1 / 43

CRA/CFRA STUDY SESSIONS Study Team Hosts Jasmine Burno & Theresa Yockey

CRA/CFRA STUDY SESSIONS Study Team Hosts Jasmine Burno & Theresa Yockey. OVERVIEW. Study sessions format 13 bi-weekly 1 hour sessions 30 – 45 min topic review 15 – 30 min Discussion/Q&A Resources Research Administrators Certification Council (RACC) VT CRA Study Team. Session One.

woodsr
Download Presentation

CRA/CFRA STUDY SESSIONS Study Team Hosts Jasmine Burno & Theresa Yockey

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. CRA/CFRA STUDY SESSIONSStudy Team HostsJasmine Burno & Theresa Yockey

  2. OVERVIEW • Study sessions format • 13 bi-weekly 1 hour sessions • 30 – 45 min topic review • 15 – 30 min Discussion/Q&A • Resources • Research Administrators Certification Council (RACC) • VT CRA Study Team

  3. Session One OMB Uniform Guidance

  4. What is it? The OMB Uniform Guidance is a new set of regulations (as of 12/16/2013) which consolidates several OMB Circulars, including A21, A110, and A133.   These regulations impact the proposals you make for federal funding, the way grants and contracts are managed, and the cost principles that guide research at the University of Cincinnati.

  5. Purpose of UG • Removes previous guidance that is conflicting and establishes standard language; • Directs the focus of audits on areas that have been identified as at risk for waste, fraud and abuse; • Lays the groundwork for Federal agencies to standardize the processing of data; • Clarifies and updates cost reporting guidelines for award recipients.

  6. Federal Regulations - 2CFR200 Subpart A-§200.000 Acronyms & Definitions Subpart B- §200.100 General Provisions Subpart C- §200.200 Pre-federal Award Requirements and Content of Federal Awards Subpart D- §200.300 Post Federal Award Subpart E- §200.400 Cost Principals Subpart F- §200.500 Audit Requirements

  7. TOP 10 CHANGES #1 - Effective date (§ 200.110) For all new awards and incremental funding of existing awards after December 26, 2014.  However, non-federal entities may elect to manage all federal awards, new and existing, in accordance with the UG as of December 26, 2014.

  8. TOP 10 CHANGES #2 - Conflict of interest (§200.112) This section relates primarily to how decisions are made to select subrecipients and procurements (contractors).

  9. TOP 10 CHANGES #3 - Procurement (§200.317 – §200.326) These regulations may be more restrictive under the UG than what some organizations are accustomed to.  There is a grace period for implementation of the updated procurement standards, and for calendar year-end 2015 and fiscal years ending in 2016, you may elect to adopt the UG or continue to follow the old regulations (OMB Circulars A89, A-102 and A-110).  However, you must document your election and ensure your policy is in compliance with the rules elected.

  10. TOP 10 CHANGES #4 - Internal Controls (§200.303) This is a section that should be reviewed by all organizations. Important items to note are: There is more explicit reference to existing internal control requirements in the UG, and this section is included in the administrative requirements. Previously, internal controls were discussed primarily in OMB Circular A-133 as part of the audit after the costs had been incurred. The section clarifies the meaning of “must” and “should.” “Must” is not optional.  “Should” is recommended.

  11. TOP 10 CHANGES #5 - Indirect F&A costs (§200.414) Federal agencies and pass-through entities must accept an indirect F&A cost rate negotiated with a federal agency, or notify the OMB as to why the negotiated rate is not accepted and make publicly available the criteria to support the deviation.  The updated guidance also allows for a one-time extension of your organization’s current negotiated indirect cost rate for a period of up to four years.

  12. TOP 10 CHANGES #6 - Indirect F&A cost recovery for subrecipients(§200.331 and §200.414) Except if the federal program is subject to a reduced indirect F&A rate, a pass-through entity “must” pay a sub-recipient its federally negotiated rate, or, If the subrecipient has never negotiated an indirect F&A cost rate with a federal agency, the subrecipient may request a de minimus F&A rate of 10% of modified total direct costs, or negotiate an indirect F&A cost rate with the awarding entity. In order to obtain the 10% de minimus rate, the subrecipient must have never had a federally negotiated indirect F&A cost rate.

  13. TOP 10 CHANGES #7 - Subrecipient monitoring (§200.331) Pass-through entities are required to evaluate the subrecipient’s risk and determine appropriate monitoring activities based on that risk assessment.  This section also specifies both mandatory and optional subrecipient monitoring obligations.  In addition, audit reports from subrecipients are now expected to be obtained by the pass-through entity from the Federal Audit Clearinghouse (available later in 2015) instead of requesting the audit reports from the subrecipient.

  14. TOP 10 CHANGES #8 Compensation - personal services (§200.430) Commonly referred to as “time and effort reporting.”  This section has been modified and now focuses more on stringent internal controls surrounding compensation costs instead of on specific procedures that must be followed in tracking and allocating the costs.  For instance, no specific “certification” of time records is required, and the UG recognizes advances in technology that may result in electronic employee time records incorporated as part of the payroll system.  However, many organizations have invested considerable effort in enforcing their current compensation tracking and allocation policies and are hesitant to relax or modify their processes.

  15. TOP 10 CHANGES #9 - Required certifications (§200.415) To assure expenditures are “proper and in accordance with the terms and conditions of the award”, the annual and final fiscal reports or vouchers requesting payment must include a certification, signed by an official who is authorized to legally bind the non-federal entity.

  16. TOP 10 CHANGES # 10 - Audit considerations – Subchapter F If your organization’s year-end is December 31, it is likely there will be little effect to your 2014 audit.  But if your fiscal year-end is after December 31, 2014, and your organization has received new federal awards or incremental funding of existing awards, expect your FY2015 audit to include test procedures under both sets of regulations: the OMB Circulars and the UG.  The compliance supplement, Part 3, is issued every year and provides guidance to the auditor for auditing the 14 compliance requirements.  The 2015 compliance supplement is broken into 2 parts: Part 3.1 addresses federal awards existing before December 26, 2014, and subject to the OMB Circulars; and Part 3.2 addresses new federal awards or incremental funding after December 26, 2014. A draft of Part 3.1 is currently available and is expected to be finalized in March 2015. Both the Davis-Bacon Act and the Real Property Acquisition testing requirements have been removed from Part 3.1.  It is expected that the FFATA testing requirements over sub-awards will also be removed.  Part 3.2 is not yet available.

  17. questions

More Related