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FastFactsFeature Presentation

June 18, 2010

We are using audio during this session, so please dial in to our conference line…

Phone number: 877-468-2134 Participant code: 182500

© 2010 The Johns Hopkins University. All rights reserved.

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Today’s TopicWe’ll be taking a look at…

Sub-Recipient Monitoring, Reporting & Records

Retention

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Today’s Presenter

Sunanda HolmesAssistant Director - Office of International Business Operations ComplianceController's Office

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Session Segments

PresentationSunanda will discuss cost sharing, the criteria used for valuations, setting up an auditable system for tracking and program income.During Sunanda’s presentation, your phone will be muted.

Q&AAfter the presentation, we’ll hold a Q&A session. We’ll open up the phone lines, and you’ll be able to ask questions. Sunanda will answer as many of your questions as time allows.

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Contact Us

If you would like to submit a question during the presentation or if you’re having technical difficulties, you can email us at: fastfacts@jhu.eduYou can also send us an instant message!

GoogleTalk – HopkinsFastFacts@gmail.comAOL Instant Messenger – HopkinsFastFactsMSN – FastFacts@jhu.edu

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How To View Full Screen

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Survey

SurveyAt the end of this FastFacts session, we’ll ask you to complete a short survey. Your honest comments will help us to enhance and improve future FastFacts sessions.

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Sub-Recipient Monitoring, Reporting & Records

Retention

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Agenda

Overview:JHU: Where We AreAssessing Proposed Sub-RecipientsMonitoring Sub-RecipientsReporting RequirementsRecord Keeping and Retention

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Where We Are…

Importance to JHU:

Over $85 million paid to foreign subrecipients in FY09.Over $30 million was paid out to foreign subrecipients on USAID funded grants in FY09.Payments made to subrecipients in 62 countries.

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DefinitionsSubaward:

Award of financial assistance in the form of money or property in lieu of money

Includes financial assistance Legal agreementMade under an award by a recipient to a subrecipient

Subrecipient:Recipient of a subagreement awarded to a foreignor domestic organization (either non-profit,educational institution, or private industry) Performance of a portion of the work statement covered by a prime agreement with sponsored funding

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Determining Subrecipient or Vendor Status

An organization is considered to be a subrecipient when it:

Is delegated programmatic responsibility In contrast to performing services or providing goods to the prime organization as a vendor

An organization is considered to be a vendor when it:

Serves as a dealer, distributor or merchant that provides goods or services for the organization’s own use Work product is not expected to be publishable in an academic journalProvides similar goods or services to many different purchasers and operates in a competitive environment.

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Risk Factors to Consider

Size of the sub-recipient awardAward size relative to the sub-recipient's sponsored research portfolio or total funding from all sourcesPercentage passed throughAward complexity, sensitivity of the work and/or extensiveness of the governing regulationsPrior experience with the sub-recipientSub-recipient’s country of operationDegree of external oversight by auditors or sponsoring agenciesSophistication of sub-recipient's accounting systems and administrative operations

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Assessing Capacity & Risk Potential

Determine what reporting & monitoring requirements are necessaryExamine organizational documentsAnalyze financial statementsVet the organization and its governing body members in compliance with US lawReview the organization’s capacity to administer a grantConsider financial health of the organization, Confirm the organization is fiscally secure and no unusual findings in audited financial statements

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Monitoring- Why is it Necessary?

USAID requirement

Budget allocation

Deliverables are met

Success of the project

Costs charged are allowable

Quality assurance

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Types of Monitoring

Program/performanceSubrecipient performance/technical progress Program output-are they being carried out as plannedPerformance quality desired impact being felt

Financial Invoices prepared in accordance with A-110 and A-133Proper accounting practices being followedReconciliation

ComplianceUSAID regulationsLocal laws JHU policies and procedures

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Audit RequirementsADS 591 Provides Policy Directives and Required Procedures for Planning and Conducting Financial Audits of USAID Contractors, Recipients, & Host Government EntitiesForeign for profit and non-profit organizations that expend $300,000 or more per their fiscal year in USAID awards” i.e. as a recipients or subrecipients of USAID grants or cooperative agreements, or as cost reimbursable subcontractors of USAID grant of cooperative agreements, shall have an annual audit conducted in accordance with the Guidelines for Financial Audits Contracted by Foreign Recipients”.Foreign for profit and non-profit organizations expending less than $300K per their fiscal year under USAID grants or cooperative agreements, or as cost reimbursable contractors of USAID grant or cooperative agreements, are exempt from the audit requirement but have to make their records available if USAID requests.

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Techniques for Monitoring

Foreign subrecipient questionnaireAnnual letter from Financial Research ComplianceOnsite review- Regular contact through telephone/emails Program specific

The nature, timing and scope of monitoring foreign sub-recipients may vary by the assessment of risks, funds provided, nature of work, duration of involvement and other factors

A-133Sets forth audit procedures for obtaining consistency & uniformity among Federal agencies for auditsForeign sub-recipients that are exempt from A-133 are required to make their financial records available for review or audit by Federal agencies or pass-thru entities as requested, under the Terms and Conditions of their Agreement

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What’s New for Subrecipient Monitoring?

BudgetingFees associated with routine oversight/monitoring should be included in the proposal and direct chargedController’s Office is working on guidelines for audit costs

Monitoring processEstablishing risk assessmentsReviewing documents provided by foreign subsReviews/auditing of subs based on established criteria

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JHU Subrecipient Monitoring Policy

JHU policy on subrecipient monitoringhttps://www.controller.jhu.edu/policyapp/displayGuidePDF.do?guideId=SUB

Questions?Please contact Rick Inglis in Financial Research Compliance compliance@jhu.edu

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Reporting Requirements

All financial reporting should be coordinated through Sponsored Projects Shared Services (SPSS).

Expenses reported must balance to SAP.SF 269’s generally due quarterly, no later than 30 days after the reporting periodFinal financial reports due no later than 90 days after end of grant periodReporting of foreign taxes (VAT) due annually by April 16For financial reporting questions, please contact Steve Culp in SPSS sculp@jhu.edu

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Record Keeping and Retention

Financial records (electronic and paper), supporting documents, statistical records, and all other records pertinent to a sponsored award (or tax return) shall be retained for a period of seven years from the date of submission of all deliverables.Financial reports, patent reports, technical reports and equipment reports are examples of deliverables.Field office staff should coordinate retention efforts with the Baltimore office.For additional guidance from JHU, please refer to:

http://www.controller.jhu.edu/acct_recon/acct_reconciliation_guide/Chapter_2_Reconciliation_Guidelines.pdf

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In ConclusionApplicable regulations:

22 CFR 226.26 – Non Federal Audits (A-133 requirements)Institutions of higher education or other non-profits are subject to the Single Audit Act

22 CFR 226.52 – Financial ReportingDesignates which forms must be used by USAID recipients

22 CFR 226.53 – Retention & Access Requirements for Records

Exclusive list of record retention & access RequirementsUSAID cannot impose additional retention requirements upon subs

22 CFR 226.70 – After the Award Requirements (Closeout)Refer to Subpart D226.71 through 226.71 sets forth the closeout procedures and subsequent disallowances for adjustments

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We’re going to open the phone lines now!

There will be a slight pause, and then a recorded voice will provide instructions on how to ask questions over this conference call line.

We’ll be answering questions in the order that we receive them.

We’ll also be answering the questions that were emailed to us during the presentation.

If there’s a question that we can’t answer, we’ll do some research after this session, and then email the answer to all participants.

Q&A

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Thank You!

Thank you for participating!We would love to hear from you.

Are there certain topics that you would like us to cover in future FastFacts sessions?Would you like to be a FastFacts presenter?Please email us at: fastfacts@jhu.edu

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Survey

Before we close, please take the time to complete a short survey.Your feedback will help us as we plan future FastFacts sessions.Click this link to access the survey… http://connect.johnshopkins.edu/fastfactssurvey/

Thanks again!