Fiscal Compliance CornerRecent Happenings, etc.

MRAM March 2015

Ted MordhorstDirector for Post Award Financial ComplianceResearch Accounting & Analysis

OMB Uniform Guidance 2 CFR 200

Cost Principals Basic Principals have not changed

Allowable (not unallowable in regulation or award)

Allocable (provides a direct benefit to the project and is Necessary or Essential to the objectives of the award)

Reasonable (a prudent person would accept as allowable & allocable)

Consistent treatment (not otherwise recovered in the F&A rate)

OMB Uniform Guidance 2 CFR 200

Specific costs added or changed Computing devices (desktops, laptops, tablets,

smartphones, etc.) Essential and allocable to but not solely used on the

project.

Child care costs related to conferences Specific to Conference grants or other grants hosting

a conference Identifying child care resources is allowable Paying for child care is unallowable

OMB Uniform Guidance 2 CFR 200

Specific costs added or changed Participant Support Costs (exempt from F&A)

paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training projects

Requires sponsor approval

Child care costs related to conferences Specific to Conference grants or other grants hosting a

conference Identifying child care resources is allowable Paying for child care is unallowable

OMB Uniform Guidance 2 CFR 200

Specific costs added or changed Direct Billing of Administrative/Clerical Salaries

integral to a project or activity requires sponsor approval individuals specifically identified with the project or

activity

Publication and printing costs May incur costs anytime before closeout Must be paid before federal closeout

OMB Uniform Guidance 2 CFR 200

Specific costs added or changed Short Term Visa Costs

Travel visa costs as opposed to immigration visa costs

Must be critical and necessary to the project

Value Added Tax (VAT) Legally required to pay in country are allowable

OMB Uniform Guidance 2 CFR 200

Prior approval requirements: (2 CFR 200.407)

Encouraged to seek prior approval for cost items when it is difficult to determine reasonableness and/or allocability.

A help document has been published which describes the various prior approval requirements under the UG. http://www.washington.edu/research/topics/uniform-grant-guidance

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Graduate Student Compensation NIH

GIM 30 (http://www.washington.edu/research/osp/gim/gim30.html)

NIH will not fund a GA for more than the NRSA -0- level post-doc stipend amount.

GA compensation is defined as Salary + Fringe Benefits + Tuition.

Unreasonable to compensate a Graduate Student at a rate that exceeds what a post-doc is paid.

Graduate Student Compensation NIH

NIH does allow rebudgeting to pay a Graduate Assistant (GA) more than was funded

Rebudgeting to pay a GA up to the salary level paid to a first year post doc in your department

Post-doc compensation is defined as salary and fringe benefits

Audit News

NSF Data Analytics AuditSecond Round

Targeted:Food and gift type transactions

Transactions at or near the end of the award period

Cost Transfers (salary and non-salary)

NSF Data Analytics Audit Questions:

Please explain why this equipment was not included in the NSF proposal budget.

How did this equipment purchase benefit the award given the limited time remaining on the award?

Was this equipment used exclusively on this NSF award?

NSF Data Analytics Audit Questions:

Please provide the allocation methodology and a list of the other projects in the allocation.

Why was this purchase required when you indicated that you had all the necessary equipment and/or facilities?

Please provide the reason for the transfer and why it was necessary so late in the award.

NSF Data Analytics Audit Questions:

Please explain why this purchase was necessary for and how it benefited the award.

What was the budget amount and the remaining balance at the time of the transfer?

NSF Data Analytics AuditThese questions demonstrate the type of documentation/justification you should be keeping to support transactions posting to sponsored projects.

They also provide insight into what should be considered before incurring an expenditure or processing a cost transfer.

NSF Data Analytics AuditThese questions demonstrate the type of documentation/justification you should be keeping to support transactions posting to sponsored projects.

They also provide insight into what should be considered before incurring an expenditure or processing a cost transfer.

Final thought Both in the UG and in the audit there is

an increased emphasis on “necessary”, “essential” and “integral” to define when a cost is allowable.

It behooves us to think in these terms when processing transactions

QUESTIONS?