NSF Compliance Agreement Activity Overview
An Overview of NSF
Compliance Agreement
Activity
Presentation to
NSF Relevant Employees
By
JSU NSF Compliance Committee
Background Information
National Science Foundation (NSF) conducted an audit of
cumulative costs for active NSF awards shown on JSU’s Federal
Financial Report as of September 30, 2011.
Audit Findings:
1.
Claimed excess indirect costs
2.
Unallowable equipment costs, fringe benefits, travel costs, and
other direct costs claimed
3.
Lack of Support and/or inadequate support for expenses charged
to awards (lack of time and effort reports; lack of acceptance
letters for participant support and stipends)
Audit Findings Resolution
In 2015, a former JSU employee pled guilty to “falsifying time
and effort reports, and directing others to do so, during an
audit in an effort to support the salary costs incurred on the
university’s NSF grants” (NSF OIG Semi-Annual Report,
September 2015, p. 23).
On January 25, 2017, JSU executed a settlement agreement
with the United States Government via the National Science
Foundation’s Office of Inspector General (NSF OIG) to
implement a Compliance Program (CP) to ensure compliance
with all laws, regulations, terms, and conditions applicable to
National Science Foundation (NSF) awards.
Requirements Under
Agreement
The Compliance Agreement is in place for 5 years
(07/24/17 – 07/24/22), during which time we must:
Develop a code of conduct that holds JSU personnel to high
ethical standards of professional conduct and integrity, and
addresses conflicts of interest;
Status: Complete
Ensure accurate time and effort reporting under NSF awards to
meet the standards of the cost principles and administrative
requirements
Status:
Complete
Requirements Under
Agreement
Ensure accurate charging of costs under NSF awards;
Status:
Complete
Ensure accurate monitoring, managing and reporting of cost
sharing when applicable;
Status:
Complete
Ensure management and retention of documents of relevant
documents for 10 years; and
Status: Complete
Requirements Under
Agreement
Ensure timely written disclosure, to NSF OIG as well as NSF
management, of credible evidence of a violation of law
involving an NSF award or relevant employees working on an
NSF award
Status: Complete
Compliance Program
Objectives
Establish and maintain effective internal controls
Describe the roles and responsibilities for managers,
administrators and principal investigators
Promote orderly, economical, and efficient operations and
achieve planned outcomes
Safeguard resources against fraud, waste, abuse and
mismanagement
Compliance Committee
Compliance Committee as appointed by President William B. Bynum, Jr. (Proposed Membership)
Dr. Joseph A. Whittaker, Associate Provost & VP of Research and Economic Development (NSF
Compliance Officer)
Dr. Daarel Burnette, Vice President of Business and Finance (CFO)
Mrs. Tracy Stapleton, Executive Director of the Division of Business & Finance
Mr. Illiad Kelly, Director, Unit of Grants and Contracts Management (Finance and Internal Controls;
Training)
Dr. Almesha Campbell, Office of Research & Sponsored Programs
Mr. Keunta McPhearson, NSF Grant Accountant, Unit of Grants and Contracts Management
Dr. Sophia Leggett, Institutional Review Board (IRB)
Mrs. Robin Spann-Pack, Human Resources
Mr. Edward O. Watson, University General Counsel
Dr. Wilbur Walters, Dean – College of Science, Engineering and Technology
Dr. Glake Hill, NSF Principal Investigator
Dr. Lynda Brown-Wright, Provost /
Ex Officio
Training Requirements
Each relevant employee shall receive a
minimum of two hours
of
initial training that shall include a discussion of the contents of
JSU’s Compliance Program as well as the relevant award
requirements, and shall receive
additional compliance training of
at least two hours on an annual basis.
This training shall take
place both in person and on-line. Relevant employees include:
Principal Investigators (PIs), co-PIs, other faculty, officers, staff,
students, contractors, sub-recipients or other persons responsible
for the design, conduct, administration or other activity funded or
supported by NSF awards.
JSU shall include in subrecipient agreements a requirement that
subrecipients provide comprehensive compliance training
Internal Reporting
JSU will utilize the existing confidential reporting mechanism of
the Mississippi Institutions of Higher Learning (EthicsPoint)
NSF OIG Fraud Hotline posters will be placed prominently on
JSU’s compliance website and in campus locations that have been
identified as areas where relevant employees conduct research and
manage other grant-related responsibilities
Mandatory annual independent audits must be conducted to
ensure compliance for the duration of the agreement
Compliance Program Monitoring
Although the Compliance Agreement requires annual
reviews, JSU will conduct self-reviews semi-annually for the
first two years to ensure the fidelity of the implementation
of the program and that internal controls employed are
sufficient. After the initial two years of the program, JSU
will conduct self-reviews annually.
Compliance Agreement
Questions
National Science Foundation (NSF) conducted an audit of cumulative costs for active NSF awards shown on JSU's Federal Financial Report. Audit findings included claimed excess indirect costs, unallowable expenses, and lack of adequate support for expenses. The audit findings led to the implementation of a Compliance Program at JSU. The Compliance Agreement, in effect for 5 years, outlines requirements such as developing a code of conduct, ensuring accurate reporting, and managing documents. Various steps have been taken to ensure compliance with NSF regulations.
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Presentation Transcript
An Overview of NSF Compliance Agreement Activity Presentation to NSF Relevant Employees By JSU NSF Compliance Committee
Background Information National Science Foundation (NSF) conducted an audit of cumulative costs for active NSF awards shown on JSU s Federal Financial Report as of September 30, 2011. Audit Findings: 1. Claimed excess indirect costs 2. Unallowable equipment costs, fringe benefits, travel costs, and other direct costs claimed 3. Lack of Support and/or inadequate support for expenses charged to awards (lack of time and effort reports; lack of acceptance letters for participant support and stipends)
Audit Findings Resolution In 2015, a former JSU employee pled guilty to falsifying time and effort reports, and directing others to do so, during an audit in an effort to support the salary costs incurred on the university s NSF grants (NSF OIG Semi-Annual Report, September 2015, p. 23). On January 25, 2017, JSU executed a settlement agreement with the United States Government via the National Science Foundation s Office of Inspector General (NSF OIG) to implement a Compliance Program (CP) to ensure compliance with all laws, regulations, terms, and conditions applicable to National Science Foundation (NSF) awards.
Requirements Under Agreement The Compliance Agreement is in place for 5 years (07/24/17 07/24/22), during which time we must: Develop a code of conduct that holds JSU personnel to high ethical standards of professional conduct and integrity, and addresses conflicts of interest; Status: Complete Ensure accurate time and effort reporting under NSF awards to meet the standards of the cost principles and administrative requirements Status: Complete
Requirements Under Agreement Ensure accurate charging of costs under NSF awards; Status: Complete Ensure accurate monitoring, managing and reporting of cost sharing when applicable; Status: Complete Ensure management and retention of documents of relevant documents for 10 years; and Status: Complete
Requirements Under Agreement Ensure timely written disclosure, to NSF OIG as well as NSF management, of credible evidence of a violation of law involving an NSF award or relevant employees working on an NSF award Status: Complete
Compliance Program Objectives Establish and maintain effective internal controls Describe the roles and responsibilities for managers, administrators and principal investigators Promote orderly, economical, and efficient operations and achieve planned outcomes Safeguard resources against fraud, waste, abuse and mismanagement
Compliance Committee Compliance Committee as appointed by President William B. Bynum, Jr. (Proposed Membership) Dr. Joseph A. Whittaker, Associate Provost & VP of Research and Economic Development (NSF Compliance Officer) Dr. Daarel Burnette, Vice President of Business and Finance (CFO) Mrs. Tracy Stapleton, Executive Director of the Division of Business & Finance Mr. Illiad Kelly, Director, Unit of Grants and Contracts Management (Finance and Internal Controls; Training) Dr. Almesha Campbell, Office of Research & Sponsored Programs Mr. Keunta McPhearson, NSF Grant Accountant, Unit of Grants and Contracts Management Dr. Sophia Leggett, Institutional Review Board (IRB) Mrs. Robin Spann-Pack, Human Resources Mr. Edward O. Watson, University General Counsel Dr. Wilbur Walters, Dean College of Science, Engineering and Technology Dr. Glake Hill, NSF Principal Investigator Dr. Lynda Brown-Wright, Provost / Ex Officio
Training Requirements Each relevant employee shall receive a minimum of two hours of initial training that shall include a discussion of the contents of JSU s Compliance Program as well as the relevant award requirements, and shall receive additional compliance training of at least two hours on an annual basis. This training shall take place both in person and on-line. Relevant employees include: Principal Investigators (PIs), co-PIs, other faculty, officers, staff, students, contractors, sub-recipients or other persons responsible for the design, conduct, administration or other activity funded or supported by NSF awards. JSU shall include in subrecipient agreements a requirement that subrecipients provide comprehensive compliance training
Internal Reporting JSU will utilize the existing confidential reporting mechanism of the Mississippi Institutions of Higher Learning (EthicsPoint) NSF OIG Fraud Hotline posters will be placed prominently on JSU s compliance website and in campus locations that have been identified as areas where relevant employees conduct research and manage other grant-related responsibilities Mandatory annual independent audits must be conducted to ensure compliance for the duration of the agreement
Compliance Program Monitoring Although the Compliance Agreement requires annual reviews, JSU will conduct self-reviews semi-annually for the first two years to ensure the fidelity of the implementation of the program and that internal controls employed are sufficient. After the initial two years of the program, JSU will conduct self-reviews annually.
Compliance Agreement Questions
