Upload
marc-loomis
View
222
Download
3
Embed Size (px)
Citation preview
OMB CIRCULAR A-110
Uniform Administrative Requirements for Grants and Agreements With Institutions of
Higher Education, Hospitals, and Other Non-Profit Organizations
CReATE ver. 05/13 © 2013 Florida State University. All rights reserved
ASSIGNMENT OF GENERAL RESPONSIBILITIES
SRS/SRAS Staff
Review award terms to determine agency’s compliance with A-110
Ensure University’s compliance at project (award) level
ASSIGNMENT OF GENERAL RESPONSIBILITIES, cont’d
SRS/SRAS Directors
Ensure their departments comply with A-110 at project/agency level (e.g., SRS/SRAS-- rebudgeting, prior approvals, SRAS-- financial reporting)
Ensure compliance in areas outside of their departments (e.g., Purchasing-- procurement standards, Controller’s Office-- Financial and Property standards)
Circular A-110 - Highlights BACKBONE OF FEDERAL GUIDELINES
Subpart A General
Requirements
Subpart B Pre-award
Requirements
Subpart C Post-award
Requirements
Subpart D After-the-Award Requirements
SUBPART A- General Requirements- Purpose
Establish standards for consistency and uniformity among Federal agencies in administration of awards with higher education institutions, hospitals and other non-profit organizations
Subpart A – General
SUBPART A- General Requirements- Applicability
Awards to recipients/subrecipients covered by A-110 Prime Recipient - Party who receives award
from a federal agency Subrecipient - Party to whom prime
recipient subcontracts with to perform a portion of the award requirements
Common misapplicationPrime recipient passes on circular
applicable to prime recipient to subrecipient, even though it does not apply to subrecipient
Subpart A – General
Example of proper application of Circulars
FLORIDA DEPT. OF EDUCATION
Prime Recipient of NSF award
OMB A-102 applies
OMB A-102 applies
FSU Subrecipient
OMB A-110
applies
Georgia Dept. of Education
Subrecipient OMB A-102
applies
Subpart A – General
SUBPART B Pre-Award Requirements
The agency determines the type of award instrument: Grant- used when principal purpose is accomplishment
of public purpose or stimulation authorized by Federal statute
Cooperative agreement (CA)- Same as for grant. Additionally, CA used when substantial involvement expected between agency and University
Contract- used when principal purpose is the acquisition of property/services for direct benefit of Federal Government
Subpart B – Pre-award
SUBPART B Pre-Award Requirements
Application forms for Federal assistance - SF-424 series (SRS)
Debarment and suspension - (SRS) Awards (or sub awards) prohibited to organizations debarred, suspended or otherwise excluded from or ineligible
Certifications and representations - (SRS) Must be filed (A-110 encourages agencies to require annually on an agency-wide basis)
Subpart B – Pre-Award
SUBPART B Pre-Award Requirements
Drug Free Workplace Lobbying Debt, Debarment and Suspension Conflict of Interest Misconduct in Science
Subpart B – Pre-award
SRS/SRAS Additional requirements may be imposed by
agency if applicant/recipient: Poor performance history Financially unstable Management system does not meet A-110
standards Nonconformance with terms and
conditions of a previous award Not otherwise responsible
SUBPART B Pre-Award Requirements
Subpart B – Pre-award
SUBPART C – Post-Award Requirements
1. Financial and Program Management
2. Property Standards
3. Procurement Standards
4. Reports and Records
5. Termination and Enforcement
SUBPART C – POST-AWARD REQUIREMENTS
SUBPART C – Post-Award Requirements1. Financial and Program Management
A. Standards for financial management systems
B. PaymentC. Cost sharing or matchingD. Program incomeE. Revision of budget & program plansF. Non-Federal auditsG. Allowable costsH. Period of availability of funds
SUBPART C – POST-AWARD REQUIREMENTS
A. Eight Standards for Financial Management
SystemsSRAS1. Accurate, current and complete disclosure of
financial activity (OMNI)2. Records that identify source and application of funds
including (OMNI): information pertaining to Federal awards authorizations obligations unobligated balances assets outlays income interest
SUBPART C – POST-AWARD REQUIREMENTSFinancial and Program Management
A. Eight Standards for Financial Management Systems,
cont’d 3. Effective control over and accountability for
funds, property and other assets
4. Adequate safeguard of all assets and assure use is solely for authorized purposes
5. Comparison of outlays with budget amounts for each award.
6. Written procedures to minimize time elapsing between transfer of funds to recipient from U.S. Treasury and issuance of payment by recipient
SUBPART C – POST-AWARD REQUIREMENTSFinancial and Program Management
A. Eight Standards for Financial Management Systems,
cont’d
7. Written procedures for determining reasonableness, allocability and allowability of costs in accordance with applicable Federal cost principles and award terms/conditions
8. Accounting records supported by source documentation P-Card and Travel receipts
SUBPART C – POST-AWARD REQUIREMENTSFinancial and Program Management
B. Payment
Written procedures minimizing time between fund transfer and disbursement
Financial management systems meet standards for fund control and accountability requirements
Agency must pay within 30 days of billing
University allowed to submit requests for advances and reimbursements
Interest earned >$250 must be remitted annually
SUBPART C – POST-AWARD REQUIREMENTSFinancial and Program Management
C. Cost sharing & D. Program Income
A-110 addresses the Federal requirements for Cost Sharing and Program Income – The details of these sections will be covered separately
SUBPART C – POST-AWARD REQUIREMENTSFinancial and Program Management
E. Revision of budget and program plans FSU must report deviations in budget/
program plans & request prior approvals for: Change in scope or objective Changes in key personnel Absence of PI for more than 3 months or
25% reduction in time devoted to project Need for additional federal funds Transfer from direct to indirect costs or
indirect to direct (if required by agency) Sub awards, if not in approved budget
SUBPART C – POST-AWARD REQUIREMENTSFinancial and Program Management
F. Non-Federal audits, G. Allowable costs, H. Period of availability of funds
Non-Federal audits- University is subject to Single Audit Act Amendments and OMB Circular A-133 (covered in A-133 session)
Allowable costs- in accordance with OMB Circular A-21 (covered in the A-21 session)
Period of availability of funds- Allowable costs resulting from obligations incurred during funding period and any authorized pre-award costs
SUSUBPART C – POST-AWARD REQUIREMENTSFinancial and Program Management
SUBPART C – Post-Award Requirements
1. Financial and Program Management
2. Property Standards
3. Procurement Standards
4. Reports and Records
5. Termination and Enforcement
SUBPART C – POST-AWARD REQUIREMENTS
Property Standards- Insurance coverage
FSU must insure property acquired with Federal $ at the same levels as FSU acquired property
Agency may require additional coverage
SUSUBPART C – POST-AWARD REQUIREMENTSProperty Standards
Property Standards- Exempt Property
Generally an agency has the option to vest title of property acquired under an award to FSU without further obligation - "exempt property"
If title to property is not specified by agency, it automatically defaults to exempt property
Exempt property does not need to be included on equipment inventory report to an agency
SUSUBPART C – POST-AWARD REQUIREMENTSProperty Standards
Property Standards- Non Exempt Property
If equipment is not “exempt property”, title vests with University but use requirements are: Must be used on project as long as needed On other activities sponsored by agency or On other federally-sponsored activities
User charges must be treated as program income
SUBPART C – POST-AWARD REQUIREMENTSProperty Standards
Property Standards- Equipment, cont’d Equipment records must be maintained accurately and
include a number of data elements (OMNI captures)
Physical inventory of equipment taken and results reconciled with equipment records at least once every two years (FSU annual)
Control system in effect to insure adequate safeguards to prevent loss, damage, or theft
Adequate maintenance procedures to keep equipment in good condition
Equipment owned by Federal Government requires Federal property tag on equipment (in addition to FSU’s)
SUBPART C – POST-AWARD REQUIREMENTSProperty Standards
Property Standards-Supplies and other expendable property
Title to supplies and other expendable property will vest in University
If “exempt property”, there is no further obligation to agency
If not “exempt property” same “use provision” as for equipment, applies
SUBPART C – POST-AWARD REQUIREMENTSProperty Standards
SUBPART C – Post-Award Requirements
1. Financial and Program Management
2. Property Standards
3. Procurement Standards
4. Reports and Records
5. Termination and Enforcement
SUBPART C – POST-AWARD REQUIREMENTS
Procurement Standards
SRS is responsible for compliance on sub-awards issued by FSU
SRAS is responsible for making Purchasing aware of requirements and ensuring compliance
SUBPART C – POST-AWARD REQUIREMENTSProcurement Standards
Procurement Standards-Codes of Conduct
University must maintain written standards regarding
conflicts of interest in the award and administration of
contracts
No employee, officer, or agent is allowed to participate in
selection, award, or administration of contract if there is
conflict of interest
Conflict of interest = employee, officer, or agent, any
member of his or her immediate family, his or her
partner, or an organization that employs these people,
has a financial or other interest in firm selected
SUBPART C – POST-AWARD REQUIREMENTSProcurement Standards
Procurement Standards-Codes of Conduct, cont’d
University officers, employees, and agents cannot solicit or accept gratuities, favors, or anything of monetary value from contractors, or parties to sub agreements
Standards of conduct must provide for disciplinary actions for violations of such standards
SUBPART C – POST-AWARD REQUIREMENTSProcurement Standards
Procurement Standards- Competition
Procurements must be conducted in manner to provide, to maximum extent practical, open and free competition
Any and all bids/offers may be rejected when it is in FSU’s interest to do so
SUBPART C – POST-AWARD REQUIREMENTSProcurement Standards
Procurement Standards- Procedures Type of procuring instrument will be determined by
University but must be appropriate for particular
procurement Fixed price, cost reimbursable, purchase order and
incentive contracts can be used
“Cost-plus-a-percentage-of-cost“ or “Percentage of
construction cost" methods of contracting cannot be
used
Contracts must be made only with responsible
contractorsSUBPART C – POST-AWARD REQUIREMENTS
Procurement Standards
Procurement Standards- Cost and Price Analysis
Some form of cost or price analysis must be made and documented with every procurement action
Price analysis may be accomplished by comparing price quotations submitted, market prices, etc.
A cost analysis is the review and evaluation of each element of cost to determine reasonableness, allocability and allowability
SUBPART C – POST-AWARD REQUIREMENTSProcurement Standards
Procurement Standards- Records
Files for purchases in excess of $100,000 must include following : Basis for contractor selection Justification for any lack of competition Basis for awarded cost
A-110 sets forth specific provisions that must be included in all contracts and subcontracts >$100,000
System for contract administration must be maintained to ensure contractor conformance with terms and adequate and timely follow up on all purchases
SUBPART C – POST-AWARD REQUIREMENTSProcurement Standards
SUBPART C – Post-Award Requirements1. Financial and Program Management
2. Property Standards
3. Procurement Standards
4. Reports and Records
5. Termination and Enforcement
SUBPART C – POST-AWARD REQUIREMENTS
Reports and Records-Monitoring and Reporting Program Performance
FSU is responsible for managing and monitoring each project and sub award
FSU must monitor sub awards to ensure audit requirements are met
Agency must prescribe the frequency performance reports are to be submitted
SUBPART C – POST-AWARD REQUIREMENTSReports and Records
Reports and Records-Financial Reporting
Agency prescribes the forms that FSU must submit financial reports require University to use including the frequency
SF-425 Federal Financial Status
SF-270 Request for Advance or Reimbursement
SRAS prepares these reports
28 Quarterly FFRs
Agency may require University to report amount of cash advances received in excess of three days (advance requests not FSU practice)
SUBPART C – POST-AWARD REQUIREMENTSReports and Records
Reports and Records-Retention and Access Requirements for Records
Financial records, supporting documents, etc. 3 years from date of final expenditure
report submission
Copies of original records may be substituted for original records if authorized by agency
SUBPART C – POST-AWARD REQUIREMENTS Reports and Records
Reports and Records-Inspections
Rights of access - as long as records are kept.
Timely and unrestricted access to any books, documents, papers, or other records pertinent to awards
Indirect cost rate proposals
If submitted for negotiation – 3 years from date of submission
SUBPART C – POST-AWARD REQUIREMENTS- Reports and Records
SUBPART C – Post-Award Requirements1. Financial and Program Management
2. Property Standards
3. Procurement Standards
4. Reports and Records
5. Termination and Enforcement
SUBPART C – POST-AWARD REQUIREMENTS
Termination and Enforcement
Sets forth uniform suspension, termination and enforcement procedures
SUBPART C – POST-AWARD REQUIREMENTS-
Circular A-110 - Highlights
Subpart A General Requirements
Subpart B Pre-award Requirements
Subpart C Post-award Requirements
Subpart D After-the-Award Requirements
Closeout procedures
All obligations must be liquidated within 90 days
All financial, performance and other reports completed within 90 days following award ending date
Agency may approve extensions Agency must pay balance due
promptly/University must refund balance due to agency promptly
SUBPART D – POST-AWARD REQUIREMENTS After-the-Award
Termination Agency may terminate award in whole or in part
only if: University materially fails to comply with terms and
conditions of award Agency and University consent
University may terminate by giving written notification to agency: Where partial termination is requested, if agency
determines that reduced or modified work will not accomplish purposes for which award was made, it may terminate award in its entirety
SUBPART D – POST-AWARD REQUIREMENTS After-the-Award
American Recovery & Reinvestment Act
Started 2009 FSU received 124 awards totaling $60.6
million Program ends September 30, 2013
OMB granted exceptions $ must be spent, liquidated (paid) and drawn
by September 30, 2013 SRAS/SRS reviewing open ARRA projects
and will be notifying PIs of deadlines very soon!!