1. Uniform Guidance and Grants Accounting
Author: Mariel Diaz
Office of Research

2. Compliance Supplement
Uniform Guidance
Compliance Supplement
A "government-wide framework for grants management" – is an authoritative set of rules and requirements for Federal awards that synthesizes and supersedes guidance from earlier OMB circulars.
The OMB A-133 Compliance Supplement is a large and extensive United States federal government guide created by the Office of Management and Budget (OMB) and used in auditing federal assistance and federal grant programs, as well as their respective recipients.
Uniform Guidance (Link)
Office of Research
Compliance Supplement (Link)

3. Compliance Requirements – Areas of Audit Review
Activities Allowed or Unallowed
Cost Principles
Cash Management
Reserved (Davis-Bacon Act)
Eligibility
Equipment and Real Property Management
Matching, Level of Effort and Earmarking
Period of Performance
Procurement and Suspension and Debarment
Program Income
Reserved (Real Property Acquisition and Relocation Assistance)
Reporting
Subrecipient Monitoring
Special Tests and Provisions
Office of Research

4. Key Focus Areas – Other Review
Administrative Management
Oversight of the sponsored program
Program and fiscal coordination
Policies, procedures and relevant manuals are available to staff
Administrative meetings and minutes documentation
Hiring of qualified staff and provide required training
Adequate resources are available to sustain program operations
Subcontract/consultant management protocols
Fiscal Management
Expenses align with budgets and burn rate for the period
Appropriate procurement methods followed
Expenses incurred within the period
Personnel records – Time and effort
Prior Approvals from sponsor obtained as applicable
Internal controls and approvals
Other special requirements and conditions as per guidelines
Office of Research

5. Cost Principles Allowable Reasonable Allocable Consistently Treated
Handout #1
Cost Principles
Federal Regulations establish principles for determining costs applicable to Awards. The four main principles are:
Allowable
Reasonable
Allocable
Consistently Treated
Office of Research

6. Internal Controls
Means a process, implemented by a non-Federal entity, designed to provide reasonable assurance regarding the achievement of objectives in the following categories:
Effectiveness and efficiency of operations
Procedures
Performance Metrics
Training
Reliability of reporting for internal and external use
Financial Status Reports
Regular Monitoring
Financial Systems
Data Entry and Standards
Compliance with applicable laws and regulations
Policies
Appropriate Approvals
Proper Documentation
Justifications/Explanations
Office of Research

7. Internal Controls - Grants and Contracts
GCA supports adherence to the Uniform Guidance and Audit requirements as follows:
Develop and implement Policies and Procedures
Develop and implement forms with approval workflow
Require support documentation, explanations and justifications as needed
Secure proper financial management
Monitor grant financial performance
Office of Research

8. Examples of Non-Compliance
Inappropriate reasons for bypassing purchasing protocols:
Insufficient time left on the grant to put request through purchasing
Purchased items to spend down balance since grant is ending soon
Purchased on personal card without prior approval because wanted rush delivery
Inappropriate Reasons for Cost Transfers
Cost transfers solely for the purpose of transferring overruns or deficit balances
Cost transfers solely for the purpose of utilizing unexpended funds of a sponsored award
Cost transfers used as a cost management strategy
Cost transfer for any other reasons of convenience
Office of Research

9. Proactive Grant Management – Burn Rate Report
A status summary of the grant portfolio by area which provides current spending and balances. This report is distributed monthly to Department Chairs, Deans and Office of Research Ambassadors.
Review of these reports on a regular basis helps identify:
Potential large balances due to unallocated expenses or budget planning revisions needed.
May also highlight no cost extensions that are needed
Potential accelerated spending that can lead to deficits
Grants in deficit that need to be reconciled
Grants that are ending in the next 90 to 30 days which need to start preparing for closeout including PO closures, subcontract invoicing, expense and labor reallocations to new funding sources, or employee terminations.

10. Proactive Grant Management – Burn Rate Report
Sample Data
Ambassadors can provide reports specific for your PI.

11. Institutional Policies
Resources - Policies
Federal Policies
Institutional Policies
Uniform Guidance Policy
National Science Foundation Policy
National Institute of Health
eRA Commons– For NIH NGAs (agreement notice), Progress Reports and FFR submissions
Office of Research Policies
Official University Policies