Fiscal Compliance Corner Recent Happenings, etc. MRAM March 2015 Ted Mordhorst Director for Post Award Financial Compliance Research Accounting & Analysis

OMB Uniform Guidance 2 CFR 200  Cost Principals  Basic Principals have not changed  Allowable (not unallowable in regulation or award)  Allocable (provides a direct benefit to the project and is Necessary or Essential to the objectives of the award)  Reasonable (a prudent person would accept as allowable & allocable)  Consistent treatment (not otherwise recovered in the F&A rate)

OMB Uniform Guidance 2 CFR 200  Specific costs added or changed  Computing devices (desktops, laptops, tablets, smartphones, etc.)  Essential and allocable to but not solely used on the project.  Child care costs related to conferences  Specific to Conference grants or other grants hosting a conference  Identifying child care resources is allowable  Paying for child care is unallowable

OMB Uniform Guidance 2 CFR 200  Specific costs added or changed  Participant Support Costs ( exempt from F&A )  paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training projects  Requires sponsor approval  Child care costs related to conferences  Specific to Conference grants or other grants hosting a conference  Identifying child care resources is allowable  Paying for child care is unallowable

OMB Uniform Guidance 2 CFR 200  Specific costs added or changed  Direct Billing of Administrative/Clerical Salaries  integral to a project or activity  requires sponsor approval  individuals specifically identified with the project or activity  Publication and printing costs  May incur costs anytime before closeout  Must be paid before federal closeout

OMB Uniform Guidance 2 CFR 200  Specific costs added or changed  Short Term Visa Costs  Travel visa costs as opposed to immigration visa costs  Must be critical and necessary to the project  Value Added Tax (VAT)  Legally required to pay in country are allowable

OMB Uniform Guidance 2 CFR 200  Prior approval requirements: (2 CFR )  Encouraged to seek prior approval for cost items when it is difficult to determine reasonableness and/or allocability.  A help document has been published which describes the various prior approval requirements under the UG. 

Graduate Student Compensation NIH  GIM 30 (  NIH will not fund a GA for more than the NRSA -0- level post-doc stipend amount.  GA compensation is defined as Salary + Fringe Benefits + Tuition.  Unreasonable to compensate a Graduate Student at a rate that exceeds what a post-doc is paid.

Graduate Student Compensation NIH  NIH does allow rebudgeting to pay a Graduate Assistant (GA) more than was funded  Rebudgeting to pay a GA up to the salary level paid to a first year post doc in your department  Post-doc compensation is defined as salary and fringe benefits

Audit News NSF Data Analytics Audit Second Round Targeted: Food and gift type transactions Transactions at or near the end of the award period Cost Transfers (salary and non-salary)

NSF Data Analytics Audit  Questions:  Please explain why this equipment was not included in the NSF proposal budget.  How did this equipment purchase benefit the award given the limited time remaining on the award?  Was this equipment used exclusively on this NSF award?

NSF Data Analytics Audit  Questions:  Please provide the allocation methodology and a list of the other projects in the allocation.  Why was this purchase required when you indicated that you had all the necessary equipment and/or facilities?  Please provide the reason for the transfer and why it was necessary so late in the award.

NSF Data Analytics Audit  Questions:  Please explain why this purchase was necessary for and how it benefited the award.  What was the budget amount and the remaining balance at the time of the transfer?

NSF Data Analytics Audit These questions demonstrate the type of documentation/justification you should be keeping to support transactions posting to sponsored projects. They also provide insight into what should be considered before incurring an expenditure or processing a cost transfer.

NSF Data Analytics Audit These questions demonstrate the type of documentation/justification you should be keeping to support transactions posting to sponsored projects. They also provide insight into what should be considered before incurring an expenditure or processing a cost transfer.

Final thought  Both in the UG and in the audit there is an increased emphasis on “necessary”, “essential” and “integral” to define when a cost is allowable.  It behooves us to think in these terms when processing transactions

QUESTIONS?