OMB CIRCULAR A-110 Uniform Administrative Requirements for Grants and Agreements With Institutions...

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


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 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


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


Drug Free Workplace Lobbying Debt, Debarment and Suspension Conflict of Interest Misconduct in Science


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 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


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


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


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


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


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


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

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)


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


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


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


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


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


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


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

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!!

Questions?

OMB CIRCULAR A-110 Uniform Administrative Requirements for Grants and Agreements With Institutions...

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