Award Monitoring & Business Assistance

1. Award Monitoring & Business Assistance NSF Tribal College Workshop November 14, 2008

2. Ask Early, Ask Often!

3. 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

4. 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

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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.

11. 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

12. 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

13. 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

14. 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

15. 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

16. 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)

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

18. 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

19. 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

20. 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

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

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