The document provides a comprehensive overview of key updates and ongoing issues discussed at the Council on Governmental Relations (COGR) June 2019 meeting, focusing on costing, audit practices, and compliance for research-intensive universities. Major topics included the handling of procurement credits and rebates, particularly in relation to federal awards, with case studies from the University of Wisconsin-Madison and Harvard University highlighting regulatory expectations, compliance challenges, and settlement outcomes. The discussion also addressed updates on Facilities & Administrative (F&A) cost negotiations, exemplified by Vanderbilt University’s recent negotiations process and outcomes, reflecting the complexities in rate-setting and documentation.
Furthermore, audit updates covered federal oversight findings and recommendations, such as the HHS OIG's audit of Northwestern University's subrecipient monitoring, emphasizing the need for robust risk assessment and timely single audit reviews. The document also reviewed common audit findings from both HHS and NSF, including compliance issues tied to cost principles, documentation failures, inappropriate charges, and misuse of F&A and fringe rates. The meeting addressed evolving guidance around single audit compliance, procurement requirements under Uniform Guidance, and best practices for price and cost analysis, including adherence to updated federal purchase thresholds. Overall, the content reflects the heightened scrutiny and regulatory complexity facing research universities in managing federal funds, underscoring the importance of transparent processes, meticulous documentation, and continual adaptation to new compliance standards.
