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OMB No A-110: Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education

I.   Uniform Administrative Requirements for Grants & Agreements

“This Circular sets forth standards for obtaining consistency and uniformity among Federal agencies in the administration of grants to and agreements with institutions of higher education, hospitals, and other non-profit organizations.”

II.  Reporting Requirements

A-110 sets forth procedures for monitoring and reporting financial and program performance and the required reporting forms, including requirements for record retention. Award recipients are responsible for managing and monitoring each project, program, function and activity supported by an award. Award recipients are also responsible for ensuring that any and all subrecipients have met applicable audit requirements. Reports must be completed not more than quarterly and not less than annually. Reports must contain the following:

a.  Comparison of actual accomplishments with set goals for the reporting period
b.  If applicable, reasons goals were not met
c.  Explanations for any cost over-runs or high unit costs

Award recipients must notify the awarding agency whenever events occur that have a significant impact on the project or program, or when problems, delays, or adverse conditions materially impair the ability to attain program objectives. The agency must be notified whenever the scope of the project changes. A Financial Status Report (FSR), such as SF-269, is required at the completion of any federally sponsored project. At OHSU, this final report is prepared in Sponsored Projects Administration (SPA), with supporting documentation provided by the department. Final scientific reports are the responsibility of the Principal Investigator. Departments should notify SPA once the final scientific report has been submitted to the sponsor.

III.  Record Retention Requirements

According to A-110, financial records, supporting documents, statistical records and all other records must be retained for three years from the date of final report, except when:

a.  Litigation requires retention until matters have been resolved
b.  Records are transferred to the agency, in which case retention requirements end
c.  Other requirements apply (eg, state or university requirements)

With agency approval, copies may be substituted for originals. Electronic copies are acceptable, provided the institution has established appropriate procedures.

IV.  Program Income

An award recipient has no responsibility to the awarding agency for income earned after the completion of the project period unless the agency's regulations or Terms and Conditions specify otherwise. Program income received during an active project may be handled in one of the following ways:

a.  Added to funds committed to the project
b.  Deducted from total project allowable costs
c.  Applied to the non-federal share of project costs
d.  Delivered to the sponsoring agency

For full text of circular see: http://www.whitehouse.gov/omb/rewrite/circulars/a110/a110.html.

Academic Dean