Inter-institutional Committee on Finance and Accounting (ICOFA) -State Agency Meetings

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Inter-institutional Committee on Finance and Accounting (ICOFA) -State Agency Meetings
Executive Summary
State university representatives requested to meet with the Department of Financial Services (DFS)
regarding issues with submitting invoices for payment to State agencies. The DFS met with
representatives from the Universities on January 31, 2013. As a follow-up to that meeting, a meeting
was held on May 9, 2013 that included both State university and State agency representatives.
Subsequent meetings were held February 6, 2014 and April 1, 2014. The following entities were
represented: University of Florida, Florida State University, ICOFA, University of South Florida,
Department of Agriculture and Consumer Services, Department of Children and Families, Department of
Environmental Protection, Department of Juvenile Justice, Department of Transportation, Fish and
Wildlife Conservation Commission, and Department of Financial Services.
The following topics were discussed during the meetings:

Salary
Timesheets are not kept by State university salary employees. Effort reporting is utilized by
professors/project employees. The Federal Office of Management and Budget, OMB
Circular A-21, relocated to 2 CFR, Part 220, recognizes in an academic setting, teaching,
research, service and administration are intermingled. A precise assessment of costs is not
expected and reliance is placed on estimates. Effort reporting that produces an equitable
distribution of charges for an employee’s activities and certification by the employee
acknowledging the percent of time spent on specific projects is acceptable to support the
hours worked on a state project. The DFS recognizes this effort report certification and
detailed payroll ledger as acceptable documentation to support salary costs on a cost
reimbursement invoice.1
The following sample language for effort reporting and true-up was provided by ICOFA for
State agencies to include in contract language with State universities:
“The University affirms that it maintains a system in compliance with OMB Circular A-81, section
200.430, section (i) Standards for Documentation of Personnel Expenses. The system ensures that “(1)
Charges to Federal awards for salaries and wages must be based on records that accurately reflect
the work performed. ” and “(2)For records which meet the standards required in paragraph (i)(1) of
this section, the non-Federal entity will not be required to provide additional support or
documentation for the work performed, other than that referenced in paragraph (i)(3) of this
section.” According to section 200.336 and Subpart F of Circular A-81, the system is audited and the
records of and documentation affirming its compliance with these standards will be made available
during regular business hours with at minimum 2 business day request.”
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As it relates to State universities and their internal controls regarding accurate payroll records.
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
Travel
Alternate travel forms may be submitted to the Bureau of Auditing for review and approval.
The alternate form must contain all necessary information as required on the official State
of Florida travel form, Voucher for Reimbursement of Travel Expenses, Form DFS-AA-15, as
prescribed by Chapter 69I-42, Florida Administrative Code. Currently, the University of
Florida and the University of Central Florida have approved alternate travel reimbursement
forms.
If a State university vehicle is used 100% of the time for services identified in an agreement
with a State agency, the gas and cost of maintenance for the vehicle may be allowable as
stated in the terms and conditions of the agreement. If the use of the vehicle is less than
100%, mileage reimbursed in accordance with s. 112.061, Florida Statutes, would be
appropriate.

Ledgers
DFS recommends State agencies accept detailed ledgers from State universities to support
operational costs invoiced and periodically conduct post-audits of sampled expenditure
documentation. The State agencies may use their discretion in implementation.
Chief Financial Officer memorandum #4 (1996-97), provides clarification on alternative
documentation to be submitted to substantiate costs by State agencies, including State
universities. The alternative documentation may be in the form of reports containing
sufficient detail. The procuring State agency may require more detailed documentation as it
deems appropriate to satisfy contract terms have been met.
All documentation requirements need to be included in the terms and conditions of the
agreement. As well as, provisions for sampling the documentation and retention of all
records. In the case that a full audit is required, the DFS recommends each State agency
work with their legal counsel to incorporate audit language.

Invoices
State universities may submit electronic invoices to State agencies as provided for in the
terms and conditions of the applicable agreement. Submission timeframes for invoices and
the required supporting documents to be submitted with the invoice should be identified in
the agreement.
Each State agency has different supporting documentation requirements depending on the
program, state and federal guidelines, and programmatic and fiscal requirements. The
Reference Guide for State Expenditures sets forth documentation requirements but is not to
be considered an exhaustive list. Each agreement should identify the specific
documentation requirements for the services provided.
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Partial or prorated invoices are allowable as outlined in the applicable agreement. For
example, payments must be made based on the deliverables that can be validated and
supported by adequate documentation in accordance with the agreement. An invoice may
be prorated or reduced according to the financial consequences established in the
agreement.
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