Site visits allow CAAR to assess awardees’ capability, performance, and compliance against the applicable elements that make up each award. This may include administrative regulations and public policy requirements, as well as special and general terms and conditions, including those contained in the NSF program announcement/solicitation, grant or cooperative agreement, and the award letter. Through site visits, NSF extends business assistance by offering award administration best practices and answering questions related to NSF expectations and Federal award administration requirements. CAAR performs approximately 30 site visits each year. Reviewers assess whether the awardee’s financial management system accurately and completely discloses and documents financial results of Federal awards and if awardee systems provide effective control and accountability of funds, property, and other assets.
In FY 2012, NSF began conducting virtual site visits. These reviews combine virtual communication tools with the proven Advanced Monitoring site visit methodology to cost effectively conduct an in-depth review of the awardee’s grant-related policies, procedures, and practices.
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.
In many cases, a desk review will be scheduled before a site visit in order to gather preliminary information from the awardee. The site visit process begins when NSF sends a letter notifying the awardee that they have been selected to participate in a site visit and options for the timing of the review. A month to six weeks prior to the site visit, the awardee receives a request for documentation from NSF. Reviewers typically look at three core review areas and a selection of three to four targeted review areas, as described in the “Topics Covered” section below. The on-site review includes interviews with the awardee’s functional area representatives and collection of additional documentation, as needed. The review team may follow up with the awardee after the on-site visit to gather additional information or clarify some aspects of a review area. The process culminates in the development and dissemination of the site review letter, which provides feedback to the awardee by identifying best business practices and areas of weakness and makes recommendations for improvement. 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.
Within the Division of Institution & Award Support (DIAS), CAAR leads the site visit process. CAAR collaborates with other NSF divisions, particularly with the Division of Grants and Agreements (DGA), the Division of Acquisition and Cooperative Support (DACS), and the various program divisions when selecting targeted review areas and planning site visits. Typically one person from CAAR and one person from DGA will attend the site visit.
Site visits typically require the participation of representatives from the sponsored programs office, business office, and finance office at awardee institutions. Individuals from these offices might include grants officers, chief financial officers, controllers, and/or accountants.
Site visits typically take five months from the start of the site visit planning through receipt of the awardee’s response to the site visit report. NSF notifies awardees four to six weeks prior to the scheduled site visit date. The site visit team uses this period to collect information about the awardee, consult with NSF program and grants officers, and analyze any results from prior monitoring activities, such as a desk review. Site visits typically last three to four days, after which the site visit team has 90 days to prepare a site visit report for internal distribution and a site visit letter with recommendations for the awardee. Awardees are expected to respond within 30 days with a corrective action plan. Virtual site visits will be completed in roughly the same amount of time, but three to four days of virtual meetings that may last several hours each day replace the on-site portion of the review.
Site visits can include core and targeted review components or a combination of the following:
- Core Review Modules
- 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.)
- Desk Review Follow-Up (if appropriate) – review any issues identified during previous monitoring activities and any action completed to resolve those concerns
- Targeted Review Modules (Note: three to four areas are typically selected for review)
- ARRA Review – verify that the awardee has developed processes to effectively segregate American Recovery and Reinvestment Act of 2009 (ARRA) related financial information in its accounting system and report that information as required by ARRA, Office of Management and Budget (OMB), and NSF. (Only being conducted for selected awardees managing ARRA-funded awards that have been extended beyond September 30, 2013)
- Consultants – verify that the claimed costs are reasonable, allocable, and allowable in accordance with the cost principles and the Grant Policy Manual and that appropriate agreements are in place
- Cost Sharing – assess the awardee’s system for documenting and accounting for claimed cost-sharing amounts
- Final Project Reports – verify that the institution has established procedures to ensure that final project reports are submitted in a timely manner
- Fringe Benefits – verify that the benefits claimed are reasonable, allocable, and allowable to the awards to which they are charged
- Indirect Costs – ascertain whether the awardee has a Negotiated Idirect Cost Rate Agreement (NICRA) or Facilities and Administrative (F&A) Rate Agreement established with NSF or another Federal agency; is accounting for indirect costs in accordance with the established rate methodology (see the NICRA or F&A Rate Agreement); and is claiming indirect costs in accordance with the terms and conditions contained in the award agreement
- Participant Support Costs – ascertain whether the awardee has appropriately, and separately, accounted for participant support costs and follows appropriate allocation procedures
- Procurement – review and assess practices and controls related to the procurement of supplies and other expendable property, equipment, and other services procured with Federal funds
- Program or Award-Related Income – ascertain whether the awardee properly accounts for, disposes of, and/or retains program or award-related income
- Property and Equipment – assess whether the claimed equipment purchased with Federal funds is administered in accordance with Federal rules and regulations
- Special Terms and Conditions – determine if the awardee is aware of and in compliance with the award special terms and conditions
- Subawards and Subrecipient Monitoring – verify that the awardee has established a system to monitor the subawards issued on Federally-sponsored projects and that appropriate agreements are in place
- Personnel Compensation Records – verify that the awardee institution maintains a system to document and support labor charges to NSF awards that is compliant with Federal regulations
- Travel – verify that travel costs are adequately documented, allocable to NSF-sponsored projects, and reasonable based on award terms and conditions and the applicable OMB circular or Federal Acquisition Regulation (FAR)
Resources and References