Transcript Circular A-110

Circular A-110
Everything You Didn’t Want to
Know
Purpose of A-110
Subpart C- Post Award
• Establishes uniform administrative
requirements for Federal grants and
agreements awarded to institutions of
higher ed, hospitals, and other non-profit
organizations.
Post Award Requirements
• A-110 Subpart C - Sets standards for financial
and program management of sponsored
research awards in:
FINANCIAL & PROGRAM MANAGEMENT
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Methods for making payments
Cost sharing and matching requirements
Accounting for program income
Budget Revisions
Audits
Allowability of Costs
Establishing Fund availability
Standards for financial
management systems
• Relate financial data to performance data
• Financial system must provide:
– Financial results of each project
– Identification of source & application of funds
– Control & accountability over all funds,
property & other assets
– Comparison of outlays to budget amounts
Standards (cont.)
• Procedures to minimize time between
transfer of funds and disbursement of
funds
• Procedures to determine reasonableness,
allocability, and allowability of costs
• Accounting records supported by source
documentation
Cost Sharing/Matching Funds
Definitions of Cost Sharing
(Matching Funds)
• A commitment made by WSU to fund a
portion of the total cost of a sponsored
agreement. The commitment may be for
direct and/or indirect costs, and may
consist of WSU funds or funds from
outside sources. Matching may either be
classified as voluntary or mandatory.
Either form is a true commitment and
must be fully documented.
Cost Sharing (Match) must meet all
of the following criteria:
In general, same requirements apply to Non-Federal Share as apply to the Federal Share
• Verifiable from recipient’s records
• Not included as Match for any other federally
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funded program
Necessary and reasonable
Allowable under the applicable Cost Principles
Not paid by the Federal Government under
another award
Provided for in the approved budget
Conform to other provisions
Types of Cost Sharing
• Mandatory Cost Sharing
• Voluntary Cost Sharing
• Third Party In Kind Contributions
• Facilities and Administrative (F&A), also
known as Indirect Costs
What Can be Used to Meet Match
Requirements?
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Cash
Third Party Contributions
Unrecovered F&A costs (Indirects)
Contributions of services and property
Volunteer Services (necessary for project)
Other employee services (regular rate +
benefits)
Donated supplies (at reasonable & fair market
value)
Unrecovered Indirect Costs
• May be included as part of cost sharing or
matching only with the prior approval of
the awarding agency.
• Current approved rate agreement is 36%
of Salaries, Wages and Benefits
Audit Procedures for Match
Compliance
• Verify that required Matching Contributions were
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met
Ascertain sources of matching contributions and
verify that they were from an allowable source
Test records to corroborate that value of in-kind
contributions are in accordance with OMB cost
principals
Verify transactions used to match are in compliance
with allowable cost principles
Procurement Standards
PURPOSE:
To establish procedures for procurement
of supplies and other expendable property,
equipment, real property, and other
services
Codes of Conduct regarding Awards
and Administration of Contracts
• Recipients shall maintain written standards
of conduct governing performance of
employees involved
• Cannot participate if conflict of interest
exists
• Cannot accept gratuities, favors, or
anything of monetary value from
contractors, subs, or parties to subgrants
Competition
• Must provide open and free competition
• Contractors that develop or draft specs or
requirements, statements of work,
invitations for bids and/or requests for
proposals are excluded
Required Written Procurement
Procedures
• Recipients must not purchase unnecessary
items
• Determine which procurement methods
are most economical and practical
• Positive efforts to utilize small business,
minority owned firms & women’s business
enterprises, whenever possible
Procurement procedures (cont.)
• Solicitations for goods & services must provide:
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Clear & accurate descriptions of technical requirements
Specify requirements which bidders must fulfill
Describe minimum acceptable standards
Include specific features of “brand name or equal” descriptions
Acceptance of products & services dimensional in the metric
system
– Preference for products & services that conserve natural
resources, protect the environment, and are energy efficient –
when practicable and economicaly feasible
Record retention & access
requirements
• Financial records, supporting
documentation, and statistical records –
Three (3) years from date of submission
of final report
– If litigation occurs – until all litigation or
claims are resolved
• Real Property or Equipment – Three (3)
years after final disposition
Closeout
• All reports (financial, performance, other) must
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be submitted within 90 days after completion
date of award
Unless extension granted, all obligations
incurred must be liquidated within 90 days
Prompt refund of any balances of unobligated
cash advances
Awarding agency to make settlement for any
upward or downward adjustments to costs after
closeout reports received
Closeout (cont.)
• Accounting of real or personal property
acquired with federal funds
• If no final audit done prior to closeout,
awarding agency retains right to recover
disallowed costs resulting from the final
audit
Closeout Does Not Affect:
• Right to disallow costs and recover funds
on the basis of a later audit
• Obligation of recipient to return funds due
• Audit requirements
• Property management requirements
• Record retention