at 2 CFR 200 - Georgia Tech Faculty Governance · at 2 CFR 200 Uniform Administrative Requirements,...
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at 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards January 20, 2015
Transcript of at 2 CFR 200 - Georgia Tech Faculty Governance · at 2 CFR 200 Uniform Administrative Requirements,...
at 2 CFR 200
Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards
January 20, 2015
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AGENDA
Preparing campus for what is changing and what is not…
• What is Grants Reform and when is it ▲effective?• What changes are most important to faculty and
research performers?• What is NOT changing?• How is Georgia Tech responding?• Next Steps
211/12/2014 2 CFR 200 Overview of Changes
did it start to become
WHAT’S CHANGING AND WHEN?
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Grants Reform• Office of Management and
Budget Circulars combined into Uniform Requirements
• A-21, A-110, A-133 replaced• Effective December 26, 2014 & after11/12/2014 2 CFR 200 Overview of Changes
FEDERAL REGULATIONS
You may also hear it called:
– 2 CFR 200 – Uniform Guidance or “UG”– Omni-circular– Super-circular– A-81– Grant reform
11/12/2014 2 CFR 200 Overview of Changes 4
FEDERAL REGULATIONS
11/12/2014 2 CFR 200 Overview of Changes 5
• Why is this change taking place?
• Who was responsible for “Grants Reform” and combining the regulations?
• Is there an organizing principle behind the new regulations?
COMMITTEE OF SPONSORING ORGANIZATIONS (COSO)
COSO is an initiative of five U.S. private sector organizations dedicated to providing thought leadership to executive management and governance entities on critical aspects of organizational governance, business ethics, internal control, enterprise risk management, fraud, and financial
reporting. COSO’s 5 supporting organizations: Institute of Management Accountants, the American Accounting Association, the American Institute of Certified Public Accountants, the
Institute of Internal Auditors, and Financial Executives International.
Key concepts of the COSO framework• Internal control is a process.• Internal control is affected by people.• Internal control can be expected to
provide only reasonable assurance, not absolute assurance.
• Internal control is geared to the achievement of objectives in separate but overlapping categories.
Definition of internal control and framework objectives• Effectiveness and efficiency of operations• Reliability of financial reporting• Compliance with applicable laws and
regulations.• Safeguarding of Assets
ORDER OF PRECEDENCE: CONTROL OF A SPONSORED PROJECT
Award
Special Conditions
Program Rules(found in the solicitation)
Agency Rules (found in agency general terms and conditions)
Uniform Requirements(2 CFR 200)
State Laws & Regulations
Institute Policies
11/12/2014 2 CFR 200 Overview of Changes 7
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Uniform Requirements – What’s Covered
• Administrative Requirements– Finances– Purchasing– Property
• Solicitations, Proposals, and Awards• Allowable Costs
– Direct and Indirect– Personal Services (Effort Reporting)– Space and Utilities
• Facilities and Administrative Cost Calculations
811/12/2014 2 CFR 200 Overview of Changes
MAJOR CHANGES
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“SHOULD” “MUST”appears 823 times
11/12/2014 2 CFR 200 Overview of Changes
MAJOR CHANGES
11/12/2014 2 CFR 200 Overview of Changes 10
Program performance must reflect financial
performance• Similar to ARRA
reporting
Emphasis is on internal controls and
documentation• Timely appointments
and cost transfers• PI Certification
Subawards• Pre‐award documentation
required
• Limits on fixed price
• Payment requirements
• Greater financial and programmatic performance monitoring
Planning is Important!• Proposing fixed price • Subawards• Purchasing will require
more quotes and bids• Close‐out timeline will
be compressed
WHAT CHANGES ARE MOST IMPORTANT TO FACULTY AND RESEARCH PERFORMERS?
11/12/2014 2 CFR 200 Overview of Changes 11
Proposals Purchasing Materials & Supplies Equipment
• Solicitation• Cost-sharing cannot
be considered in review and requires agency head approval
• Agencies are expected to pay the full negotiated F&A
• Documentation standards have changed
• Micro-purchasing threshold reduced from $10,000 to $3,000
• Accounting for residual supplies and documentation for late-term charges
• New cost-transfer limitations
• Equipment purchased with federal funds must be made available to other federally-funded projects
• Additional closeout / disposition requirements
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WHAT’S NOT CHANGING?
1211/12/20142 CFR 200 Overview of Changes
COST ACCOUNTING STANDARDS
• An institution’s practices used in estimating costs in pricing a proposal shall be consistent with the institution’s cost accounting practices used in accumulating and reporting costs
• Like costs in like circumstances must be treated in the same manner
• Unallowable costs shall be excluded from any billing, claim, or proposal applicable to a Government contract
• An institution shall use their fiscal year as their cost accounting period
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NEXT STEPS
• Agency Specific Requirements– NSF published new PAPPG
• OMB Published Technical Corrections and Agency Specific Exceptions on December 19, 2014
• Procurement Requirements delayed until July 1, 2016 for GT
• F&A changes effective July 1, 2015– GT preparing its proposal NOW
• GT Team will be issuing policy revisions at appropriate times
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Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards at 2 CFR 200 became effective December 26, 2014 for new awards.
11/12/2014 2 CFR 200 Overview of Changes
NOTEWORTHY EXCEPTIONS
11/12/2014 2 CFR 200 Overview of Changes 15
DHHS has a number of additions & definitions e.g. conflict of
interest, patient care
Timing of Payments(DoD, DoE)
Program Income(DoT)
Exceptions based on
Award Type, e.g. DoD Small
Awards
Cost Sharing Statutory(DoE)
Commercial Entity Requirement
(NASA)
https://cfo.gov/wp-content/uploads/2014/12/Agency-Exceptions.pdf
11/12/2014 2 CFR 200 Overview of Changes 16
WATCH FOR
Department of Defense• Implemented on Interim Basis • Revising grant guidelines• Mulling greater use of
Other Transaction Authorities
Statutory Limits on F&A Recovery
• Department of Agriculture• Department of Education
Cost‐transfers and Close‐out Procedures
• Timing of invoice review, payment and close‐out for subcontracts In!AND Out!
• Time allowed for cost transfers to be shortened
Internal Control Tools• Enhanced project
management tools with drill‐down capability
• PI/PD Certifications for costs
Changes in Procurement and Asset Management
• Bid & Quote Procedures• End‐of‐project Inventory• Equipment Sharing
