June 8-11, 2009Joint Annual Meeting Human Resource Development National Science Foundation Office of Inspector General John P. Cieplak, Investigator Laura.
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June 8-11, 2009 Joint Annual MeetingHuman Resource Development
National Science FoundationOffice of Inspector General
John P. Cieplak, Investigator
Laura Hansen-Rainey, Audit Manager
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
Our Mission
• Office of Inspector General (OIG) – Created 02/10/89 at NSF– Conduct independent audits,
investigations, and reviews of NSF and its programs
– To promote efficiency, economy and effectiveness of internal operations and external programs thereby promoting the integrity of NSF
OIG Performs Its Mission
• Investigations – Allegations–Fraud, waste, and abuse–Violations of federal policy, laws, etc.–Research Misconduct
• Audit – Conduct / Oversee Audits– Internal, external, and A-133 audits
• Outreach – Presentations / Briefing
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
Office of Investigations
• Civil & Criminal Investigations
• Administrative Investigations
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
What We Do With Allegations
• Investigate administrative, civil, criminal allegations–May refer to federal, state, or local
authorities, as well as to NSF–Criminal or civil outcomes –
prosecution or settlements–Administrative outcomes – award
termination, restrictions, debarments
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
Investigative Process
• Allegation received in OIG• Conduct preliminary investigation• Investigate substantive allegations• Report of investigation –
conclusions, recommendations• If appropriate, refer to audit• Work with NSF, DOJ, and awardeeJune 8-11, 2009 Joint Annual Meeting
Human Resource Development
Institutional Responsibilities
• Notify OIG–Of allegations of wrongdoing–Of significant administrative or
financial problems–That affect NSF awards or interests
• Take appropriate remedial actions• Respond to OIG’s requests for records
and information
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
Research Misconduct
• Fabrication – making up data or results & recording or reporting
• Falsification – manipulating materials, equipment or processes, or changing / omitting results, data
• Plagiarism – misappropriation of another’s ideas, words, results
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
Research Misconduct
• Institutions are required to report substantive allegations to OIG
• OIG frequently defers investigation to let institution investigation proceed
• Subjects have substantial due process• Confidentiality is protected• Certain timelines apply
Civil / Criminal Trends
• Purchase card abuses• Poor time & effort documentation• Shifting costs between projects• Failing to contribute cost sharing• Mischarging for budget items
unrelated to award
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
Common Civil/Criminal Issues
• Embezzlement/Theft• Fraud (including mail or wire fraud)• False Statements/Claims• Civil False Claims (treble damages)• Criminal False Claims• Obstruction of Justice
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
Other Investigative Concerns
• Conflicts of interest• Improper influence on peer review• Lobbying with federal funds• Commingling federal & non –
federal funds• Dual Compensation – paid by NSF
and other sources
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
Keys to Success
• Effective Award Management–Know requirements–Focus on research –Good accounting practices–Request & document NSF approvals
• Effective Compliance Programs–Risk assessment & stewardship
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
American Recovery and Reinvestment Act of 2009
• Related to ARRA funds, the Act prohibits reprisals against any non-federal employee for reporting:
• Gross mismanagement; waste; danger to public health or safety; abuse of authority; implementation or use of covered funds; or violation of law, rule, or regulation related to ARRA funds.
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
ARRA 2009
• Institution & contractor employees may submit complaints to OIG
• OIG investigates unless frivolous, no covered $ involved, or another adjudicative proceeding is underway
• Institutions & employers are required to post notice of employee rights and remedies
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
Office of Audit
• Internal Audits• External Audits • A-133 Audits
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
Internal Audits
• Evaluate the internal operations of NSF• Review agency policies and
procedures• Evaluate agency processes• Make recommendations for
improvements
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
External Audits• Financial aspects of institutions
who conduct NSF-funded research
• Review internal controls and compliance
• Audits performed by OIG auditors and/or CPA firms
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
Common Audit Findings
• Unallowable Costs • Award administration• Sub recipient monitoring• Cost sharing
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
Determination of Costs
• Allowable, reasonable, allocable, documented, consistent treatment of costs
• Unsupported costs• Expenditures and/or reimbursements
not properly documented • Time and effort reports not timely, not
signed/certified
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
Unallowable Costs
• Direct charges for costs in the indirect pool
• Overload salary (unless NSF-approved)
• Meals above per diem, alcohol• Expenditures not permitted
under OMB Cost Circulars
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
Award Administration
• Financial Management System• Document participant support per
award• Ensure accuracy and timeliness of
reporting and notifications• Maintain equipment inventory and
document bi-annual counts of federally-funded inventory
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
Subrecipient Monitoring
• Responsible for program and financial oversight
• Ensure award terms / federal requirements are followed
• Assess and monitor subrecipient's capability for managing awards
• Ensure timely and appropriate corrective action
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
Cost Sharing• No federal funds can be used (as a
general rule)• Track cost sharing per award (no
duplication)• Documented and certified (AOR
>$500,000)• Valuation at actual/fair market value• Report annual and cumulative amounts• Both awardee and subawardee cost
sharing
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
A-133 Audits
• Audit of financial statement, internal controls, and compliance with federal requirements
• Required each year when auditee expends $500,000 or more in federal funds
• OIG reviews completed reports for identification of NSF-related findings and questioned costs, and for quality of audit reports
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
Results of A-133 Audits• April 2008 – March 2009
–Reviewed 320 reports –Reports covering $9.4 billion in NSF
expenditures–Less than unqualified opinions for 37
awardees–Auditors disclosed 412 audit findings
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
When Should You Contact OIG?
• Report allegations of wrongdoing• Research misconduct• Financial fraud, theft from NSF or
NSF-funded activities• Violation of research related
regulations, directives, or policy
• Report significant administrative or financial problems
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
When Should You Contact OIG?
• Request an Outreach event or training session
• Questions related to ongoing audits (including A-133 audits) and investigations (but confidentiality restrictions may apply)
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
OIG Outreach• Presentations, Seminars, and On-
Site Visits
• For students, PIs, and administrators• Emphasize education, partnerships,
and lessons learned• Assistance with matters relating to
Investigations /Audits and NSF activities
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
How Can I Contact OIG?• Website: http:///www.nsf.gov/oig/• Outreach website:
http://www.nsf.gov/oig/outreach_all.jsp• E-mail: oig@nsf.gov• US Mail: 4201 Wilson Blvd., Arlington,
VA 22230• Phone: 703-292-7100• Hotline: 1-800-428-2189
June 8-11, 2009 Joint Annual MeetingHuman Resource Development
OIG Liaisons to EHR
• John P. Cieplak jcieplak@nsf.gov 703-292-4976
• Laura Hansen-Rainey lhansenr@nsf.gov 703-292-7302
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