Office of Management and Budget (OMB) CIRCULAR

Transcript:Office of Management and Budget (OMB) CIRCULAR:
Office of Management and Budget (OMB) CIRCULAR A-21 Principles for determining costs applicable to grants, contracts, and other agreements with educational institutions CReATE ver. 05/13 © 2013 Florida State University. All rights reserved OMB Circular A-21 THE PRIMARY ACCOUNTING REFERENCE FOR FEDERAL SPONSORED AGREEMENTS 2 DHHS Audit Experience Entrance Conference December 6, 2010 Fieldwork December 6, 2010 – May 26, 2011 Exit Conference May 27, 2011 Draft report received from OIG November 16, 2011 Response to draft submitted January 31, 2012 Final report issued by DHHS OIG July 19, 2012 Response to final report submitted October 9, 2012 Audit Resolution Phase Awaiting DHHS decision on what division will negotiate the final resolution with FSU 3 A-21: A Brief History Originally issued in 1958 Significant changes made in 1996: Raised threshold for capitalizing equipment to $5,000 Established use of Facilities & Administration (F&A) rate(s) in effect at start of sponsored agreement over life of agreement Incorporated four Cost Accounting Standards (CAS) Required educational institutions to submit a Disclosure Statement (DS-2) regarding cost accounting practices Draft Super Circular issued Combines 7 circulars into one document COGR has issued draft response Responses to OMB due June 2, 2013 4 Why talk about OMB Circular A-21? SRS and SRAS employees need to refer to OMB Circulars A-21 and A-110 (next presentation) on a daily basis Every decision on federally funded agreements is guided by these pronouncements 5 A-21: Applicability To all research and development, training and other work funded with federal funds at educational institutions Principles used only as guide in pricing of fixed price or lump sum agreements The Proposal budget on a fixed price agreement is subject to audit for compliance with A-21 Basis for requiring a detailed budget on a fixed price award Actual expenditures on a fixed price agreement are not subject to audit 6 Major Functions Instruction Teaching and training activities Not research training Departmental research Not organized research Not separately budgeted Not considered major function Organized Research Research and development activities Separately budgeted Includes research training 7 Major Functions Other Sponsored Activities Programs and projects that are service oriented Not instruction or organized research Examples Head Start program WFSU activities Other Institutional Activities All activities not otherwise classified Dorms Dining facilities F&A costs Specialized Service Facilities 8 A-21: Direct Costs Can be identified specifically with a particular sponsored project, an instructional activity, or any other institutional activity, or