1. E-Verify
Julia Puntenney

2. E-VERIFY
E-VERIFY Employment Eligibility Verification

3. E-VERIFY
FAR Clause
Applicable only to federal and subfederal contracts
Listed in contract terms and conditions

4. E-VERIFY
Employees assigned to the contract. For each employee assigned to the contract, the Contractor shall initiate verification within 90 calendar days after date of contract award or within 30 days after assignment to the contract, whichever date is later.

5. E-VERIFY
Employee assigned to the contract means an employee who was hired after November 6, 1986

6. E-VERIFY
All UA employees who began work prior to November 6, 1986 are exempt
UA E-Verifies all new and rehired employees since January 1, 2008
For employees that are assigned to contracts with FAR and their hire date falls between 11/6/86 and 1/1/08 E-Verification is required

7. E-VERIFY
SPCS reviews all new fed/subfed contracts for clause
Flag Account Name
Review personnel in budget / Workforce Systems to request I-9s as needed
Fiscal Officer Dear Fiscal Officer, The above referenced contract includes the E-Verify clause (FAR )  When the E-Verify clause has been included in a contract, the University is required to E-Verify all employees assigned to the contract.  Sponsored Projects Services will perform an initial review of employees listed in the budget and a periodic review of employees paid from the account.  A list of employees who require E-Verify will be sent to Workforce Systems.  Workforce Systems will notify departments if an I-9 is required to perform the E-Verify.  Please provide I-9’s to Workforce Systems as soon as possible if you are contacted.  Additional information regarding E-Verify as it applies to federal contracts may be viewed at the U.S. Citizen and Immigration website: Thank you for your cooperation.  Please feel free to contact me with any questions.

8. E-VERIFY
Please ensure E-verification for employees assigned to contracts that contain FAR
Can affect approval of:
Salary Expense Transfers
Effort Reports
Supplemental Compensation
Retro Pay

9. NSF Audit Lessons Learned
Marcel Villalobos, Tara Gonzales, Tabatha Holan

10. Objectives
Evaluating risk level of expenditures
Understanding how to properly justify and document
Being able to apply knowledge to real cases

11. Scope of Audit
Purpose: Are costs charged to NSF projects allowable, allocable, reasonable, and in conformity with NSF and Federal terms and conditions?
Period: 1/1/2012 to 12/31/2014
Total Cost: $140 million direct costs across 772 projects.
Contracted Firm: Moss Adams
We received the NSF OIGnotice on February 2015

12. Allowability Reasonable Allocable Conforms to terms Consistent
Necessary
Arm’s length bargaining: a transaction in which the buyers and sellers act independently of each other and have no relationship to each other.
The prudent person test: a sound business decision made by a prudent person under the circumstance prevailing at the time.
Allocable
Incurred specifically for a project
Chargeable or assignable to a project in proportion to the benefit received
Reasonable allocation basis without undue effort or cost
May not shift costs to eliminate deficit or for convenience
Documentation
Conform to limitations or exclusions set by laws, regulations, terms of an award, and policies.
Consistently treated under similar circumstance

13. What is a High Risk Cost? OIG Methodology Data Analytics & Risk Based

14. Questioning of Costs
Review of costs against NSF and Federal terms and conditions
Evaluate justification in the proposal and/or purchase documentation
Require additional justification from fiscal officer and investigator

15. Questioned Costs Overtime General Rebudgeting Late Cost Transfers
> 120 Days
After End Date
Equipment not Budgeted
Purchases near term
Computers
Equipment
Relocation Costs
Travel
During a period with no payroll
Allocated to multiple awards over long period
Foreign
Excessive PI travel to workshops/conferences

16. Lesson Learned
Expenditures on Federal projects must be supported by a business purpose.
It can either be in the proposal budget justification, or accompany the transaction in Financials.
The level of documentation should scale with the level of risk of the cost.

17. Outcome
250 Transactions
Nine Preliminary Findings, Down to Five Findings in Moss Adams audit report
One Management Note {

18. Findings
Compassionate leave
Subaward without prior approval
Pre-award costs outside of 90 days
Travel charged to the wrong award
Campus rec fees for student participants

19. How do we Compare?
University of Southern California $639,479
University of Kansas Center for Research $172,030
Georgia Tech Research Corporation $62,009
University of Arizona $56,904
*Figures include direct and F&A costs

20. Thank You!