June 8-11, 2009Joint Annual Meeting Human Resource Development Business Assistance NSF 2009 Joint Annual Meeting June 11, 2009 Washington, DC.

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Business Assistance

NSF 2009 Joint Annual Meeting

June 11, 2009

Washington, DC

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Ask Early, Ask Often!!Pamela Hawkins, Team Leader

Rashawn Farrior, Grants Officer

–Division of Grants and Agreements–Education and Human Resource

(EHR) Team– (703) 292-8210pahawkin@nsf.gov; lfarrior@nsf.gov

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Ask Early, Ask Often!!

Tamara Bowman, Team LeaderRosalind Jackson-Lewis, Project DirectorCharlie Zeigler, Special Assistant–Cost Analysis & Audit Resolution

Branch/Division of Institution and Award Support (703) 292-8244

tbowman@nsf.gov; rjackson@nsf.gov; czeigler@nsf.gov

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Oversight and Monitoring of Federal Awards

• Emphasis on Stewardship of Federal Funds

• Award Monitoring and Business Assistance Program

• Compliance & Common Areas of Concern

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Cost Analysis & Audit Resolution (CAAR) Award

Monitoring & Business Assistance Program (AMBAP)• Approximately 30 site visits per

year, many at EHR organizations –Core Review Areas–Targeted Review Areas

• Desk Reviews

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Compliance & Common Areas of Concern

• Time and Effort Reporting (A-21, J.10)• Participant Support (GC-1, Article 7 &

Award and Administration Guide (AAG) Chapter V. Subchapter B.8

• Consultants (AAG Chapter V. B.6;• A-21.J.37)• Subrecipient Monitoring (OMB A-133, Subchapter

C._51)• Cost Sharing [A-110, _.23(a)]

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Time & Effort Reporting

• System to document and support salary charges to Federal awards

• Time & attendance records vs. Time & effort reports

• Time & Effort Reporting is a Management Tool

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

OMB Circular A-21Time & Effort Reporting

Plan Confirmation

• Initially based on budget or assigned work and then adjusted to actual, if there are modifications

• Includes confirmation statement that the work was performed as budgeted.

After the Fact Activity Reports • Prepared each academic term for faculty

& professional staff. Prepared for other employees at least monthly and coincides with payroll

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

OMB Circular A-21Time & Effort Reporting

• Official records – by academic periods - semester, quarter

• Reasonably reflect activities employee is compensated for

• Encompass both sponsored projects and other activities

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Time & Effort Reports Should Contain:• Employee name or identification code

• Project name / number or account code, total effort that pay period

• Hours or percentage charged to different projects

• Employee or supervisor signature (can be electronic)

• Not determined based on the budget, but developed after the fact, based upon actual activities performed

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Participant Support Costs• Participants or Trainees (not

employees – exception school districts – teacher training)

• Stipends, subsistence allowance, travel, registration fees, copies, tuition

• Funds may not be re-budgeted to other expense categories with out prior written approval of the NSF program officer

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Participant Support Costs• Awardee organizations must be able to

identify participant support costs.• Participant Support is not a normal

account classification• Highly recommended that separate

accounts, sub-accounts sub-task or sub-ledgers be established accumulate these costs.

• Should have written policies & procedures

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Participant Support Costs• Typically excluded by NSF from

application of the indirect cost rate• Participant support eligibility-

– what did participants have to do to receive the payment

• Documentation of attendees at conferences or workshops

• Reference: GC-1, Article 7; A-21, J.17 and J.48

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Consultants

• Members of particular profession or possess certain skill;

• Technical advice & support –work under awardee organization’s

direction–generally not responsible for a deliverable

• Reasonableness of consultant rate of pay –Rates should be comparable to the normal

or customary fees charged in relation to the services rendered

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Consultants • Past: Appropriations Acts limited the

maximum rate of compensation paid to consultants.

• Currently: Appropriation Act applicable to NSF contains no limitation on payments to consultants under NSF awards; therefore, eliminating this constraint began with the FY 2006 appropriated funds.

• However: Funds awarded prior to March 15, 2006 are still subject to the consultant pay limitation

• Reference: AAG Chapter V. Subchapter B.6

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Consultant - Agreement• Name of Consultant - Business or

organization• Rate of pay• Period of performance• Description of service to be provided• Cost information on:

– indirect costs, travel (per diem rates), supplies other expenses

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Consultant - Invoice• Consultant Name - Organizations• Rate charged and time worked - hourly

or daily rate• Short description of services provided• Include all hours

– (example - preparation time & response time for speakers)

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Sub-awards & Sub-Recipient Monitoring

• Vendor –“off the shelf” technical services

• Subcontractor – responsible for piece of the work

• Consultant –provides specific, professional

expertise on a project

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Sub-Awards

Characteristics indicative of a Federal award received by a subrecipient :

• Performance is measured against

objectives of the Federal award being met • Responsibility for programmatic decision

making • Responsibility for adherence to applicable

Federal program compliance requirements

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

VendorsPayment for goods and services:

• Provided within normal business operations

• Many different purchasers• Operates in a competitive environment• Supplemental to the operation of the

Federal program • Not subject to compliance requirements

of the Federal program.

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Prime Awardee Sub-award Monitoring Responsibilities

• Determine Reasonableness of Cost

• Performs cost or price analysis

–Cost Analysis–Price Analysis

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Prime Pre-award Procedures

Ensure that the subawardee:• Has the ability to perform both

technically and administratively • Financial Capable to manage subaward• Uses an appropriate indirect cost rate &

base• Has not been debarred or suspended

by Federal Government

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Flow Through Provisions• Audit & access to records• Prime awardee – perform on site technical

& administrative reviews• Cost Principles A-87, A-122, A-21, FAR• Administrative Requirements

–A-110, A-102 – “The Common Rule”• Statutory & Regulatory

–COI, human subjects, drug-free workplace, CA-1 Article 8

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Subrecipient OMB A-133 Audits

• Receive OMB A-133 audit reports or

• access Federal Audit Clearinghouse–http://harvester.census.gov/sac/

• Resolve those findings that apply to your subcontract, if any

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

NSF Expectations• System in place for monitoring

subrecipients – “risk based approach” encouraged

• Evidence University is monitoring subawards

• Technical, Financial, and Compliance reviews

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Cost Sharing• Line M is the amount subject to audit by OIG

• New awards issued under the FY07 Appropriation, are not required to meet the Statutory 1%. If cost sharing not required, don’t offer it up.

• Any cost sharing proposed & accepted under an award prior to the policy change is still required to be provided by the awardee

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Cost Sharing Must Meet ALL of these Criteria:

• Verifiable from recipient’s records• Not included as contributions for any other federally

assisted project or program• Necessary & reasonable for proper and efficient

accomplishment of project or program objectives• Allowable under the applicable cost principles• Not paid by Federal Government under another

award• Provided for in approved budget• Conform to provisions of this Circular

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

NSF Cost Sharing• Possible Consequences in the

Event of Failure to Provide Cost Sharing noted on Line M

–Disallowance of award costs–Refunding of award funds–Possible Termination of Award–Serious violations could even

result in debarment or suspension

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Examples of Cost Sharing Audit Findings

• Accounting System not capturing cost sharing

• Inadequate documentation• Unclear Valuation of In-Kind Donated

Contributions• Lack of Support for subawardee cost

sharing – a subrecipient monitoring issue• Failure to complete Annual and Final

Certifications for Cost Sharing of $500k+

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Responsibilities at NSF in resolution of audit findings?

• NSF management represented by Cost Analysis and Audit Resolution Branch (CAAR) is responsible for resolution of audit findings on audit reports referred for resolution by the Office of Inspector General (OIG)

• CAAR is involved in the following activities during audit resolution:– experts in interpreting OMB Circulars– coordinate with NSF Program Managers– coordinate with NSF Grants Officers & Specialists– coordinate with NSF Finance Staff

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Need more information?• General information http://www.nsf.gov• Division of Institution & Award Support

http://www.nsf.gov/bfa/dias/index.jsp–Cost Analysis & Audit Resolution

http://www.nsf.gov/bfa/dias/caar/index.jsp

–Policy Office http://www.nsf.gov/bfa/dias/policy/index.jsp

June 8-11, 2009 Joint Annual MeetingHuman Resource Development

Keys to Success for Awardees• Know requirements (read award letter,

award terms and conditions, OMB Circulars)

• Good accounting practices – accumulation & segregation of costs

• Focus on the objectives of the project/program

• Document! Document! Document!