09-29 April 2009
III - Financial Requirements and Payments
The acceptance of a grant from NSF creates a legal duty on the part of the grantee organization to use the funds or property made available in accordance with the conditions of the grant. Payments may be made in advance of work performed or as a reimbursement for work performed and/or costs incurred by the grantee. However, payments may not be made in advance of a grant being signed by a Grants and Agreements Officer for the project period. NSF has a reversionary interest in the unused balance of advance payments, in any funds improperly applied (whether or not received as an advance payment), and in property acquired through the grant, to which NSF specifically either retains title or reserves the right to require title transfer.
The provisions of this chapter cover all NSF assistance awards (grants and cooperative agreements). Graduate fellowship agreements with domestic colleges and universities are included, but individual fellowships and contracts are excluded. All categories of grantees (academic, non-academic, profit and non-profit) are covered by this chapter. The procedures in this chapter apply primarily to the comptroller’s office or business office.
A. Standards for Financial Management
NSF grantees are required to have financial management systems that meet the requirements of Section .21 of OMB Circular A-110. (2 CFR §215.21)
The following definitions are either not included elsewhere in the Guide or are repeated in this section because of their special applicability to this chapter.
BUSINESS OFFICER - the financial official of the grantee organization who has primary responsibility for the accountability for and reporting on NSF grant funds.
CASH ON HAND - the balance remaining of the funds an organization has received from NSF.
DISBURSEMENTS/OUTLAYS/EXPENDITURES - charges made to the project during a given period for:
a. Goods and other tangible property received;
b. Services performed by employees, subawardees, contractors and other payees.
FASTLANE FINANCIAL FUNCTIONS - functions of NSF’s FastLane System used by grantees to transmit financial information to NSF. There are three primary Financial Functions used by grantees.
- Federal Financial Report Function - electronic version of the standard “Federal Financial Report”. Used by grantees to report the financial activity of NSF awards on a quarterly basis. (See AAG Chapter III.E.1)
- Cash Request Function - used by grantees to request funds. (See AAG Chapter III.C.1)
- Grantee EFT Update Function. - used by grantees to provide NSF with their banking information. (See AAG Chapter III.C.6)
GRANTEE - the organization or other entity that receives a grant and assumes legal and financial responsibility and accountability both for the awarded funds and for the performance of the grant-supported activity. NSF grants are normally made to organizations rather than to individual PI/PD(s).
NSF OBLIGATIONS - funds authorized by an NSF Grants Officer for a specific NSF award creating a balance payable to a grantee.
GRANTEE OBLIGATIONS - the amounts of orders placed, subawards issued, contracts awarded, services received and similar transactions during a given period that will require a future payment by the grantee.
PAYMENTS - funds transferred from NSF to the grantee by direct deposit (Automated Clearing House (ACH) Vendor Express) and on some rare occasions by check.
UNLIQUIDATED OBLIGATIONS - expenses incurred but not paid. Such obligations are included in reports prepared by grantees whose financial records are maintained on an accrual basis.
UNOBLIGATED BALANCE - the portion of the funds authorized by the grant that have not been obligated by the grantee. It is determined by deducting outlays and unliquidated obligations from the funds authorized.
C. Payment Requirements
1. Requesting Payments
NSF's grantees, except for Special Payment grantees, AAG Chapter III.C.4, and some foreign grantees, are required to request payments electronically through the FastLane Cash Request Function. The Special Payment and certain foreign grantees without access to a U.S. bank are required to request funds by submitting a "Request for Advance or Reimbursement Form", (SF 270) (see (AAG Exhibit III-1), to NSF either through mail, email or by fax.
2. Payment Policies
The purpose of this section is to prescribe the timing of advances and the procedures to be observed to assure that cash payments occur only when essential to meet the needs of a grantee for its actual disbursements.
a. Timing of Payments. Advances to a grantee shall be limited to the minimum amount needed and shall be timed to be in accordance with the actual, immediate cash requirements of the grantee in carrying out the purpose of the approved program or project. The timing and amount of cash advances shall be as close as is administratively feasible to actual disbursements for direct program costs and the proportionate share of any allowable indirect costs.
b. Payments to Subawardees. Cash advances made by primary grantees (those which receive advances directly from NSF) to others (subawardees) shall conform to the same standards of timing and amount as apply to advances by NSF to primary grantees, including the furnishing of reports of cash disbursements and balances.
c. Withholding payments. NSF reserves the right, upon written notice, to withhold future payments after a specified date if the recipient:
(i) Fails to comply with the conditions of an NSF grant, including the reporting requirements; or
(ii) Is indebted to the U.S. Government.
Safeguarding Funds. In no case will NSF-furnished funds be commingled with the personal funds of, or be used for personal purposes by, any officer, employee, or agent of the grantee; nor will any of these funds be deposited in personal bank accounts for disbursement by personal check.
3. Request for Advance
a. Grantees may receive payments from NSF in advance of cost incurred provided that the following conditions exist:
(i) Funds for the project period have been obligated by a Grants and Agreements Officer in the form of a signed grant;
(ii) The grantee has established or demonstrated to NSF the willingness and ability to establish written procedures that will minimize the time elapsing between the transfer of funds from the U.S. Treasury and their disbursement by the grantee; and
(iii) The grantee’s financial management system meets the standards for fund control and accountability prescribed in Section .21 of OMB Circular A-110. (2 CFR §215.21)
b. The grantee’s designated official (Accounting Officer, Business Officer, Treasurer, etc.) must submit their cash requests for payment by using the FastLane Cash Request System. Grantees submit requests on a periodic basis (monthly, biweekly or other regular cycle) depending on their normal disbursement patterns. Such requests should be limited to the minimum amounts needed and be timed to meet the anticipated cash requirements for allowable charges to active NSF projects.
c. Grantees shall maintain advances of NSF funds in interest bearing accounts as specified in AAG Chapter III.D.3.
4. Special Payment Gran4tees
When grantees do not meet the conditions specified in AAG Chapter III.C.3, or when otherwise considered appropriate by NSF, they are not allowed to request funds electronically through the FastLane Cash Request Function or to request funds in advance, NSF will make payments to these grantees on a reimbursable basis only. These grantees are required to request funds by using a “Request for Advance or Reimbursement Form” (SF 270). For a copy of the form see AAG Exhibit III-1. The amount requested is reported on line 11i of the form. Unless instructed otherwise in the NSF award notice, the form should be submitted to the cognizant Grants and Agreements Officer by email, by fax to 703-292-9142, or through the mail to:
National Science Foundation
Division of Grants & Agreements
4201 Wilson Blvd
Arlington, VA 22230
5. Working Capital Advance
In those cases where the reimbursement method described in AAG Chapter III.C.4 is not feasible, arrangements may be made whereby NSF projects are financed on a working capital advance basis. On this basis, funds may be advanced to the grantee to cover estimated disbursement needs for a given initial period. Thereafter, the grantee would be reimbursed for the amount of its actual cash disbursements. The amount of the initial advance shall be geared to the reimbursement cycle so that after the initial period, the advance approximately equals the average amount of the grantee’s unreimbursed program disbursements. Under this method of payment, the NSF grant will specify if the grantee is required to use the SF 270. If use of the form is required, section 12 of the SF 270 will be used for the initial advance; thereafter, reimbursements will be requested on the SF 270, line 11i.
6. Grantee EFT Update
Grantee Electronic Funds Transfer (EFT) Update is a FastLane Financial Function used by grantees to provide NSF with their electronic banking information. This system enables NSF to transfer funds electronically to a grantee’s bank account by using the banking information provided by the grantee. All NSF grantees, with the exception of certain non-U.S. grantees noted in paragraph C.1.above, must provide banking information through Grantee EFT Update in order to request and/or receive payments
7. Use of Women-Owned and Minority-Owned Banks
Recipients of NSF grants are encouraged by the Federal government to use banks which are owned (at least 50 percent) by women or minority groups such as Asian, Black, Hispanic, Native Americans and Pacific Islanders. This action is consistent with the national goal of expanding the opportunities for women-owned and minority owned business enterprises.
D. Cash Refunds and Credits to NSF
1. Final Unobligated Balance
NSF has a reversionary interest in the unobligated balance of a grant upon expiration or completion of the grant. Based on final disbursements reported on the FFR, the final unobligated balance will be computed by NSF and reported in the “Unobligated Balance” column of the FFR. (See AAG Chapter III.E.2.) The entry reduces the grantee’s “Balance Authorized” as computed on the report page, section 10 (Transactions) of the FFR. (Detailed instructions for submission of the FFR are available on the FastLane website at https://www.fastlane.nsf.gov/jsp/homepage/faulogin.jsp.)
2. Erroneous Payments
Advances or reimbursements made in error must be refunded to the National Science Foundation if the erroneous payment creates excess cash on hand condition or a negative “Balance Authorized” as computed on the FFR. Excess funds should be promptly refunded electronically or by check. Contact the NSF Division of Financial Management at (703) 292-8280 for instruction for electronically refunding monies to NSF. Checks shall be mailed to NSF, Attn. Cashier, 4201 Wilson Boulevard, Arlington, VA 22230.
The only exception to the requirement for prompt refunding is when the funds involved will be disbursed within 30 calendar days. This exception for prompt refunding should not be construed as approval by NSF for a grantee to maintain excessive funds on hand.
3. Interest Earned on Advance Payments
Grantees shall maintain advances of NSF funds in interest bearing accounts, unless any of the following apply:
a. The grantee receives less than $120,000 in Federal grants per year;
b. The best reasonably available interest bearing account would not be expected to earn interest in excess of $250 per year on Federal cash balances; or
c. The depository would require an average or minimum balance so high that it would not be feasible within the expected Federal and non-Federal cash resources.
Interest earned on NSF advances deposited in interest bearing accounts shall be remitted annually to the Department of Health and Human Services (DHHS), Payment Management System, P.O. Box 6021, Rockville, MD 20852 (telephone number: (301) 443-9247). Grantees are authorized to retain up to $250 per year for administrative expenses.
The requirement to annually remit interest does not apply to grantees subject to the Cash Management Improvement Act (CMIA) and its implementing regulations (i.e., State agencies and instrumentalities). State universities and hospitals shall comply with the CMIA, as it pertains to interest. In accordance with Section .22 of OMB Circular A-110 (2 CFR §215.22) if a grantee subject to CMIA uses its own funds to pay pre-award costs without prior written approval from NSF, it waives its right to recover the interest under CMIA.
4. Program Income
If, in accordance with the grant, program income is designated for credit to grant costs, it will be recovered by NSF by crediting costs otherwise chargeable against the grant on the FFR. (See AAG Chapter VI.F.) In these cases, income in excess of the grant will be remitted to NSF electronically or by check payable to the National Science Foundation.
5. Other Cost Credits
Purchase discounts, rebates, allowances, credits resulting from overhead rate adjustments and other credits relating to any allowable cost received by or accruing to the grantee shall be credited against NSF grant costs if the grant has not been financially closed out. A grant is financially closed out when the final disbursements have been reported on the FFR. Credits of $300 or more shall be credited against NSF grant costs even if the grant has been closed out. See also AAG Chapter V.B.7.
E. Grant Financial Reporting Requirements
1. Quarterly Disbursement Reporting – Federal Financial Report (FFR)
Grantees are required to report the status of funds received from NSF on a quarterly basis through the submission of a Federal Financial Report (FFR). The reports are prepared and submitted electronically to NSF through the FastLane Federal Financial Report Function.
Within seven to ten business days after the end of a calendar quarter, NSF will create and make the FFR’s available to grantees through the FastLane Financial Functions at https://www.fastlane.nsf.gov/jsp/homepage/faulogin.jsp. E-mail notices are sent to each grantee announcing the reports availability and its due date. Grantees are required to update, certify and submit the FFR to NSF by the due date even if funds have not been drawn during the reporting period. Grantees certify the report’s truthfulness as stated in the Certification page of the FFR. The FFR elements are in compliance with the uniform Federal standards applicable to financial reporting by grantees.
Failure to submit the FFR to NSF in a timely manner can result in one or more of the following actions:
a. Suspension of all future payments;
b. Closeout of expired awards based on previously reported disbursements;
c. Suspension of unexpired awards; or
d. Suspension of review and processing of new proposals.
2. Final Disbursement Reporting
NSF does not require grantees to submit individual FFR’s for each award for purposes of final grant accountability. NSF procedures have been designed to extract the final financial data from the entries in the FFR. This reporting is accomplished as follows:
a. For any grant listed on the FFR that expired prior to the beginning of the quarter covered by the FFR, the grantee will enter the final disbursement amount in the Cumulative Cash Disbursements column on the FFR Attachment.
b. If there are valid unpaid obligations outstanding at the time final disbursements are due, the obligations must be charged against the NSF cash advance and reported in the Cumulative Cash Disbursements column on the FFR as if they had actually been paid. If subsequent disbursements differ by $300 or more from the amount previously reported, the grantee must report the amount as an “Adjustments to Financially Closed Awards” and specify the reason for the adjustment under the remarks section of the FFR Adjustments Worksheet.
c. If by law, regulation, and/or accounting system limitations, valid unpaid obligations cannot be charged against the NSF advance and reported as disbursed in accordance with b. above, closeout by NSF will be deferred provided that:
(i) grantee identifies grants with “unpaid obligations” in the Remarks section of the FFR;
(ii) grantee submits the FFR before the quarterly financial closeout procedure is run; and
(iii) The appropriation that funds the grant has not cancelled as noted under Title 31 USC Sec. 1552.
d. The final disbursement amount may not exceed the amount of the award.
e. When the final disbursements have been recorded by NSF, the award will be financially closed and no additional disbursements shall be shown by the grantee in subsequent reports. When all final reporting requirements have been met, the award will be deleted from the FFR. When this is done, the award will be shown in the next “Schedule of Awards Purged and Subsequent Adjustments during the Quarter,” of the FFR.