Fiscal Compliance CornerRecent Happenings

MRAM Sept 2013

Ted MordhorstAssistant Director for Post Award Financial ComplianceResearch Accounting & Analysis

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/draftpappg_june2013.pdf.

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.

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/gposbul/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.

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

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

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.

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