SELECTED DISCUSSION OF SPONSORED PROGRAMS TOPICS RELATED TO POSTAWARD, FINANCE AND COMPLIANCE

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SELECTED DISCUSSION OF SPONSORED PROGRAMS TOPICS
RELATED TO POST-AWARD, FINANCE AND COMPLIANCE

• Lisa Thompson
• (Monsanto Company previously at the University of
  Tulsa)
• Govind Narasimhan
• (UT M.D. Anderson Cancer Center)
• NCURA Region V Regional Conference
• April 2009
• San Antonio, Texas

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SUBRECIPIENT vs. VENDOR

• Regulation / Source
• www.whitehouse.gov/omb/circulars
• OMB Circular A-133
• OMB Circular A-110

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SUBRECIPIENT vs. VENDOR

• Definitions
• Sub recipient
• the entity that expends federal awards
  received from pass-through entity to carry out a
  federal program, but does not include an
  individuals. A sub recipient may also be a
  recipient of other Federal awards directly
• Vendor
• a dealer, distributor, merchant, or other
  seller providing goods or services that are
  required for the conduct of a Federal program.
  These goods or services may be for an
  organizations own use or for the beneficiary of
  the Federal program

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SUBRECIPIENT vs. VENDOR

• Sub recipient indicative characteristics
• Organization determines who is eligible to
  receive federal funds
• Has performance measured to ensure objectives of
  Federal program are met
• Responsible for programmatic decisions
• Responsible for adherence to Federal program
  compliance requirements
• Uses Federal funds to carry out a program of the
  organization as compared to providing goods or
  services for the program of the pass-through
  entity

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SUBRECIPIENT vs. VENDOR

• Vendor indicative characteristics
• Provide goods or services within normal business
  operations
• Provides similar goods or services to many
  different purchasers
• Operates in a competitive environment
• Provides goods or services that are ancillary to
  the operation of the federal program and
• Is not subject to compliance requirements of
  federal programs

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EQUIPMENT

• Regulation / Source
• www.whitehouse.gov/omb/circulars
• OMB Circular A-21
• OMB Circular A-110
• OMB Circular A-133
• Federal Acquisition Regulation (FAR)

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EQUIPMENT

• Useful life and unit cost
• Special vs. general purpose equipment
• Excluded from FA base
• Capital expenditures
• Inventory and asset management
• Audit

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TRAVEL

• Regulation / Source
• OMB Circular A-21
• Foreign Travel
• Fly America Act
• General Services Administration
• Department of Defense
• State and Institutional guidelines

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COST SHARING

• Represents portion of costs borne or paid for by
  MDACC and not the Sponsor
• Three types of cost sharing
• Mandatory cost sharing
• Required by sponsor, program requirements,
  statute etc as a condition of obtaining award
• Voluntary committed cost sharing
• Not required as above but resources committed
  by MDACC in the proposal that becomes part of
  the award
• Voluntary uncommitted cost sharing
• All or any effort over and above that agreed to
  as part of the award is faculty donated effort

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Effort Reporting

• Why necessary
• Frequency
• After the fact reporting
• Effort reporting system
• Labor cost transfers
• Your Institutions process

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COST SHARING

• Majority of cost sharing involves salaries
• Cost sharing must be tracked
• Funds from one federal project may not be
  utilized as source of cost sharing on another
  federal project
• Cost principles under A-21 apply

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PROGRAM INCOME

• Gross income earned by grantee
• Directly generated by the grant-supported
  activity or earned from award
• A-21 cost principles apply
• Must be reported on SF269
• Royalties, license fees etc exempt from reporting

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PROGRAM INCOME

• Accounting and use
• Additive
• Added to funds committed
• Deductive
• Deducted from total allowable cost
• Combination
• Additive up to 25,000. Deductive for amount
  exceeding 25,000.
• Matching
• Used for cost sharing

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COST PRINCIPLES

• OMB A-21
• Allowable
• Allocable
• Reasonable
• Consistent
• Availability of funds
• Period of eligibility

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COST TRANSFER CONSIDERATIONS

• Reconcile departmental records to Institutional
  financial statements
• Correct errors timely
• Justify and substantiate cost transfers
• Follow policy and procedure
• A-21 cost principles apply

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COST TRANSFER CONSIDERATIONS

• Unacceptable charging practices
• Charging costs to federal projects based on
  largest balance
• Charging cost to federal project only when cost
  also supporting non-federal project or other
  activity
• Engaging in ordering supplies and equipment close
  to the end of the project period
• Charging costs for the sole purpose of expending
  all funds

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EXPANDED AUTHORITY

• MDACC is under expanded authorities
• SNAP (Streamlined non-competing award process)
• FDP (Federal Demonstration Partnership)
• Re-budgeting No cost extensions
• Change in scope
• 2590
• Excluded from expanded authority / SNAP
• NIH versus other sponsors

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BUDGET AND PROJECT PERIOD CLOSE OUT

• Ensure all expenses charged are consistent with
  A-21
• Ensure payroll appointments are correct and do
  not extend beyond period
• Review effort reports of employees working on
  project
• Review encumbrances and accruals
• Dont forget sub-recipients
• Contact internal service centers

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BUDGET AND PROJECT PERIOD CLOSE OUT

• Ensure all technical and progress reports are
  completed and submitted timely
• Ensure program income and cost sharing is
  reported on FSR
• Review FA base, rate and amount on FSR
• Review FSR and FSR comments
• Review non-competing / competing segment budget

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Payment and Receivable Issues

• Policies and Procedures
• Financial systems
• Management reports
• Deliverables
• Regulations / Sources
• A-110, A-133
• CMIA, CFR etc

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REPORTING ISSUES

• Regulation / source
• A-110, A-133, Other
• Financial Systems and other database
• Management reports
• Policies and Procedures
• TE, Cost Transfers, Un-liquidated obligations
• Non-financial reports
• Effective close out process
• FSR (SF269) versus Quarterly PMS 272 report

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RECORDS RETENTION

• Regulation / Source
• A-110, A-133, State Institutional Policy
• Exceptions
• Litigation
• Real Property and equipment
• Indirect cost rate proposal

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AUDITS

• Regulation / Source
• A- 133
• Managing the audit
• Policies and Procedures
• Financial systems and other database
• Sub-recipient monitoring
• TE and Cost transfers
• Management response

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Contact Information

• Lisa Thompson
• Senior Contract Administrator
• Technology Alliance Team
• Monsanto Company
• PH [phone]
• Fax [phone]
• EmailLisa.L.Thompson_at_monsanto.com

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Contact Information

• Govind Narasimhan
• Associate Director
• Research Finance
• The University of Texas M. D. Anderson Cancer
  Center
• PH [phone]
• Fax [phone]
• Email gnarasim_at_mdanderson.org