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


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

Rashawn Farrior, Grants Officer

–Division of Grants and Agreements–Education and Human Resource

(EHR) Team– (703) [email protected]; [email protected]

mailto:[email protected]

mailto:[email protected]


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

[email protected]; [email protected]; [email protected]


Oversight and Monitoring of Federal Awards

• Emphasis on Stewardship of Federal Funds

• Award Monitoring and Business Assistance Program

• Compliance & Common Areas of Concern


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


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)]


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


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


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


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


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


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


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


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


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


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


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)


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


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


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.


Prime Awardee Sub-award Monitoring Responsibilities

• Determine Reasonableness of Cost

• Performs cost or price analysis

–Cost Analysis–Price Analysis


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


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


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

http://harvester.census.gov/sac/


NSF Expectations• System in place for monitoring

subrecipients – “risk based approach” encouraged

• Evidence University is monitoring subawards

• Technical, Financial, and Compliance reviews


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


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


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


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+


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


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


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!

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

Documents

human resource ehr team

dc slide

payroll slide

total effort

management tool slide

award support

activities employee

subrecipient monitoring