Federal Grant Preparation, Non-Federal Grants, UCLA Policies, Reference Info.

THE FOLLOWING MATERIAL HAS BEEN SHAMELESSLY, FLAGRANTLY, AND METICULOUSLY PLAIGERIZED FROM NUMEROUS CAMPUS SOURCES.
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All Federally funded financial activities of the University must conform to the policies as defined by two Federal circulars:

1. OMB A-21
2. A-110. 

Campus contract and grant management policies are defined in:

1. UCLA policy 910.  NOTE: These requirements are generally applied to non-Federal funding as well.

Section I

Management of Contract and Grant Projects - UCLA Policy 910

1. PI is responsible for the technical, administrative, and fiscal management of the project.
2. PI recognizes that it is necessary and appropriate to rely on staff for assistance in carrying out this responsibility.
3. PI and staff must be knowledgeable about agency and University guidelines.
4. Comply with specific terms and conditions of each award and with all administrative requirements.
5. Conduct work in a timely and professional manner.
6. Maintain budgetary control through the use of departmental bookkeeping, cost control systems and monthly reconciliation of ledgers.
7. PI and staff must certify all costs charged to a given award specifically benefit that project.
8. Review ledgers monthly and ensure that only applicable charges (in approved budget and incurred during the award period) are allocated to the fund.

Section II

Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations - OMB A-110

Provides uniform administrative requirements for grants and other agreements with institutions of higher education, including financial reporting.

Minimum management standards include:

1. Accurate, current, and complete financial results of each sponsored project.
2. Records that adequately identify the source and application of funds.
3. Maintenance of effective controls and accountability, including adequate safeguarding of assets.
4. Comparisons of actual results to budgets on a regular basis.
5. Written procedures to minimize the time between the receipt and disbursement of funds.
6. Written procedures for determining reasonableness, allocability and allowability of costs.
7. Accounting records (including cost sharing) with supporting documentation.

Section III

Cost Principles for Educational Institutions for Grants, Contracts,Other Agreements -OMB A-21 

Provides cost principles for educational institutions defining allowable, allocable, and consistent treatment of costs.

Core requirements:

Allocable:

1. A cost incurred solely to advance the work of the project.
2. A cost that benefits both the project and other work of the institution must be distributed using reasonably approximated proportions.

 Allowable  

1. Compliant with terms/conditions of the award, sponsoring agency, A-21, and University policy.

Consistent

1. Is the cost consistently treated according to generally accepted accounting principles using the institutions policies and procedures?
2. Is the cost consistently incurred for the same purposes and treated consistently as either direct or F&A (overhead)?

Reasonable

1. If the nature of the goods/service and amount involved reflect the action that a prudent person would have taken under the circumstances.

Section IV

Cost Accounting Standards (CAS):

Provides standardization of cost accounting practices for colleges and universities receiving Federal funds and to prevent the charging of unallowable costs to Federal awards.

How does CAS affect us?

Proposal Preparation and Budgeting

All anticipated costs must comply with all guiding principals and be:

1. Allocable
2. Allowable
3. Consistent
4. Documented 
5. Reasonable

When budgeting, consider and document figures for proposed:

Salaries:

1. Based on current pay data for known employees who will support the project.  MSOs - check the EDB.
2. For unfilled/new positions, use midrange figures for the proposed title.  
   Refer here for non-academic titles (note the differences between student a non-student pay rates).
   For non-student academic titles, consult with Payroll Manager.
3. Anticipate merit/range increases.
4. Consider sponsor-imposed salary caps, if applicable.
5. Administrative salaries are generally unallowable.
6. Documentation includes job descriptions, screen prints of current EDB system information, salary projection notices, etc., and must be made available upon request and retained in accordance with UC records retention policy.

Benefits:        

1. For current employees, apply their specific benefit rates.
2. For Graduate Student titles, refer here for current fee remission rates.
3. For unfilled positions, refer to the UC Employee Benefits Rates chart for current rates. 
4. Refer here for current charts for campus insurance premiums for workers compensation, general and employment practices liability, self-insured property and purchased insurance. 
5.  Documentation includes Employee Benefit Rate tables, projection notices, and GSR fee schedule.

Supplies/Expenses:

1. Generally unallowable costs requiring specific justification include:
   Office supplies
   Telephone expenses
   Postage
   Photocopying
   Newsletters/publications
   
   Specifically budget the aforementioned costs if they are directly related and/or necessary to the progress of the project.
   
2. Entertainment is allowable if related to dissemination of project specific information and if those costs are specifically budgeted and approved.
3. Memberships should not be charged directly to a project unless the membership is essential to a specific project and it has been included in the approved proposal budget.
4. Documentation includes historical documentation and worksheets for each category of supplies/expense to support expense estimates.

Travel:

1. Documentation includes historical documentation; current airfare and lodging rates from UCLA Travel Center, published sources, the Internet; worksheets for travel by budget period; use of U.S. flag carriers. 

Consultants:

1. Must be non-UC personnel.
2. Must be compliant with the terms of the award.
3. Budget justification includes name(s), hours and rate(s), travel, the consultant’s resume or biosketch, and the proposed consultant’s expertise specific to the project.

Equipment (costing $5,000 or more):

1. General purpose items are generally unallowable, unless used for scientific purposes specific to the project.
2. Documentation includes historical documentation supporting the expense, current vendor quotes, justification for purchase of general purpose equipment.

F&A (Indirect/Overhead) Costs:

1. Use current negotiated F&A rates.  Refer to this site

Tuition/Fees/Stipends:

1. Refer here for current rates.
2. Documentation includes the above referenced information.

Subcontracts:

1. Awarded to an organization for a substantive portion of the scope of work.
2. Use sponsor guidelines to apply F&A costs (on the first $25,000 of each subaward).
3. Documentation in the form of endorsement from the organization’s business office including a budget, justification, scope of work statement included in the original proposal.

Cost Sharing:

1. Circular A-110 permits all contributions furthering program objectives to be used for meeting cost sharing or matching requirements when the costs are:
   o Verifiable from institutional records.  Ledger costs.
   o Not used as cost sharing on another project.
   o Necessary and reasonable for the support of the project.
   o Allowable.
   o Not funded by the Federal government (except where statutorily provided).
   o Included in the program budget when required by the sponsor.
   o Conform to requirements of A-110.
2. The commitment for cost sharing, regardless of whether referenced in the budget OR quantified in the narrative, will be considered a REQUIREMENT if an award is made.
3. Proposed shared costs will be carefully reviewed before the Vice Provost signs the goldenrod.
4. A cost sharing policy is currently under development at both the UC and Federal levels.

Rebudgeting:

1. Agencies recognize that as projects progress, budgets may need adjusting.  Refer to sponsor guidelines regarding rebudgeting requirements.
2. When rebudgeting is necessary and to forestall questions by EFM at award closing, obtain agency approval.
3. Correspondence to the sponsor concerning rebudgeting (or no-cost time extensions) should be co-signed by the PI and the appropriate OCGA officer.  E-mail correspondence to the agency should be routed through OCGA.

Section V

Noncompliance Consequences

1. Disallowance of expenditures
2. Reductions in award amounts
3. Withholding of payments
4. Ineligibility for letter of credit
5. Suspension and debarment (debarment applies to the entire institution for 5 years
6. Prosecution under the False Claims Act

Published: Monday, December 2, 2013