OMB CIRCULAR A-110 - Office of Research

Report
OMB CIRCULAR
A-110
Uniform Administrative Requirements for
Grants and Agreements With Institutions of
Higher Education, Hospitals, and Other NonProfit 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 RequirementsPurpose
 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 RequirementsApplicability
 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 misapplication
Prime recipient passes on circular applicable
to prime recipient to subrecipient, even
though it does not apply to subrecipient
Subpart A – General
Example of proper application of Circulars
F L O R ID A D E P T . O F
E D U C A T IO N
P rim e R e c ip ie n t o f N S F
a w a rd
O M B A-1 0 2 a p p lie s
O M B A-1 0 2 a p p lie s
FSU
S u b re cip ie n t
O M B A-1 1 0
a p p lie s
G e o rg ia D e p t. o f
E d u c a tio n
S u b re cip ie n t
O M B A-1 0 2
a p p lie s
Subpart A – General
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
SUBPART B
Pre-Award Requirements
 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
SUBPART B
Pre-Award Requirements





Drug Free Workplace
Lobbying
Debt, Debarment and Suspension
Conflict of Interest
Misconduct in Science
Subpart B – Pre-award
SUBPART B
Pre-Award Requirements
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 B – Pre-award
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 Requirements
1. Financial and Program Management
A. Standards for financial management
B.
C.
D.
E.
F.
G.
H.
systems
Payment
Cost sharing or matching
Program income
Revision of budget & program plans
Non-Federal audits
Allowable costs
Period of availability of funds
SUBPART C – POST-AWARD REQUIREMENTS
A.
Eight Standards for
Financial Management Systems
SRAS
1. 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 REQUIREMENTS
Financial 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
SUBPART C – POST-AWARD REQUIREMENTS
Financial and Program Management
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
SUBPART C – POST-AWARD REQUIREMENTS
Financial and Program Management
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
SUBPART C – POST-AWARD REQUIREMENTS
Financial and Program Management
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
SUBPART C – POST-AWARD REQUIREMENTS
Financial and Program Management
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
SUBPART C – POST-AWARD REQUIREMENTS
Financial and Program Management
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 preaward costs
SUSUBPART C – POST-AWARD REQUIREMENTS
Financial and Program Management
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
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 REQUIREMENTS
Property 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 REQUIREMENTS
Property Standards
Property StandardsNon 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 REQUIREMENTS
Property 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)
SUBPART C – POST-AWARD REQUIREMENTS
Property Standards
Property StandardsSupplies 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
SUBPART C – POST-AWARD REQUIREMENTS
Property Standards
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
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 REQUIREMENTS
Procurement Standards
Procurement StandardsCodes 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
SUBPART C – POST-AWARD REQUIREMENTS
Procurement Standards
Procurement StandardsCodes 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
SUBPART C – POST-AWARD REQUIREMENTS
Procurement 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
SUBPART C – POST-AWARD REQUIREMENTS
Procurement Standards
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
contractors
SUBPART C – POST-AWARD REQUIREMENTS
Procurement Standards
Procurement StandardsCost 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
SUBPART C – POST-AWARD REQUIREMENTS
Procurement Standards
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
SUBPART C – POST-AWARD REQUIREMENTS
Procurement Standards
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
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 REQUIREMENTS
Reports and Records
Reports and RecordsFinancial 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 REQUIREMENTS
Reports 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 REQUIREMENTSReports and Records
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
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?

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