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.” 1 As it relates to State universities and their internal controls regarding accurate payroll records. 1 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. 2 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. 3