Basics of Circular A-110

Holly Benze, Director, Research Projects Administration, Johns Hopkins University

Anthony Beckman, Research Administrator, University of Rochester

NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

What is the Purpose of A-110

According to the circular itself:“This circular sets forth standards for

obtaining consistency and uniformity among federal agencies in the administration of

grants to and agreements with institutions of higher education, hospitals, and other non-

profit organizations”

NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

So what in the world does that mean?

• In a nutshell – 2 things: 1. A-110 sets the MAXIMUM administrative requirements that federal agencies may require from institutions.2. Establishes the MINIMUM administrative standards for institutional systems and procedures.

General (Subpart A)Pre-award Requirements (Subpart B)Post-award Requirements (Subpart C)

financial & program managementProperty standardsProcurement standardsReports and records

After-the-award requirements (Subpart D)

Uniform Administrative Requirements

NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

Subpart A

• Equipment: Tangible, non-expendable property charged directly to an award having a useful life of more than a year and an acquisition cost >= $5000.

• Program income: gross income earned by the recipient that is generated by a supported activity or earned as a result of the award.

• Subaward: An award of financial assistance, through any legal agreement, made under and award by a recipient to a Subrecipient. Does not include procurement of goods and services.

NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

Subpart B

• Instruction on appropriate award mechanism (Grant/Cooperative Agreement/Contract)

• Prescribes the use of the SF424 (thanks to the “Controlling paperwork Burdens on the Public”)

• Debarment and Suspension• Special Award Conditions

NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

Post-Award Requirements

Financial and Program Management Standards—written procedures,

accounting records, & controls Payment—Check, EFT, advance Cost Sharing or Matching

oMandatory or Voluntary (Committed or uncommitted)oMust be an allowable expense on the awardoCan be cash, in-kind, or third-party

NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

Financial & Program Management (cont.)

Program Income How should it be used?

1) Added to the project*, 2) deducted from the award amount, or 3)used to fund the non-federal share

*Default if not in the award and for research Usually counts as program income only during

the project period

NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

Financial & Program Management (cont.)

Revision of Budget and Program Planso Prior approval required for: -change in scope -change in key personnel -need additional funds-absence of PI for more than 3 months-reduction of effort of 25% or more-transfer of funds from participant support-issuing a subaward for substantive effort if not in proposal

NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

Financial & Program Management (cont.)

Expanded Authority– Pre-award costs – One-time no-cost extension– Automatic carry-forward

Non-Federal Audits (A-133) Instructions Allowability of Costs (A-21, A-87, A-122) Period of Availability of Funds (Instructions on

spending period)

NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

Property Standards

• Instructions on management and disposition of property

• Instructions on management and disposition of equipment, supplies, intangible property and data

NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

PROCUREMENT STANDARDS

• To make sure that materials and services are procured in an effective manner and in compliance with Federal statutes

• Written standards to prevent a conflict of interest when procuring a contract

• Free and open competition• Procurement procedures

Must be written

NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

Procurement Procedures (cont.)

Effort to use small, minority, or women-owned business

Cost and price analysis—reasonableness, allocability, and allowability

Procurement recordsContract provisions and administration

NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

Reports and Records

• Procedures for monitoring and reporting on projects—financially and technically including any subawards

• Frequency and due dates of reports• What the reports should contain and on what

forms• Site visits• Record retention

NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

Reports and Records (cont.)

• Termination and Enforcement– When can awards be terminated– Why: cause, convenience, mutual agreement– Remedies for enforcement• Withhold payments• Disallow charges• Suspend or terminate• Withhold further awards• Other legally available remedies

NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

AFTER-THE-AWARD REQUIREMENTS

Closeout Procedures End of project

reports: technical,final financial, equipment, and invention (when and what)

Adjustments—disallowances, repayments

Audit?

NCURA 54th annual Meeting, November 4-7, 2012, Washington DC

Case Studies

Questions

Anthony Beckman – abeckman@ORPA.Rochester.eduHolly Benze – hab@jhu.edu