1. Fiscal Compliance Corner Recent Happenings MRAM Sept 2013 Ted Mordhorst Assistant Director for Post Award Financial Compliance Research Accounting & Analysis

2. 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 http://www.nsf.gov/bfa/dias/policy/papp/papp14_1/draftpa ppg_june2013.pdfhttp://www.nsf.gov/bfa/dias/policy/papp/papp14_1/draftpa ppg_june2013.pdf.

3. 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.

4. Dept. of Education food purchase policy In a memo issued in May 2013 the DOEd provides an extensive Q&A related to food purchases. http://www2.ed.gov/policy/fund/guid/g 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.

5. 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

6. 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

7. 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.

8. Late breaking news  NIH is changing their process for requesting payments on grants beginning October 1, 2013.  Impacts :  Early terminations @ 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 )  http://grants.nih.gov/grants/guide/notice-files/NOT-OD-13-112.html http://grants.nih.gov/grants/guide/notice-files/NOT-OD-13-112.html