Transcript Slide 1

2CFR215 (A-110)
Uniform Administrative Requirements for
Grants and Agreements with Institutions of
Higher Education, Hospitals, and Other NonProfit Organizations
Introduction to OMB Circular
A-110
Purpose:
 Establish uniform administrative
requirements;
 Establish consistent application of the
requirements
 Prevent deviations or additional
requirements without OMB approval
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Federal Proposal Considerations:
OMB Circular A-110
Uniform Administrative Requirements for Grants
and Agreements with Institutions of Higher
Education and Other Non-profit Organizations
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Subpart A – General
Subpart B - Pre-award requirements
Subpart C - Post-award requirements
Subpart D - After the award requirements
Appendix A - Contract provisions
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A-110: Subpart A - General

Effect of A-110 on other
issuances
◦ Awards subject to A-110, all
other administrative
requirements codified in
program regulations, manuals,
handbooks inconsistent with
this circular are superseded,
unless required by statute or
authorized by the deviations
provision of this circular

Deviations
◦ Exceptions to A-110 are
permitted in unusual
circumstances by OMB
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Subawards
◦ A-110 should be flowed
down to subrecipients
which are normally
subject to it
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A-110: Subpart B - Pre Award
Requirements
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Purpose:
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Pre Award Policies:
◦ Establishes instructions and forms used in applying for
federal assistance
◦ Agency decides on appropriate award instrument
◦ Grant used when principal purpose is to provide
support to accomplish a public purpose
◦ Cooperative Agreement same as a grant, except
substantial involvement is expected by the awarding
agency
◦ Contract used only when principal purpose is
acquisition of property or services for direct benefit of
Government
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A-110: Subpart B - Pre Award
Requirements (continued)
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Forms Used When Applying For Assistance:
◦ Agencies must comply with 5CFR part 1320 - “Controlling
Paperwork Burdens on the Public”
◦ Applicants shall use SF-424 series, or forms and instructions
prescribed by agency
◦ Programs covered by E. O. 12372 “Intergovernmental Review of
Federal Programs” -- applicants must complete appropriate
sections of SF 424 or if agency not using SF-424, whether E.O.
12372 review is required.
Debarment And Suspension
◦ Agencies and recipients must comply with the non-procurement
common rule
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A-110: (continued)

Special Award Conditions
◦ Additional requirements may be imposed by agencies
if:
 Recipient has history of poor performance
 Recipient is not financially stable
 Recipient has management system that does not meet
standards
 Recipient has not conformed with terms and conditions of
previous award
 Recipient is not responsible
◦ Recipient must be notified in writing
◦ Special conditions removed once corrections are
made
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A-110: Subpart C - Post Award
Requirements

Prescribes standards for financial and program
management of sponsored research awards
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Standards for financial management systems
Methods for making payments
Cost sharing and matching
Program income
Revision of budget and program plans
Non-federal audits
Allowable costs
Fund availability
Conditional Exemptions
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A-110: Subpart C – continued
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Prescribes standards for financial and program
management of sponsored research awards
◦ Property standards for the management and
disposition of Federally-funded property.
◦ Title to equipment
◦ Property management standards
◦ Feds maintain a royalty-free nonexclusive right to
copyrighted material.
◦ Procurement Standards
◦ Reports and Records
◦ Termination and Enforcement
Standards for financial management
systems
◦ Relate financial data to performance data
◦ Recipient’s financial system must provide:
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Financial results of each sponsored project
Identification of source & application of funds
Control & accountability over all funds, property & other assets
Comparison of outlays to budget amounts
◦ Procedures to minimize time between transfer of
funds and the disbursement of those funds
◦ Procedures for determining reasonableness, allocability
and allowability of costs
◦ Accounting records supported by source
documentation
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Payment Methods
Payment times should be minimized between the
time of invoicing and Federal reimbursement.
 Advances are possible; but cost reimbursement
is preferred method.
 Advances are to be maintained in interest
bearing accounts.
 Stipulates which Federal forms should be used.
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Cost Sharing
…represents that portion of the total project
costs of a sponsored agreement paid for by
the institution, rather than by the sponsor.
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Proposing Cost Sharing
Mandatory
Cost Sharing is Required by the sponsor as a condition of
obtaining an award.
Voluntary
Cost Sharing is Offered to increase competitiveness against peer
institutions for an award or for other non-mandatory reasons
Committed
Once Mandatory or Voluntary Cost Sharing is Proposed to a
sponsor, and Accepted in an award it becomes committed!
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Cost Sharing
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Mandatory and Voluntary committed cost
sharing must be monitored, verified and included
in the F&A rate calculation
◦ Lowers the F&A rate and decreases recovery of F&A
revenue
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Voluntary uncommitted cost sharing
◦ Effort put forth by a PI or senior researcher on a
project that was not pledged in the proposal or
required by the award (e.g. the PI committed 5% effort
but actually devoted 20% effort, the 15% difference
would be considered voluntary uncommitted cost
sharing)
◦ Does not have to be included in the F&A rate
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Examples of Cost Sharing
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Effort - faculty, staff or
student (Example, “30%
effort with 10% of salary
charged to the project”)
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Cash
Third Party
Contributions
Unrecovered F&A
costs (can be used if
agency has approved)
Volunteer Services:
Necessary and integral
part of project
Establishing values for
contributions of services
and property (in
accordance with applicable
cost principles)
 Other employee services
(valued at regular rate of
pay plus fringe benefits)
 Donated supplies (must be
reasonable and at fair
market value)
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Expenditures That Can NOT Be
Proposed as Cost Sharing
 Unallowable costs
◦ Salaries over the salary cap
◦ Cost overruns/overdrafts
Purchase price of equipment in current
inventory
 Other items your institution might
prohibit?
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If a sponsor wouldn’t pay for it anyway, it can’t be proposed as
cost sharing.
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Cost Sharing Considerations
Cash and third party in-kind contributions
must meet all the following criteria:
◦ Are verifiable from the recipient’s records
◦ Cannot be used as cost sharing on other federal
projects
◦ Are necessary and reasonable for accomplishment of
project objectives
◦ Are allowable under the cost principles
◦ Are not paid by the Federal government under another
award
◦ Are provided for in the approved budget when
required by Federal agency
◦ Conform to other provisions of A-110, as applicable
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Cost Sharing Issues
A-110 requires that actual expenditures must be
verifiable from the recipient's records.
 A-21/CAS requirements
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◦ All costs of a project must be classified consistently,
regardless of the funding source
◦ Do we classify all cost sharing consistently with the
project costs?
◦ Cost sharing can have a significant impact on the F&A
rate, auditors and negotiators want institutions to
capture all cost sharing, mandatory and voluntary
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Potential Problems Associated
with Cost Sharing
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Do effort reports capture cost shared
effort (both mandatory and voluntarily
committed)?
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Are the same cost sharing funds used to
meet the matching requirements on more
than one project?
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A-110: Program Income
Recipients must account for income related to
projects financed by the federal government
 Recipients may retain and use income if allowed
by agency by:
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Adding to the project to further the objectives
Financing the non-federal share
Deducting from the total cost of the project
If agency does not specify in award:
1. Support research - added to project
2. All others - deducted from the cost of the project
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A-110: Program Income
(continued)
No obligation to government for income
earned after end of project
 Costs for generation of income may be
deducted from gross income
 No obligation to government for income
earned from license fees and royalties
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A-110: Budget and Program
Changes
Budget and Program Plan Revisions
 Deviations must be reported and prior
approval requested
 Prior approval required in nonconstruction awards as follows:
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◦ Change of scope
◦ Change of Key Personnel
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A-110: Budget and Program
Changes (continued)
◦ Absence of 3 months or 25% reduction in time
of Key Personnel
◦ Additional funding
◦ Transfer of F&A to direct or vice versa
◦ Inclusion of costs requiring prior approval in
Circulars
◦ Transfer of funds allotted for training
◦ Subawards
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A-110: Budget and Program
Changes (continued)
No other prior approvals can be imposed
 Agencies authorized to waive approvals except
for:
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◦ Change in scope of work
◦ Additional funding
Transfers between budget line items may be
restricted if award is $100,000 or more and
transfer exceeds 10% of approved budget
 Agency should respond to request within 30
days from the date of receipt of the request
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Expanded Authorities
Federal Demonstration Partnership
Group of Universities, Federal Agencies, and Others
(including NCURA) focused on improving Federal grants
management
 Expanded Authorities
Delegated approvals to the grant recipients in 7 areas:
1. Pre-award Costs
2. Domestic Travel
3. Foreign Travel
4. Equipment
5. Carry-Over of Funds
6. No-Cost Extensions
7. Rebudgeting
 Not all agencies or programs have delegated these
approvals
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A-110: Reports And Records
Sets forth procedures for monitoring and reporting financial and
program performance and the necessary standard reporting
forms (including record retention requirements). (See C. 50 to
53)
Monitoring And Reporting Program Performance
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Recipients are responsible for:
◦ Managing and monitoring each project, program, subaward,
function or activity supported by the award; and
◦ Ensuring subrecipients have met the audit requirements
delineated in C. 26.
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Time of reporting:
◦ Not more frequently than quarterly or less frequently than
annually.
A-110: Reports And Records
(Cont’d)
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When required, performance reports (technical reports) shall generally
contain:
◦ Comparison of actual accomplishments with goals established for
the period, the finding or both;
◦ Reasons why established goals were not met; and
◦ Other information including, when appropriate, analysis and
explanation of cost overruns or high unit costs.
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Recipient shall notify the federal awarding agency when:
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Site visits
◦ Events occur that have a significant impact on the project or
program; and/or
◦ Problems, delays or adverse conditions occur that materially impair
the ability to attain program objectives.
A-110: Reports And Records
(Cont’d)
Financial Reporting
 Standard forms are specified for obtaining financial
information.
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Financial Status Report (SF-269)
◦ Federal Agency has option to use Request for Advance
or Reimbursement or Cash Transactions Report if they
provide adequate information.
◦ FSR is required at completion of project.
◦ May require cash or accrual basis.
◦ Timing: 30 days after the conclusion of each specified
reporting period for quarterly and semi-annual reports
and within 90 days of annual or final reports.
A-110: Reports And Records
(Cont’d)
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Report of Federal Cash Transactions (SF-272)
◦ For advances through letter of credit and reporting
within 15 days after each quarter.
◦ May require explanation of cash in excess of 3 days
needs, legislative requirements, or accounting
standards questions.
◦ Machine readable formats allowed.
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Request for advance or reimbursement (SF-270)
◦ Used only where letter of credit or predetermined
advance method is not used.
A-110: Reports And Records
(Cont’d)
Retention And Access Requirements For Records
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Federal awarding agencies shall not impose any other record
retention or access requirements upon recipients.
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Financial records, supporting documents, statistical records and all
other records shall be retained for a period of THREE years, with
the following exceptions:
◦ Litigation requires retention until all matters have been resolved;
◦ Real property and equipment records retained three years after final
disposition of the property; and/or
◦ When records are transferred to the agency, the retention requirement
ends.
◦ F&A cost rate proposals, cost allocation plans have unique requirements.
A-110: Reports And Records
(Cont’d)
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With agency approval, copies can be substituted for original records.
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When does the clock start?
◦ Awards - Date of submission of the final expenditure report or, for
awards that are renewed quarterly or annually, from the date of the
submission of the quarterly or annual financial report;
◦ F&A Costs - Date of submission of a proposal for negotiation; the end of
the fiscal year if not submitted for negotiation.
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Access to records by agency, inspector general, or comptroller
general is allowable.
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Agencies may not limit public access to recipients' records without
justification.
A-110: Termination And Enforcement
Sets forth uniform suspension, termination and
enforcement procedures (See C. 60 to 62)
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Termination
◦ By the federal awarding agency
◦ By the federal awarding agency with the consent of the recipient
◦ By the recipient
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Enforcement
◦ Remedies for noncompliance
◦ Hearings and appeals
◦ Effects of suspension and termination
◦ Relationship to debarment and suspension (See B,13)
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Regulations provide information on how to proceed with termination for
cause and termination for convenience
A-110: Subpart D - After Award
Requirements
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Purpose:
◦ Establish procedures for close-outs, disallowances and adjustments
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Close-out:
◦ All reports must be submitted within ninety days
◦ All obligations must be liquidated within ninety days
◦ Agency must make prompt payment
◦ Recipient shall refund any unobligated cash advance
◦ Agency makes adjustments after reports are received
◦ Recipient must account for real and personal property
◦ Agency retains right to recover disallowances until final audit
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Subsequent Adjustments
◦ Close-out does not affect:
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Right of agency to disallow and recover funds
Obligation of recipient to return funds due as a result of refunds
Audit requirements
Property management requirements
Record retention
A-110: Subpart D - (Cont’d)
Collection of amounts due

Funds paid to recipient in excess of final
award, if not returned agency, may:
◦ Be offset against other awards
◦ Withhold advance payments
◦ Other actions permitted by statute
◦ Agency may charge interest
A-110: Appendix A
Provisions for contracts awarded by recipient.

All contracts, awarded by a recipient shall contain the
following provisions (as applicable):
◦ Equal Employment Opportunity
◦ Copeland “Anti-Kickback” Act
◦ Davis-Bacon Act
◦ Contract Work Hours and Safety Standards Act
◦ Rights to Inventions Made Under a Contract or
Agreement
◦ Clean Air Act
◦ Byrd Anti-Lobbying Amendment
◦ Debarment and Suspension
Recap of OMB Circular A-110:
Highlights
Uniform Administrative Requirements for Grants
and Agreements with Institutions of Higher
Education and Other Non-profit Organizations
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Financial and programmatic management
Cost sharing
Program income
Property standards
Procurement standards
Reporting and Records
Resources
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US Government Printing Office/FDSYS (electronic CFRs)
◦ http://www.gpo.gov/fdsys/
◦ Select the year
◦ Select “Title 2 – Grants and Agreements
◦ Pick your type – pdf, XML, or other
◦ In the pdf, scroll down to about page 4, that’s where Part 215 (A-110) begins
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FDSYS XML link for A-21
◦ http://www.gpo.gov/fdsys/pkg/CFR-2010-title2-vol1/xml/CFR-2010-title2-vol1chapII.xml
Contact Information
Maggie Griscavage
Email: [email protected]
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Acknowledgment:
◦ Liberally borrowed, by permission, from the NCURA FRA Workshops.
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