Codify the FAQs in the New 2 CFR 200
Codify the Frequently Asked Questions (FAQs) to eliminate potential interpretation differences of future auditors and inspectors general between Uniform Guidance and FAQs.
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Grantees
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Grants practices and processes
Key Participants: grantees, cooperative agreement holders, subgrantees
- Question: If you could change one thing that would ease your reporting burden associated with your grants or subgrants, what would it be (e.g., time, cost, resource burden)?
- Question: If you have reporting requirements to the Federal government, how are those met? (feel free to be specific about what is reported to whom and through what mechanism)
- Question: If you could create a central reporting portal into which you could submit all required reports, what capabilities/functions would you include?
OMB circular A-133:
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting by the auditee?
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting by the auditor?
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting to the Federal Audit Clearinghouse?
Uniform Guidance (2 CFR 200):
- Question: Are there requirements in the new 2 CFR 200 that need additional clarification for improved implementation with reduced administrative burden ?
- Question: What are the perceived burdens associated with the new standards such as the documentation of salaries & wages and time & effort (2 CFR 200.430), subrecipient monitoring (2 CFR 200.331), procurement standards (2 CFR 200.317- 2 CFR 200.324)?
- Question: How can the administrative burden associated with standards compliance be lowered?
General comment
I am surprised more people haven't been commenting or making suggestions. Do you think it might be due to the fact that most of us are so busy with our jobs, lacking funds, burnt out and trying to pick up pieces of pie because we are spending our own time working and ignoring everything else? Our jobs have become so complicated with reporting and regulations that we don't have time to take care of the people and partners ...more »
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Eliminate Subcontracting from Prime Awardees
Grant Proposals indicate all institutions involved and require separate budget submissions. Not only is it a waste of taxpayer $ to pay institutions F&A on the first 25K of each sub, but it is so inefficient to dole out the $ to us to turn around and pay out the subs when you can utilize a LOC payment system. Then you impose subrecipient monitoring on us and everybody has to document everyone else's audit report/FCOI ...more »
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Change in Modified Total Direct Costs
Currently Modified Total Direct Cost (MTDC) only allows inclusion of subcontracts up to the first $25,000 of each subaward or subcontract (regardless of the period of performance of the subawards and subcontracts under the award). We suggest increasing this to the first $50,000.
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Raise the Questioned Cost Threshold Above $25,000
The OMB Compliance Supplement for the Single Audit increased the threshold for known or likely questioned costs from $10,000 to $25,000. Princeton University suggests that consideration should be given for a threshold higher than $25,000, particularly when extrapolation could occur throughout the rest of the organization. An alternative solution would be to make the threshold related to a percentage of expenditures ...more »
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More guidance in FAC on Subrecipient Monitoring
Princeton University suggests that the Federal Audit Clearinghouse (FAC) should provide more guidance (e.g. definitions, acronyms) on how to access and leverage annual reports to monitor subrecipients per Uniform Guidance requirements in order to reduce the burden. Assistance in navigating through the forms similar to guidance provided to comply with the Federal Funding Accountability and Transparency Act (FFATA) would ...more »
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Allow PDFs to be Uploaded to Portal
Faculty at Princeton University find it frustrating that each agency requires different data in different formats and that not all the web portals work well. For example, the DOE-BES PAMS system does not always save entries, and this can lead to loss of edits. Clicking to save an entry often takes the PI to the login page, often resulting in loss of data. So having a robust portal that automatically saves data entered ...more »
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Conflict of Interest
Right now the federal conflict of interest statements are due at the application and then reconfirmed upon award. Since most grants aren't funded, it would save hours of time to not have this due until the Just in time documents.
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Adopt a two-stage proposal process
In at least some areas of NSF there is a two-stage proposal process: A short preliminary proposal goes to an initial screening. If it passes that initial screening then a full proposal must be written. I would propose that NEH adopt this process as well. Given the intense competition for NEH grants, with a success rate hovering around 15%, although for the most competitive grants it’s about 6%. Writing grants is a ...more »
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Better Entity Classifications
Comment from June 10 Data Act Summit breakout session on Recipient Reporting:
I’m interested in Entity Classifications- better classifications, better utilization of existing classifications. I want to, for example, be able to look in USASpending.gov and analyze the dollars going to non-profits.
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Remove Administrative Components from Progress Reporting
The RPPR continues to evolve into more financial and administrative reporting than it has to do with scientific/technical progress ever since you eliminated annual FFR's for SNAP grants. Institutions are getting hammered on follow-up questioning from Grants Mgmt Specialists regarding unobligated balances, effort reported on the participants tab, other support, use of IDP's and MyNCBI noncompliant pubs. Many followup ...more »
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True single audit
1. Achieve a true single audit. IHEs are still subject to multiple audits of their individual programs and compliance processes, despite the Single Audit Act of 1984, OMB Circular A-133 and 2CFR-200 Uniform Guidance which mandate single audits for non-federal entities that receive federal funding. The University is subject to a major compliance audit, desk audits and program audits each year.
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