Fiscal Compliance Corner Recent Happenings MRAM Sept 2013 Ted Mordhorst Assistant Director for Post Award Financial Compliance Research Accounting & Analysis
Revisions to NSF Grants Policy NSF is revising their Proposal and Award Policy Procedure Guide (PAPPG) effective Jan 2014 Provides updates to both pre and post-award policies and procedures. Two primary updates to post award are: Added Short term visa costs as opposed to long term visa (immigration) as a potential allowable cost Clarify that Participant support costs are exempt from F&A ppg_june2013.pdfhttp:// ppg_june2013.pdf.
From the COGR June Meeting Report Some institutions have found that DOJ, NIAID and DOE Golden Colorado are requiring “vendor” contracts to be treated the same as a sub-contract for F&A purposes. They allow for F&A on only the first $25K of a vendor contract.
Dept. of Education food purchase policy In a memo issued in May 2013 the DOEd provides an extensive Q&A related to food purchases. posbul/gposbul.html This and other federal agency information related to food purchases policies have come under scrutiny as a result of GSA reports on extravagant retreats and conferences sponsored by federal agencies.
Dept. of Education - food purchase Provides examples of “technical Information” Specifies a “very high burden of proof” that the cost is “necessary to meet the goals and objectives of the grant” Disallows food costs “buried” in the hotel bill More good information not just for DOEd but all federal awards
Audit Developments NSF Audit – Questioned costs of $6.3 million including: $2.8 million because cost share commitment was not fulfilled $1.9 million because NSF faculty salary limitation (2 months) was not followed. $496K inadequate justification on cost transfers $440K unsupported costs
Audit Developments NIH Audit – Questioned costs of $1.4 million including: $7.9K inadequately supported salary transactions $329 in admin/clerical costs $950 in Office supplies $400 unsupported costs Auditor cited internal control weakness and extrapolated these findings to the institutions entire NIH portfolio and came up with $1.4 million in unallowable costs for the institution to repay.
Late breaking news NIH is changing their process for requesting payments on grants beginning October 1, Impacts : Early non-competing cycle & reissuance of new award ( New budget # ) Final financial reports Additional reports for SNAP awards due 90 days after end (strictly enforced) Subcontractors need to get invoices in by due date. Budget closeout ( Final action date strictly enforced )