SOURCE: NSF WORK PLAN 2013

What is Audited??….HOT Topics Watching Nationally New regulations or changes to existing law Audit findings at other institutions Review other institution ’ s A-133 reports Keep abreast of agency-specific and program specific audits by reviewing agency OIG reports 2/24/2014UCSF-UCB-Stanford Collaborative Training2

What is Audited??….HOT Topics Follow this link…thanks to our colleague Charlene Blevins, University of Miami….this is the best TOOL for you as a research administrator…to follow what is happening nationally. 2/24/2014UCSF-UCB-Stanford Collaborative Training3

Keeping Abreast of Audits at Other Universities Cornell (NSF) Computer & computer-relatedForeign TravelCost Clerical & Admin in Recharge Ctr.Participant Support University of Santa Barbara (NSF) Summer SalariesCost Transfers Cost SharingUnallowable Costs Florida State University (NIH) Administrative and ClericalEffort Bulk SuppliesService Centers 2/24/2014UCSF-UCB-Stanford Coolaborative Training5

NIH Related Awards NIH Office of Inspector General Indirect Costs Claimed as Direct Costs “We will determine whether colleges and universities have appropriately charged administrative and clerical salaries to federally sponsored grants. SOURCE: DHHS Work Plan 2103 Grantee Compliance We will assess colleges’ and universities’ compliance with selected cost principles issued by OMB A-21. Context-We will conduct reviews at selected colleges and universities on the basis of the dollar value of federal grants received and on input from the HHS operating divisions and the offices of the Assistance Secretaries for Financial Resources and Administration. SOURCE: DHHS Work Plan /24/2014UCSF-UCB-Stanford Collaborative Training6

Highlights of the NSF Audit Plan Detailed Work Plan: Section 2 Determine whether costs charged to NSF awards are allowable, allocable, and reasonable, and in compliance with Federal and NSF requirements. Section 3 Determine NSF findings and questioned costs in A-133 audit reports. Assess the adequacy of selected A-133 audits and determine compliance with the requirements of OMB Circular A /24/2014UCSF-UCB-Stanford Collaborative Training7

What is Happening Now at NSF… Data Analytics Audits The first group were audited using data analytics and extrapolation across the entire NSF award base. The second group (10-12 institutions) is being audited using data analytics but without extrapolation. Stanford is one of Institutions 2/24/2014UCSF-UCB-Stanford Collaborative Training8

What is Data Analytics… “Data analytics is useful in identifying risk at all stages of awards. For example, at the preaward stage, risks would include inflated budgets and conflicts of interest among proposal reviewers. At the active award stage, risks would include unusual burn rates (e.g., expenditures for equipment at the end of an award), excess cash on hand, and no, late, or inadequate project reports. Red flags at the end of an award include multiple post-closeout financial adjustments.” *Source NSF Audit Work Plan /24/2014UCSF-UCB-Stanford Collaborative Training9

What Was the Process? The NSF Contracted the work to a CPA Firm Wanted to complete the audit in 9 months Requested information for 1 quarter to obtain an understanding of our data Then requested 3 full calendars years of data 2/24/2014UCSF-UCB-Stanford Collaborative Training10

What did they ask for? Reconciliation from SU books to the quarterly FFR for 6/30/12 data dictionary, crosswalk of NSF Award ID numbers to University records Crosswalk of University expenditure accounts to NSF Budget Categories Detailed query parameters and methodology used to extract the data System architecture, data models, database schema, data flowcharts describing financial system structure 2/24/2014UCSF-UCB-Stanford Collaborative Training11

What did they ask for? Continued F&A Rate agreements Chart of accounts including description of cost categories University Policies and Procedures for admin and financial management Payroll database P-card database More than 390,000 transactions 2/24/2014UCSF-UCB-Stanford Collaborative Training12

Then the Fun Started Audit Firm studied the data and selected 275 transactions and requested backup documentation (invoices, receipts, journals, Pos, etc). First Round Visited campus for 10 days to engage in interviews with Central Staff and begin looking at documentation Explained the Audit was on High Risk Categories but implied these would not extrapolate to our entire population of NSF expenditures. 2/24/2014UCSF-UCB-Stanford Collaborative Training13

The hits just keep on coming First Round selected only non-salary transactions Areas of High Risk Identified Travel – Foreign, Domestic, Field Trips, Non-STAP Conf Fees (STAP – Staff Training Assistance Program) Equipment – Scientific technical equipment, Fabrications, General Purpose Food – At conferences and meetings, Interpartmental catering charges Consulting, Other Professional Services, Temporary Services, Supplies and Materials Gen Office, Supply charges in round amounts, Participant Support Costs 2/24/2014UCSF-UCB-Stanford Collaborative Training14

More specific questions Travel What was traveler’s role on the award Please explain how this conference was necessary for the award, since it was not included in the proposal. How does this conference benefit the grant? Please explain how this conference was necessary for the award, since it was not included in the proposal. Why was travel removed from the original budget and then billed? Please explain how this was necessary for and benefited the award when the travel occurred on the last 3 days of a five year-award and there was no foreign travel budgeted, and the costs appeared to be initially charged to a non-NSF award. 2/24/2014UCSF-UCB-Stanford Collaborative Training15

More NSF follow-up questions Food NSF OIG Follow-up questions - In accordance with NSF policy, meetings and conferences need to be specifically identified in both the proposal and the budget, can you please identify the meeting in the proposal. In addition meals are only allowed if they are an integral and necessary part of the conference, please describe how these meals are integral and necessary? 2/24/2014UCSF-UCB-Stanford Collaborative Training16

NSF follow-up questions Wait a minute – NSF gives institutions rebudgeting authority Right? 2/24/2014UCSF-UCB-Stanford Collaborative Training17

More specific questions What is the NSF Policy Meetings and Conferences The points below summarize the allowability of various items of cost associated with conferences, symposia, workshops or other meetings supported by an NSF grant. Any costs charged to an NSF grant also need to be reasonable and directly allocable to the supported activity. Meeting and conference costs identified below, are only allowable if such costs are specifically and clearly identified in the proposed scope of work and budget, as modified and approved by NSF. NSF funds are not otherwise to be spent for meals or coffee breaks for intramural meetings of an organization or any of its components, including, but not limited to, laboratories, departments and centers. Meals and Coffee Breaks. When certain meals are an integral and necessary part of a conference (e.g., working meals where business is transacted), grant funds may be used for such meals. Grant funds may also be used for furnishing a reasonable amount of hot beverages or soft drinks to conference participants and attendees during periodic coffee breaks. 2/24/2014UCSF-UCB-Stanford Coolaborative Training18