Written By

• Jane Youngers, Assistant Vice President for Research and Sponsored Programs, University of Texas Health Science Center, San Antonio, was one of the principal authors of the initial narrative sections of A Guide to Managing Federal Grants for Colleges and Universities. In addition, Ms. Youngers plans and creates the quarterly Web updates and, assisted by a team of her campus-based peers, writes the monthly newsletter, Federal Grants News.
  
  
• The section on “Managing Subrecipient Awards” was written by Gunta J. Liders, Associate VP for Research Administration, University of Rochester.
  
  
• The section on “Facility and Administrative Costs” was co-authored by Patrick Fitzgerald, Associate Dean for Research Administration, Faculty of Arts and Sciences, Harvard University, and Jerry Fife, Associate Vice Chancellor for Business Services and Research Finance, Vanderbilt University.
• The section on “Administering International Subawards” was written by David Richardson, Assistant Vice President for Research and Director of Sponsored Programs at The Pennsylvania State University.

Written For

Contents

Section 100: INTRODUCTION

Federal Budgetary Constraints • Institutional Considerations • The Sponsored Programs Office • The Relationships of the Players • Audits and Auditors • New Developments

Section 300: DEFINING THE GRANT

Grants vs. Cooperative Agreements • Available Funds • Nature of the Grant Relationship • Additional Award Distinctions • Mandatory vs. Discretionary • Formula vs. Project • Award Instruments and Applicable Regulations • OMB Circulars Applicable to All Awards • OMB Circulars Applicable to Financial Assistance Awards • OMB Circulars Which May Impact Awards to Educational Institutions • Regulations Applicable to Procurement Actions • “Other Transaction” Awards • Consolidation of the Circulars at 2 CFR • Subawards

Section 500: SOLICITATION

Program Announcements • Commercial and Non-Profit Sources • Agency Standards for Program Announcements • Application Materials • Electronic Application Materials • Catalog of Federal Domestic Assistance

Section 700: APPLICATION

Electronic Proposal Submission • Agency Initiatives • Proposal Components • Resources and Facilities • Facilities and Administrative (Indirect) Cost Rates • Other Common Information Requested in the Proposal • Certification and Assurances • The Drug-Free Workplace and Drug-Free Schools and Campuses Act • Certification Regarding Lobbying and Disclosure of Lobbying Activities • Debarment and Suspension • Misconduct in Science • Conflict of Interest • Bloodborne Diseases • Human Subjects Compliance • Use of Animals in Research • Other Certification and Assurances

Section 900: AGENCY REVIEW AND NEGOTIATION

Scientific and Technical Merit • Cost Analysis of Grant Budgets • Personnel • Fringe (Employee) Benefits • Travel • Supplies, Materials, Equipment and Other Capital Expenditures • Subawards • Contracting for Services • Construction • Other Expenses • Facilities and Administrative (Indirect) Costs • Grants Management System Review • Financial Capability • Negotiation • “Expanded Authorities”

Section 1100: AWARD

Authorizing Officials • Signature Authority • Standard Provisions • Special Provisions • Interpretation • Government-Wide Directives • Presidential Executive Orders • OMB Circulars • Regulations • Terms and Conditions of the Award

Section 1200: ADMINISTERING INTERNATIONAL SUBAWARDS

The Foreign Subrecipient Proposal • Pre-Award Assessment • The International Subrecipient Agreement • Post-Award Monitoring • Foreign Financial Compliance Considerations • Foreign Nonfinancial Compliance Considerations • Final Considerations • Sample Agreements • Reference Materials

Section 1500: PAYMENT AND CASH MANAGEMENT

Methods and Operation of Payment Mechanisms • Advance • Working Capital Advance • Reimbursement • Cash Management • Cash Depositories

Section 1600: FACILITY AND ADMINISTRATIVE RATES

Principles for Cost Reimbursement • Direct Costs and F&A (Indirect) Costs • Determination and Application of F&A Rates • F&A Rates • Cognizant Agencies and Rate Negotiation Process • Limitations on Reimbursement of F&A Costs • Cost Sharing

Section 1700: POST-AWARD ADMINISTRATION

Cost Sharing and Matching • Program Income • Incurring Allowable Costs • General Tests of Allocability • Charging Practices • Departmental Administrative Expenses • Selected Items of Cost • Cost Accounting Standards • Consistency with Other Cost Principles • Cost Transfers • Limiting Institutional Exposure • Administrative Issues • Effort Reporting • Prior Approval and Expanded Authorities • Property Management Systems • Inventions • Availability of Research Data, Reports and Publications • Financial Management Systems • Bonding and Insurance • Procurement

Section 1800: INTELLECTUAL PROPERTY

Patents • Copyright • Software • Trademarks • Other Intellectual Property • OMB Circular A-110 • Bayh-Dole (Patent Rights) • Rights in Data (Copyrights) • Computer Software • Biomaterials • Protecting Government Rights • Commercializing IP • Technology Assessments • Licensing Agreements • Confidentiality Agreements • Conflicts of Interest • IP Policy

Section 1900: REPORTING

Financial Reporting • Report of Federal Cash Transactions • Standard Form 270, “Request for Advance or Reimbursement” • Standard Form 271, “Outlay Report and Request for Reimbursement for Construction Projects” • Performance Reporting • Extraordinary Reporting • Monitoring • Other Reporting Requirements • Other Federal Initiatives

Section 2100: CLOSEOUT

Time Constraints • Financial Considerations • Equipment • Other Requirements • Residual Inventory of Unused Supplies • Program Income • Continuing Responsibilities • Record Retention • Retained Property • Audit Rights and Adjustment • Suspension and Termination • Transfer of Investigator

Section 2300: Audit

Federal Audits • Federal Audit Policy • The Role of the Inspectors General • Evolution of Federal Audit Policy Relating to Non-Federal Audits • Circulars A-128 and A-133 • Pre-Award Audits • Post-Award Audits • Audits Related to Whistleblowers • The A-133 Audit • The A-133 Compliance Supplement • Internal Controls and SAS 112 • National Single Audit Sampling Project • Institutional Responsibilities Under A-133 Audits • Auditor Selection • Preparation of Financial Statements • Follow-Up on Prior Audit Findings • Preparation of the Corrective Action Plan • Report Submission • Funds Awarded to Subrecipient Organizations • Cost Accounting Standards • CAS DS-2 • CAS Audit Requirements • Audit Readiness • Audit Guides • The Importance of Internal Controls

Section 2500: AUDIT RESOLUTION

Federal Requirements for Audit Resolution • Audit Standards • Process for Audit Resolution • Audit Findings • Corrective Action Plan • Management Decision • Final Action • Dealing With Adverse Findings • Appeals

Section 2600: MANAGING SUBRECIPIENT AWARDS

The Subrecipient Relationship • Incorporating the Subrecipient Proposal • Pre-Award Stage • Subrecipient Agreements • Post-Award Administration • Subrecipient Closeout • Subrecipient Audit • Subcontracting for Multi-Site Clinical Trials • Sample Subaward Agreement

Section 2700: ELECTRONIC RESEARCH ADMINISTRATION

Public Law 106-107 • The President’s Management Agenda • Other Statutory Requirements • College and University Initiatives • Grants.gov • Government-Wide Topic-Focused Initiatives • Agency-Specific Electronic Initiatives • Current Activities

Section 2800: INSTITUTIONAL COMPLIANCE

Establishing an Institutional Compliance Program • Animal Care and Use • The Protection of Human Subjects • Financial Conflict of Interest • Misconduct in Science • Export Controls • Biosafety

Section 2900: AMERICAN RECOVERY AND REINVESTMENT ACT: GRANTEE REPORTING AND OTHER OBLIGATIONS

Overview of the American Recovery and Reinvestment Act of 2009 • Reporting Under ARRA-Funded Agreements • Other Compliance Requirements • Recovery Act and Grants.gov • ARRA and Single Audits • Notifying OIG and Whistleblower Protections  • ARRA and GAO

Goverment Documents

• Administrative Requirements, such as OMB Circular A-110 and various standard forms
• Cost Policies such as OMB Circular A-21 and related documents
• Audit-Related Requirements such as OMB Circular A-133
• Other Related Materials

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