National Institute of Health Solutions

The expertise to keep your award safe and well.

The NIH differs greatly from other government agencies; it has its own payment system, its own rules for indirect rate negotiations and its own accounting and reporting mandates. Naturally, Jameson is well-versed in them all.

The National Institutes of Health (NIH) and its parent, the Department of Health and Human Services (HHS) exist to protect and improve our nation’s health. They do this by funding, conducting and supporting research through SBIR/STTR, BARDA, BAA, R21, R01 and U01 awards.  The vast majority of these funds are awarded as grants, with a smaller portion being awarded through contracts.

All of the awards listed above are “cost reimbursable” type funding vehicles and require the recipient to properly account for all actual project specific costs in accordance with the FAR and NIH Supplemental Regs. including the proportional indirect costs associated with the award, and are subject to several types of audits.

 

NIH REPORTS AND AUDITS

Every government award comes with an assortment of mandatory reports and audits. You can count on the following:

1. An Annual Incurred Cost Submission or “true up” report is due 180 days after the Company’s fiscal year end and must reflect all general ledger expenses on a generally accepted accounting principles (GAAP) basis. This report is used by the Division of Financial Advisory Services (DFAS) located in Bethesda, MD to settle the final accounting for all HHS/NIH grants and contracts, including the negotiation of a final indirect cost rate agreement as well as a provisional indirect cost rate agreement for future government billing and proposal purposes.

Included in the schedules and information, which needs to be submitted to DFAS are:

  •  A copy of your financial statements, audited if available. Investors and lenders generally require these accrual basis statements to be audited in accordance with generally accepted auditing standards (GAAS).
    All expenses must be accounted for and reported as either direct, indirect and unallowable based on the Federal Acquisition Regulations (FAR). Additionally, the NIH Supplemental Regulations must be applied – which usually affects the cost recovery of salaries, patent & legal costs, and internal research & development expenses among others.
  •  All labor costs must be distributed through the general ledger, on an accrual basis, based on monthly labor distributions derived from employee prepared (and supervisor approved) time sheets, which must be reconciled to the quarterly payroll tax returns – a cash basis document.
  •  Indirect costs must be proportionally allocated to all grant and non-grant (including commercial) activities based on the methodology agreed to in the annual indirect cost rate negotiation. Care must be taken to ensure that the recovery of indirect costs is properly established to avoid negative cash flow surprises.
  •  A schedule detailing all employee salaries costs distributed, as well as an organization chart, which provides DFAS with visibility into the “reasonableness” of your pay methodology as well has how your employees report their time charges.
  •  An Accounting Policies and Procedures manual and any Employee Handbooks.
  •  Detailed descriptions of all consulting and subcontracting costs.
  •  The annual incurred cost submission must be certified by an officer of the Company.

Once the annual incurred cost report is submitted, any over-billing or under-billing of indirect expenses must be proactively remedied on a grant by grant basis.

2. OMB A-133 audit.  If an awardee has annual revenue from grants that exceeds $500,000 ($750,000 for fiscal years beginning on or after January 1, 2015) then it is also subject to an annual OMB A-133 audit. The awardee is required to hire and pay for a CPA firm professionally qualified to conduct this type of audit, which encompasses both financial and compliance components. The audit report must be submitted to the National External Audit Review Center within nine months of the Company’s fiscal year end. The auditor’s report is reviewed by the Inspector General’s Office (IG) for quality control purposes and the CPA firm’s work papers may be audited by the IG.

The annual negotiation of your incurred cost submission will not occur until DFAS is provided a copy of your final OMB A-133 report.

3. Form SF-425, Federal Financial Report (FFR)  Filed on a quarterly basis, this report reconciles the funds drawn from the Payment Management System (PMS) to the actual spending from the Company’s accounting system.  The form sign-off includes a certification (on line 13) that “any false, fictitious, or fraudulent information may subject me to criminal, civil, or administrative penalties”.

Improper cash draws from the PMS and improper supervision/accountability of subcontractors and consultants are the most common audit findings that require repatriation of funds.

 

GET THE HELP—AND EXPERTISE—YOU NEED

If you’re overwhelmed by the previous section, consider Jameson & Company. We are the leading experts in government grants and contracts, we know the NIH inside and out, and there are a number of ways in which we can help.

  • assist in the development of the financial portion of your grant proposal including the appropriate indirect cost rate
  • set up your accounting system and train your financial liaison
  • negotiate the initial and ongoing indirect rate agreements and represent you during the annual audit(s)
  • oversee your accounting system on a periodic basis including ensuring that Payment Management System (PMS) draw downs are accurate
  • prepare the quarterly Federal Financial Report (FFR) aka SF-425, which reconciles the actual project funding earned to the PMS draws for your signature
  • help you hire a qualified auditor to conduct the annual OMB A-133 audit and represent you during the audit itself
Jameson on Twitter Jameson on YouTube Jameson on LinkedIn
209 Burlington Road | Suite 215 | Bedford, MA 01730 | Phone: (781) 862-5170Privacy | Terms of Use | Copyright Jameson & Company 2017
Your browser is out-of-date!

Update your browser to view this website correctly. Update my browser now

×