Basics of Circular A-110

1. Basics of Circular A-110 Holly Benze, Director, Research Projects Administration, Johns Hopkins University Anthony Beckman, Research Administrator, University of Rochester

2. What is the Purpose of A-110 According to the circular itself: “This circular sets forth standards for obtaining consistency and uniformity among federal agencies in the administration of grants to and agreements with institutions of higher education, hospitals, and other non-profit organizations” NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

3. So what in the world does that mean? • In a nutshell – 2 things: 1. A-110 sets the MAXIMUMadministrative requirements that federal agencies may require from institutions. 2. Establishes the MINIMUM administrative standards for institutional systems and procedures. NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

4. General (Subpart A) Pre-award Requirements (Subpart B) Post-award Requirements (Subpart C) financial & program management Property standards Procurement standards Reports and records After-the-award requirements (Subpart D) Uniform Administrative Requirements

5. Subpart A • Equipment: Tangible, non-expendable property charged directly to an award having a useful life of more than a year and an acquisition cost >= $5000. • Program income: gross income earned by the recipient that is generated by a supported activity or earned as a result of the award. • Subaward: An award of financial assistance, through any legal agreement, made under and award by a recipient to a Subrecipient. Does not include procurement of goods and services. NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

6. Subpart B • Instruction on appropriate award mechanism (Grant/Cooperative Agreement/Contract) • Prescribes the use of the SF424 (thanks to the “Controlling paperwork Burdens on the Public”) • Debarment and Suspension • Special Award Conditions NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

7. Post-Award Requirements • Financial and Program Management • Standards—written procedures, accounting records, & controls • Payment—Check, EFT, advance • Cost Sharing or Matching • Mandatory or Voluntary (Committed or uncommitted) • Must be an allowable expense on the award • Can be cash, in-kind, or third-party NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

8. Financial & Program Management (cont.) • Program Income • How should it be used? 1) Added to the project*, 2) deducted from the award amount, or 3)used to fund the non-federal share *Default if not in the award and for research • Usually counts as program income only during the project period NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

9. Financial & Program Management (cont.) • Revision of Budget and Program Plans • Prior approval required for: -change in scope -change in key personnel -need additional funds -absence of PI for more than 3 months -reduction of effort of 25% or more -transfer of funds from participant support -issuing a subaward for substantive effort if not in proposal NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

10. Financial & Program Management (cont.) • Expanded Authority • Pre-award costs • One-time no-cost extension • Automatic carry-forward • Non-Federal Audits (A-133) Instructions • Allowability of Costs (A-21, A-87, A-122) • Period of Availability of Funds (Instructions on spending period) NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

11. Property Standards • Instructions on management and disposition of property • Instructions on management and disposition of equipment, supplies, intangible property and data NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

12. PROCUREMENT STANDARDS • To make sure that materials and services are procured in an effective manner and in compliance with Federal statutes • Written standards to prevent a conflict of interest when procuring a contract • Free and open competition • Procurement procedures Must be written NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

13. Procurement Procedures (cont.) Effort to use small, minority, or women-owned business Cost and price analysis—reasonableness, allocability, and allowability Procurement records Contract provisions and administration NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

14. Reports and Records • Procedures for monitoring and reporting on projects—financially and technically including any subawards • Frequency and due dates of reports • What the reports should contain and on what forms • Site visits • Record retention NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

15. Reports and Records (cont.) • Termination and Enforcement • When can awards be terminated • Why: cause, convenience, mutual agreement • Remedies for enforcement • Withhold payments • Disallow charges • Suspend or terminate • Withhold further awards • Other legally available remedies NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

16. AFTER-THE-AWARD REQUIREMENTS • Closeout Procedures • End of project reports: technical, final financial, equipment, and invention (when and what) • Adjustments—disallowances, repayments • Audit? NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

17. Case Studies Questions Anthony Beckman – abeckman@ORPA.Rochester.edu Holly Benze – hab@jhu.edu NCURA 54th annual Meeting, November 4-7, 2012, Washington DC