OGC News - November 2020
Financial Services ConnectionNov 1, 2020
HHS FFR SF425 Moving to PMS
(Federal Financial Reports / Payment Management System)
All financial reporting for recipients of Health and Human Services (HHS) grants and cooperative agreements will be consolidated through a single point of entry, which has been identified as the Payment Management System (PMS).
This process will ensure that reporting and cash draws are reconciled and tied out before financial reports can be submitted and accepted. This will increase scrutiny and visibility of expenses booked to federal grants after the end date, as draws need to be complete for reports to be submitted. This becomes especially crucial for the FINAL FFR.
Here are links to the agency sites for more information:
The Office of Grants and Contracts is working through these changes to align our processes as agencies implement this change. HRSA implemented their process on October 1, 2020 and NIH is expected to implement in January of 2021.
If you have questions or concerns please reach out to Ginger Acierno.
Awards that have reached Billing Limits - In the spring, we announced an upcoming notification for projects that have exceeded their reimbursable billing limit.
This process went live on October 19, 2020.
When a project exceeds the billing limit/budget, we can no longer generate a correct invoice that properly balances Salary and Fringe or Direct Charges and F&A. It is important to know that 9.2 transaction-based billing does not give us the ability to pick-and-choose which transactions to bill in an effective manner. Therefore, going over the limit on cost reimbursable billed projects can cause delay in billing for transactions that are within the limit, until those over the limit/budget are removed.
Emails will be sent the same night a project reaches its limit and every 30 days thereafter. The emails will go to Project Fiscal Managers, OGC Grant Accountants, and all Speedtype Fiscal Staff.
The email will only be for projects that are newly exceeding limit. If you have a project that is currently over limit, you will not receive this notice unless additional expenses are incurred. Projects over limit with no new expenses will not be included.
SAMPLE EMAIL (will come from firstname.lastname@example.org)
Award/Contract Number: 123456
Ref Award Number: AWD-123456
Contract Line 1 Limit: $54,756.00
Total Post Budget: $54,756.00
Total Current Expenses: $57,840.85
Total Excess Amount: $3,084.85
|Contract Line||Project||Project Status||Project End||Posted Budget||Current Expenses||Excess Amount||Limit Reached|
What can I do to resolve?
- Please review the budget and billing limit included. If there is a variance, please work with your Post Award Grant Accountant to resolve.
- If you have concerns about the budget posted, please review your award notice and work with your Post Award Grant Accountant to resolve.
- For projects that are not letter of credit, please see your award notice to determine final invoice deadline, and make sure expenses are removed at least one month prior to that deadline in order to allow any fringe or F&A to run.
- For cost reimbursable projects, you can use PSQUERY to run the query “Billing_Inquiry_By_Project?” to see what amount has been invoiced so far. Note: Any expenses not already invoiced will not be invoiced until this deficit is removed.
- For letter of credit projects, we will draw up to the limit; no additional draws can be made until additional funds are awarded.
If you have questions about this upcoming notification process, please contact Ginger Acierno.
New Proposal Routing Process ReminderOn July 1st, OGC implemented a new proposal routing process. If you missed this change, please visit our website for the update.
As a follow up to this change, we want to remind everyone to make sure to provide the original/master proposal routing number when submitting an amendment via Formstack. For example, if the original routing number was 165123, and there were subsequent amendments prior to the process change under 175123 and 185123, you would list the previous routing number on the Formstack as the original/master number 165123. This helps us to connect the newest amendment with the Master record in InfoEd.
Please reach out if you have questions about this to TK Keith, and we appreciate your help with this process requirement.
Please join us in welcoming Garrett Steed as the new OGC PreAward Manager. Garrett started with the team on September 21 and is coming to us from the Aspen Skiing Company where he served as a Senior Business Analyst. His research administration experience spans over a decade serving as Senior Grants Officer and Contract Officer and Government Project Liaison roles with the University of Colorado Boulder and the Georgia Institute of Technology. We are excited to bring Garrett’s leadership and experience to the OGC team and University!
Effective immediately, please list Garrett as the AOR/SO for all proposal applications and post submission action items. For those items already in process that include Ryan Holland as AOR/SO, Garrett will be signing on his behalf. No changes will be necessary for these items unless explicitly requested by the sponsor. The OGC PreAward review team will make the necessary changes to the signature prior to submission to the sponsor for action items in process for those signature pages that are editable.
Note: Garrett has been made the primary option for the institution AOR for all InfoEd S2S proposal applications submitted to Grants.gov.
NCURA Subrecipient Monitoring Webinar
On October 15, Financial Services and RAIN provided free access to an NCURA webinar entitled “Subawards and Subrecipient Monitoring.” A recording of the webinar is located at https://onlinelearning.ncura.edu/products/subawards-and-subrecipient-monitoring?force_login=1.
You will need to login to NCURA’s website before you can access the recording. Subrecipient monitoring is a critical component of award management and is subject to audit review. 2 CFR 200.331 details the responsibilities of pass-through entities in issuing subaward agreements and monitoring subrecipients. The NCURA webinar examined the complexities, obscurities, and changing landscape of subawards by examining recent OMB changes, potential risks, lesser known federal requirements, foreign subrecipient monitoring, and how to address high-risk subrecipients.
In the coming months, the Compliance Office will begin testing internal controls to ensure University compliance with subrecipient monitoring requirements and to protect the University and Colorado taxpayers from disallowed costs. Additional information about the internal reviews will be announced soon.