1. Office of Management and Budget (OMB) CIRCULAR A-21 Principles for determining costs applicable to grants, contracts, and other agreements with educational institutions CReATE ver. 05/13 © 2013 Florida State University. All rights reserved

2. OMB Circular A-21 THE PRIMARY ACCOUNTING REFERENCE FOR FEDERAL SPONSORED AGREEMENTS 2

3. DHHS Audit Experience Entrance Conference December 6, 2010 Fieldwork December 6, 2010 – May 26, 2011 Exit Conference May 27, 2011 Draft report received from OIG November 16, 2011 Response to draft submitted January 31, 2012 Final report issued by DHHS OIG July 19, 2012 Response to final report submitted October 9, 2012 Audit Resolution Phase Awaiting DHHS decision on what division will negotiate the final resolution with FSU 3

4. A-21: A Brief History  Originally issued in 1958  Significant changes made in 1996:  Raised threshold for capitalizing equipment to $5,000  Established use of Facilities & Administration (F&A) rate(s) in effect at start of sponsored agreement over life of agreement  Incorporated four Cost Accounting Standards (CAS)  Required educational institutions to submit a Disclosure Statement (DS-2) regarding cost accounting practices  Draft Super Circular issued  Combines 7 circulars into one document  COGR has issued draft response  Responses to OMB due June 2, 2013 4

5. Why talk about OMB Circular A-21? SRS and SRAS employees need to refer to OMB Circulars A-21 and A- 110 (next presentation) on a daily basis Every decision on federally funded agreements is guided by these pronouncements 5

6. A-21: Applicability  To all research and development, training and other work funded with federal funds at educational institutions  Principles used only as guide in pricing of fixed price or lump sum agreements  The Proposal budget on a fixed price agreement is subject to audit for compliance with A-21  Basis for requiring a detailed budget on a fixed price award  Actual expenditures on a fixed price agreement are not subject to audit 6

7. Major Functions Instruction Teaching and training activities Not research training Departmental research Not organized research Not separately budgeted Not considered major function Organized Research Research and development activities Separately budgeted Includes research training 7

8. Major Functions Other Sponsored Activities Programs and projects that are service oriented Not instruction or organized research Examples Head Start program WFSU activities Other Institutional Activities All activities not otherwise classified Dorms Dining facilities F&A costs Specialized Service Facilities 8

9. A-21: Direct Costs identified specifically directly assigned easilyhigh degree of accuracy  Can be identified specifically with a particular sponsored project, an instructional activity, or any other institutional activity, or can be directly assigned to such activities relatively easily with a high degree of accuracy treats incurred for same purpose in like circumstances must be treated as direct costs  Where an institution treats a particular type of cost as direct cost of sponsored agreements, all costs incurred for same purpose in like circumstances must be treated as direct costs of all institutional activities 9

10. Direct Costs – Personnel Costs  Salaries and fringe benefits working on the sponsored project Faculty and other non administrative/clerical and student employees working on the sponsored project Job titles (not all inclusive)  Researcher  Lab Assistant/Researcher  Graduate Research Assistant 10

11. Direct Costs – Non Personnel  Other direct costs: Animals Animal care Audio-visual supplies (chemicals, glassware, etc.) Books and periodicals Specialized & technical svcs Consulting services Lab equipment & equipment maintenance Computer equipment and supplies - research purpose Computer equipment and supplies - research purpose Laboratory supplies Long distance telephone Publication costs Rent & other off-campus facilities costs Scientific reprints Subawards Travel Tuition 11

12. Facilities & Administrative (F&A) Costs common or joint objectives cannot be identified readily and specifically Costs incurred for common or joint objectives and, therefore, cannot be identified readily and specifically with a particular sponsored project, instructional activity, or any other institutional activity 12

13. Computer Purchases Deemed to be “general purpose equipment” per A-21 J18a(4) Generally unallowable as direct charges (J18b(1)) Requires approval in advance by awarding agency Refer to guidance issued in June 2012 http://www.research.fsu.edu/contractsgra nts/documents/ITguide.pdf http://www.research.fsu.edu/contractsgra nts/documents/ITguide.pdf http://www.research.fsu.edu/contractsgra nts/documents/ITguide.pdf http://www.research.fsu.edu/contractsgra nts/documents/ITguide.pdf Included in proposal – adequate justification Included in proposal – adequate justification Not included in proposal – seek approval Not included in proposal – seek approval Prior to purchase Prior to purchase 13

14. A-21: Cost Accounting Standards  CAS 501- Consistency in estimating, accumulating and reporting costs estimating charging reporting  Basis used in estimating costs in proposal budget, charging costs to sponsored agreement and reporting costs to sponsor must be consistent with one another  CAS 502- Consistency in allocating costs incurred for same purpose same purpose like circumstancesdirect costs only or indirect costs only  All costs incurred for same purpose, in like circumstances, are either direct costs only or indirect costs only 14

15. A-21: Cost Accounting Standards CAS 505 - Accounting for unallowable costs  Unallowable costs must be identified in accounting system or identifiable from departmental records CAS 506 - Cost accounting period  FSU’s fiscal year – July 1, xxxx – June 30, xxxx 15

16. A-21: Disclosure Statement  Large educational institutions $25 million per year or more in federally funded awards To cognitive agency (DHHS) for review and approval  FSU Disclosure Statement (DS-2) History Submitted – June 1998 FSU submitted revisions – September 2006, April 2009 and January 2010 Received approval March 2010 Revised capitalization threshold to $5,000 approved with most recent negotiated F&A rate agreement in July 2012 Revised capitalization threshold to $5,000 approved with most recent negotiated F&A rate agreement in July 2012 16

17. Key FSU Practices  Accounting system description: cash basis  Cost accounting period: 7/1 to 6/30  Capitalization of non-expendable tangible personal property $5,000/useful life greater than one year  Treatment of costs – direct and indirect declared 17

18. FSU Policies Related to DS-2 Direct and Indirect Costs of Sponsored Agreements  Issued a policy on Direct and Indirect Costs of Sponsored Agreements Cost Sharing  Issued a policy on Cost Sharing Unallowable Costs of Federally Sponsored Projects  Issued a policy on Unallowable Costs of Federally Sponsored Projects  Policies can be found on Sponsored Research Web site ( http://www.research.fsu.edu )http://www.research.fsu.edu 18

19. A-21 Cost Principles  Allowability Factors Reasonableness Reasonableness Allocability Allocability Consistency of treatment Consistency of treatment Conformity to limitations or exclusions 19

20. Reasonableness 1 - Reasonable Prudent person would have paid the stated amount for the goods/services necessary Cost necessary to accomplish objectives of sponsored award arm’s- length bargaining/Federal & State laws/sponsored award terms & conditions Restraints or requirements imposed by arm’s- length bargaining/Federal & State laws/sponsored award terms & conditions Due prudence Due prudence Consistent Consistent with institutional policies 20

21. Researcher requesting reimbursement for purchase of 1,000 pipette tips from vendor with no price agreement with FSU and paid for with personal credit card. Price paid $.50/tip vs. eMarket vendor cost = $.10/tip. Travel by researcher to Washington to discuss technical issue on sponsored project with sponsoring agency’s program manager. Researcher followed FSU travel rules. Lunch for researcher and department chair at Governor’s Club to discuss courses for next semester. 21 Examples

22. Answers Not reasonable – did not follow institutional policies Reasonable – meets criteria Not reasonable – not research purpose 22

23. Allocability 2 - Allocable Goods or services involved can be charged in accordance with relative benefits received Identifiable Identifiable to a sponsored award solely to advance work Incurred solely to advance work under sponsored agreement Benefits more than one sponsored project or other institutional activity cost must be shared Benefits more than one sponsored project or other institutional activity, the cost must be shared Necessary Necessary for operation of sponsored and/or other institutional activity 23

24. Allocability subsequently Equipment specifically authorized under sponsored agreement, is assignable to sponsored agreement regardless of any use that may subsequently be made 24

25. Allocability - Lab Manager In multi award lab general duties must be allocated across awards on a reasonable basis. Examples, Training of students, other researchers in lab protocols and procedures Animal care that may not be specific to one project Performing or supervising others in the preparation of experiments, equipment maintenance, and lab inventory Staying abreast of animal care developments 25

26. Example – Lab Manager Dr. Gold performs retinal research with zebra fish on 2 R01 NIH awards and conducts some departmental research. Ms. Seminole trains all students in lab techniques and protocols (10%), orders supplies for the lab (5%), cares for the fish colonies (25%), performs experiments assigned by Dr. Gold (60%) How allocate? 26

27. Answer 40% general duties Both R01 grants Non sponsored source for the departmental research % as determined by Dr. Gold 60% directly related to performing experiments allocated (Dr. Gold estimate) 27

28. Example – Salary Charges  Research associate’s salary for month of July 2008 charged to sponsored project for actual work performed on project in January 2008  Research associate’s effort in July 2008 did not pertain to sponsored project  Sponsored project period was 1/1/08 to 12/31/08 28

29. Answer Charge is unallowable because research associate’s effort in July did not benefit sponsored project This practice is referred to as “cost substitution” and does not conform to A-21 requirements 29

30. Allocability – General Lab Supplies In multi award lab general lab supplies (pipettes, gloves, etc.) must be allocated across awards on a reasonable basis. Considerations, Can/will items be used by all awards in lab? Specialized items? Is item used for general lab upkeep? What are the lab supply and ordering practices? Is there non sponsored research occurring in the lab? Length of awards using items? What type of experiments are being conducted? 30

31. Example – General Lab Supplies Dr. Tomahawk performs sense of smell research with rats and has 1 R01 NIH and 2 NSF grants all in the same lab. The aims do not overlap but all of the grants use similar research techniques and equipment. The lab manager requests for purchase 5000 pipette tips ($500), 300 glass test tubes ($150) and 1 gustometer ($6,000) that will be used only on the R01 award. How should the items purchased be charged to each award? 31

32. Answer 1 The pipette tips and test tubes should be allocated to all awards: PI estimate % of usage on each award Charge 100% of gustometer to the R01 award. 32

33. Answer 2 Each researcher works on only 1 award and requests supplies from lab manager monthly: Grad Student A (R01) 2000 pipette tips = $200 Grad Student B (NSF A) 2000 pipette tips 200 test tubes = $300 Grad Student C (NSF B) 1000 pipette tips and 100 test tubes = $150 Charge 100% of gustometer to the R01 award = $6,000 33

34. Allocability – Service Agreements In multi award lab service agreements for equipment must be allocated across awards on a reasonable basis. Considerations, When was the equipment purchased? Source of funding? Source active? What is the equipment used for? What projects require the use of the equipment for the svc agmt period Is there non sponsored research occurring in the lab? Length of awards using items? What type of experiments are being conducted? 34

35. Example – Service Agreement Dr. Tomahawk performs sense of smell research with rats and has 1 R01 NIH (ends 6/30/2012) and 2 NSF grants (both end 12/31/2013) all in the same lab. The aims do not overlap but all of the grants use similar research techniques and equipment. There are 5 centrifuges in the lab. The R01 uses the 3 large centrifuges and the 2 NSF awards use the 2 smaller ones with equal usage. Each service agreement costs $500 for period 1/1/2012-12/31/2012 How should the service agreements’ costs be charged to each award? 35

36. Answer R01 = $750 NSF A = $500 NSF B = $500 Non sponsored source = $750 Total = $2,500  Note rotation among awards generally not acceptable method 36

37. Example – Equipment  Dr. Garnett purchased a microscope costing $10,000 on an NSF-funded project during last month of a one-year grant period. The microscope has a 5 year life.  The microscope was included in the budget approved by the agency.  The equipment was required to complete the analysis phase of research. 37

38. Answer Charge for this equipment is allowable as it was purchased during grant period. Even though equipment had five year useful life and was used only one month of grant period, it conforms to A-21 provision “specifically authorized in grant… regardless of subsequent use”. 38

39. Allocability – Cost Transfer Policy Effective April 1, 2008; revised July 1, 2010 http://www.research.fsu.edu/contractsgrants/ documents/costtranspolicy.pdf http://www.research.fsu.edu/contractsgrants/ documents/costtranspolicy.pdf Expenditure transfers to or between sponsored projects Red flags Frequent transfers Transfers close to end of project Inadequate documentation to support transfer 39

40. Cost Transfers Improper cost transfers Cover overruns Spend available balance close to end of project Transfer of unallowable cost from one project to another Circumvention of award limitation/restriction Charge costs to one project that belong to an award not yet executed  Advance policy enacted for this reason! 40

41. Cost Transfers Allowable transfers Correct erroneous charge Allocate portion of charge that applies to the project (e.g. split purchases) Cost Transfer Justification Form at http://www.research.fsu.edu/contractsgrants/forms.html http://www.research.fsu.edu/contractsgrants/forms.html Must be received by SRAS as follows: Within 90 calendar days from the end of the month in which the error occurred (personnel and non-personnel) Retroactive Distribution of Funding  Moving salary between or onto projects reallocating original ePAF distribution as a result of the effort certified is acceptable justification for salary cost transfers 41

42. Cost Transfers Cost transfers not received by SRAS by deadline will only be approved in extenuating circumstances, which does not include: Absences of PI or project administrators Non qualified staff Shortage of staff SRAS Compliance Committee reviews on weekly basis SRAS Director approves >$25,000 or > 90 days Monthly reconciliations needed to detect and correct errors within established timeframes Controller’s Office offers training: BTFA03 - General Ledger Reconciliation 42

43. Cost Transfers Justifications – what not to say! “Charged to NSF grant waiting for NIH grant to get set up.” “Reconciliations were not performed for 6 months because of support staff turnover.” “There are funds left on Project Aaa and we want to spend the balance. We charged the costs to Project Bee but now that there is funding left so we need to move the costs.” 43

44. Example – Cost Transfers A graduate assistant worked and was paid 50% on grant from US Dept. of Agriculture (USDA) and 50% on grant from National Science Foundation (NSF). Each grant was charged 50% of tuition. Since USDA policy does not permit charges for tuition, the PI requested that the tuition charge be transferred from USDA account to NSF account. Would you approve this cost transfer?? Why or Why not?? 44

45. Answer Tuition charge transferred to NSF account is unallowable because Charge to NSF grant (now at 100%) was not proportional to effort devoted to NSF grant (50%) Transfer was made to avoid restriction of USDA policy. 45

46. Example – Cost Transfers At the start of Fall 2011 semester, Dr. Nole was appointed as follows: E&G funding = 65% NIH P01 award = 20% NSF award = 15% Dr. Nole certified his Fall 2011 effort report as follows: E&G funding = 65% NIH P01 award = 15% (Error occurred <20% paid) NSF award = 20% How do we resolve the effort error?? 46

47. Answer An RDF is required to move 5% from the NIH to the NSF award. Allowable because it “trues” up to actual Meets time criterion because as a result of actual effort IS NOT Requesting the PI to change his/her effort certification “to get rid of the error” IS NOT the solution!!!! 47

48. Cost Transfers - NIH Policy The NIH Grants Policy Statement  Cost Transfers to NIH grants by grantees…should be accomplished within 90 days…  Transfers must be supported by documentation that fully explains how error occurred and certification of correctness of new charge by responsible University official …  Stating that transfer was made “to correct error” or “to transfer to correct project” is not sufficient.  Transfers of costs solely to cover cost overruns are not allowable. 48

49. Cost Transfers - NIH policy  Grantee’s must maintain prescribed documentation of cost transfers and must make it available for audit…  Frequent errors in recording costs may indicate need for accounting system improvements and/or enhanced internal controls.  If such errors occur, grantees are encouraged to evaluate need for improvements and to make whatever improvements are deemed necessary to prevent reoccurrence.  NIH also may require a grantee to take corrective action by imposing additional terms and conditions on an award. 49

50. Allocation & Documentation Standard - Internal Controls  An institution's financial management system must provide that no one person has complete control over all aspects of a financial transaction 50

51. Example – Internal Control  PI (also department chair) prepares TAR for PI’s travel and signs as traveler, PI and PI’s supervisor.  PI prepares travel reimbursement and reconciles departmental accounting records.  Is this appropriate? 51

52. Answer No This would be an unacceptable practice and would not meet the criteria of A-21 FSU’s signature requirements on accounting documents prevents an internal control violation such as this from occurring 52

53. Allocation & Documentation Standard - Applicable Credits  Applicable credits must be applied to related expenditures  Typical examples of applicable credits are: purchase discounts, rebates, or allowances; and adjustments of overpayments or erroneous charges 53

54. Example – Applicable Credits  Lab equipment was purchased in July 2011 for $2,000 on Dr. Gold’s R01 grant that ended September 30, 2011.  In September 2011 it was discovered that the vendor overcharged for the equipment by $500.  A credit was received and the department charged the credit to Dr. Gold’s P01 award because it was the only award open.  Is this appropriate? 54

55. Answer The $500 credit should have been applied against Dr. Gold’s R01 grant that was closed SRAS is supposed to receive all refund checks when related to sponsored projects SRAS is supposed to receive all refund checks when related to sponsored projects Department submits refund form that includes chartfield information where the original charge was posted SRAS verifies chartfields to ensure the appropriate sponsored project is credited even if project is closed 55

56. Limitations on Allowance of Costs  Sponsored agreements may be subject to statutory requirements that limit allowance of costs  When maximum amount allowable under limitation is less than total amount allowed in A-21, amount not recoverable under sponsored agreement may not be charged to other sponsored agreements  Must be funded by a non-sponsored source of funds 56

57. Example – Limitations  PI had an NIH grant and devoted 50% effort to it during month of August 2005 PI’s annual salary rate was $190,000/yr, $15,834/mo Grant period was Feb. 05 to Jan. 06 Grant was charged $7,917 (50% of $15,834) for PI’s August salary NIH had salary rate cap of $180,100/yr or $15,008/mo for 2005 [Current 2012 NIH Salary Cap is $179,700] 57

58. Answer  Costs of $413 are unallowable because the salary charged to the grant exceeded the sponsoring agency’s “rate of pay” limitation  Maximum amount chargeable to grant for 50% effort was $7,504 (50% of $15,008)  The grant should have been charged $7,504 for effort and amount in excess of the NIH cap ($7,917-$7,504=$413) charged to E&G or another unrestricted funding source [Current (2012) NIH Salary Cap is $179,700] 58

59. Cost Accounting Standard 502  CAS 502- Consistency in allocating costs incurred for same purpose same purpose like circumstancesdirect costs only or indirect costs only  All costs incurred for same purpose, in like circumstances, are either direct costs only or indirect costs only 59

60. Cost Accounting Standard (CAS) Exemption Allowable to charge Administrative costs directly to the sponsored project Exceptional Circumstances Exceptional Circumstances Must be approved in advance of charges normally classified as administrative being charged directly to a project Try to handle at proposal stage Try to handle at proposal stage 60

61. Exceptional Circumstances – Definition extensive amount of administrative and/or clerical support goods/services significantly greater than the routine level  If the nature of a sponsored project requires an extensive amount of administrative and/or clerical support or goods/services significantly greater than the routine level provided by an academic department, then the effort is deemed an exceptional circumstance and such costs can be accounted for as direct 61

62. Exceptional Circumstances – Other conditions required  Be specifically identifiable to a particular sponsored project  Meet A-21 requirements for reasonableness, allowability and allocability  Be specified in the proposal budget and approved by the sponsoring agency 62

63. Exceptional Circumstances - Documentation Requirements  CAS Form Complete and submit to SRS  Salaries: Title(s), FTE, and salary amount(s) for the clerical/administrative position(s) What it is about the scope of the project that requires this extensive effort  Other Costs (office supplies, memberships, postage, local telephone, cell phones, etc.): Description and cost of supplies/services What it is about the scope of the project that requires these goods/services to further the research or other sponsored activity 63

64. Exceptional circumstances – Examples  Large, complex programs, such as Clinical Research Centers, program projects, environmental research & engineering research centers & projects that entail assembling & managing teams of investigators from a number of institutions  Projects which involve extensive data accumulation, analysis & data entry, surveying, tabulation, cataloging, searching literature, & reporting, such as epidemiological studies & clinical records  Projects that require making travel & meeting arrangements for large numbers of participants, such as conferences and seminars 64

65. Exceptional circumstances – Examples (cont’d)  Projects whose principal focus is the preparation & production of manuals & large reports, books & monographs (excluding routine progress & technical reports).  Projects that are geographically inaccessible to normal departmental administrative services, such as seagoing research vessels, radio astronomy projects, & other research field sites that are remote from campus.  Individual projects requiring project-specific database management; individualized graphics or manuscript preparation; human or animal protocols; and multiple project-related investigator coordination and communications. 65

66. Example - CAS Exemption Professor Washington is awarded a $5,000,000 (5 year) grant to coordinate Medical teams from all Florida universities to train medical professionals on new geriatric caretaking techniques. Training meetings are to be conducted 4 times per year at different locations across the state. Professor Washington is requesting a CAS exemption for two administrative positions to coordinate the training teams, organize training conferences including travel arrangements for the University teams and to do outreach to the bring/entice the professionals to participate in the training. These positions were included in the budget approved by the agency. Approve or Deny???? 66

67. Example - CAS Exemption Professor Adams is awarded a $50,000 (1 year) grant to write and produce training materials for the US Dept of Education’s early childhood education program. The materials will be used to train childcare professionals. Professor Adams is requesting a CAS exemption to charge $25,000 for printing/reproduction of 1,000 manuals. These costs were included in the budget approved by the agency. Approve or Deny???? 67

68. F&A Costs and Rate Agreement common or joint objectives cannot be identified readily and specifically F&A costs defined as those incurred for common or joint objectives and, therefore, cannot be identified readily and specifically with a particular sponsored project, instructional activity, or any other institutional activity F&A a.k.a. Overhead a.k.a. Indirect Costs FSU negotiates F&A rates with the FSU’s cognitive agency – Department of Health and Human Services (DHHS) Division of Cost Allocation (DCA) Negotiations culminate in a Rate Agreement at http://www.research.fsu.edu/contractsgrants/documents/rateagreemen t.pdf http://www.research.fsu.edu/contractsgrants/documents/rateagreemen t.pdf 68

69. F&A Cost Categories Facilities Building and Equipment Depreciation Interest Operations and Maintenance Library Administration General Administration Departmental Administration Sponsored Projects Administration Student Services Administration 69

70. F&A Rate Development Negotiating cycle is every four years Prepare and submit F&A cost allocation proposal FSU’s current rates negotiated July 2012 Effective through June 30, 2016 aggregate and distribute F&A costs major functions proportions reasonably consistent nature and extent of their use Objective of the F&A allocation proposal is to aggregate and distribute F&A costs to the major functions of the institution in proportions reasonably consistent with the nature and extent of their use 70

71. F&A Rate Application Multiple Rates are allowed: On Campus – comprised of both facility and administrative costs Off Campus – comprised of administrative costs only (26%) Separate functions – rates for instruction, organized research, and other sponsored activity Separate rate for NHMFL at FSU The actual charge to the sponsored project is calculated by multiplying the F&A rate by the distribution base 71

72. Facilities & Administrative Rates Organized Research On Campus 51.3% (52% effective July 1, 2014) Off Campus 26.0% National High Magnetic Field Lab (NHMFL) Rate On Campus 70.0% Off Campus 26.0%

73. F&A Distribution Bases Federal = Modified Total Direct Cost (MTDC) Exclusions: Equipment/capital expenditures Patient care Rent Scholarships/fellowships Subcontract amount > $25,000 Tuition Remission State of Florida = Total Direct Costs (TDC) Exclusion: Tuition Remission 73

74. Example Calculation TDCMTDC Salaries$10,000$10,000 Benefits2,0002,000 Tuition1,0001,000 Materials and Supplies2,0002,000 Equipment5,0005,000 Total Direct Costs $20,000$20,000 F&A Base$19,000$14,000 F&A Rate10%51.3% F&A Amount1,9007,182 Total Project Cost$21,900$27,182 74

75. F&A Costs Recovered The F&A costs recovered by the University from charges made to sponsored projects are placed into the Sponsored Research and Development (SRAD) Fund Presentation on the SRAD recovery and distribution later 75

76. A-21: Selected Items of Cost  A-21 principles must be applied in establishing allowability of cost, whether particular item is treated as direct cost or indirect cost  Fifty-four specific items of costs are addressed in section J.  Other items not specified may be allowable or unallowable  Items specifically stated as “allowable” must meet the “allowability principles” 76

77. Section J. Unallowable Costs Public Relations Alcoholic Beverages Bad Debts Commencement/Convocation Contingencies Entertainment Improvements to land, buildings, or equip that increase value or life (unless prior agency approval) Fines/Penalties 77

78. Section J. Unallowable Costs Goods or Services for personal use Lobbying Losses on other awards Memberships Preagreement/pre award (unless approved by agency) Student Activity Fees (unless specifically provided for in award) 78

79. A-21: Certification of Charges/Payment  Required on financial reports and payment requests  Reads essentially as follows: "I certify that all expenditures reported (or payment requested) are for appropriate purposes and in accordance with the provisions of the application and award documents.“  SRAS requests PI signature on final expenditure report or invoice 79

80. QUESTIONS 80