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OVERVIEW OF THE UNIFORM GRANT GUIDANCE Brown Bag Session March 5, 2015 Paul Rylander Controller’s Office.

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Presentation on theme: "OVERVIEW OF THE UNIFORM GRANT GUIDANCE Brown Bag Session March 5, 2015 Paul Rylander Controller’s Office."— Presentation transcript:

1 OVERVIEW OF THE UNIFORM GRANT GUIDANCE Brown Bag Session March 5, 2015 Paul Rylander Controller’s Office

2 Background: Goals of the Controller’s Office Enable compliant grant spending, not restrict it Prevent risk of waste, fraud and abuse Protect the College Provide assistance when questions arise When in doubt: just ask Always better to ask before something is done rather than after 2

3 Background: OMB Federal Office of Management and Budget (OMB)OMB Core Mission: “is to serve the President of the United States in implementing his vision across the Executive Branch” Reports directly to the President Issued Uniform Grant Guidance (UGG) 3

4 Background: COFAR Council on Financial Assistance Reform (COFAR)COFAR Established by the OMB Federal interagency group formed to provide recommendations for grants management Reported to OMB with recommendations for the UGG 4

5 Why does the UGG matter? It is very likely that the UGG will apply to most federal and state grants awarded after 12/26/2014 Multi-year installment grants might use old Circulars (for now) or UGG – check to see Read the grant’s fine print – contained in the grant documents 5

6 The Fine Print A.k.a - terms and conditions The grant documents will contain the terms and conditions Terms and conditions are important because they spell out the agreement – promises made Will point you to the relevant laws, regulations and terms and conditions – promises – that are part of the agreement Important to fully read and have a copy at your fingertips Excerpt from a GAN 6

7 Side Note: The Law of Agency Makes institutions responsible for the acts of their representatives 1 If an authorized agent from this institution signed a valid agreement, the institution is bound to the agreement As an employee of this institution, we are bound to the institution’s agreements Bottom Line: You have to follow the agreement’s terms and conditions, even if you didn’t agree to them personally 7

8 Side Note: Legal Authority ConstitutionStatutesRegulationsTerms and Conditions UGG Adoption 8

9 Uniform Grant Guidance: Applicability It’s just that: Guidance Not binding unless: Awarding agency has adopted Most federal agencies have adopted the UGG in its entirety 2 However, there are agency specific exceptions to the UGG 3 State award could pass along UGG requirements Table of agency codification provided by RI OMB: Exceptions to the UGG highlight the need to check the grant’s terms and conditions COFAR’s UGG Crosswalk 4UGG Crosswalk When in doubt: check with the funding source or the Controller’s Office 9

10 Uniform Grant Guidance: Goals Initiated by the President to “reduce unnecessary regulatory and administrative burdens.” Streamlined Circulars A-21, A-50, A-87, A-89, A-102, A-110, A-122, A-133 Make government more efficient, effective and transparent Focus on improving performance and outcomes Ensure financial integrity Reduce the risk of waste, fraud and abuse 10

11 Uniform Grant Guidance: Overview Subpart A—Acronyms and Definitions Subpart B—General Provisions Subpart C—Pre-Federal Award Requirements and Contents of Federal Awards Subpart D—Post Federal Award Requirements Subpart E—Cost Principles Subpart F—Audit Requirements 11 Grant Cycle

12 Uniform Grant Guidance: Basic Considerations §200.403 Factors affecting allowability of costs. Costs must: §200.403 Be necessary and reasonable Conform to any limitations or exclusions in the grant Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program Be adequately documented 12

13 Uniform Grant Guidance: Basic Considerations §200.453 Materials and supplies costs, including costs of computing devices §200.453 Must be used for the performance of the award Buy the supplies at the beginning, not the end of the grant Do not stockpile. If value of supplies residual inventory > $5,000, the stock must be used on another Federal award or sold. Federal government must be compensated for its share. §200.314§200.314 13

14 Uniform Grant Guidance: Important Changes §§200.1-200.99 contains uniform definitions for federal assistance §§200.1-200.99 Before there were varying definitions across 8 Circulars Now there is one uniform set “Contractor” is the preferred term, not “vendor” Supplies are items < $5,000 – even computing devices COFAR reasoned that the administrative burden for a lower threshold would be too great 14

15 Uniform Grant Guidance: Important Changes §200.112 Conflict of interest §200.112 Must disclose any potential conflict of interest to the awarding agency 15

16 Uniform Grant Guidance: Important Changes §200.113 Mandatory disclosures §200.113 Must disclose, in a timely manner, in writing all violations of Federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the Federal award Failure to disclose could lead to suspension or debarment 16

17 Uniform Grant Guidance: Important Changes §200.205 Federal awarding agency review of risk posed by applicants §200.205 Pre-award review required Grantor required to check federal OMB-designated repositories for eligibility, including any debarments or suspensions, and financial integrity information (e.g., SAM)SAM Could consider risk evaluation for: Financial stability Quality of management systems History of performance in managing grants Reports and findings from audits Applicant’s ability to follow statutory, regulatory, or other requirements 17

18 Uniform Grant Guidance: Important Changes §200.210 Information contained in a Federal award §200.210 Requires important details to be listed in the award When you receive a GAN please forward a full copy to the Controller’s Office This makes reporting and compliance much less burdensome Performance Goals Timing and scope of performance for outcomes must be included the award document Performance reporting required 18

19 Uniform Grant Guidance: Important Changes §200.301 Performance Measurement (metrics) §200.301 Recipient must relate financial data to performance accomplishments Recipients must demonstrate cost effective practices Should be measured and reported in a way to improve outcomes 19

20 Uniform Grant Guidance: Important Changes §200.303 Internal Controls §200.303 Must manage the award “in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award” New requirement to take reasonable measures to safeguard protected personally identifiable information (PII) PII defined in §200.79 – case-by-case assessment200.79 Protected PII defined in §200.82200.82 Name + any of the following: SSN, passport no., credit card nos., clearances, bank nos., biometrics, date and place of birth, mother’s maiden name, criminal, medical and financial records, educational transcripts 20

21 Uniform Grant Guidance: Important Changes Subrecipient Monitoring and Management Applicable if college issues a subaward Distinction between subrecipient and contractor not always clear Determination – Subrecipient or contractor §200.330§200.330 Requirements for pass-through entities §200.331§200.331 Reporting requirements Indirect rate Risk assessment required 21

22 Uniform Grant Guidance: Important Changes §200.414 Indirect (F&A) costs §200.414 Must accept negotiated rate, unless exception applies from: Statute Regulation Agency head or documented justification This requirement applies to state pass-through grants. §200.331(a)(4)200.331 Excerpt from current negotiated rate 22

23 Uniform Grant Guidance: Important Changes §200.415 Required Certifications §200.415 Required certification language strengthened to show statutory consequences “By signing this report, I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise. (U.S. Code Title 18, Section 1001 and Title 31, Sections 3729-3730 and 3801-3812).” 23

24 Uniform Grant Guidance: Enforcement Office of Inspector General U.S. Department of Education Audit Reports Investigative Reports U.S. Department of Labor Audit Reports News Releases National Science Foundation 24

25 Questions? 25

26 Endnotes 1 See generally, Soar v. Nat’l Football League Players Ass’n, 438 F.Supp. 337 (D.R.I. 1975); Lawrence v. Anheuser-Busch, Inc., 523 A.2d 864, 867 (R.I. 1987) (quoting Restatement (Second) Agency § 1(1)). 2 79 Fed. Reg. 76092 Dec. 19, 201479 Fed. Reg. 76092 Dec. 19, 2014 3 E.g., 34 C.F.R. § 75.562 (2015)34 C.F.R. § 75.562 (2015) 4 COFAR, Uniform Guidance Crosswalk for Federal agency Exceptions and Additions, (accessed Mar. 3, 2015). 26

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