Transcript NSF Award Monitoring and Business Assistance

NSF Tribal College Workshop
Award Monitoring
& Business Assistance
November 14, 2008
Ask Early, Ask Often!
Name
Title
Contact
Charlie Zeigler
Special Assistant, Cost Analysis &
Audit Resolution
Division of Institution & Award
Support (DIAS); Office of
Budget, Finance & Award
Management (BFA)
[email protected]
(703) 292-4578
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NSF Award Portfolio
• Active award dollars - $19.7 billion
• Active awards – 34,370
• Awardee Institutions – 2,200
• 81% of NSF awards less than $500,000
• Tribal Colleges 39 awards $81,893,262
• Average Tribal College award size $2,099,827 at
22 organizations
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BSF Risk Assessment
• Award Factors – Amount, Type of award
instruments, Sub-awards, Participant Support,
Equipment,
• Institutional Factors – Awardee Type, NSF
Cognizant, Experience
• Previous Monitoring results – OIG Audits, A133, Site Visits, Desk Reviews
• NSF Admin & Program – FCTR, FPR, Special
Payment, Annual Call to Program
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Post Award Monitoring Program
• Business System Reviews – Large Facilities
• Award Monitoring and Business Assistance
Site Visits – CAAR & DGA
• Award Monitoring Desk Reviews – CARRB
contract with Booz Allen Hamilton
• Transaction Testing – DFM contract with
McBride Lock & Associates
• Baseline Monitoring – DGA DACS
• NSF OIG – Audit & Investigations
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Baseline Monitoring
• DGA, DACS, DFM – general NSF business
Systems, automated checks and system edits,
generating awards, continuing increments
• No Cost Extensions, Change in PI, Cost
Sharing, Financial Reporting FCTR-FFR,
Award Terms & Conditions, Approvals
• Program – Annual Reports, Site Visits, MidTerm Review – future funding years 4-5, PI
meetings
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Transaction Testing - DFM
• Contract with McBride Lock & Associates
for Improper Payment Act – Government
wide requirement
• Based on Risk Assessment – Statistical
Sample by category
• FCTR reconciliation between costs reported
and Project Cost Accounting record
• Select Sample transaction – allowable cost
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Award Monitoring Desk Reviews
• Contract with Booz Allen Hamilton
• High and Medium Risk Organizations
• General Management Survey – written policies
and Procedures, Organization Chart, Duties
and Key Personnel, Expenditure Approvals
• Accounting & Financial – Allowable Costs, A133 audit, Project Cost Accounting, Time &
Effort Reporting, Cost Policy Statement (direct
or indirect),
• FCTR Reconciliation
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AMBAP – Site Visits
• High Risk and Program Recommended
• Core Review Modules – General Management,
Accounting & Financial System, FCTR
reconciliation
• Targeted Review Modules – Time & Effort,
Fringe Benefits, Travel, Consultants, Cost
Sharing, Participant Support, Indirect Costs,
Procurement, Subrecipient Monitoring,
Property & Equipment, Program Income,
Final Project Reporting
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Business System Reviews
• Large Facility Office – Research
Platforms, Construction MREFC,
FFRDC, all high risk awards
• Modules or Systems– Award
Management, General Management,
Planning & Budget, Financial
Management, Financial Reporting,
Procurement, Property & Equipment,
Human Resources.
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Audits
• OMB Circular A-133 (Old A-128) requires
Annual Independent Audit if
expenditures of Federal Funds >
$500,000 / year
• Schedule of Federal Financial
Assistance, Compliance, Internal
Control, Transaction Testing
• NSF OIG – Audit and Investigations
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AMBAP Site Visits
• Pre-Site Visit – 4 weeks – Notify awardee and
Coordinate time, Request Documentation, Internal
– PO & Award Review, Analysis, Plan
• Site Visit – 3-4 days - Entrance Conference, Field
Work & Interviews, Exit Conference
• Post Site Visit – 90 days - draft report, Letter to
awardee, Awardee Responds
• Close-out – 10 days - Determination on awardee
response, Corrective action and
• Follow-up - if required
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General Management
• Organizational Structure
• Internal Controls
• Written policies and Procedures and how well
they are followed
• Management Staff & Duties
• Safeguards and crosschecks – segregation of
duties
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Accounting & Financial Sytems
• Management and accounting controls
related to charges on NSF award
• Financial Accounting System
• Project Cost Accounting
• Books of Account – General Ledger,
Project Ledger, Chart of Accounts,
Journals - Receipts, Disbursements,
Purchases
• Unallowable cost accounting
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FCTR Reconciliation
• Billing system and requests for funds
from NSF = Cost shown in award project
accounts
• Established procedures for preparing
requests
• Can reconcile draw downs to
expenditures for the project
• Minimize time to expend if receives
advances
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Time & Effort Reporting
• Policies and Procedures for completing
• Can bill based on budget or estimates, but
• After the Fact Verification of Actual Effort
• Signed by Employee or Supervisor
• First Hand Knowledge of employee
activities (suitable means of verification)
• Accounts for all activities (percentage)
• Generally, prepared at least semi-annually
(faculty)
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Travel
• Written policies and procedures
• Documentation of costs
• Per diem rates or actual
• In-Travel Status (local meals?)
• US Flag Air-carriers
• Premium Airfare
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Participant Support Costs
• Funds budgeted for P/S – requires NSF
PO approval to re-budget
• Account for through sub account code
• Exclude from IDC allocation base
• Documentation attendance eligibility
workshops
• Not Employees – Stipends, Allowances,
other payments
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Procurement
• Written policies and procedures
(purchasing manual)
• Segregation of Duties, Approval Levels,
Authorities
• Sole source Justification, Excluded
Parties, COI
• Cost and Price Analysis
• Required flow down provisions
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Subrecipient Monitoring
• Prime awardee responsible for subawardee (privity of contract)
• Preaward Review – risk assessment
• Subcontract document (clauses and flow
down)
• Monitoring – Technical, Financial A-133
reports
• Special award Conditions
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Property & Equipment
• More than $5,000 and one year useful life
• Scientific not general purpose
• Exclude from IDC calculation
• Records and Inventory
• Title vesting
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Questions?
• Charlie Zeigler
• Cost Analysis & Audit Resolution
• (703) 282-4578
• [email protected]
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