National Science Foundation (NSF)
NSF Accounting, Proposal Pricing & CAP (CAAR) Reviews
The National Science Foundation normally awards grants to various types of organizations. The cost principles applicable to the awardee vary depending upon the type of organization. For instance, commercial firms are normally held to the Federal Acquisition Regulations (FAR) for cost principles. NSF awardees are normally required to have a financial management system meeting the requirements of Section .21 of OMB Circular A-110 (2 CFR §215.21).
The Federal Financial Report (required usually for payment from the NSF) requires that the awardee's Authorized Certifying Official (ACO) certify that the financial report is true, complete, accurate and expenditures are for the purposes set forth in the award documents. This may imply that the organization have a government type job cost accounting system in order to verify this statement. The grant document will contain other requirements applicable to the awardee and it is critical to review all of the requirements in the grant document to verify what is required.
ReliAscent is experienced in helping NSF awardees, especially in the area of the SBIR program, and can help determine these requirements and design a system that meets the requirements; including the calculation of indirect billing rates for a Phase II award, as well as providing CAP Review (formerly known as the CAAR Review), support services. In fact, we have been selected by DawnBreaker to provide NSF grantees with webinars and consulting services on how to prepare and pass an NSF CAP (CAAR) Review.
ReliAscent can also perform the accounting on a virtual, outsourced basis, so that the client may concentrate on the scientific work, business development, and the areas that will cause the firm to grow. ReliAscent can thus be a strategic partner; offering not only outsourced compliant accounting, but functioning as a CFO and offering the firm advice contributing to the growth of the company.
"Why do I need a Compliant Job Cost System for an NSF Award?"
At the end of Ph II, the government wants you to declare, under penalty of perjury, that the money spent was in accordance with the proposed budget. The only way to prove this is to have a job cost accounting system, and a properly maintained labor distribution & timekeeping system. You also need to ensure this system was properly maintained throughout the duration of the contract/grant. ReliAscent can provide you with that system.
NSF SBIR Ph. II Pricing Proposal Support
We highly recommend you enlist the services of our Outsourced CFO and NSF accounting experts when putting together your Pricing Proposal (also known as the Cost Section of your proposal). This (typically) only requires a few hours of review, but it can be extremely important and helpful.
NSF CAP (formerly "CAAR") Review Support
After our experts have helped you with the pricing proposal, your company needs to begin collecting all of the required information for the CAP (formerly known as CAAR) review (see the NSF's CAAR Review Checklist).
What is a CAP Review? CAP stands for "Cost Analysis and Pre-Award," and it is a branch of the NSF that does pre-award and post-award reviews of NSF grants. CAP requires that that all SBIR/STTR grantees must complete a pre-award review for all Ph II proposals.
What types of reviews does the CAP perform?
- Financial Capability Review – Does your company have adequate financial resources to
perform the award?
- Accounting System Review – Does your company meet the basic accounting requirements for a Federal award?
- Budget Review – Are the budgeted amounts fair and reasonable, based on certified cost and pricing data, and justified properly?
As soon as you get the indication from your Contracting Officer that your proposal will be selected (this often happens before the official announcement of award, at which time, you only have 10 days to gather all of the required information and documents), it is critical to act quickly, and have ReliAscent review all of the information in your CAP Review data package, to ensure you will pass the review. This usually takes a few hours, but can take longer if there are a lot of issues and missing documents.
Outsourced Monthly NSF Accounting
While ReliAscent provides monthly outsourced accounting for a large number of NSF grantees, those winning an NSF SBIR Ph. II award (or those with multiple awards that are overwhelmed by accounting compliance), are typically the small businesses that require outsourced accounting services.
Should you be awarded a Ph II, our experts can operate as your outsourced accounting department. However, unless you have multiple ph II awards, or awards with other agencies, we may not need to get involved. However, we can provide support to ensure you are keeping your system compliant, in the form of:
- Quarterly Closes – ReliAscent performs the close (this option is slightly cheaper than having us handle your monthly accounting, but requires more work from your accounting or management staff)
- Red Light/Green Light Compliance Reviews – less comprehensive review of your system, but more affordable than quarterly closes, and can be done at intervals specified by the small business.
NSF Audit Support
The NSF reserves the right to audit the awardee but many of the actual audit requirements are contained in the award document. Again, it is imperative to read and understand what this document requires from the awardee. A good example is that non-profit organizations that receive an NSF award are required to complete an audit per the requirements of OMB Circular A-133. Typically this is at the awardee's expense.
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