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Source and Application of Funds - PowerPoint


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									    Circular A-110
Everything You Didn’t Want to
          Purpose of A-110
        Subpart C- Post Award
• Establishes uniform administrative
 requirements for Federal grants and
 agreements awarded to institutions of
 higher ed, hospitals, and other non-profit
      Post Award Requirements
• A-110 Subpart C - Sets standards for financial
  and program management of sponsored
  research awards in:
  –   Methods for making payments
  –   Cost sharing and matching requirements
  –   Accounting for program income
  –   Budget Revisions
  –   Audits
  –   Allowability of Costs
  –   Establishing Fund availability
        Standards for financial
        management systems
• Relate financial data to performance data
• Financial system must provide:
  – Financial results of each project
  – Identification of source & application of funds
  – Control & accountability over all funds,
    property & other assets
  – Comparison of outlays to budget amounts
         Standards (cont.)

• Procedures to minimize time between
  transfer of funds and disbursement of
• Procedures to determine reasonableness,
  allocability, and allowability of costs
• Accounting records supported by source
Cost Sharing/Matching Funds
     Definitions of Cost Sharing
         (Matching Funds)
• A commitment made by WSU to fund a
 portion of the total cost of a sponsored
 agreement. The commitment may be for
 direct and/or indirect costs, and may
 consist of WSU funds or funds from
 outside sources. Matching may either be
 classified as voluntary or mandatory.
 Either form is a true commitment and
 must be fully documented.
Cost Sharing (Match) must meet all
      of the following criteria:
In general, same requirements apply to Non-Federal Share as apply to the Federal Share

• Verifiable from recipient’s records
• Not included as Match for any other federally
    funded program
•   Necessary and reasonable
•   Allowable under the applicable Cost Principles
•   Not paid by the Federal Government under
    another award
•   Provided for in the approved budget
•   Conform to other provisions
       Types of Cost Sharing

• Mandatory Cost Sharing
• Voluntary Cost Sharing
• Third Party In Kind Contributions
• Facilities and Administrative (F&A), also
 known as Indirect Costs
    What Can be Used to Meet Match
•   Cash
•   Third Party Contributions
•   Unrecovered F&A costs (Indirects)
•   Contributions of services and property
•   Volunteer Services (necessary for project)
•   Other employee services (regular rate +
•   Donated supplies (at reasonable & fair market
   Unrecovered Indirect Costs

• May be included as part of cost sharing or
 matching only with the prior approval of
 the awarding agency.

• Current approved rate agreement is 36%
 of Salaries, Wages and Benefits
        Audit Procedures for Match
• Verify that required Matching Contributions were
•   Ascertain sources of matching contributions and
    verify that they were from an allowable source
•   Test records to corroborate that value of in-kind
    contributions are in accordance with OMB cost
•   Verify transactions used to match are in compliance
    with allowable cost principles
    Procurement Standards

To establish procedures for procurement
of supplies and other expendable
property, equipment, real property, and
other services
Codes of Conduct regarding Awards
  and Administration of Contracts
• Recipients shall maintain written standards
  of conduct governing performance of
  employees involved
• Cannot participate if conflict of interest
• Cannot accept gratuities, favors, or
  anything of monetary value from
  contractors, subs, or parties to subgrants

• Must provide open and free competition
• Contractors that develop or draft specs or
 requirements, statements of work,
 invitations for bids and/or requests for
 proposals are excluded
   Required Written Procurement
• Recipients must not purchase unnecessary
• Determine which procurement methods
  are most economical and practical
• Positive efforts to utilize small business,
  minority owned firms & women’s business
  enterprises, whenever possible
Procurement procedures (cont.)
• Solicitations for goods & services must provide:
   – Clear & accurate descriptions of technical requirements
   – Specify requirements which bidders must fulfill
   – Describe minimum acceptable standards
   – Include specific features of “brand name or equal” descriptions
   – Acceptance of products & services dimensional in the metric
   – Preference for products & services that conserve natural
     resources, protect the environment, and are energy efficient –
     when practicable and economicaly feasible
      Record retention & access
• Financial records, supporting
 documentation, and statistical records –
 Three (3) years from date of submission
 of final report
  – If litigation occurs – until all litigation or
    claims are resolved
• Real Property or Equipment – Three (3)
 years after final disposition
• All reports (financial, performance, other) must
    be submitted within 90 days after completion
    date of award
•   Unless extension granted, all obligations
    incurred must be liquidated within 90 days
•   Prompt refund of any balances of unobligated
    cash advances
•   Awarding agency to make settlement for any
    upward or downward adjustments to costs after
    closeout reports received
           Closeout (cont.)

• Accounting of real or personal property
  acquired with federal funds
• If no final audit done prior to closeout,
  awarding agency retains right to recover
  disallowed costs resulting from the final
    Closeout Does Not Affect:

• Right to disallow costs and recover funds
  on the basis of a later audit
• Obligation of recipient to return funds due
• Audit requirements
• Property management requirements
• Record retention

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