Circular A-110Circular A-110

Everything You Didn’t Want to Everything You Didn’t Want to KnowKnow

Purpose of A-110Purpose of A-110Subpart C- Post AwardSubpart C- Post Award

• Establishes uniform administrative Establishes uniform administrative requirements for Federal grants and requirements for Federal grants and agreements awarded to institutions agreements awarded to institutions of higher ed, hospitals, and other of higher ed, hospitals, and other non-profit organizations.non-profit organizations.

Post Award RequirementsPost Award Requirements

• A-110 Subpart C - Sets standards for A-110 Subpart C - Sets standards for financial and program management of financial and program management of sponsored research awards in:sponsored research awards in:FINANCIAL & PROGRAM MANAGEMENTFINANCIAL & PROGRAM MANAGEMENT– Methods for making paymentsMethods for making payments– Cost sharing and matching requirementsCost sharing and matching requirements– Accounting for program incomeAccounting for program income– Budget RevisionsBudget Revisions– AuditsAudits– Allowability of CostsAllowability of Costs– Establishing Fund availabilityEstablishing Fund availability

Standards for financial Standards for financial management systemsmanagement systems

• Relate financial data to performance dataRelate financial data to performance data

• Financial system must provide:Financial system must provide:– Financial results of each projectFinancial results of each project– Identification of source & application of fundsIdentification of source & application of funds– Control & accountability over all funds, Control & accountability over all funds,

property & other assetsproperty & other assets– Comparison of outlays to budget amountsComparison of outlays to budget amounts

Standards (cont.)Standards (cont.)

• Procedures to minimize time Procedures to minimize time between transfer of funds and between transfer of funds and disbursement of fundsdisbursement of funds

• Procedures to determine Procedures to determine reasonableness, allocability, and reasonableness, allocability, and allowability of costsallowability of costs

• Accounting records supported by Accounting records supported by source documentationsource documentation

Cost Sharing/Matching Cost Sharing/Matching FundsFunds

Definitions of Cost Sharing Definitions of Cost Sharing (Matching Funds)(Matching Funds)

• A commitment made by WSU to fund a A commitment made by WSU to fund a portion of the total cost of a sponsored portion of the total cost of a sponsored agreement. The commitment may be agreement. The commitment may be for direct and/or indirect costs, and for direct and/or indirect costs, and may consist of WSU funds or funds may consist of WSU funds or funds from outside sources. Matching may from outside sources. Matching may either be classified as voluntary or either be classified as voluntary or mandatory. Either form is a true mandatory. Either form is a true commitment and must be fully commitment and must be fully documented.documented.

Cost Sharing (Match) must Cost Sharing (Match) must meet all of the following meet all of the following

criteria:criteria:In general, same requirements apply to Non-Federal Share as apply to the In general, same requirements apply to Non-Federal Share as apply to the

Federal ShareFederal Share• Verifiable from recipient’s recordsVerifiable from recipient’s records• Not included as Match for any other federally Not included as Match for any other federally

funded programfunded program• Necessary and reasonableNecessary and reasonable• Allowable under the applicable Cost Allowable under the applicable Cost

PrinciplesPrinciples• Not paid by the Federal Government under Not paid by the Federal Government under

another awardanother award• Provided for in the approved budgetProvided for in the approved budget• Conform to other provisionsConform to other provisions

Types of Cost SharingTypes of Cost Sharing

• Mandatory Cost SharingMandatory Cost Sharing

• Voluntary Cost SharingVoluntary Cost Sharing

• Third Party In Kind ContributionsThird Party In Kind Contributions

• Facilities and Administrative (F&A), Facilities and Administrative (F&A), also known as Indirect Costsalso known as Indirect Costs

What Can be Used to Meet What Can be Used to Meet Match Requirements?Match Requirements?

• CashCash• Third Party ContributionsThird Party Contributions• Unrecovered F&A costs (Indirects)Unrecovered F&A costs (Indirects)• Contributions of services and propertyContributions of services and property• Volunteer Services (necessary for project)Volunteer Services (necessary for project)• Other employee services (regular rate + Other employee services (regular rate +

benefits)benefits)• Donated supplies (at reasonable & fair Donated supplies (at reasonable & fair

market value)market value)

Unrecovered Indirect CostsUnrecovered Indirect Costs

• May be included as part of cost May be included as part of cost sharing or matching only with the sharing or matching only with the prior approval of the awarding prior approval of the awarding agency.agency.

• Current approved rate agreement is Current approved rate agreement is 36% of Salaries, Wages and Benefits36% of Salaries, Wages and Benefits

Audit Procedures for Match Audit Procedures for Match ComplianceCompliance

• Verify that required Matching Contributions Verify that required Matching Contributions were metwere met

• Ascertain sources of matching contributions Ascertain sources of matching contributions and verify that they were from an allowable and verify that they were from an allowable sourcesource

• Test records to corroborate that value of in-Test records to corroborate that value of in-kind contributions are in accordance with kind contributions are in accordance with OMB cost principalsOMB cost principals

• Verify transactions used to match are in Verify transactions used to match are in compliance with allowable cost principlescompliance with allowable cost principles

Procurement StandardsProcurement Standards

PURPOSE: PURPOSE:

To establish procedures for To establish procedures for procurement of supplies and other procurement of supplies and other expendable property, equipment, expendable property, equipment, real property, and other servicesreal property, and other services

Codes of Conduct regarding Codes of Conduct regarding Awards and Administration of Awards and Administration of

ContractsContracts• Recipients shall maintain written Recipients shall maintain written

standards of conduct governing standards of conduct governing performance of employees involvedperformance of employees involved

• Cannot participate if conflict of Cannot participate if conflict of interest existsinterest exists

• Cannot accept gratuities, favors, or Cannot accept gratuities, favors, or anything of monetary value from anything of monetary value from contractors, subs, or parties to contractors, subs, or parties to subgrants subgrants

CompetitionCompetition

• Must provide open and free Must provide open and free competitioncompetition

• Contractors that develop or draft Contractors that develop or draft specs or requirements, statements of specs or requirements, statements of work, invitations for bids and/or work, invitations for bids and/or requests for proposals are excludedrequests for proposals are excluded

Required Written Procurement Required Written Procurement ProceduresProcedures

• Recipients must not purchase Recipients must not purchase unnecessary itemsunnecessary items

• Determine which procurement methods Determine which procurement methods are most economical and practicalare most economical and practical

• Positive efforts to utilize small business, Positive efforts to utilize small business, minority owned firms & women’s minority owned firms & women’s business enterprises, whenever business enterprises, whenever possiblepossible

Procurement procedures Procurement procedures (cont.)(cont.)• Solicitations for goods & services must provide:Solicitations for goods & services must provide:

– Clear & accurate descriptions of technical requirementsClear & accurate descriptions of technical requirements– Specify requirements which bidders must fulfillSpecify requirements which bidders must fulfill– Describe minimum acceptable standardsDescribe minimum acceptable standards– Include specific features of “brand name or equal” Include specific features of “brand name or equal”

descriptionsdescriptions– Acceptance of products & services dimensional in the Acceptance of products & services dimensional in the

metric systemmetric system– Preference for products & services that conserve natural Preference for products & services that conserve natural

resources, protect the environment, and are energy resources, protect the environment, and are energy efficient – when practicable and economicaly feasibleefficient – when practicable and economicaly feasible

Record retention & access Record retention & access requirementsrequirements

• Financial records, supporting Financial records, supporting documentation, and statistical documentation, and statistical records – Three (3) years from date records – Three (3) years from date of submission of final reportof submission of final report– If litigation occurs – until all litigation or If litigation occurs – until all litigation or

claims are resolvedclaims are resolved

• Real Property or Equipment – Three Real Property or Equipment – Three (3) years after final disposition(3) years after final disposition

CloseoutCloseout

• All reports (financial, performance, other) All reports (financial, performance, other) must be submitted within 90 days after must be submitted within 90 days after completion date of awardcompletion date of award

• Unless extension granted, all obligations Unless extension granted, all obligations incurred must be liquidated within 90 daysincurred must be liquidated within 90 days

• Prompt refund of any balances of Prompt refund of any balances of unobligated cash advancesunobligated cash advances

• Awarding agency to make settlement for Awarding agency to make settlement for any upward or downward adjustments to any upward or downward adjustments to costs after closeout reports receivedcosts after closeout reports received

Closeout (cont.)Closeout (cont.)

• Accounting of real or personal Accounting of real or personal property acquired with federal fundsproperty acquired with federal funds

• If no final audit done prior to If no final audit done prior to closeout, awarding agency retains closeout, awarding agency retains right to recover disallowed costs right to recover disallowed costs resulting from the final auditresulting from the final audit

Closeout Does Not Affect:Closeout Does Not Affect:

• Right to disallow costs and recover Right to disallow costs and recover funds on the basis of a later auditfunds on the basis of a later audit

• Obligation of recipient to return Obligation of recipient to return funds duefunds due

• Audit requirementsAudit requirements

• Property management requirementsProperty management requirements

• Record retentionRecord retention