Presentation on theme: "Fiscal Compliance Corner Recent Happenings, etc. MRAM August 2014 Ted Mordhorst Director for Post Award Financial Compliance Research Accounting & Analysis."— Presentation transcript:
Fiscal Compliance Corner Recent Happenings, etc. MRAM August 2014 Ted Mordhorst Director for Post Award Financial Compliance Research Accounting & Analysis
OMB Uniform Guidance (Omni-Circular) Published in Dec. 2013 with an effective date of Dec 26, 2014. 2 CFR 200 Applies to new funds. Implication is that two sets of rules will apply for a while: A-110/A-21 for existing awards made prior to Dec 26 th Uniform Guidance/ Agency implementation regulations for new awards/funds
OMB Uniform Guidance We have a team of Subject Matter Experts working on this: Members from Central offices and Departments Draft changes to policy due by Sept 30th. Will share with University community for feedback.
OMB Uniform Guidance Awaiting Agency implementation plans Discussions are underway with OMB concerning the dual regulation application and other troubling clauses such as: Small purchase threshold of $3K above which some evidence of comparison of other vendors has taken place. (competitive bid?) Closeout within 90 days of end date.
OMB Uniform Guidance Changes to UW Policies and Procedures Potential some new GIMs Internal Controls Subrecipient Monitoring Transfer of Residual Balances (Fixed Price awards) Equipment
OMB Uniform Guidance Changes to UW Policies and Procedures Revisions to existing GIMS 7 - Subcontracts for Research 10 – Significant Financial Interest 13 – F&A rates 18 – Post Award Admin- NIH awards 21 – Cost Sharing 23 – Costing Policy 39 - Closeout
OMB Uniform Guidance Equipment/Computing Devices Under Materials & Supplies: “In the specific case of computing devices, charging as direct costs is allowable for devices that are essential and allocable, but not solely dedicated, to the performance of a Federal award.” Includes desktop, laptops, tablets, etc. with a cost of $2K or less.
OMB Uniform Guidance Administrative & Clerical Salaries “should normally be treated as indirect (F&A) costs. Direct charging of these costs may be appropriate only if all of the following conditions are met:” No change from prior regulation Did delete the reference to “major programs”
OMB Uniform Guidance Administrative & Clerical Salaries (Cont.: The services provided are integral ( essential, necessary )to a project or activity; Individuals can be specifically identified with the project or activity; The costs are explicitly ( leaving nothing merely implied ) included in the budget or have the prior written approval and The costs are not also recovered as indirect costs.
OMB Uniform Guidance Cost Sharing or Matching: “Under Federal research proposals, voluntary committed cost sharing is not expected. It cannot be used as a factor during the merit review of applications or proposals,” But it may be considered if it is both in accordance with Federal awarding agency regulations and specified in a notice of funding opportunity. “Criteria for considering voluntary committed cost sharing … must be explicitly described in the notice of funding opportunity”
Audit News GOOD NEWS! NSF sided with an institution in resolving most audit findings from a recent audit NSF management disagreed with the auditors and allowed over $5 million of auditor disallowed expenses. Most disallowed costs were incurred near the end of the award periods.
Other Audit News Disallowed costs: Items purchased near the end of an award period. Implied that the cost should at the least be allocated based on the use in meeting project objectives. Lack of documentation that supports the allocation decision.