omb circular a110 presented by ann holmes and toni lawson january 11 2006
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OMB Circular A110 Presented by Ann Holmes and Toni Lawson January 11, 2006. You will. …learn about pre-award requirements contained in A110 …explore the federal rules governing cost-sharing …learn UM’s government property control procedures …explore A110 post-award requirements .

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you will
You will...
  • …learn about pre-award requirements contained in A110
  • …explore the federal rules governing cost-sharing
  • …learn UM’s government property control procedures
  • …explore A110 post-award requirements
omb circular a 110 uniform administrative requirements
OMB Circular A-110Uniform Administrative Requirements
  • Maximum requirements from the government
  • Minimum standards for institutions
  • Federal agencies implement
a110 emphasizes
A110 Emphasizes
  • Definitions
  • Systems
  • Written Procedures
omb circular a 110 uniform administrative requirements5
OMB Circular A-110Uniform Administrative Requirements
  • Subpart A General
  • Subpart B Pre-Award Requirements
  • Subpart C Post-Award Requirements
  • Subpart D After-the-Award Requirements
subpart a general
Subpart A: General
  • Purpose
  • Definitions
  • Effect on other issues
  • Deviations
  • Sub-awards
a110 purpose
A110 Purpose:
  • “Sets forth standards for obtaining consistency and uniformity among Federal agencies in the administration of grants to and agreements with institutions of higher education…”
definition grant
Definition: Grant
  • Purpose is to transfer money, property, services or anything of value to recipient in order to accomplish a public purpose
    • No substantial involvement anticipated between government and recipient
definition cooperative agreement
Definition: Cooperative Agreement
  • Purpose is to transfer money, property, services or anything of value to recipient in order to accomplish a public purpose
    • Substantial involvement anticipated between government and recipient
definition contract
Definition: Contract
  • Purpose is to acquire property or services for direct benefit or use of the federal government
    • Very restrictive
    • No expectation of cost sharing
other transaction agreement
Other Transaction Agreement
  • Appropriate agreement to be used when government decides it has sufficient cause to make an award not subject to the standard terms and conditions used for one of the other types of agreements
  • Currently, only DoD and DHS have authority to issue. Can be a problem!
assistance vs procurement
Assistance Vs. Procurement
  • Assistance - generally, what the proposer wants to do. Awards are either grants or cooperative agreements
  • Procurement- generally, what the government buys [can include research]. Awards are contracts
aspects of a110
Aspects of A110
  • Effect on Issues
    • No agency can impose rules that are in conflict with A-110
  • Deviation
    • OMB can grant exceptions in unusual circumstances
  • Subawards
    • A-110 applies to any subrecipients performing work under an award
subpart b pre award requirements
Subpart B: Pre-Award Requirements
  • Pre-award policies
  • Forms for applying for Federal assistance
  • Special award conditions
  • Certifications and representations
pre award policies
Pre-Award Policies
  • Agency decides what type of funding instrument
  • Federal agencies must notify public of funding opportunities (RFP, RFQ, Federal Register, program announcements)
components of subpart b
Components of Subpart B
  • Forms
    • Federal agency specific
    • SF 424
  • Special Award Conditions
    • If previous problems, agency can impose additional requirements
  • Certificates & Representations
    • Must be submitted annually
subpart c post award requirements financial and program management
Subpart C: Post-Award Requirements: Financial and Program Management
  • Standards for financial management systems
  • Payment
  • Cost sharing or matching
  • Program income
  • Revision of budget and program plans
  • Non-Federal audits
  • Allowable costs
  • Period of availability of funds
aspects of subpart c
Aspects of Subpart C
  • Written procedure for determining the reasonableness, allocability and allowability of cost
  • Accounting records that are supported by source documentation
c 21 financial program management
C.21 Financial & Program Management
  • Accurate, current and complete disclosure of each project
  • Records that identify source & application of funds
  • Effective control over & accountability for all functions, property & other assets
c 22 payments
C.22 Payments
  • Advances
  • Reimbursements
  • Forms
c 23 cost sharing
C.23 Cost Sharing
  • Cash: the recipient\'s cash outlay; contributions under the direct control of the recipient.
  • In-Kind: value of non-cash contributions provided by non-Federal third parties.
third party in kind what qualifies
Third Party In-kind: What Qualifies?
  • Webster’s Definition: “with goods or produce rather than money”
    • Volunteer Services
      • Based on rates paid for similar work
      • Associated Benefits
      • * can not include F&A see A-110 c23(e)
    • Donated Equipment & Supplies
      • At current fair market value
cash contributions what the university pays
Cash Contributions“What the University Pays”
  • A-110 Definition: “the recipient’s cash outlay, including money contributed to the recipient by third parties.”
    • Salaries & benefits of University employees
    • University purchased equipment
    • Facility & Administrative costs on the above
    • Waived F & A Costs (with permission of the sponsor)
sources of cash contributions
Sources of “Cash” Contributions
  • University unrestricted funds contributed to project:
    • State funds
    • Gift accounts
    • Endowment funds
    • F&A recovered and returned to departments (i.e. DRIF)
    • Program income
c 23 requirements for cost sharing
C.23 Requirements for Cost Sharing
  • Verifiable from the recipient’s records
  • Not included as contributions for any other federally-assisted program
  • Necessary & reasonable for accomplishment of the project
c 23 requirements for cost sharing26
C.23 Requirements for Cost Sharing
  • Allowable under A-21
  • Have not been paid by the federal government under another award
  • Provided for in the approved budget
more cost sharing
More Cost Sharing
  • Conform to other provisions
    • Unrecovered F&A cost may be included only with prior approval
    • Donated supplies and volunteer services values consistent with market rates
c 24 program income
C.24 Program Income
  • Must be reported to the government
  • Must be used in one of the following ways:
      • Added to funds committed to the project
      • Used to finance the non-federal share of the project
      • Deducted from the total cost to determine net allowable costs
c 25 revision of budget or program plan
C.25 Revision of Budget or Program Plan
  • Required to report deviation from budget & program plans
  • Request prior approval for:
      • Change in scope
      • Change in key personnel
      • Absence for more than 3 months or 25% reduction in time
      • The need for additional funding
c 25 e expanded authorities
C.25 (e) Expanded Authorities
  • Agencies can waive cost-related and administrative prior approvals for:
      • Pre-award Costs (90 days prior to award)
      • One-time 12 month extension
      • Carry forward of balances
federal demonstration partnership fdp
Federal Demonstration Partnership (FDP)
  • Purpose-to reduce administrative burdens to maximize research productivity
  • Mission-to demonstrate that accountability can be maintained while simplifying research administration
federal demonstration partnership fdp32
Federal DemonstrationPartnership (FDP)
  • Phase IV FDP includes 90 universities and research organizations
  • 10 Federal Agencies
  • Institution representatives include both faculty and administrators (Federal representatives are both grants and program staff)
federal demonstration partnership fdp33
Federal DemonstrationPartnership (FDP)
  • Phase IV includes Initiative to Reduce Administrative Burden:
    • Review of A-21, A-110 and A-133 to reduce burdensome administrative requirement.
    • Efficient & Effective ways to support research
  • Ensures that FDP is involved in implementation of Public Law 106/107
other aspects of subpart c
Other Aspects of Subpart C
  • C.26 Non-Federal audits
    • Recipients are subject to A-133 (requires external non-fed. audit)
  • C.27 Allowable cost
    • Recipients are subject to A-21
  • C.28 Period of availability of funds
    • A recipient may charge to the grant only costs…incurred during the funding period
c 30 37 property standards
C.30 -.37 Property Standards
  • Insurance coverage
  • Real property
  • Federally-owned and exempt property
  • Equipment
  • Supplies and other expendable property
  • Intangible property
c 31 insurance coverage
C.31 Insurance Coverage
  • Coverage on Contractor Acquired equipment must be equivalent to coverage on state-owned equipment
  • Coverage is not needed for Federally-owned property unless it is written in the award
c 32 real property
C.32 Real Property
  • Land, land improvements, structure
c 33 federally owned property
C.33 Federally-Owned Property
  • Tangible property acquired with federal funds or on loan from a federal agency
  • Title to federally-owned equipment vests with the government
c 33 exempt property
C.33 Exempt Property
  • Tangible property acquired with federal funds
  • Title to exempt property vests with UM
c 34 equipment
C.34 Equipment
  • Nonexpendable, tangible personal property having a useful life greater than one year
  • Acquisition cost of $5,000 or more
c 35 supplies and material
C.35 Supplies and Material
  • Property to be consumed or expended in performing a project
  • Deliverable items or attached to an end item
  • Assemblies, components, parts, raw and process materials, small tools
  • Acquisition cost of less than $5000
property control
Property Control
  • UM is required to establish and maintain a system for managing and accounting for government property purchased with government funds or on loan from the Federal Government.
  • Contracts - FAR sec 52 & 45
  • Grants - A-110, Subpart C
federal government concerns
Federal Government Concerns
  • What types of equipment does UM have in its possession?
  • Is it required for the contract/grant performance?
  • Is the equipment only used as authorized?
  • Is proper care taken to protect the government\'s interest?
  • Is it properly accounted for? (Tagged?)
acquisition of federal property
Acquisition of Federal Property
  • UM comes into possession of government property from…

...Internal - Contract/Grant acquired property, funded using a UM purchase order.

...External - Furnished or loaned by government agencies using written agreements

government furnished or loaned property
Government Furnished (or loaned) Property
  • UM is responsible to account for all
  • Government furnished property.
    • …Dept. must notify Inventory Control about all Govt. furnished property of any value when it arrives.
    • …When property value is $5,000 or more Dept. staff must manually input the item into FFX Fixed Asset System.
equipment title
Equipment Title


1. Transfer

2. Donation

3. Abandon



Title vests with

the Government


1. Transfer

2. Donation

3. Abandon

Contractor’s Acquired


Title vests

with UM or Government

government property audits
Government Property Audits
  • The Government may audit the University’s property control system as frequently as conditions warrant.
  • A-133 Audit Sampling
  • ONR on-site visit every 2 years

Rating - Satisfactory or Unsatisfactory

  • Physical Inventory
c 36 intangible property
C.36 Intangible Property
  • Includes trademarks, copyrights, patents, patent applications
    • Recipient may retain ownership of any work developed under an award
    • Federal agencies receive the right to use the results for their internal purposes
c 40 48 procurement standards
C.40-.48 Procurement Standards
  • Recipient responsibilities
  • Codes of conduct
  • Competition
  • Procurement procedures
  • Cost and price analysis
  • Procurement records
  • Contract administration
  • Contract provisions
procurement standards
Procurement Standards
  • C.42 Codes of Conduct
    • No favors or anything of monetary value
  • C.43 Competition
    • To extend practical, open and free competition
c 44 procurement procedures
C.44 Procurement Procedures
  • Avoid purchasing unnecessary items
  • Must analyze lease vs purchase for savings
  • Solicitations for goods & services must give clear & accurate descriptions
c 44 procurement procedures52
C.44 Procurement Procedures
  • Efforts shall be made to use small minority & woman owned business
  • Procurement instrument (fixed price, cost reimbursable) must be in the best interest of the project
c 44 procurement procedures53
C.44 Procurement Procedures
  • Contracts must be made with responsible contractors who have the ability to perform the work
  • Recipient must make available all procurement documents including invitation for bids & cost estimates
other aspects of procurement
Other Aspects of Procurement
  • C.45 Cost and Price Analysis
    • Must be analyzed & documented
  • C.46 Procurement Records
    • Basis for contractor selection
    • Justification for lack of competitive bids (sole source)
    • Basis for award cost
c 51 reports and records
C.51 Reports and Records
  • Performance reports are required annually and are due 90 days after grant year
  • Final reports are due 90 days after expiration
  • Monitor sub-recipients
c 52 financial reporting
C.52 Financial Reporting
  • Recipients must use a form SF-269 or 272 to report the status of funds
  • Each agency can determine frequency of financial reports
c 53 retention and access requirement
C.53 Retention and Access Requirement
  • Financial record, supporting documents, statistical records and all other records... must be retained for 3 years.
  • FOIA- (Freedom of Information Act)
  • Access to data may be requested by federal agencies.
c 61 termination
C.61 Termination
  • Awards may be terminated in whole or in part if :
    • The recipient materially fails to comply with terms & conditions
    • If the Federal Government and recipient mutually agree to terminate
    • The recipient notifies the Federal Government of termination
c 62 enforcement
C.62 Enforcement
  • If a recipient fails to comply with terms
    • Withhold cash payments
    • Deny use of funds & applicable matching credit for all/part of cost
    • Suspend or terminate the award
    • Withhold future awards
    • Other legally available remedies
        • Debarment & suspension
subpart d 71 close out procedures
Subpart D.71 Close-Out Procedures
  • Financial and performance reports must be submitted within 90 calendar days
  • The recipient must refund any advances or payment not authorized
  • The recipient must account for any property acquired with Federal funds or received from the Federal Government
other aspects of subpart d
Other Aspects of Subpart D
  • D.72 Subsequent adjustments and continuing responsibilities
  • D.73 Collections of amounts due
all subcontracts must include
All Subcontracts Must Include...
  • Equal Employment Opportunity Act
  • Copeland “Anti-Kick Back” Act
  • Davis-Bacon Act (Prevailing Wage)
  • Contract Work Hours & Safety Standard
all subcontracts must include63
All Subcontracts Must Include...
  • Rights to Inventions
  • Clean Air Act
  • Byrd Anti-Lobbying Amendment
  • Debarment And Suspension
  • Ann Holmes

Director of Finance & Administration, CASL

[email protected]


  • Toni Lawson

Associate Director, ORAA

[email protected]