1 uniform guidance med campus hiebert lounge 11/18/2014 12:00 – 2:00 pm cr campus colloquial room...

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Uniform Guidance

Med CampusHiebert Lounge

11/18/201412:00 – 2:00 pm

CR CampusColloquial Room

11/20/201412:00 – 2:00 pm

Post Award Financial OperationsSponsored Programs

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Agenda

• Introduction• Uniform Guidance Overview• Impact on Researchers

– Direct Charging– Financial Reporting / Closeouts– Cost Sharing– Subcontracts / Subrecipient Monitoring– Effort Reporting– Procurement

• Tools• Next Steps


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Introductions

• Andy Horner, Vice President for Research Finance & Operations– [email protected]– 617-353-2290

• Gretchen Hartigan, Assistant Vice President for Post Award Financial Operations– [email protected]– 617-358-6361

• Diane Baldwin, Assistant Vice President for Sponsored Programs– [email protected]– 617-638-4521 (BUMC) or 617-353-4377 (CRC)


mailto:[email protected]



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Uniform Guidance Overview

Why are we here?


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Executive Orders. . .

• Executive Order 13563, January 18, 2011– “Some sectors and industries face a significant number of regulatory

requirements, some of which may be redundant, inconsistent, or overlapping. Greater coordination across agencies could reduce these requirements, thus reducing costs and simplifying and harmonizing rules.”

• Executive Order 13579 of July 11, 2011– “Independent regulatory agencies should consider how best to promote

retrospective analysis of rules that may be outmoded, ineffective, insufficient, or excessively burdensome, and to modify, streamline, expand, or repeal them in accordance with what has been learned.”


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. . . Lead to The OMB Uniform Guidance

• Competing objectives1. Streamline guidance for Federal awards to ease administrative burden

2. Strengthen oversight over Federal funds to reduce risks of waste, fraud, and abuse

• Creation of the Uniform Guidance– Combines (streamlines?) requirements from OMB Circulars A-21, A-

87, A-110, A-122, A-89, A-102, and A-133– BU Subject to A-21, A-110 and A-133


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• Uniform implementation date of 12/26/14 for all Subparts, except Subpart F (Audits), which will be effective the first FY beginning after 12/26/14… for BU, this is effective FY2016 (7/1/2015 – 6/30/2016) – Generally speaking, the Uniform Guidance will be applicable for new

awards and for incremental funding awarded on or after 12/26/14

• Existing Awards will follow previous OMB Circulars• Waiting on clarification of Continuing Awards• Agency Comments will be available 12/26/2014

– BU DRAFT policies may change based on these new comments


We welcome and encourage your comments and feedback on the draft policies. Contact one of us or [email protected]

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• Creation of Working Group • Close coordination with stakeholders

– COGR– FDP– NCURA– Peers institutions– External audit community

• BU website: http://www.bu.edu/uniformguidance/


This federal guidance and the implementation plans of the agencies is NOT final. We are providing what we know today. We will

continue to provide updates through (and beyond) December 26, 2014.

http://www.bu.edu/uniformguidance/

http://www.bu.edu/uniformguidance/

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Impact on Researchers

Policy on Charging of Direct Costs to Sponsored Awards

(New BU Policy)


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Allowable / Unallowable• Allowable / Unallowable (§§200.403 – 405 and §§200.420-

475)– Core principles have not materially changed:

• Allowable– Be necessary and reasonable– Conform to limitations / exclusions set forth in the Federal award– Be consistent with policies and procedures– Consistently treated– Be in accordance with generally accepted accounting principles (GAAP)– Not included to meet cost share or match requirements– Be adequately documented

• Allocable– Goods and Services involved are chargeable or assignable to that Federal

award or cost objective in accordance with relative benefits received• Reasonable

– Costs that in its nature and amount, do not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made


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Allowable / Unallowable• Typically allowable direct costs:

– Salaries and Wages– Fringe Benefits– Subawards– Lab Supplies– Computing Devices– Participant Support Costs– Travel– Equipment

• Typically unallowable costs:– Alcohol– Alumni/ae Activities– Audit Services– Bad Debt– Lobbying


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Administrative / Clerical Salaries §200.413(c)• Generally, administrative and clerical salaries should not be

direct charged to federal awards• However, the UG allows if the following conditions are met:

– Administrative or clerical services are integral to a project or activity; – Individuals involved can be specifically identified with the project or

activity (and spend 20% / one day per week, on average);– Such costs are explicitly included in the budget or have the prior

written approval of the Federal awarding agency; and– The costs are not also recovered as indirect costs

• A form was created to assist you in determining whether it is appropriate to budget for and charge such costs:

http://www.bu.edu/uniformguidance/files/2014/10/Guidelines_Direct_Charging_Admin_Clerical_Costs_10.30.pdf




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Administrative / Clerical Salaries §200.413(c)• If proposed budget is awarded, Administrative / Clerical costs

that were included can be direct charged – If not explicitly included in the budget, PI’s can request a budget

change to the Federal Agency for existing awards under OMB Circulars citing this new UG change

• Administrative Salaries that are included as part of direct costs will be excluded from the F&A cost pools to avoid “double-dipping”


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Supplies• Supplies (§200.314)

– Unused supplies exceeding $5,000 in total aggregate value upon termination or completion of the project or program and the supplies are not needed for any other Federal award, BU must retain the supplies for use on other activities or sell them, but in either case, must compensate the Federal Government for its share

– PIs and Admins should ensure that they have less than $5,000 in unused supplies at Project End


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Computing Devices• Computing Devices (§200.453)

– Charging Computing Devices as direct costs is allowable for devices that are essential and allocable, but not solely dedicated to the performance of a Federal award

– Laptop and Desktop Computers, defined as supplies when the cost is less than the University’s capitalization threshold of $5,000 may be direct charged to a project or activity under the following circumstances:

• Machines are essential and allocable to the project in that they are necessary to acquire, store, analyze, process, and publish data and other information electronically

• Project does not have reasonable access to other devices or equipment that can achieve the same purpose


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Computing Devices

• Devices cannot be purchased for reasons of convenience or preference

• PIs are responsible for determining whether or not the device is essential and to what extent the cost of the device is allocable to the sponsored project

• PIs and departments should maintain documentation that describes how the proposed computing device is essential to the project


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Participant Support• Participant Support (§200.456)

– Defined as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences or training projects

– Are not routinely allowed on research projects but can be charged if the project includes an education or outreach component

– Are allowable with the prior approval of the Federal awarding agency


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Equipment• Equipment (§200.313)

– Title to equipment will vest with Boston University upon acquisition• Prior to Uniform Guidance, title to equipment purchased on a grant

belonged to BU but equipment purchased on a contract, title remained with the Federal Agency

– Use the equipment for the authorized purposes of the project until funding for the project ceases, or until the property is no longer needed for the purposes of the project

– Use and dispose of the property in accordance with federal and BU Guidelines

– http://www.bu.edu/cfo/post-award-financial-operations/departments/property-management-pm/resources-overview/


http://www.bu.edu/cfo/post-award-financial-operations/departments/property-management-pm/resources-overview/



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Policies and Procedures for Financial Reporting and Closeout of Sponsored

Awards

(Updated Existing BU Policy)


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Financial Reporting and Closeout

Boston University must be reimbursed by the Sponsoring Agency no later than 90 calendar days from the end of period

performance


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Financial Reporting and Closeout• Financial Reporting

– PAFO is responsible for the preparation and submission of individual interim, final and revised financial reports as well as final invoices

– General procedures for preparing and submitting financial reports:• Prior to award end date, an Award Ending Notice (AEN) is sent to PI and

Department Administrator– Award End Date– Final Report / Final Invoice Due Dates– Checklist of procedures to ensure that the award is in proper status for closeout

• Immediately after the award end date has passed, PAFO will send the PI and Department Administrator a message reminding them of all final financial reporting and/or final invoicing requirements and respective due dates

• PI / Department Administrator Responsibilities:– Identify any outstanding charges / credits that have yet to post to the account– Confirm the final award ending balance– Provide the completed Cost Share documentation form if applicable


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• Interim Financial Reports– Department approval is generally not required– PAFO will prepare and submit reports based on the transactions posted

to the account as of the end date of the interim reporting period– In some cases, sponsors deem interim reports as “final” for budgeting

or programmatic purposes. In such cases PAFO will work with the Department to ensure accuracy of the numbers

• Revised Financial Reports and Invoices– Revised reports should be a rare circumstance and must be legitimate– Credits to sponsors will always result in a revised report and invoice


If PI and / or Department Administrator does not respond, PAFO will submit the Final Financial Report to Agency as required with

expenses as of the end date in SAP.

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• Financial Closeout• Shared responsibility between PIs and PAFO

– Closeouts should be completed within 120 days of the award end date– Commitments must be closed– Remove any and all over-expenditures– Completeness of Billing and Collections– Budget adjustments, refunds and residual funds complete– Award status change in SAP


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• Non-Financial Closeout• Shared responsibility between PIs, PAFO and OSP

– PIs are solely responsible for the creation and submission of Progress and / or Technical Reports

– OSP Research Administrator will coordinate the submission of the Invention Statement

– Property Reports are the responsibility of the Property Management team within PAFO. Property Management will work with PI and Department Administrator as needed

– FFATA Reporting is the responsibility of the Subaward Administrator within Sponsored Programs


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Policy for the Treatment of Cost Sharing for Sponsored Awards (including

Supplementation of Training Grants)

(New BU Policy)


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Cost Sharing

• Shared oversight responsibility between Office of the Provost, OSP, PAFO, ROSA, and Budget Office.

• Purpose is to create a streamlined and uniform process for:– Cost share requests from Department, Dean, or Central Funds.– Cost share funding within SAP.– Cost share fund reporting for IDC rate negotiation.

• Identifies centralized responsibility for proper funding of mandatory and voluntary committed cost share accounts.

• Consistent with UG, states BU’s policy is to discourage Voluntary Committed Cost Sharing

• Voluntary uncommitted cost share in the form of training grants also covered by policy.


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Cost Sharing

Type of Cost Share Sponsor Type Who is Funding the Cost Share

Required Approval(s)

Mandatory Federal Non-Federal

Dept. Chair/Center Director

School Dean VP Research

Cost Share Funder(s) andIf CRC: VP Research If BUMC: School Dean

Voluntary Committed Federal Dept. Chair/Center Director


Cost Share Funder(s) and If CRC: VP ResearchIf BUMC: School Dean

Voluntary Committed Non-Federal Dept. Chair/Center Director

School Dean

Cost Share Funder(s)

Voluntary Uncommitted(Training Grants ONLY)

Federal Dept. Chair/Center Director


Cost Share Funder(s) andIf CRC: VP ResearchIf BUMC: School Dean


• Approval processes identified for:• Federal v. Non-Federal• Mandatory, Voluntary Committed/Uncommitted• Training Grant Supplementation

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Cost Sharing

• Documentation includes– Cost Share Policy– Budget Template for Non-Training Grant– Budget Template for Training Grant– Proposal Decision Tree and Workflow– Award Set Up Workflow

• Available on Research and OSP sites:– URL TBD

• Effective for any proposal submitted after 12/26/2014.


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Policies and Procedures for the Administration and Monitoring of Subawards Issued to Third Parties

(Updated BU Policy)


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Subaward / Subrecipient Monitoring

• Definitions – Subrecipient (§200.93)

• A non-federal entity that receives a subaward from a pass-through entity to carry out part of a Federal program

– Subaward (§200.92)• An award provided by a pass-through entity to a subrecipient for the

subrecipient to carry out part of Federal award received by the pass-through entity.

– Subrecipient Monitoring • Boston University undertakes the review of the financial status and

management controls of our Subrecipients. – Contractor

• Is defined as “an entity that receives a contract” which is defined as “a legal instrument by which a non-Federal entity purchases property or services needed to carry out the project or program under a Federal award.”


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• Subrecipient and Contractor Determinations (§200.330)– BU must make a case-by-case determination whether each agreement it

makes for the disbursement of Federal funds classifies the party receiving the funds as a subrecipient or a contractor

– Shared responsibility between PI and OSP for ensuring the proposal reflects the proper determination (subaward vs. contractor/consultant)


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• Characteristics of subrecipient and contractor


Subrecipient Contractor

Has its performance measured in relation to whether objectives of a Federal program were met

Provides the goods and services within normal business operations

Has responsibility for programmatic decision making

Provides similar goods or services to many different purchasers

Is responsible for adherence to applicable Federal program requirements specified in the Federal award

Normally operates in a competitive environment

In accordance with the agreement, uses the Federal funds to carry out a program for a public purpose specified in authorizing statute as opposed to providing goods or services for the benefit of the pass-through entity

Provides good or services that are ancillary to the operation of the Federal program and is not subject to compliance requirement of the Federal program as a result of the agreement

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• Requirements for Pass-Through Entities (§200.331)– A pass-through entity is a non Federal entity that provides a subaward

to a subrecipient to carry out part of a Federal program.– Every subaward must include the subrecipient’s negotiated Federal

indirect cost rate or, if no such rate exists, either a rate negotiated between BU and the subrecipient or a de minimis indirect cost rate of 10% MTDC.

– BU’s subrecipient monitoring activities must include:• Reviewing financial and programmatic reports• Evaluating the subrecipient’s risk of noncompliance to determine

additional subrecipient monitoring, which may include:– Providing subrecipients with training and technical assistance

on program-related matters; or– Performing on-site reviews of the subrecipient’s program

operations.

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• Principal Investigator Responsibilities– Responsible for reviewing and approving all subrecipient invoices

presented to Boston University• PI signature means that expenses claimed are reasonable and represent

progress-to-date– Responsible for obtaining Progress Reports from each subrecipient site

• PAFO / OSP Responsibilities– Risk Assessment of subrecipient entities before issuance– Conflict of Interest between PI and subrecipient entities

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Sponsored Program Effort Certification Policy

(NO Changes . . . Yet. . . )


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Effort Reporting

• Compensation for Personal Services (§200.430)– Eliminated from UG

• “Certification”• Specific examples for acceptable validation

– Many of same principles over what is acceptable do not appear to have explicitly changed. . . Charges must still be based on percentage distribution of total institutional base salary activities

– We will continue to follow the “After the Fact” reporting method• Professional Staff certify their effort twice a year• Non Professional Staff certify their effort four times a year• Students (non hourly) certify their effort on an annual basis


The federal audit community has not bought into the full “elimination” of effort reporting. We are monitoring closely.

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Procurement

(NO Changes . . . Yet. . . )


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Procurement

• Procurement (§200.317-323)

• Good news!– Grace period through July 1, 2016– More clarification to come, should be able to apply university-wide

contracts to the small purchase thresholds


Threshold Method

Less than $3,000 (micro-purchase) No competitive bidding

$3,001 - $150,000 (small purchase) Relatively simply and informal, but do require price or rate quotations from an adequate number of sources

Greater than $150,000 Requires sealed bidding, competitive proposals or sole source justification

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Now What?


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Next Steps

• www.bu.edu/uniformguidance• Draft Policies are available

– Feedback / comments / questions to [email protected]

• Individual Agencies will release their individual work plans by 12/26/2014


http://www.bu.edu/uniformguidance


1 uniform guidance med campus hiebert lounge 11/18/2014 12:00 – 2:00 pm cr campus colloquial room...

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