Circular A-110

1. Circular A-110 Everything You Didn’t Want to Know

2. Purpose of A-110Subpart C- Post Award • Establishes uniform administrative requirements for Federal grants and agreements awarded to institutions of higher ed, hospitals, and other non-profit organizations.

3. Post Award Requirements • A-110 Subpart C - Sets standards for financial and program management of sponsored research awards in: FINANCIAL & PROGRAM MANAGEMENT • Methods for making payments • Cost sharing and matching requirements • Accounting for program income • Budget Revisions • Audits • Allowability of Costs • Establishing Fund availability

4. Standards for financial management systems • Relate financial data to performance data • Financial system must provide: • Financial results of each project • Identification of source & application of funds • Control & accountability over all funds, property & other assets • Comparison of outlays to budget amounts

5. Standards (cont.) • Procedures to minimize time between transfer of funds and disbursement of funds • Procedures to determine reasonableness, allocability, and allowability of costs • Accounting records supported by source documentation

6. Cost Sharing/Matching Funds

7. Definitions of Cost Sharing (Matching Funds) • A commitment made by WSU to fund a portion of the total cost of a sponsored agreement. The commitment may be for direct and/or indirect costs, and may consist of WSU funds or funds from outside sources. Matching may either be classified as voluntary or mandatory. Either form is a true commitment and must be fully documented.

8. Cost Sharing (Match) must meet all of the following criteria:In general, same requirements apply to Non-Federal Share as apply to the Federal Share • Verifiable from recipient’s records • Not included as Match for any other federally funded program • Necessary and reasonable • Allowable under the applicable Cost Principles • Not paid by the Federal Government under another award • Provided for in the approved budget • Conform to other provisions

9. Types of Cost Sharing • Mandatory Cost Sharing • Voluntary Cost Sharing • Third Party In Kind Contributions • Facilities and Administrative (F&A), also known as Indirect Costs

10. What Can be Used to Meet Match Requirements? • Cash • Third Party Contributions • Unrecovered F&A costs (Indirects) • Contributions of services and property • Volunteer Services (necessary for project) • Other employee services (regular rate + benefits) • Donated supplies (at reasonable & fair market value)

11. Unrecovered Indirect Costs • May be included as part of cost sharing or matching only with the prior approval of the awarding agency. • Current approved rate agreement is 36% of Salaries, Wages and Benefits

12. Audit Procedures for Match Compliance • Verify that required Matching Contributions were met • Ascertain sources of matching contributions and verify that they were from an allowable source • Test records to corroborate that value of in-kind contributions are in accordance with OMB cost principals • Verify transactions used to match are in compliance with allowable cost principles

13. Procurement Standards PURPOSE: To establish procedures for procurement of supplies and other expendable property, equipment, real property, and other services

14. Codes of Conduct regarding Awards and Administration of Contracts • Recipients shall maintain written standards of conduct governing performance of employees involved • Cannot participate if conflict of interest exists • Cannot accept gratuities, favors, or anything of monetary value from contractors, subs, or parties to subgrants

15. Competition • Must provide open and free competition • Contractors that develop or draft specs or requirements, statements of work, invitations for bids and/or requests for proposals are excluded

16. Required Written Procurement Procedures • Recipients must not purchase unnecessary items • Determine which procurement methods are most economical and practical • Positive efforts to utilize small business, minority owned firms & women’s business enterprises, whenever possible

17. Procurement procedures (cont.) • Solicitations for goods & services must provide: • Clear & accurate descriptions of technical requirements • Specify requirements which bidders must fulfill • Describe minimum acceptable standards • Include specific features of “brand name or equal” descriptions • Acceptance of products & services dimensional in the metric system • Preference for products & services that conserve natural resources, protect the environment, and are energy efficient – when practicable and economicaly feasible

18. Record retention & access requirements • Financial records, supporting documentation, and statistical records – Three (3) years from date of submission of final report • If litigation occurs – until all litigation or claims are resolved • Real Property or Equipment – Three (3) years after final disposition

19. Closeout • All reports (financial, performance, other) must be submitted within 90 days after completion date of award • Unless extension granted, all obligations incurred must be liquidated within 90 days • Prompt refund of any balances of unobligated cash advances • Awarding agency to make settlement for any upward or downward adjustments to costs after closeout reports received

20. Closeout (cont.) • Accounting of real or personal property acquired with federal funds • If no final audit done prior to closeout, awarding agency retains right to recover disallowed costs resulting from the final audit

21. Closeout Does Not Affect: • Right to disallow costs and recover funds on the basis of a later audit • Obligation of recipient to return funds due • Audit requirements • Property management requirements • Record retention