NSF Tribal College WorkshopAward Monitoring

& Business AssistanceNovember 14,

2008

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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)

czeigler@nsf.gov(703) 292-4578

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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

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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

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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 McBride Lock & Associates

•Baseline Monitoring – DGA DACS•NSF OIG – Audit & Investigations

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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

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Transaction Testing - DFM•Contract with McBride 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

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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

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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

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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.

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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

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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

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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

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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

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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

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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)

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Travel

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

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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

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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

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Subrecipient Monitoring

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

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Property & Equipment

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

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Questions?

•Charlie Zeigler•Cost Analysis & Audit Resolution•(703) 282-4578•czeigler@nsf.gov