A Bird s Eye View OMB Circulars

1. A Bird�s Eye View�OMB Circulars NCSRA 2006 Pam Whitlock UNCW

2. The Basic Trio A-21 Costs A-110 Systems A-133 Audit

3. A-21Cost Principles Guidance on expenditures Not all inclusive � a guide Allowable and unallowable

4. The most requested from faculty Alcoholic beverages Communication Costs Compensation for personal services Employee morale, health and welfare Entertainment Material and supply Memberships, subscriptions, professional activities Proposal costs Publication and printing costs

5. Prudent Person TestThree Questions Reasonable? Allowable? Allocable?

6. And even more important� Can you look yourself in the eye and say it�s necessary and related Does it pass the �SMELL TEST�

7. And even more important� Can you look yourself in the eye and say it�s necessary and related Does it pass the �SMELL TEST�

8. A-110Administrative What we need to manage Pre-award guidance to agencies Award instruments Forms permissible �Eligible� recipients � debarment� Special award conditions Certs and reps � annual basis encouragement

9. A-110 Administrative Post-Award Requirements Financial /Program Management standards Payment methods Cost sharing guidance Program Income Sponsor approvals Single Audit Period of availability of $$ Property/equipment standards vs supplies Procurement standards Reports and records Termination Closeout (After the Award)

10. Financial Management Accurate, current and complete disclosure of financial results Source documents Identify source and application of funds Control over and accountability for funds Written procedures � cash management Written procedures � reasonable, allocable, allowable

11. Cash Management Minimize time between transfer from federal government and expenditure Paid in advance if qualify- draw, EFT, SF270 Reimbursement if not � delinquent, inadequate systems and procedures Advances in insured accounts if possible Interest bearing accounts Must pay back interest >$250/year

12. Cost Sharing/Matching Verifiable Not included in commitment to another project Are necessary and reasonable for this project Allowable under appropriate cost principles Not federal funds Identified in the budget Valuation Current fair market value

13. Program Income Additive Used to finance the non-Federal share of the project Deductive If not specified, then deductive EXCEPT RESEARCH No obligation after end of project No obligation from royalties

14. Budgets Prior approval for Change of scope Change in key personnel Absence >3 months/25% decrease � PI Need for additional funding Transfer of F&A/DC IF REQUIRED BY SPONSOR Inclusion of costs that A-21 requires approval Training allowances to other categories New subagreement No other approvals allowed unless approved by OMB May be Waived � Expanded Authorities 90 day pre-award spending One time NCX >12 months Carryforward of $ For research automatically waived unless specifically in award

15. Property Insurance � equal to what institution does Real property Federally-owned Other Title to recipient Use fee must be market rate When no longer needed That project Same agency Other federal agency Other users Life of project That project Others � if doesn�t interfere Same agency Other federal agencies If federally owned, need agency approval Program income May use as trade-in

16. Property Management Description Serial number, model number, etc Source of funding, including award # Title Acquisition date Information to calculate federal % Location Unit acquisition cost Ultimate disposal data Federally owned identified Physical inventory 2 years Control system to safeguard Adequate Maintenance Title to supplies � university < $5000 worth

17. Reports and Records Monitor subawards Performance reports � no more than quarterly or less frequent than annual Annual 90 days after grant year Quarterly/semi annual � 30 days after reporting period Final 90 days after termination

18. Report Contents Comparison of actual/planned Reasons why established goals not met Other ifo: analysis � cost overruns No more than original and 2 Agencies may make site visits

19. Types SF269-269A (expenditures/total award/program income) SF270 (Request for advance/reimbursement) may be used instead of 269 SF272 (Report of Federal Cash Transactions) may be used instead of 269 Final 269 will be requried

20. SF 272 Advances Monitor cash May require forecasts in �remarks� Cash on hand > 3 days needs = report Frequency depends on dollar volume

21. Record Retention Three years from date of submission of final expenditure report unless Litigation, claim, or audit is started prior to that Real property and equipment � 3 years after disposition Records transferred to federal agency IG, CG, agency � access at any time Public access mostly

22. Termination and Enforcement Feds for cause Mutual agreement Recipient for convenience but feds can decide if partial that what�s left won�t accomplish the grant purposes and they can terminate in entirety Must be provided in any subagreements

23. Closeout Ninety days Liquidate all obligations Refund any balances Account for real and personal property Fiscal and programmatic reports

24. Continuing Responsibilities Right of feds to disallow costs and recover funds on later audit Obligation to return any funds due as a result of late refunds, corrections, or other transactions Audit requirements Property management requirements Records retention

25. A-133Audits Non-federal entities that expend >$500,000 in a year of federal awards Can elect under certain circumstances to have programmatic audit Less than $500K no audit but records must be available for review or audit State or local � biennially Non-profit � some Can now access http://harvester.census.gov/sac/to monitor subs

26. Sub recipient Monitoring Audit findings Compliance with flowed T&C�s Access to records Fiscal reports Programmatic reports

27. Increased Risk Current/prior experience Subrecipients Technology Prior audit findings Oversight exercised by agencies/prime Phase of a program in life cycle

28. Criteria for a Low-Risk Auditee Single audits were performed annually Auditor�s opinions on financials were unqualified No deficiencies in internal controls noted None of the federal programs had audit findings from either internal controls or non-compliance

29. Thank You! Pam Whitlock, Director, OSP UNC Wilmington 601 S. College Road Wilmington, NC 28403-5973 V 910 962 3167 F 910 962 4011 Email: Whitlock@uncw.edu