Desk reviews are essentially an overarching appraisal of an institution’s award administration capacity. These reviews include four core review areas: General Management, Accounting System, Award Cash Management (ACM$) Reconciliation, and American Recovery and Reinvestment Act of 2009 (ARRA) Reporting Procedures Review (as needed). By gathering information in these four core areas, CAAR assesses the extent to which an awardee maintains a controlled environment within which awards are likely to be administered in compliance with Federal regulations and NSF agreement provisions. The process also ensures that NSF’s recipient institutions are utilizing sound business and administrative practices in order to achieve the purpose of their grant-funded projects. CAAR performs approximately 120 desk reviews every year.
In some cases, desk reviews are scheduled in advance of a site visit. Desk reviews may also be performed on awardees whose prior monitoring activities include a desk review, site visit, or both. These desk reviews may include both the standard review and/or a review of ARRA related information. CAAR will document changes in policies and procedures since the last monitoring activity and any related concerns identified during the review will be noted in the summary report.
CAAR prioritizes awardee institutions to participate in advanced monitoring (i.e., site visits or desk reviews) based on the results of its annual award portfolio risk assessment, monitoring requests from other NSF divisions, and professional judgment. The annual risk assessment assigns each awardee to a review category and includes award factors, institutional factors, prior monitoring activities and results, and award administration and program staff feedback.
The desk review process begins when NSF sends a letter notifying the awardee that they have been selected to participate in a desk review. The awardee will then receive a request for documentation from an external contractor. The contractor will correspond directly with the awardee to collect the required information and schedule one or more discussion calls. After completion of the discussion call(s), the contractor may request additional documentation. In most cases, the contractor will then send a letter notifying the awardee about any issues identified during the review, and the awardee will be allowed a short period of time to respond and/or submit additional documentation. Last, the contractor compiles the draft desk review report for NSF review and approval. Throughout the desk review process, the contractor communicates the status of each desk review to NSF, including any issues that may arise during the review.
After the desk review has been completed and approved by NSF, the awardee will receive a letter which provides feedback by describing any issues identified during the review. Awardees may be required to prepare a corrective action plan to remedy any deficiencies. NSF tracks the status of each awardee’s implementation of a mutually agreed upon remedy until the issues are resolved. Minor concerns may not require a corrective action plan, but awardees are expected to address the issues promptly.
CAAR leads the desk review effort in collaboration with other NSF divisions. Desk reviews are typically prepared by an external contractor. CAAR staff review the draft report to verify that the review meets NSF standards and that any issues identified in the report are adequately substantiated.
Typically, two to four representatives from the awardee institution (e.g., two sponsored programs office staff and one accounting staff) participate in the desk review process. Since the review process focuses on award administration and not award performance, the Principal Investigator of the award reviewed is not usually involved in the process.
Desk reviews are typically completed within 90 to 120 days of awardee notification. Abbreviated reviews of only ARRA related information are typically completed within 45 to 60 days of awardee notification.
Desk reviews include three or four core review areas:
- General Management Survey – assess the extent to which an organization has a sound organizational structure that will protect assets, ensure against the incurrence of improper liabilities, and ensure the accuracy and reliability of financial and operating information
- Accounting and Financial System Review – assess the sufficiency of the awardee’s financial management policies, procedures, and controls in accurately and completely disclosing and documenting the financial results of Federal awards; provide effective control and accountability of funds, property, and other assets; and determine the reasonableness, allocability, and allowability of costs
- ACM$ Reconciliation to the Recipient Institution’s Accounting Records – gather from the awardees supporting accounting records and a reconciliation between award-related cumulative disbursements reported to NSF and corresponding information in the awardee’s accounting records. (After the Award Cash Management Service (ACM$) was deployed, FFRs were eliminated effective March 31, 2013. As a result, NSF discontinued FFR reviews as of September 30, 2013.)
- ARRA Module (if applicable) – verify that the awardee has developed policies, procedures, and appropriate changes to underlying financial and grant management systems to separately account for and report on ARRA funding, and an FFR reconciliation of an ARRA-funded award. (Only being conducted for selected awardees managing ARRA-funded awards that have been extended beyond September 30, 2013)
Resources and References