About Costs Primer

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10 Νοε 2013 (πριν από 3 χρόνια και 9 μήνες)

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Division of Grants Compliance and Oversight

Office of Policy for Extramural Research Administration, OER

National Institutes of Health, DHHS



NIH Regional Seminar


Baltimore, MD


June 2013


1

Diane Dean
, Director



Kathy Hancock
, Assistant Grants Compliance Officer


Sahar Rais,
Assistant Grants Compliance Officer


Cost Principles


Administrative
Standards


Audit Requirements


Grant Award Basics


Award Restrictions


Responsibilities


Accounting Basics




Monitoring Basics


Subrecipient

Monitoring


Other Cost
Considerations


NIH Financial
Reporting Basics


Closeout



2


OMB Circular A
-
21 (2 CFR Part 220)
-

Educational Institutions


OMB Circular A
-
122 (2 CFR Part 230)


Non
-
Profits


OMB Circular A
-
87 (2 CFR Part 225)


State/Local Governments


45 CFR Part 74, Appendix E
-

Hospitals


48 CFR Subpart 31.2 (FAR)


For
-
profits



Foreign institutions comply with the applicable cost principles
depending on the type of organization

http://www.whitehouse.gov/omb/circulars/

http://www.gpoaccess.gov/cfr/index.html

4


Establishes principles for determining
costs applicable to grants, contracts, and
other agreements


Direct costs


F&A/indirect costs


Selected items of cost

o
allowable/unallowable costs

o
time and effort reporting

5


OMB Circular A
-
110


relocated to 2 CFR Part
215
-

Uniform Administrative Requirements
for Grants and Agreements with Universities,
Hospitals and Other Non
-
Profit
Organizations (domestic and foreign)




6

Prescribes:



Preaward

requirements


Postaward

requirements


Also includes requirements for:

o
Payment

o
Matching or Cost sharing

o
Accounting for program income

o
Revision of budget and program plans

o
Non
-
Federal audits

o
Allowable costs



Financial management systems standards


Property standards


Procurement standards


Reports and records



7


In general, OMB Circular A
-
133 requires a State
government, local government, or non
-
profit
organization (including institutions of higher
education) that expends $500,000 or more per year
under Federal grants, cooperative agreements,
and/or procurement contracts to have an annual
audit by a public accountant or a Federal, State, or
local government audit organization.



Foreign and Commercial (for
-
profit) organizations
are subject to audit provisions contained in 45 CFR
74.26(d) and the NIH Grants Policy Statement (GPS).



8

Summary of Applicable Regulations

Grantee Type

Administrative

Requirements

Cost Principles

Audit Requirements

State & Local
Governments

A
-
102

(45 CFR Part 92)

A
-
87

(2 CFR Part 225)

A
-
133










_________________

45 CFR Part 74.26(d)

Colleges &
Universities

A
-
110

(2 CFR Part 215)


A
-
21

(2 CFR Part 220)


Non
-
Profits

A
-
122

(2 CFR Part 230)


Hospitals

45 CFR Part 74,
Appendix E

For
-
Profits

FAR 31.2

(48 CFR Subpart
31.2)

Foreign

As stated above
for the grantee
type


NIH GPS, uses

45 CFR Part 74.26(d)


9

10


Terms of Award


Section III

o
45 CFR Part 74 or 92
-

HHS rules and
requirements that govern the administration of
grants

o
NIH Grants Policy Statement (GPS)


policy
requirements that serve as the terms and
conditions of NIH awards (latest version
10/01/12)

o
Program legislation

o
Appropriation acts

o
Program regulations

42 CFR Part 52
-

Grants for Research Projects



Special Terms and Conditions


Section IV


11


Only applied to a particular grant for cause


Shown on the Notice of Award (
NoA
) after Section III


Institute and/or Center specific terms of award


Funds usually are not restricted in the Payment
Management System


Restricted funds must be tracked by grantee to
ensure compliance


o
EXAMPLE of Award Restriction: Funds may not be
used to purchase equipment without the written prior
approval of the NIH awarding component.

12



A. The Principal Investigator



B. The Departmental Administrator



C. The Department Chair



D. The Institution


13

14


Requires that:

o
Separate account is established for each project


o
Program Income is identified and accounted for
by project


o
Program Income is used in accordance with the
appropriate alternative, i.e.,


Additive


Deductive


Combination


Matching



15


Requires that:

o
Expenses are charged in accordance
with


NoA

Terms and Conditions


NIH Grants Policy Statement


Salary Cap / Rate Limitation


Cost Accounting Standards


OMB Circulars

o
ALL
expenses are appropriately documented



16

17


Requires that:

o
Actual expenses are periodically compared with budget


o
Actual expenses are
accurate,

i.e., reasonable, allocable,
allowable and consistently charged


o
Mischarges are corrected in a timely manner (cost transfers)


o
Prior approvals are obtained when required


o
Subrecipient

expenses are monitored


(Grantee’s
responsibility to monitor expenses)



18


Actual expenses should be compared at
least monthly to the budget to ensure:


o
Total funds on the grant have not been exceeded

o
Total funds are used appropriately

o
Total funds for any cost category have not been
exceeded if restricted on the
NoA

19


Actual expenses should be reviewed to
ensure they are accurate and allowable


o
Reasonable (including necessary)

o
Allocable

o
Consistently applied

o
Conforms to any limitations or exclusions

20



A cost may be considered
reasonable

if the
nature of the goods or services acquired or
applied reflect the action that a prudent
person would have taken under the
circumstances prevailing at the time the
decision to incur the cost was made.



21


Dr. Grant needed a specialized microscope
for his research supported by an NIH grant
from the National Cancer Institute. When
deciding on the model that would best suit
his needs, he received several price quotes
on various models that were all within the
same general price range. However, one
microscope in particular appealed to him


it
met all of the necessary specifications plus
many additional features. Although it was
about $8,500 more than the others, he
ordered it.

22



A cost is
allocable

to a specific grant if it is
incurred solely in order to advance work
under the grant and is deemed assignable, at
least in part, to the grant.



23


When Dr. Grant’s microscope finally arrived,
he found that equipment funds for his
National Cancer Institute grant were fully
expended. Since the microscope was for use
on an NIH grant, he decided to charge the
cost to another one of his NIH grants that
was funded by the National Eye Institute.

24


Grantees must be
consistent

in assigning
costs to cost objectives.


Costs may be charged as either direct costs
or F&A costs, depending on their identifiable
benefit to a particular project or program.


All costs must be treated
consistently

for all
work of the organization under similar
circumstances,
regardless of the source of
funding
.



25


Dr. Grant’s lab was running low on office
supplies and postage stamps. Since he
couldn’t wait any longer for his institution to
provide the supplies, he purchased them
and charged them to his NIH grant account.

26


A cost is
allowable

if it is
reasonable
,
allocable

and
conforms

to the cost principles and the sponsored
agreement AND is
not prohibited

by law, regulation
or term of award.



This type of allowability
--

conformance with
limitations and exclusions as contained in the terms
and conditions of award including those in the cost
principles

varies by type of activity, type of
recipient, and other characteristics of individual
awards.

27


Dr. Grant decided to host a very important
Departmental meeting at his home and serve
beer and pizza hoping that everyone would
attend. The purpose of the meeting was to
discuss changes in NIH grants policy, which
affected the work of the entire Department.
Therefore, he decided to charge the cost of
the beer and pizza to his grant, especially
since he was providing the use of his home.

28


Used to correct:

o
Erroneous charges

o
Unreasonable charges

o
Unallocable

charges

o
Inconsistently applied charges

o
Unallowable charges


Must be well documented


Must be made within 90 days from
the time error was discovered

29


Other Cost

Considerations

30


NIH Grants Policy Statement defines actions
requiring NIH prior approval.


Some prior approval actions affecting cost include
the following:

o
Carryover of funds (if required
-
see Section III of
NoA
)

o
Incurrence of
preaward

costs greater than 90 days

o
Deviation from award terms and conditions

o
Activities disapproved or restricted as a condition
of award


For a complete listing of prior approval
requirements see:
http://grants.nih.gov/grants/policy/nihgps_2012/nihgps
_ch8.htm#prior_approval_requirements

31


Requests for carryover of funds should be
signed by Authorized Representative.


Request must be sent to GMO and include:

o
Detailed budget by direct cost category with F&A
cost information (base and rate). If personnel
costs are requested, include


a detailed breakdown of personnel costs


base salary


salary requested


effort to be spent on the project

o
A scientific justification for the use of funds

o
The reason for the unobligated balance

32

33

Federal Financial Report (FFR)(SF
-
425)

Expenditure Data



Timely
-

Must adhere to submission deadlines:

o
Annual


(Non
-
SNAP Awards)


FFR submitted for each budget period no later than 90 days after the
end of the
calendar
quarter (CQ) in which the budget period ended.


Budget period ends 1/31/2013


FFR due 6/30/13




(90 days after the end of the CQ of 3/31/13)


o
Final (End of Competitive Segment)


(SNAP and Non
-
SNAP
Awards)


FFR submitted within 90 days following the end of the
project

period


(
SNAP


Streamlined Non
-
competing Award Process)






34




FFRs should be submitted accurately



Reported expenses and program income must
agree with institutional accounting records



Routine Revisions to correct FFRs are not
appropriate



Any revisions must be submitted in the same format
as the original submission.





For example:
If the original report was submitted as a


Financial Status Report (FSR)(SF
-
269), the revised report


must be submitted as an FSR.



35


Information and NIH Guide Notices related to
Financial Reporting:



See FFR (SF425) Instructions for NIH Grantees available at
http://grants.nih.gov/grants/forms.htm





See NIH Guide, January 4, 2011, Implementation of Federal Financial Report


Upcoming Mandatory Use of the Federal Financial Report System in the
eRA

Commons beginning February 1, 2011 (NOT
-
OD
-
11
-
017)
http://grants.nih.gov/grants/guide/notice
-
files/NOT
-
OD
-
11
-
017.html







See NIH Guide, July 27, 2007, NIH Requiring Mandatory Use of the Electronic
Financial Status Report System in the
eRA

Commons Beginning October 1,
2007
http://grants.nih.gov/grants/guide/notice
-
files/NOT
-
OD
-
07
-
078.html





See NIH Guide, February 22, 2001, FINANCIAL STATUS REPORTS: REMINDER
AND INFORMATION ON TIMELINESS AND ACCURACY REQUIREMENTS


http://grants.nih.gov/grants/guide/notice
-
files/NOT
-
OD
-
01
-
021.html

36


Failure to submit timely final reports may affect future funding to the
organization

o
Final Federal Financial Report (FFR) SF
-
425 Expenditure Data

o
Final Invention Statement and Certification

o
Final Progress Report



Final Reports are due within 90 days of the end of grant support.



Grantee must ensure there are no discrepancies between final FFR
expenditure data (in eRA Commons) and FFR cash disbursement
data in the Payment Management System.



April 2, 2008, NIH Announces New Centralized Processing Center for Receipt of Grant
Closeout Documents and Reminds Grantees of Required Closeout Reports for NIH
Assistance Awards

http://grants.nih.gov/grants/guide/notice
-
files/NOT
-
OD
-
08
-
061.html




June 17,2005, NIH Announces New Closeout Feature in the eRA Commons and Reminds
Grantees of Required Closeout Reports for NIH Assistance Awards


http://grants2.nih.gov/grants/guide/notice
-
files/NOT
-
OD
-
05
-
051.html




37


Whenever you are contemplating a
significant
postaward

change, and you are
uncertain about the need for prior approval,
consult
in advance

with:



The Notice of Award (terms and conditions)


Your Office for Sponsored
Research/Projects


NIH awarding component Grants
Management Officer/Specialist

38


Diane Dean,
Director, Division of Grants Compliance and Oversight


diane.dean@nih.gov


301
-
435
-
0949



Kathy Hancock
,
Assistant Grants Compliance Officer


kathy.hancock@nih.gov


301
-
435
-
1962



Sahar Rais,
Assistant Grants Compliance Officer


raisdanais
@nih.gov


301
-
435
-
0940



GrantsCompliance@nih.gov