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NSF Tribal College Workshop Award Monitoring & Business Assistance November 14, 2008 NSF Tribal College Workshop Award Monitoring & Business Assistance November 14, 2008

Ask Early, Ask Often! Name Title Contact Charlie Zeigler Special Assistant, Cost Analysis & Ask Early, Ask Often! Name Title Contact Charlie Zeigler Special Assistant, Cost Analysis & Audit Resolution Division of Institution & Award Support (DIAS); Office of Budget, Finance & Award Management (BFA) [email protected] gov (703) 292 -4578 2

NSF Award Portfolio • Active award dollars - $19. 7 billion • Active awards NSF Award Portfolio • Active award dollars - $19. 7 billion • Active awards – 34, 370 • Awardee Institutions – 2, 200 • 81% of NSF awards less than $500, 000 • Tribal Colleges 39 awards $81, 893, 262 • Average Tribal College award size $2, 099, 827 at 22 organizations 3

BSF Risk Assessment • Award Factors – Amount, Type of award instruments, Sub-awards, Participant BSF Risk Assessment • Award Factors – Amount, Type of award instruments, Sub-awards, Participant Support, Equipment, • Institutional Factors – Awardee Type, NSF Cognizant, Experience • Previous Monitoring results – OIG Audits, A 133, Site Visits, Desk Reviews • NSF Admin & Program – FCTR, FPR, Special Payment, Annual Call to Program 4

Post Award Monitoring Program • Business System Reviews – Large Facilities • Award Monitoring Post Award Monitoring Program • Business System Reviews – Large Facilities • Award Monitoring and Business Assistance Site Visits – CAAR & DGA • Award Monitoring Desk Reviews – CARRB contract with Booz Allen Hamilton • Transaction Testing – DFM contract with Mc. Bride Lock & Associates • Baseline Monitoring – DGA DACS • NSF OIG – Audit & Investigations 5

Baseline Monitoring • DGA, DACS, DFM – general NSF business Systems, automated checks and Baseline Monitoring • DGA, DACS, DFM – general NSF business Systems, automated checks and system edits, generating awards, continuing increments • No Cost Extensions, Change in PI, Cost Sharing, Financial Reporting FCTR-FFR, Award Terms & Conditions, Approvals • Program – Annual Reports, Site Visits, Mid. Term Review – future funding years 4 -5, PI meetings 6

Transaction Testing - DFM • Contract with Mc. Bride Lock & Associates for Improper Transaction Testing - DFM • Contract with Mc. Bride Lock & Associates for Improper Payment Act – Government wide requirement • Based on Risk Assessment – Statistical Sample by category • FCTR reconciliation between costs reported and Project Cost Accounting record • Select Sample transaction – allowable cost 7

Award Monitoring Desk Reviews • Contract with Booz Allen Hamilton • High and Medium Award Monitoring Desk Reviews • Contract with Booz Allen Hamilton • High and Medium Risk Organizations • General Management Survey – written policies and Procedures, Organization Chart, Duties and Key Personnel, Expenditure Approvals • Accounting & Financial – Allowable Costs, A 133 audit, Project Cost Accounting, Time & Effort Reporting, Cost Policy Statement (direct or indirect), • FCTR Reconciliation 8

AMBAP – Site Visits • High Risk and Program Recommended • Core Review Modules AMBAP – Site Visits • High Risk and Program Recommended • Core Review Modules – General Management, Accounting & Financial System, FCTR reconciliation • Targeted Review Modules – Time & Effort, Fringe Benefits, Travel, Consultants, Cost Sharing, Participant Support, Indirect Costs, Procurement, Subrecipient Monitoring, Property & Equipment, Program Income, Final Project Reporting 9

Business System Reviews • Large Facility Office – Research Platforms, Construction MREFC, FFRDC, all Business System Reviews • Large Facility Office – Research Platforms, Construction MREFC, FFRDC, all high risk awards • Modules or Systems– Award Management, General Management, Planning & Budget, Financial Management, Financial Reporting, Procurement, Property & Equipment, Human Resources. 10

Audits • OMB Circular A-133 (Old A-128) requires Annual Independent Audit if expenditures of Audits • OMB Circular A-133 (Old A-128) requires Annual Independent Audit if expenditures of Federal Funds > $500, 000 / year • Schedule of Federal Financial Assistance, Compliance, Internal Control, Transaction Testing • NSF OIG – Audit and Investigations 11

AMBAP Site Visits • Pre-Site Visit – 4 weeks – Notify awardee and Coordinate AMBAP Site Visits • Pre-Site Visit – 4 weeks – Notify awardee and Coordinate time, Request Documentation, Internal – PO & Award Review, Analysis, Plan • Site Visit – 3 -4 days - Entrance Conference, Field Work & Interviews, Exit Conference • Post Site Visit – 90 days - draft report, Letter to awardee, Awardee Responds • Close-out – 10 days - Determination on awardee response, Corrective action and • Follow-up - if required 12

General Management • Organizational Structure • Internal Controls • Written policies and Procedures and General Management • Organizational Structure • Internal Controls • Written policies and Procedures and how well they are followed • Management Staff & Duties • Safeguards and crosschecks – segregation of duties 13

Accounting & Financial Sytems • Management and accounting controls related to charges on NSF Accounting & Financial Sytems • Management and accounting controls related to charges on NSF award • Financial Accounting System • Project Cost Accounting • Books of Account – General Ledger, Project Ledger, Chart of Accounts, Journals - Receipts, Disbursements, Purchases • Unallowable cost accounting 14

FCTR Reconciliation • Billing system and requests for funds from NSF = Cost shown FCTR Reconciliation • Billing system and requests for funds from NSF = Cost shown in award project accounts • Established procedures for preparing requests • Can reconcile draw downs to expenditures for the project • Minimize time to expend if receives advances 15

Time & Effort Reporting • Policies and Procedures for completing • Can bill based Time & Effort Reporting • Policies and Procedures for completing • Can bill based on budget or estimates, but • After the Fact Verification of Actual Effort • Signed by Employee or Supervisor • First Hand Knowledge of employee activities (suitable means of verification) • Accounts for all activities (percentage) • Generally, prepared at least semi-annually (faculty) 16

Travel • Written policies and procedures • Documentation of costs • Per diem rates Travel • Written policies and procedures • Documentation of costs • Per diem rates or actual • In-Travel Status (local meals? ) • US Flag Air-carriers • Premium Airfare 17

Participant Support Costs • Funds budgeted for P/S – requires NSF PO approval to Participant Support Costs • Funds budgeted for P/S – requires NSF PO approval to re-budget • Account for through sub account code • Exclude from IDC allocation base • Documentation attendance eligibility workshops • Not Employees – Stipends, Allowances, other payments 18

Procurement • Written policies and procedures (purchasing manual) • Segregation of Duties, Approval Levels, Procurement • Written policies and procedures (purchasing manual) • Segregation of Duties, Approval Levels, Authorities • Sole source Justification, Excluded Parties, COI • Cost and Price Analysis • Required flow down provisions 19

Subrecipient Monitoring • Prime awardee responsible for subawardee (privity of contract) • Preaward Review Subrecipient Monitoring • Prime awardee responsible for subawardee (privity of contract) • Preaward Review – risk assessment • Subcontract document (clauses and flow down) • Monitoring – Technical, Financial A-133 reports • Special award Conditions 20

Property & Equipment • More than $5, 000 and one year useful life • Property & Equipment • More than $5, 000 and one year useful life • Scientific not general purpose • Exclude from IDC calculation • Records and Inventory • Title vesting 21

Questions? • Charlie Zeigler • Cost Analysis & Audit Resolution • (703) 282 -4578 Questions? • Charlie Zeigler • Cost Analysis & Audit Resolution • (703) 282 -4578 • [email protected] gov 22