by the Federal Government under another award Not paid by the Federal Government under another award Provided for in the approved budget Provided for in the approved budget Conform to other provisions Conform to other provisions

Types of Cost Sharing Mandatory Cost Sharing Mandatory Cost Sharing Voluntary Cost Sharing Voluntary Cost Sharing Third Party In Kind Contributions Third Party In Kind Contributions Facilities and Administrative (F&A), also known as Indirect Costs Facilities and Administrative (F&A), also known as Indirect Costs

What Can be Used to Meet Match Requirements? Cash Cash Third Party Contributions Third Party Contributions Unrecovered F&A costs (Indirects) Unrecovered F&A costs (Indirects) Contributions of services and property Contributions of services and property Volunteer Services (necessary for project) Volunteer Services (necessary for project) Other employee services (regular rate + benefits) Other employee services (regular rate + benefits) Donated supplies (at reasonable & fair market value) Donated supplies (at reasonable & fair market value)

Unrecovered Indirect Costs May be included as part of cost sharing or matching only with the prior approval of the awarding agency. May be included as part of cost sharing or matching only with the prior approval of the awarding agency. Current approved rate agreement is 36% of Salaries, Wages and Benefits Current approved rate agreement is 36% of Salaries, Wages and Benefits

Audit Procedures for Match Compliance Verify that required Matching Contributions were met Verify that required Matching Contributions were met Ascertain sources of matching contributions and verify that they were from an allowable source Ascertain sources of matching contributions and verify that they were from an allowable source Test records to corroborate that value of in-kind contributions are in accordance with OMB cost principals Test records to corroborate that value of in-kind contributions are in accordance with OMB cost principals Verify transactions used to match are in compliance with allowable cost principles Verify transactions used to match are in compliance with allowable cost principles

Procurement Standards PURPOSE: To establish procedures for procurement of supplies and other expendable property, equipment, real property, and other services

Codes of Conduct regarding Awards and Administration of Contracts Recipients shall maintain written standards of conduct governing performance of employees involved Recipients shall maintain written standards of conduct governing performance of employees involved Cannot participate if conflict of interest exists Cannot participate if conflict of interest exists Cannot accept gratuities, favors, or anything of monetary value from contractors, subs, or parties to subgrants Cannot accept gratuities, favors, or anything of monetary value from contractors, subs, or parties to subgrants

Competition Must provide open and free competition Must provide open and free competition Contractors that develop or draft specs or requirements, statements of work, invitations for bids and/or requests for proposals are excluded Contractors that develop or draft specs or requirements, statements of work, invitations for bids and/or requests for proposals are excluded

Required Written Procurement Procedures Recipients must not purchase unnecessary items Recipients must not purchase unnecessary items Determine which procurement methods are most economical and practical Determine which procurement methods are most economical and practical Positive efforts to utilize small business, minority owned firms & women’s business enterprises, whenever possible Positive efforts to utilize small business, minority owned firms & women’s business enterprises, whenever possible

Procurement procedures (cont.) Solicitations for goods & services must provide: Solicitations for goods & services must provide: –Clear & accurate descriptions of technical requirements –Specify requirements which bidders must fulfill –Describe minimum acceptable standards –Include specific features of “brand name or equal” descriptions –Acceptance of products & services dimensional in the metric system –Preference for products & services that conserve natural resources, protect the environment, and are energy efficient – when practicable and economicaly feasible

Record retention & access requirements Financial records, supporting documentation, and statistical records – Three (3) years from date of submission of final report Financial records, supporting documentation, and statistical records – Three (3) years from date of submission of final report –If litigation occurs – until all litigation or claims are resolved Real Property or Equipment – Three (3) years after final disposition Real Property or Equipment – Three (3) years after final disposition

Closeout All reports (financial, performance, other) must be submitted within 90 days after completion date of award All reports (financial, performance, other) must be submitted within 90 days after completion date of award Unless extension granted, all obligations incurred must be liquidated within 90 days Unless extension granted, all obligations incurred must be liquidated within 90 days Prompt refund of any balances of unobligated cash advances Prompt refund of any balances of unobligated cash advances Awarding agency to make settlement for any upward or downward adjustments to costs after closeout reports received Awarding agency to make settlement for any upward or downward adjustments to costs after closeout reports received

Closeout (cont.) Accounting of real or personal property acquired with federal funds Accounting of real or personal property acquired with federal funds If no final audit done prior to closeout, awarding agency retains right to recover disallowed costs resulting from the final audit If no final audit done prior to closeout, awarding agency retains right to recover disallowed costs resulting from the final audit

Closeout Does Not Affect: Right to disallow costs and recover funds on the basis of a later audit Right to disallow costs and recover funds on the basis of a later audit Obligation of recipient to return funds due Obligation of recipient to return funds due Audit requirements Audit requirements Property management requirements Property management requirements Record retention Record retention