Expenses on federal awards should be treated consistently with non-federal expenses. Ultimately, all expenditures must be reasonable, prudent, allocable, and be of benefit to the government.Įach transaction should have a well-documented audit trail that includes authorization for expenditure, backup documentation and allocation of expenditure. All sub recipients (subcontractors and consultants) have been properly monitored.ĭuring the UGA audit, or the “2 CFR 200 audit”, auditors will look for weaknesses in the grantee´s internal control system. Costs are consistently treated in accordance with the NIH Grants Policy Statement.ħ. The grantee has properly filed all Financial Status Reports (FSR).Ħ. The grantee has properly managed cash and used the Payment Management System ( PMS) correctly and can demonstrate that funds have been drawn correctly as instructed on the quarterly filed form PSC 272.ĥ. The generation of program income during the project has been credited to the government.Ĥ. All funds have been expended during the period of performance.ģ. Costs which are common to a number of projects and cannot be clearly allocated to one project should be treated as an indirect expense.Ģ. Costs which are clearly identifiable to a specific project should be treated as a direct expense. Direct, indirect and unallowable costs should be properly identified and treated consistently. Some of the significant elements to be tested during the Uniform Guidance Audit include:ġ. The level of accounting required by a small business subject to UGA is far greater than the acceptable accounting system needed for Phase 1 Grant and Contract awardees in several regards. The burden of proof rests with the grantee. STTR, ARPA-E and EERE awards that exceed $750,000 in federal funds (irrespective of amounts drawn) during their fiscal year must have an annual audit performed in accordance with UGA.įrom the receipt of a Notice of Grant Award ( NGA), policies and procedures that document direct and indirect grant expenditures will be tested to ensure that spending occurs in accordance with all applicable laws, rules, regulations, and terms and conditions governing your grant. Organizations with expenditures from SBIR. SBIR, STTR, ARPA-E, AND EERE AWARDS ARE SUBJECT TO 2 CFR PART 200 AND THE UNIFORM GUIDANCE AUDIT The 2 CFR 200 regulations requires Companies with certain Grant awards (including NIH grants and DOE Grants and Cooperative Agreements) to be audited in accordance with the Uniform Guidance Audit rules and includes for-profit Companies. In order to ensure that federal grant awards are handled in a fiscally responsible manner, the Office of Management and Budget ( OMB) issued 2 CFR Part 200, THE UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS.Ģ CFR Part 200, Subpart F outlines the accounting requirements to a Uniform Guidance Audit, also known as a 2 CFR 200 Audit and formerly known as the OMB A-133 Audit.
0 Comments
Leave a Reply. |
AuthorWrite something about yourself. No need to be fancy, just an overview. ArchivesCategories |