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Fiscal Compliance Corner Recent Happenings MRAM Sept 2013

Fiscal Compliance Corner Recent Happenings MRAM Sept 2013. Ted Mordhorst Assistant Director for Post Award Financial Compliance Research Accounting & Analysis. Revisions to NSF Grants Policy. NSF is revising their Proposal and Award Policy Procedure Guide (PAPPG) effective Jan 2014

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Fiscal Compliance Corner Recent Happenings MRAM Sept 2013

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  1. Fiscal Compliance CornerRecent HappeningsMRAM Sept 2013 Ted Mordhorst Assistant Director for Post Award Financial Compliance Research Accounting & Analysis

  2. 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.

  3. 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.

  4. 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.

  5. 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

  6. 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

  7. 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.

  8. 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

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