Compliance Resources

A. Common Areas of Grantsmanship and Accountability
  1. Federal Regulations & Certifications (Refer to Section on Certifications & Forms)

    1. Office of Management and Budget (OMB Circular) Uniform Guidance
      1. The new OMB 2 CFR Part 200 Uniform Guidance streamlines Administrative Requirements, Cost Principles, and Audit Requirement guidelines for federal awards received by all types of non-federal entities. Overlapping requirements were eliminated, and overly burdensome or conflicting requirements were reformed in an effort to allow federal award recipients to focus their efforts on programmatic objectives instead of compliance with complex requirements. (Excerpt provided by CostTree Academy)

      2. Goals of the 2 CFR 200:
        • To ensure the integrity of taxpayer dollars by improving
          performance outcomes of federal resources
        • To ease administrative burden and strengthen oversight to
          reduce risks of waste, fraud, and abuse
        • 2 CFR Part 200 supersedes OMB Circulars, A-21, A-87, A-110,
          A-122, A-89, A-102, A-133.

  2. Federal Certifications
    • Debarment and Suspension
    • Federal Lobbying Regulations
    • Procurement Integrity (Federal Acquisition Regulations-FAR & USC)

  3. JCSU Policies (Responding to Agency Guidelines)
    • Responsible Conduct in Research (RCR)
    • Financial Conflict of Interest in Research
    • Misconduct in Science
    • Extra Compensation
B. Federal Regulations and Certifications

Certifications on debarment and suspension and federal lobbying are remitted to satisfy regulations and required upon submission of application for federal funds. Special conditions in post-award policies relating to budget revisions, cost sharing, reporting and record retention are discussed in 2 CFR 200 Subpart E. Guidelines for procurement integrity such as the Davis-Bacon Act must be adhered to as it relates to 2 CFR 200 Subpart F audit processes.

 

  1. Uniform Guidance - 2 CFR 200 Subpart E
    These Administrative Requirements establish principles for determining costs applicable to grants, contracts, and other agreements with educational institutions. The principles deal with the subject of cost determination, and make no attempt to identify the circumstances or dictate the extent of agency and institutional participation in the financing of a particular project. The principles are designed to provide that the Federal Government bear its fair share of total costs, determined in accordance with generally accepted accounting principles, except where restricted or prohibited by law. Agencies are not expected to place additional restrictions on individual items of cost. Provision for profit or other increment above cost is outside the scope of this Circular.

    1. Subpart C, 200.2XX (Pre-Award – Federal): These Administrative Requirements set 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.

    2. Subpart E, 200.4XX – Cost Principles: Allowable, Allocable, and Reasonable Costs: A primary responsibility of the office of Government Sponsored Programs and Research is to insure that all costs charged to the sponsored research award are allowable and allocable. A determination of allowability and allocability for a given cost is based on the specific guidelines of the sponsoring agency and according to federal costs principles. Once a determination of allowability, allocability, and reasonable has been made, it is important that all expenses be charged to the appropriate expenditure type or natural class.

    3. Subpart F, 200.5XX - Audit: This part sets forth standards for obtaining consistency and uniformity among Federal agencies for the audit of non-Federal entities expending Federal awards.
C. Johnson C. Smith University Policies Responding to Agencies Regulations & Guidelines
  1. Responsible Conduct in Research (RCR)
    1. Background: The responsible and ethical conduct of research (RCR) is critical for excellence, as well as public trust, in science and engineering. Consequently, education in RCR is considered essential in the preparation of future scientists and engineers. Section 7009 of the America Creating Opportunities to Meaningfully Promote Excellence in Technology, Education, and Science (COMPETES) Act (42 U.S.C. 1862o–1 requires that "each institution that applies for financial assistance from the Foundation for science and engineering research or education describe in its grant proposal a plan to provide appropriate training and oversight in the responsible and ethical conduct of research to undergraduate students, graduate students, and postdoctoral researchers participating in the proposed research project."

  2. Financial Conflict of Interest in Research Policy - Summarized:
    • Presents and discusses circumstances which can create real or perceived conflicts of commitment and conflicts of interest.
    • Defines key terms.
    • Details substantive prohibitions and restrictions.
    • Describes the procedures for disclosing financial and other interests, reviewing disclosures, reporting information to other agencies, implementing the policy, appealing decisions concerning the policy, and sanctioning non-compliance with the policy.
    • Establishes requirements for ongoing certifications and financial disclosures. Specifies special restrictions on human subject research.
    An institutional policy must ensure that investigators have provided all required financial disclosures at the time the proposal is submitted. It must also require that those financial disclosures are updated during the period of the award, either on an annual basis, or as new reportable significant financial interests are obtained.

  3. Misconduct in Science
    Misconduct in Research is defined as: fabrication of information, falsification of data, plagiarism, or other practice which seriously deviate from commonly accepted practices in proposing, carrying out or reporting research. Research misconduct does not include honest error or honest differences in interpretations or judgment of data. Johnson C. Smith University expects that all research conducted by its faculty, students or other associates will comply with generally accepted ethics and legal standards for research. The University has an established policy and procedures for handling Misconduct in Science.

  4. Extra Compensation
    The University has established a policy for the payment of faculty and staff who provide services to the University beyond the scope of their normal employment. The policy establishes guidelines for determining the rate and amount of extra compensation that may be received by faculty and staff members for services performed through the University. This policy is in accordance with the U.S. Office of Management and Budget (OMB) Uniform Guidance 2 CFR 200, Subpart E)- that details the issue of extra compensation, the allowable conditions under which grant personnel may receive extra compensation, and the minimum standards for documentation in support of extra compensation.

COMPLIANCE

Certifications & Forms

Assurance of Debarment Statement

This certification is required by the regulations implementing Executive Order 12549, Debarment and Suspension.

Lobbying Disclosure

This disclosure form shall be completed by the reporting entity, whether subawardee or prime Federal recipient, at the initiation or receipt of a covered Federal action.

Procurement Integrity

he Procurement Integrity Act as codified at41 U.S.C. 423 prohibits disclosing or obtaining procurement-sensitive information, to include contractor bid or proposal information.

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