An Overview of NSF Compliance Agreement Activity Presentation

An Overview of NSF Compliance Agreement Activity Presentation to NSF Relevant Employees By JSU NSF Compliance Committee S

Background Information S National Science Foundation (NSF) conducted an audit of cumulative costs for active NSF awards shown on JSU’s Federal Financial Report as of September 30, 2011. S Audit Findings: 1. Claimed excess indirect costs 2. Unallowable equipment costs, fringe benefits, travel costs, and other direct costs claimed 3. Lack of Support and/or inadequate support for expenses charged to awards (lack of time and effort reports; lack of acceptance letters for participant support and stipends)

Audit Findings Resolution S In 2015, a former JSU employee pled guilty to “falsifying time and effort reports, and directing others to do so, during an audit in an effort to support the salary costs incurred on the university’s NSF grants” (NSF OIG Semi-Annual Report, September 2015, p. 23). S On January 25, 2017, JSU executed a settlement agreement with the United States Government via the National Science Foundation’s Office of Inspector General (NSF OIG) to implement a Compliance Program (CP) to ensure compliance with all laws, regulations, terms, and conditions applicable to National Science Foundation (NSF) awards.

Requirements Under Agreement S The Compliance Agreement is in place for 5 years (07/24/17 – 07/24/22), during which time we must: S Develop a code of conduct that holds JSU personnel to high ethical standards of professional conduct and integrity, and addresses conflicts of interest; S Status: Complete S Ensure accurate time and effort reporting under NSF awards to meet the standards of the cost principles and administrative requirements S Status: Complete

Requirements Under Agreement S Ensure accurate charging of costs under NSF awards; S Status: Complete S Ensure accurate monitoring, managing and reporting of cost sharing when applicable; S Status: Complete S Ensure management and retention of documents of relevant documents for 10 years; and S Status: Complete

Requirements Under Agreement S Ensure timely written disclosure, to NSF OIG as well as NSF management, of credible evidence of a violation of law involving an NSF award or relevant employees working on an NSF award S Status: Complete

Compliance Program Objectives S Establish and maintain effective internal controls S Describe the roles and responsibilities for managers, administrators and principal investigators S Promote orderly, economical, and efficient operations and achieve planned outcomes S Safeguard resources against fraud, waste, abuse and mismanagement

Compliance Committee S Compliance Committee as appointed by President William B. Bynum, Jr. (Proposed Membership) S Dr. Joseph A. Whittaker, Associate Provost & VP of Research and Economic Development (NSF Compliance Officer) S Dr. Daarel Burnette, Vice President of Business and Finance (CFO) S Mrs. Tracy Stapleton, Executive Director of the Division of Business & Finance S Mr. Illiad Kelly, Director, Unit of Grants and Contracts Management (Finance and Internal Controls; Training) S Dr. Almesha Campbell, Office of Research & Sponsored Programs S Mr. Keunta Mc. Phearson, NSF Grant Accountant, Unit of Grants and Contracts Management S Dr. Sophia Leggett, Institutional Review Board (IRB) S Mrs. Robin Spann-Pack, Human Resources S Mr. Edward O. Watson, University General Counsel S Dr. Wilbur Walters, Dean – College of Science, Engineering and Technology S Dr. Glake Hill, NSF Principal Investigator S Dr. Lynda Brown-Wright, Provost / Ex Officio

Training Requirements S Each relevant employee shall receive a minimum of two hours of initial training that shall include a discussion of the contents of JSU’s Compliance Program as well as the relevant award requirements, and shall receive additional compliance training of at least two hours on an annual basis. This training shall take place both in person and on-line. Relevant employees include: S Principal Investigators (PIs), co-PIs, other faculty, officers, staff, students, contractors, sub-recipients or other persons responsible for the design, conduct, administration or other activity funded or supported by NSF awards. S JSU shall include in subrecipient agreements a requirement that subrecipients provide comprehensive compliance training

Internal Reporting S JSU will utilize the existing confidential reporting mechanism of the Mississippi Institutions of Higher Learning (Ethics. Point) S NSF OIG Fraud Hotline posters will be placed prominently on JSU’s compliance website and in campus locations that have been identified as areas where relevant employees conduct research and manage other grant-related responsibilities S Mandatory annual independent audits must be conducted to ensure compliance for the duration of the agreement

Compliance Program Monitoring S Although the Compliance Agreement requires annual reviews, JSU will conduct self-reviews semi-annually for the first two years to ensure the fidelity of the implementation of the program and that internal controls employed are sufficient. After the initial two years of the program, JSU will conduct self-reviews annually.

Compliance Agreement S Questions