Delinquent grant/contract receivables become a risk to the PI’s department. Transfers to the department local fund are required for un-reimbursable/unallowable expenses. There are various reasons a receivable can become delinquent (progress reports not submitted on time, work not satisfactorily completed, etc.). The following Grant & Contract Accounting procedures will keep the department chairs/managers and Deans/Directors apprised of risk from delinquent receivables.
As a result of Monthly Accounts Receivable (A/R) Aging Reports, the following procedures will be applied as/when necessary:
- At 60 days – if waiting on a progress report, a Grant & Contract Accounting (GCA) Officer will email the PI and Department Chair, and cc the Director of GCA and Associate VP for SPA (include Executive Director, Corporate & Foundation Research Relations if sponsor is a private company and the award is not federal flow-through)
- At 90 days – GCA Officer will send a notification to the sponsor and cc the PI, Department Chair, Director of GCA and Associate VP for SPA (include Executive Director, Corporate & Foundation Research Relations, as necessary)
- At 120 days – GCA Director will contact the sponsor and work with the PI and Department Chair to considering putting a hold on the project – will cc: GCA Officer, Associate VP for SPA, Controller, and College Dean (include Exec Dir, Corporate & Foundation Research Relations, as necessary)
- At 150 days – project will be placed on hold until payments are current. For sponsors who reach the point of 150 days delinquent on any invoice, careful consideration should be given (1) to terms and conditions of future agreements (ex. making future awards Advance Pay, where sponsors pay in full at the time of the award execution and before work begins) or (2) whether or not it is a prudent business practice to continue to enter into agreements with that sponsor.
There are many factors to consider before taking any action, including:
- changes to the contract that made the receivable look older than it is (PeopleSoft Limitations)
- system glitches
- is the sponsor waiting on a progress report from NDSU
- if work wasn’t completed satisfactorily
- pending award changes that impact payment
In accordance with 2 CFR PART 200, Appendix XI Compliance Supplement “Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred.” A verification of suspension and debarment can be accomplished by:
- Checking the Excluded Parties List maintained by the General Services Administration (GSA) available at https://www.sam.gov/portal/public/SAM/,
- Collecting a certification from the entity, or
- Adding a clause or condition to the covered transaction with the entity
NDSU’s Procedures for maintaining compliance with this requirement are:
- The North Dakota University System is now fully integrated with Visual Compliance as of 03/16/2018. With this integration, our entire Supplier (Vendor) database will be vetted against the EPLS and OFAC-SDN lists, along with many other various restricted, debarred and/or suspended lists. This vetting will occur on a daily basis by Visual Compliance and will be done against our entire Supplier database.
- Subaward Agreements contain a certification from the entity. “Acceptance of this Subaward constitutes certification that the Recipient is not proposed for disbarment, declared ineligible or voluntarily excluded from covered transactions by any Federal department or agency.”
- Contracted Service Agreements contain a certification from the entity. “Acceptance of this Contract constitutes certification that the Recipient is not proposed for disbarment, declared ineligible or voluntarily excluded from covered transactions by any Federal department or agency.”
- Purchase requisitions over $10,000 are checked against the PeopleSoft Supplier database during the Purchase Order creation process. If the requisition is processed using the Procurement card the transaction will be checked against https://www.sam.gov/portal/public/SAM/ (this includes purchases from state contracts). For these a screen shot of the inquiry in SAM.gov will be printed.
- Procurement card transactions over $10,000 are being checked against https://www.sam.gov/portal/public/SAM/ by the Director of Purchasing when the "Procurement card for over $ 10,000" form is received.
The Federal Property Management Procedure Guide provides basic procedures for the management of federal property under North Dakota State University’s control. The manual describes the system used for the acquisition, records, maintenance, physical inventory, control and disposition of facilities and property of North Dakota State University (NDSU), the United States Government and various other grantee agencies. The manual complies with Federal Acquisition Regulation (FAR), OMB Circular A-110, OMB Circular A-21, DoD Property Administration Guidelines, State of North Dakota Century Code, and North Dakota University System State Board of Higher Education (SBHE) policies.
Those individuals utilizing a grant or contract fund for the purchase of airline tickets should take note of the Fly America Act. The Fly America Act (49 U.S.C. Section 40118) requires federal government financed air transportation to be "provided by" air carriers holding certificates of public convenience and necessity as U.S. flag air carriers. This requirement is applicable to all federal and federal flow through Grants, Cooperative Agreements and Contracts, for either domestic or international travel.
If you are planning on any travels or are making arrangements for someone to travel on a Grant Cooperative Agreement or Contract, the Fly America Act may be applicable to the arrangements. It is important to note this will have a direct effect on international travel, but may also create problems for domestic travel.
The Comptroller General issued a decision regarding the Code Sharing (Airline Alliances) of flights by U.S. and foreign flag carriers utilizing the equipment of the foreign flag carrier. If a U.S. flag air carrier has an arrangement to provide passenger service in international air transportation on the aircraft of a foreign air carrier under a "code-share" arrangement with a foreign air carrier this could meet the requirement of the Fly America Act. The key to meeting the requirements appears to be whether the ticket is purchased through the U.S. air carrier. If the ticket is issued through the U.S. air carrier, it would be eligible for reimbursement. However, if the ticket were issued by a foreign air carrier, even under a code sharing arrangement, the ticket may not be eligible for reimbursement on a Federal Grant, Cooperative Agreement or Contract. Caution in making arrangements for foreign travel is warranted.