Single audit (for US federal grants)

There are some points in the guideline as summarised below which have clear implications on the way US Federal funded awards are managed:

Effort Reporting

​One of the key areas of change resulted from the Uniform Guidance is the requirements related to tracking and reporting of staff costs. The requirements are outlined in 2 CFR 200.430. Briefly, the minimum that can be accepted as evidence is:

• An assessment of time completed by the researcher, covering all of their time on a monthly basis (either hourly, i.e., a timesheet), showing 100% of their time in total.
• This time assessment must be authorised by their direct supervisor, or someone who knows where they have spent all their time.

The requirements also apply to staff working 100% on a federal funded grant.

Timesheet templates and declaration form can be accessed via ROO's SharePoint.

Overhead recovery

The university does not have a negotiated rate with any US federal agency, hence for NIH grants we receive a rate of %8 for overhead. For other federal agencies, on most of cases, a rate of %10 is acceptable.

However, depending on the sponsored we might be able to negotiate FEC rate at the time of application.

Please note in such cases, the claimed overhead need to be propionate to the staff effort and hence backed up by evidence of staff working on the project (directly and indirectly), to support the claimed overheads.

For indirect staff the evidence can be an annual declaration, signed by line manager, confirming the % of time spent on the Federal grant.

Value Added TAX (VAT)

Previously, VAT was an unallowable cost (NIH grant policy statement dated 10/1/2013; part 16.6). VAT is now an eligable cost on Federally funded grants (2 CFR 200.470):  

“Value Added Tax (VAT) Foreign taxes charged for the purchase of goods or services that a non-Federal entity is legally required to pay in country is an allowable expense under Federal awards.”

Sub-recipient Monitoring

Applicable parts of the Uniform Guidance should flow down from the Prime recipient to sub-recipients. In addition, the prime recipient must monitor compliance. Sub-recipient monitoring is performed by the Department at different stages of the sub agreement from proposal to award closeout. The requirements for Sub-recipient Monitoring and Management are described in section §200.331.

In summary in addition to flowing down the grant’s T&Cs:

• A comprehensive due diligence check is required in advance of starting the collaboration; plesae contact your relevant Research Support Advisor to arrange this.
• Scientific progress needs to be monitored by PI periodically  and evidence documented.
• Sub-recipients need to be monitored on annual basis to ensure compliance with requirements of Uniform Guidance. Sub-recipient monitoring form can be downloaded from here.

Audit Threshold

The triggering threshold of Federal expenditure by recipient during the fiscal period for a Single Audit requirement has been raised from $750,000 to $1,000,000 (2 CFR 200.501) from 01 Oct 2024.  

• $750,000 or more for Fiscal Years starting before October 1, 2024
• $1,000,000 or more for Fiscal Years starting on or after October 1, 2024 

As a foreign institution, subpart F of 2 CFR 200 is not applicable to the University of Cambridge (§200.101), and as such a review of all US federal funded grants is not a mandatory requirement.  

The University conducts a Single audit in accordance with the guidelines set out in 2 CFR Part 200 Subpart F Uniform Guidance of the DHHS(NIH) funded grants and any grants funded by a federal agency having an audit requirement in their grant agreement.

The audit is conducted on a sample basis, with a percentage of federally funded grants selected for review each year. The proportion of sampled grants is determined based on the risk assessment from the prior year’s audit.