Transcript What we’ll go over today

Slide 1
FastFacts
Feature Presentation
June 18, 2010
We are using audio during this session, so please dial in
to our conference line…
Phone number: 877-468-2134
Participant code: 182500
© 2010 The Johns Hopkins University. All rights reserved.
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Today’s Topic
We’ll be taking a look at…
Sub-Recipient Monitoring,
Reporting & Records Retention
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Today’s Presenter
Sunanda Holmes
Assistant Director - Office of International Business Operations Compliance
Controller's Office
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Session Segments
Presentation
Sunanda will discuss cost sharing, the criteria used for
valuations, setting up an auditable system for tracking and
program income.
During Sunanda’s presentation, your phone will be muted.
Q&A
After the presentation, we’ll hold a Q&A session.
We’ll open up the phone lines, and you’ll be able to ask
questions.
Sunanda will answer as many of your questions as time allows.
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Contact Us
If you would like to submit a question during the presentation or if
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How To View Full Screen
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Survey
Survey
At the end of this FastFacts session, we’ll ask you to complete a
short survey.
Your honest comments will help us to enhance and improve
future FastFacts sessions.
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Sub-Recipient Monitoring,
Reporting & Records Retention
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Agenda
Overview:
JHU: Where We Are
Assessing Proposed Sub-Recipients
Monitoring Sub-Recipients
Reporting Requirements
Record Keeping and Retention
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Where We Are…
Importance to JHU:
Over $85 million paid to foreign subrecipients in FY09.
Over $30 million was paid out to foreign subrecipients on
USAID funded grants in FY09.
Payments made to subrecipients in 62 countries.
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Definitions
Subaward:
Award of financial assistance in the form of money or
property in lieu of money
Includes financial assistance
Legal agreement
Made under an award by a recipient to a subrecipient
Subrecipient:
Recipient of a subagreement awarded to a foreign
or domestic organization (either non-profit,
educational institution, or private industry)
Performance of a portion of the work statement covered
by a prime agreement with sponsored funding
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Determining Subrecipient or Vendor Status
An organization is considered
to be a subrecipient when it:
Is delegated programmatic
responsibility
In contrast to performing
services or providing goods
to the prime organization
as a vendor
An organization is considered
to be a vendor when it:
Serves as a dealer,
distributor or merchant
that provides goods or
services for the
organization’s own use
Work product is not
expected to be publishable
in an academic journal
Provides similar goods or
services to many different
purchasers and operates in
a competitive environment.
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Risk Factors to Consider
Size of the sub-recipient award
Award size relative to the sub-recipient's sponsored research
portfolio or total funding from all sources
Percentage passed through
Award complexity, sensitivity of the work and/or extensiveness of
the governing regulations
Prior experience with the sub-recipient
Sub-recipient’s country of operation
Degree of external oversight by auditors or sponsoring agencies
Sophistication of sub-recipient's accounting systems and
administrative operations
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Assessing Capacity & Risk Potential
Determine what reporting & monitoring requirements are necessary
Examine organizational documents
Analyze financial statements
Vet the organization and its governing body members in compliance
with US law
Review the organization’s capacity to administer a grant
Consider financial health of the organization,
Confirm the organization is fiscally secure and no unusual findings in
audited financial statements
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Monitoring- Why is it Necessary?
USAID requirement
Budget allocation
Deliverables are met
Success of the project
Costs charged are allowable
Quality assurance
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Types of Monitoring
Program/performance
Subrecipient performance/technical progress
Program output-are they being carried out as planned
Performance quality desired impact being felt
Financial
Invoices prepared in accordance with A-110 and A-133
Proper accounting practices being followed
Reconciliation
Compliance
USAID regulations
Local laws
JHU policies and procedures
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Audit Requirements
ADS 591 Provides Policy Directives and Required Procedures
for Planning and Conducting Financial Audits of USAID
Contractors, Recipients, & Host Government Entities
Foreign for profit and non-profit organizations that expend $300,000
or more per their fiscal year in USAID awards” i.e. as a recipients or
subrecipients of USAID grants or cooperative agreements, or as cost
reimbursable subcontractors of USAID grant of cooperative
agreements, shall have an annual audit conducted in accordance with
the Guidelines for Financial Audits Contracted by Foreign Recipients”.
Foreign for profit and non-profit organizations expending less than
$300K per their fiscal year under USAID grants or cooperative
agreements, or as cost reimbursable contractors of USAID grant or
cooperative agreements, are exempt from the audit requirement but
have to make their records available if USAID requests.
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Techniques for Monitoring
Foreign subrecipient questionnaire
Annual letter from Financial Research Compliance
Onsite review- Regular contact through telephone/emails
Program specific
The nature, timing and scope of monitoring foreign subrecipients may vary by the assessment of risks, funds provided,
nature of work, duration of involvement and other factors
A-133
Sets forth audit procedures for obtaining consistency &
uniformity among Federal agencies for audits
Foreign sub-recipients that are exempt from A-133 are required
to make their financial records available for review or audit by
Federal agencies or pass-thru entities as requested, under the
Terms and Conditions of their Agreement
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What’s New for Subrecipient Monitoring?
Budgeting
Fees associated with routine oversight/monitoring should be
included in the proposal and direct charged
Controller’s Office is working on guidelines for audit costs
Monitoring process
Establishing risk assessments
Reviewing documents provided by foreign subs
Reviews/auditing of subs based on established criteria
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JHU Subrecipient Monitoring Policy
JHU policy on subrecipient monitoring
https://www.controller.jhu.edu/policyapp/displayGuidePDF.do?guideI
d=SUB
Questions?
Please contact Rick Inglis in Financial Research Compliance
[email protected]
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Reporting Requirements
All financial reporting should be coordinated through Sponsored
Projects Shared Services (SPSS).
Expenses reported must balance to SAP.
SF 269’s generally due quarterly, no later than 30 days after the
reporting period
Final financial reports due no later than 90 days after end of grant
period
Reporting of foreign taxes (VAT) due annually by April 16
For financial reporting questions, please contact Steve Culp in SPSS
[email protected]
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Record Keeping and Retention
Financial records (electronic and paper), supporting
documents, statistical records, and all other records
pertinent to a sponsored award (or tax return) shall be
retained for a period of seven years from the date of
submission of all deliverables.
Financial reports, patent reports, technical reports and
equipment reports are examples of deliverables.
Field office staff should coordinate retention efforts with
the Baltimore office.
For additional guidance from JHU, please refer to:
http://www.controller.jhu.edu/acct_recon/acct_reconciliation_gu
ide/Chapter_2_Reconciliation_Guidelines.pdf
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In Conclusion
Applicable regulations:
22 CFR 226.26 – Non Federal Audits (A-133 requirements)
Institutions of higher education or other non-profits are subject to
the Single Audit Act
22 CFR 226.52 – Financial Reporting
Designates which forms must be used by USAID recipients
22 CFR 226.53 – Retention & Access Requirements for Records
Exclusive list of record retention & access Requirements
USAID cannot impose additional retention requirements upon subs
22 CFR 226.70 – After the Award Requirements (Closeout)
Refer to Subpart D
226.71 through 226.71 sets forth the closeout procedures and
subsequent disallowances for adjustments
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Q&A
We’re going to open the phone lines now!
There will be a slight pause, and then a recorded voice will provide
instructions on how to ask questions over this conference call line.
We’ll be answering questions in the order that we receive them.
We’ll also be answering the questions that were emailed to us
during the presentation.
If there’s a question that we can’t answer, we’ll do some research
after this session, and then email the answer to all participants.
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Thank You!
Thank you for participating!
We would love to hear from you.
Are there certain topics that you would like us to cover in future
FastFacts sessions?
Would you like to be a FastFacts presenter?
Please email us at: [email protected]
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Survey
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Your feedback will help us as we plan future FastFacts sessions.
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http://connect.johnshopkins.edu/fastfactssurvey/
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