June 8-11, 2009Joint Annual Meeting Human Resource Development Business Assistance NSF 2009 Joint Annual Meeting June 11, 2009 Washington, DC

June 8-11, 2009Joint Annual Meeting Human Resource Development Ask Early, Ask Often!! Pamela Hawkins, Team Leader Rashawn Farrior, Grants Officer –Division of Grants and Agreements –Education and Human Resource (EHR) Team –(703)

June 8-11, 2009Joint Annual Meeting Human Resource Development Ask Early, Ask Often!! Tamara Bowman, Team Leader Rosalind Jackson-Lewis, Project Director Charlie Zeigler, Special Assistant –Cost Analysis & Audit Resolution Branch/Division of Institution and Award Support (703)

June 8-11, 2009Joint Annual Meeting Human Resource Development Oversight and Monitoring of Federal Awards Emphasis on Stewardship of Federal Funds Award Monitoring and Business Assistance Program Compliance & Common Areas of Concern

June 8-11, 2009Joint Annual Meeting Human Resource Development Cost Analysis & Audit Resolution (CAAR) Award Monitoring & Business Assistance Program (AMBAP) Approximately 30 site visits per year, many at EHR organizations –Core Review Areas –Targeted Review Areas Desk Reviews

June 8-11, 2009Joint Annual Meeting Human Resource Development Compliance & Common Areas of Concern Time and Effort Reporting (A-21, J.10) Participant Support (GC-1, Article 7 & Award and Administration Guide (AAG) Chapter V. Subchapter B.8 Consultants (AAG Chapter V. B.6; A-21.J.37) Subrecipient Monitoring (OMB A-133, Subchapter C._51) Cost Sharing [A-110, _.23(a)]

June 8-11, 2009Joint Annual Meeting Human Resource Development Time & Effort Reporting System to document and support salary charges to Federal awards Time & attendance records vs. Time & effort reports Time & Effort Reporting is a Management Tool

June 8-11, 2009Joint Annual Meeting Human Resource Development OMB Circular A-21 Time & Effort Reporting Plan Confirmation Initially based on budget or assigned work and then adjusted to actual, if there are modifications Includes confirmation statement that the work was performed as budgeted. After the Fact Activity Reports Prepared each academic term for faculty & professional staff. Prepared for other employees at least monthly and coincides with payroll

June 8-11, 2009Joint Annual Meeting Human Resource Development OMB Circular A-21 Time & Effort Reporting Official records – by academic periods - semester, quarter Reasonably reflect activities employee is compensated for Encompass both sponsored projects and other activities

June 8-11, 2009Joint Annual Meeting Human Resource Development Time & Effort Reports Should Contain : Employee name or identification code Project name / number or account code, total effort that pay period Hours or percentage charged to different projects Employee or supervisor signature (can be electronic) Not determined based on the budget, but developed after the fact, based upon actual activities performed

June 8-11, 2009Joint Annual Meeting Human Resource Development Participant Support Costs Participants or Trainees (not employees – exception school districts – teacher training) Stipends, subsistence allowance, travel, registration fees, copies, tuition Funds may not be re-budgeted to other expense categories with out prior written approval of the NSF program officer

June 8-11, 2009Joint Annual Meeting Human Resource Development Participant Support Costs Awardee organizations must be able to identify participant support costs. Participant Support is not a normal account classification Highly recommended that separate accounts, sub-accounts sub-task or sub-ledgers be established accumulate these costs. Should have written policies & procedures

June 8-11, 2009Joint Annual Meeting Human Resource Development Participant Support Costs Typically excluded by NSF from application of the indirect cost rate Participant support eligibility- – what did participants have to do to receive the payment Documentation of attendees at conferences or workshops Reference: GC-1, Article 7; A-21, J.17 and J.48

June 8-11, 2009Joint Annual Meeting Human Resource Development Consultants Members of particular profession or possess certain skill; Technical advice & support –work under awardee organization’s direction –generally not responsible for a deliverable Reasonableness of consultant rate of pay –Rates should be comparable to the normal or customary fees charged in relation to the services rendered

June 8-11, 2009Joint Annual Meeting Human Resource Development Consultants Past: Appropriations Acts limited the maximum rate of compensation paid to consultants. Currently: Appropriation Act applicable to NSF contains no limitation on payments to consultants under NSF awards; therefore, eliminating this constraint began with the FY 2006 appropriated funds. However: Funds awarded prior to March 15, 2006 are still subject to the consultant pay limitation Reference: AAG Chapter V. Subchapter B.6

June 8-11, 2009Joint Annual Meeting Human Resource Development Consultant - Agreement Name of Consultant - Business or organization Rate of pay Period of performance Description of service to be provided Cost information on : – indirect costs, travel (per diem rates), supplies other expenses

June 8-11, 2009Joint Annual Meeting Human Resource Development Consultant - Invoice Consultant Name - Organizations Rate charged and time worked - hourly or daily rate Short description of services provided Include all hours – (example - preparation time & response time for speakers)

June 8-11, 2009Joint Annual Meeting Human Resource Development Sub-awards & Sub-Recipient Monitoring Vendor –“off the shelf” technical services Subcontractor –responsible for piece of the work Consultant –provides specific, professional expertise on a project

June 8-11, 2009Joint Annual Meeting Human Resource Development Sub-Awards Characteristics indicative of a Federal award received by a subrecipient : Performance is measured against objectives of the Federal award being met Responsibility for programmatic decision making Responsibility for adherence to applicable Federal program compliance requirements

June 8-11, 2009Joint Annual Meeting Human Resource Development Vendors Payment for goods and services: Provided within normal business operations Many different purchasers Operates in a competitive environment Supplemental to the operation of the Federal program Not subject to compliance requirements of the Federal program.

June 8-11, 2009Joint Annual Meeting Human Resource Development Prime Awardee Sub-award Monitoring Responsibilities Determine Reasonableness of Cost Performs cost or price analysis –Cost Analysis –Price Analysis

June 8-11, 2009Joint Annual Meeting Human Resource Development Prime Pre-award Procedures Ensure that the subawardee: Has the ability to perform both technically and administratively Financial Capable to manage subaward Uses an appropriate indirect cost rate & base Has not been debarred or suspended by Federal Government

June 8-11, 2009Joint Annual Meeting Human Resource Development Flow Through Provisions Audit & access to records Prime awardee – perform on site technical & administrative reviews Cost Principles A-87, A-122, A-21, FAR Administrative Requirements –A-110, A-102 – “The Common Rule” Statutory & Regulatory –COI, human subjects, drug-free workplace, CA-1 Article 8

June 8-11, 2009Joint Annual Meeting Human Resource Development Subrecipient OMB A-133 Audits Receive OMB A-133 audit reports or access Federal Audit Clearinghouse – Resolve those findings that apply to your subcontract, if any

June 8-11, 2009Joint Annual Meeting Human Resource Development NSF Expectations System in place for monitoring subrecipients – “risk based approach” encouraged Evidence University is monitoring subawards Technical, Financial, and Compliance reviews

June 8-11, 2009Joint Annual Meeting Human Resource Development Cost Sharing Line M is the amount subject to audit by OIG New awards issued under the FY07 Appropriation, are not required to meet the Statutory 1%. If cost sharing not required, don’t offer it up. Any cost sharing proposed & accepted under an award prior to the policy change is still required to be provided by the awardee

June 8-11, 2009Joint Annual Meeting Human Resource Development Cost Sharing Must Meet ALL of these Criteria: Verifiable from recipient’s records Not included as contributions for any other federally assisted project or program Necessary & reasonable for proper and efficient accomplishment of project or program objectives Allowable under the applicable cost principles Not paid by Federal Government under another award Provided for in approved budget Conform to provisions of this Circular

June 8-11, 2009Joint Annual Meeting Human Resource Development NSF Cost Sharing Possible Consequences in the Event of Failure to Provide Cost Sharing noted on Line M –Disallowance of award costs –Refunding of award funds –Possible Termination of Award –Serious violations could even result in debarment or suspension

June 8-11, 2009Joint Annual Meeting Human Resource Development Examples of Cost Sharing Audit Findings Accounting System not capturing cost sharing Inadequate documentation Unclear Valuation of In-Kind Donated Contributions Lack of Support for subawardee cost sharing – a subrecipient monitoring issue Failure to complete Annual and Final Certifications for Cost Sharing of $500k+

June 8-11, 2009Joint Annual Meeting Human Resource Development Responsibilities at NSF in resolution of audit findings? NSF management represented by Cost Analysis and Audit Resolution Branch (CAAR) is responsible for resolution of audit findings on audit reports referred for resolution by the Office of Inspector General (OIG) CAAR is involved in the following activities during audit resolution: – experts in interpreting OMB Circulars – coordinate with NSF Program Managers – coordinate with NSF Grants Officers & Specialists – coordinate with NSF Finance Staff

June 8-11, 2009Joint Annual Meeting Human Resource Development Need more information? General information Division of Institution & Award Support –Cost Analysis & Audit Resolution jsp –Policy Office jsp

June 8-11, 2009Joint Annual Meeting Human Resource Development Keys to Success for Awardees Know requirements (read award letter, award terms and conditions, OMB Circulars) Good accounting practices – accumulation & segregation of costs Focus on the objectives of the project/program Document! Document! Document!