These documents, policies and instructions will assist UAA Principal Investigators and their support staff in the management of their awards.
Changes in the level of effort of key personnel must be approved in advance by the funding agency when the amount of reduction in dedicated effort differs from the award budget by 25% or more. Key personnel may not be substituted without the prior written approval of the awarding agency. See OMB Circular A-110 Subpart C 25 (c). (2) Change in a key person specified in the application or award document. (3) The absence for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
Note: If an exemption to this policy is required, you must submit at Cost Accounting Standards (CAS) Exemption Form with the proposal at the time of initial review/approval by the Office of Sponsored Programs.
Attachment A to Appendix A—CASB’s Cost Accounting Standards (CAS)
A. CAS 9905.501—Consistency in estimating, accumulating and reporting costs by educational institutions.
1. Purpose The purpose of this standard is to ensure that each educational institution’s practices used in estimating costs for a proposal are consistent with cost accounting practices used by the educational institution in accumulating and reporting costs. Consistency in the application of cost accounting practices is necessary to enhance the likelihood that comparable transactions are treated alike. With respect to individual sponsored agreements, the consistent application of cost accounting practices will facilitate the preparation of reliable cost estimates used in pricing a proposal and their comparison with the costs of performance of the resulting sponsored agreement. Such comparisons provide one important basis for financial control over costs during sponsored agreement performance and aid in establishing accountability for costs in the manner agreed to by both parties at the time of agreement. The comparisons also provide an improved basis for evaluating estimating capabilities.
2. Definitions(a)The following are definitions of terms which are prominent in this standard.(1)Accumulating costs means the collecting of cost data in an organized manner, such as through a system of accounts.(2)Actual cost means an amount determined on the basis of cost incurred (as distinguished from forecasted cost), including standard cost properly adjusted for applicable variance.(3)Estimating costs means the process of forecasting a future result in terms of cost, based upon information available at the time.(4)Indirect cost pool means a grouping of incurred costs identified with two or more objectives but not identified specifically with any final cost objective.(5)Pricing means the process of establishing the amount or amounts to be paid in return for goods or services.(6)Proposal means any offer or other submission used as a basis for pricing a sponsored agreement, sponsored agreement modification or termination settlement or for securing payments thereunder.(7)Reporting costs means the providing of cost information to others.3. Fundamental Requirement(a)An educational institution’s practices used in estimating costs in pricing a proposal shall be consistent with the educational institution’s cost accounting practices used in accumulating and reporting costs.(b)An educational institution’s cost accounting practices used in accumulating and reporting actual costs for a sponsored agreement shall be consistent with the educational institution’s practices used in estimating costs in the related proposal or application.(c)The grouping of homogeneous costs in estimates prepared for proposal purposes shall not per se be deemed an inconsistent application of cost accounting practices of this paragraph when such costs are accumulated and reported in greater detail on an actual costs basis during performance of the sponsored agreement.4. Techniques for application(a)The standard allows grouping of homogeneous costs in order to cover those cases where it is not practicable to estimate sponsored agreement costs by individual cost element. However, costs estimated for proposal purposes shall be presented in such a manner and in such detail that any significant cost can be compared with the actual cost accumulated and reported therefor. In any event, the cost accounting practices used in estimating costs in pricing a proposal and in accumulating and reporting costs on the resulting sponsored agreement shall be consistent with respect to:(1)The classification of elements of cost as direct or indirect;(2)The indirect cost pools to which each element of cost is charged or proposed to be charged; and(3)The methods of allocating indirect costs to the sponsored agreement.(b)Adherence to the requirement of this standard shall be determined as of the date of award of the sponsored agreement, unless the sponsored agreement has submitted cost or pricing data pursuant to 10 U.S.C. 2306(a) or 41 U.S.C. 254(d) (Pub. L. 87–653), in which case adherence to the requirement of this standard shall be determined as of the date of final agreement on price, as shown on the signed certificate of current cost or pricing data. Notwithstanding 9905.501– 40(b), changes in established cost accounting practices during sponsored agreement performance may be made in accordance with Part 9903 (48 CFR part 9903).(c)The standard does not prescribe the amount of detail required in accumulating and reporting costs. The basic requirement which must be met, however, is that for any significant amount of estimated cost, the sponsored agreement must be able to accumulate and report actual cost at a level which permits sufficient and meaningful comparison with its estimates. The amount of detail required may vary considerably depending on how the proposed costs were estimated, the data presented in justification or lack thereof, and the significance of each situation. Accordingly, it is neither appropriate nor practical to prescribe a single set of accounting practices which would be consistent in all situations with the practices of estimating costs. Therefore, the amount of account and statistical detail to be required and maintained in accounting for estimated cots has been and continues to be a matter to be decided by Government procurement authorities on the basis of the individual facts and circumstances.
E-Verify Process E-Verify is an Internet-based system that allows an employer, using information reported on an employee's Form I-9, Employment Eligibility Verification, to determine the eligibility of that employee to work in the United States. For most employers, the use of E-Verify is voluntary and limited to determining the employment eligibility of new hires only. There is no charge to employers to use E-Verify. The E-Verify system is operated by the Department of Homeland Security in partnership with the Social Security Administration.
This procedure establishes the university's policy for obtaining effort certifications for employees whose salaries are paid under sponsored agreements. OMB Circular A-21 (2 CFR Part 220) requires effort to be substantiated for charges to a sponsored project. UA uses a bi-weekly time sheet to certify effort performed on a restricted fund. Since labor is generally the largest budget item on a project, it is critical that effort is recorded accurately. All personnel paid on restricted funding must sign and submit a time sheet to certify their effort. This applies to all classes of employees including APT (Exempt) and faculty who are not normally required to file a bi-weekly time sheet. Charging labor to a restricted fund should be in harmony with the original proposed budget to the sponsoring agency. All labor should relate to the scope of work as identified in the award budget. If a job assignment listed on a time sheet does not reflect the actual effort for that payroll period, the time sheet should be adjusted prior to signing by the employee and certification of the Principal Investigator. UA Administrative-Accounting Manual section D-04 allows for a + or - 10% threshold of variance before a correction must be made. If an error is discovered after the payroll posting date, a labor reallocation must be initiated immediately to correct the labor expenditure to reflect the actual level of effort expended on the project.
A helpful guide for Effort Certification is the Top Ten Things a Principal Investigator Should Know About Effort Certification.Information on Frequently Asked Questions concerning Effort Certification are available in this document.
Excluded Parties List System The EPLS is an electronic, web-based system that identifies those parties excluded from receiving Federal contracts, certain subcontracts, and certain types of Federal financial and non-financial assistance and benefits. The EPLS keeps its user community aware of administrative and statutory exclusions across the entire government, and individuals barred from entering the United States. The user is able to search, view, and download both current and archived exclusions. At UAA, the EPLS is reviewed prior to proposal submission, prior to Grants & Contracts signing a subaward and prior to Procurement issuing a purchase order/subaward. Documentation of the review is noted at each stage of review by the responsible department (i.e., OSP, G&C, Procurement).
The funding agencies of the Federal Government have been given a mandate to increase their use of the Debarment and Suspension remedy available to them in keeping grantees compliant. OMB Memorandum M-12-02
As of January 10, 2011, the final Facilities and Administrative Cost Rates are now fully negotiated with our cognizant Federal agency, the Office of Naval Research. (See notification memo from Tanya Hollis , SW Office of Cost Analysis.)
A new F&A rate is currently being negotiated by Statewide Cost Analysis with our cognizant federal agency, the Office of Naval Research. When a new rate to be applied for awards for the fiscal years from FY2014-2016, Grants & Contracts will establish these rates in Banner Finance.
Per A-21 Section J.10.d
The federal False Claims Act permits a person with knowledge of fraud against the United States Government, referred to as the "qui tam plaintiff," to file a lawsuit on behalf of the Government against the person or business that committed the fraud (the defendant). If the action is successful, the qui tam plaintiff is rewarded with a percentage of the recovery.
After the "qui tam lawsuit" has been filed, but before the defendant is notified of the lawsuit, the qui tam plaintiff must notify the U.S Department of Justice, and provide it with all available information about the fraud. The Justice Department then has the option of intervening and taking over prosecution of the lawsuit from the qui tam plaintiff. If the Justice Department decides not to intervene, the qui tam plaintiff may pursue the lawsuit on behalf of the Government.
FFATA-Federal Funding Accountability and Transparency Act
The Federal Funding Accountability and Transparency Act of 2006, as amended ("FFATA", or "Transparency Act"), requires the Office of Management and Budget to establish a single searchable database, accessible to the public, with information on financial assistance awards made by Federal agencies. The Transparency Act also includes a requirement for recipients of Federal grants to report information about first-tier subawards and executive compensation under Federal assistance awards. In accordance with OMB guidance, grantees have implemented the Transparency Act subaward reporting requirements by applying it to only competing awards issued on or after October 1, 2010 with an expectation that the scope of the requirement would be expanded by OMB to be applicable to all award transactions competing and non-competing. Since then, it became apparent that the scope will remain just new awards issued on/after October 1, 2010 and any subsequent award action following an applicable award.
See NIH NOT-OD-12-010 Notice of Expanded Transparency Act Subaward and Executive Compensation Reporting Requirements for FY2012 and Beyond.
Federal travelers are required by 49 U.S.C. 40118, commonly referred to as the "Fly America Act," to use United States air carrier service for all air travel and cargo transportation services funded by the United States Government. One exception to this requirement is transportation provided under a bilateral or multilateral air transport agreement, to which the United States Government and the government of a foreign country are parties, and which the Department of Transportation has determined meets the requirements of the Fly America Act.
The United Sates Government has entered into several air transport agreements that allow federal funded transportation services for travel and cargo movements to use foreign air carriers under certain circumstances.
There are currently four bilateral/multilateral “Open Skies Agreements” (U.S. Government Procured Transportation) in effect:
Journal Vouchers are forms prepared to process current accounting entries and corrections for which other means of entry into the financial system are not available, effective or efficient.Journal Vouchers also record services performed by one segment of the University for another such as postage, general support services copying, catering, housing or bookstore purchases.
This guide provides practical advice in grants management.
NSF Limitation on Faculty Salary-The 2/9ths Rule
As a general policy, NSF limits salary compensation for senior project personnel to no more than two months of their regular salary in any one year. This limit includes salary compensation received from all NSF-funded grants. This effort must be documented in accordance with the applicable cost principles. If anticipated, any compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award notice.
Program Code Information
What is the purpose of "Program Codes" in the UAA Banner Financial System?
The “Program” code segment of the Banner C-FOAPAL accounting string was designed to serve two objectives:
Our ability to accurately report University activities to funding entities and therefore receive needed appropriations, recover costs, and assess overhead depends upon accurate Program code assignment.
Descriptions are based on the National Association of College and University Business Officers (NACUBO) Accounting and Reporting Manual.
It is vital that the Program Code associated with the ORG code used when a fund is established reflects the work of the project (i.e. Public Service, Research, Student Services, Instruction, Academic Support, etc.)
Program income is defined as "gross income received by the
grantee……directly generated by a grant supported activity, or earned
only as the result of the grant agreement during the grant period"[CFR
§2541.250(b) and §2543.249(a)]. Program income includes fees from
services performed under the grant, and income from sale of commodities
or items fabricated under a grant agreement. Revenue you receive from
sources to support the program that doesn't directly result from grant
activities is not program income.
How long must UAA retain Grants and Contracts records? When does the clock start? Who has the official University records? Are there documents that your department must keep that relate to grants such as Procard receipts? Who retains these records in your department? What happens if an audit action occurs?
General information about budget revisions for the most common funding agencies is listed below. Please refer to your project's specific funding regulations to determine if a budget revision is allowable. Contact your Grant Coordinator with any questions and to initiate the revision process.
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The University of Alaska negotiates their Staff Benefit and Leave Rates with the Office of Naval Research (ONR) annually. The ONR is the cognizant federal agency for the University of Alaska. FY2014 Staff Benefit and Leave Rates will be available in May 2013 for inclusion in Proposals submitted for work in FY2014.
UAA has an negotiated FY2012-2013 Facilities and Administrative (F&A) rate for all agreements with the State of Alaska. These agreements are typically in the form of an RSA or Reimbursable Services Agreement.
UAA has a new Memorandum of Understanding for FY2014-2015 Facilities and Administrative (F&A) rates for all agreements with the State of Alaska.
To provide guidance for identifying and accounting for unallowable expenses or activities to ensure compliance with federal requirements for treatment of specific costs. Unallowable costs are defined as costs that cannot be charged as direct costs to a sponsored agreement or included in the university's F&A cost rate according to OMB Circular A-21 (relocated to 2 CFR, Part 220). By identifying them as unallowable, the government has stated that federal funds may not be used to pay for these expenses nor may they be counted as cost sharing on federally sponsored projects. A list of the main unallowable costs is available in Part J of Circular A-21. A partial list include Advertising (J.1), Alcoholic Beverages (J.2), Alumni Activities (J.3), Bad debt expense (J.4), Commencement and convocation costs (J.6), Contingency Provisions (J.9), Defense and prosecution of criminal proceedings, claims, appeals and patent infringements (J.11), Donations or contributions (J.13), Entertainment (J.15), Fines and penalties (J.18), Fund raising (J.22), Goods and services for personal use (J.19) including housing and personal living expense (J.20), Insurance against defects (J.21.f) and medical liability (malpractice) insurance (J.21.g), Interest (J.22), Investment management (J.22), Lobbying (J.17 and J.24), Losses on sponsored projects or contracts (J.25), Memberships, subscriptions and professional activity costs (J.28), Pre-agreement costs (J.31), Selling and marketing (J.42), Student Activity Costs (J.45), and some Travel Costs (J.48). There may be reasonable exceptions to this list of unallowable costs.
The order of precedence for assuming the burden of unallowable costs will be first to charge the Principal Investigator's department. If resources are not available at the department level, the college/school will be responsible for any unallowabe cost. In any case, the federally funded project will not be charged.