Business Systems Review Guide

BUSINESS SYSTEMS REVIEW (BSR) GUIDE
Prepared by the Large Facilities Office (LFO)
Office of Budget, Finance, and Award Management Office (BFA)

NSF FY21-XX
October 2020

BSR Guide, NSF FY21-XX

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SIGNIFICANT CHANGES – BUSINESS SYSTEMS REVIEW GUIDE – NSF FY21-XX

Significant Changes – Business Systems Review Guide – NSF FY21-XX
Revisions to Terminology have been made to align with the Uniform Guidance and the NSF Major
Facilities Guide. Position descriptions were revised to better describe the roles of the participants in the
BSR process which, together with the BSR Lead, are referred throughout the Guide as the BSR
Participants. In addition, the Guide references a BSR Core Team, composed primarily of contractor staff,
who manage and execute the entire BSR process with the exception of inherently governmental
decisions.
Minor Editorial Changes have been made throughout the document to either clarify or enhance the
intended meaning of a sentence or section. Part I has been streamlined to eliminate redundancies and
repetitiveness in sections (e.g., combining supporting documentation subsections and detailed sections).
Part I – Business Systems Review Process
•

Section 1. Introduction reflects the current requirements for projects that are subject to a BSR
and introduces a reduction in total number of core functional area modules.

•

Section 1.3 Frequency of BSR explains that the frequency of a BSR is now informed by the Major
Facility Portfolio Annual Risk Assessment.

• Table 1. BSR Stakeholders’ Roles and Responsibilities specifies the role of the BSR Lead is
typically the assigned Large Facilities Office Liaison. The responsibilities of the LFO Liaison,
Integrated Project Team (IPT) core members, Program Officer, and Grants and Agreements
Officer are further expanded upon.
• Figure 1. Stakeholders shows the new titles and reflects the reduced number of core functional
area modules.
• Figure 2. Overview of the BSR Process timeline has been updated to extend the due dates
associated with the draft and final reports and provide additional time.
•

Sections 3.0 and 4.0 were renumbered and text was aligned with the revised Figure 2.

•

Section 3.2 Scoping emphasizes the involvement of the core IPT members in the scoping
activities.

•

Section 3.6 Report Generation and Follow-up and Monitoring captures the report writing
process and the observations captured in the written materials.

•

Section 3.6.1 Draft BSR Report Preparation expands on the change in categories of observations
and the due date for generating the draft report within 33 business days of the last day of the
site visit.

•

Section 3.6.2 Final BSR Report Preparation specifies the new format and tracking of an
extended due date. The final BSR Report will continue to serve as the historical summary and
final snapshot of the overall BSR activity.

•

Section 3.6.4 Follow-up and Monitoring specifies the key role of the BSR Lead who now serves
as the primary point of contact with the Recipient for follow-up and monitoring. Follow-up and
monitoring on high-risk areas will be initiated within 15 business days following the last day of
the site visit.

•

Section 3.6.5 Administrative Closeout has been updated to clarify that completion of this
denotes the end of the BSR, and to recognize the responsibilities of the various internal
stakeholders to update records with BSR status.

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SIGNIFICANT CHANGES – BUSINESS SYSTEMS REVIEW GUIDE – NSF FY21-XX

•

Section 4.0 Program Management and Oversight has been updated to delineate post-BSR
program management and oversight activities that may be needed if findings cannot be resolved
within the one-year period of the implementation plan.

Part II – Core Functional Area Review Modules
•

All Modules fully align with the Uniform Guidance.

•

Budget and Planning was given a new module title, Budget Planning and Execution, to
emphasize the major stages of the function. It was strengthened to better align with
requirements in the Major Facilities Guide.

• Financial Reporting was eliminated as a stand-alone module and content incorporated into the
Financial Management module to streamline the review.
•

Property and Equipment was given a new module title, Property Management, to better align
with Federal Property Management Systems (41 CFR Part 101-39 – Interagency Fleet
Management Systems).

Appendices
•

Appendix A was reorganized with matrices that include the list of questions, which have been
enhanced and have corresponding references for each principle, to facilitate interpretation and
traceability by reviewers. Questions and references are separated into sections according to
CFA.

•

Appendix B was reconciled with updated information in the BSR Guide.

•

Appendix C contains the new glossary of terms and definitions.

The BSR Guide will be updated periodically based on process improvements and changes to Federal
regulation requirements. In the intervening period, the changes that are made will be documented in
NSF’s internal Standard Operating Procedures. A copy of the most current BSR Guide will be shared by
NSF with Recipient stakeholders prior to commencing each BSR.

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PURPOSE OF THE BUSINESS SYSTEMS REVIEW AND GUIDE

PURPOSE OF THE BUSINESS SYSTEMS REVIEW AND GUIDE
Business Systems Reviews (BSR) of National Science Foundation’s (NSF) Major Facility projects (Facilities)
are an integral part of NSF’s advanced monitoring program. The Large Facilities Office (LFO) within the
NSF’s Office of Budget, Finance, and Award Management (BFA), has the lead role in executing the BSR
process. These reviews are designed to provide reasonable assurance that the business systems (people,
processes, and technologies) of NSF Recipients are effective in meeting administrative responsibilities
and satisfying Federal regulatory requirements, including those listed in NSF’s Proposal & Award Policies
& Procedures Guide (PAPPG). These reviews are not considered audits but are intended to be assistive
in nature; aiding the Recipient in following good practices where appropriate and bringing them into
compliance, if needed. LFO assembles a team of BSR Participants, including expert Content Specialists,
to assess the Recipient’s policies, procedures, and practices to determine whether, taken collectively,
these administrative business systems used in managing the Facility meet NSF award expectations and
comply with Federal regulations. The BSR Guide is designed for use by both our customer community
and NSF staff for guidance in leading these reviews.
The BSR Guide defines the overall framework and structure and summarizes the details outlined in the
internal operating guidelines and procedures used by BSR Participants to execute the review process.
Management principles and practices are specified for seven core functional areas (CFA) and are used by
BSR Participants in performing these evaluations. Roles and responsibilities of the NSF stakeholders
involved in the process are outlined in the BSR Guide as well as the expectations of the Recipient.
The BSR Guide is divided into three parts:
1. Part I – Business Systems Review Process. This part outlines the planning, execution, and
follow-up activities of a BSR, and defines the roles and responsibilities of the individuals involved
in the process.
2. Part II – Core Functional Area Review Modules. This part, divided into seven CFA modules,
includes guidance that is used by the Content Specialists to evaluate the administrative business
systems supporting the Major Facility. The framework for each module includes specific
principles and practices as well as a list of suggested questions to guide BSR Participants in
conducting their review. However, these modules are designed to be flexible to allow BSR
Participants an opportunity to explore additional review areas that they deem necessary to
complete their evaluation.
3. Appendices. The appendices include a matrix of references and questions, a list of acronyms,
and glossary of terms used throughout the BSR Guide.
The BSR Guide is used in conjunction with relevant Uniform Guidance (2 CFR 200 – Uniform
Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards), Federal
Property Management Systems (41 CFR Part 101-39 – Interagency Fleet Management Systems), and
documents such as the Major Facilities Guide (MFG). The referenced Uniform Guidance sections are
accessible at https://ecfr.io/Title-02/cfr200_main. The referenced Federal Property Management
Systems sections are accessible at https://ecfr.io/Title-41/cfr101-39_main. NSF-related material, such as
the PAPPG and the financial and administrative award terms and conditions of the award, are located on
NSF’s external website at http://nsf.gov/bfa/dias/policy/index.jsp. The BSR Guide is based broadly on
the principles and practices framework contained in the document, Managing Externally Funded
Research Programs: A Guide to Effective Management Practices, developed by the Council on
Government Relations (COGR).

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TABLE OF CONTENTS

TABLE OF CONTENTS
PART I – BUSINESS SYSTEMS REVIEW PROCESS
1. INTRODUCTION..........................................................................................................................
1.1 BSR BENEFITS.......................................................................................................................
1.2 BSR FOCUS: ADMINISTRATIVE BUSINESS SYSTEMS SUPPORTING THE MAJOR
FACILITY......................................................................................................................................
1.3 FREQUENCY OF BSR..............................................................................................................
1.4 DURATION OF THE BSR.........................................................................................................
2. ROLES AND RESPONSIBILITIES....................................................................................................
2.1 NSF STAKEHOLDERS.............................................................................................................
2.2 RECIPIENT STAKEHOLDERS...................................................................................................
3. BSR PROCESS PHASES.................................................................................................................
3.1 SCHEDULING AND PLANNING..............................................................................................
3.2 SCOPING...............................................................................................................................
3.3 DESK REVIEW........................................................................................................................
3.4 TELECONFERENCE................................................................................................................
3.5 SITE VISIT..............................................................................................................................
3.6 REPORT GENERATION AND FOLLOW-UP AND MONITORING..............................................
4. PROGRAM MANAGEMENT AND OVERSIGHT..............................................................................
PART II – CORE FUNCTIONAL AREA REVIEW MODULES...................................................................
1. GENERAL MANAGEMENT REVIEW MODULE...............................................................................
1.1 SCOPE OF REVIEW................................................................................................................
1.2 SUPPORTING DOCUMENTATION..........................................................................................
2. AWARD MANAGEMENT REVIEW MODULE.................................................................................
2.1 SCOPE OF REVIEW................................................................................................................
2.2 SUPPORTING DOCUMENTATION..........................................................................................
3. BUDGET PLANNING AND EXECUTION REVIEW MODULE.............................................................
3.1 SCOPE OF REVIEW................................................................................................................
3.2 SUPPORTING DOCUMENTATION..........................................................................................
4. FINANCIAL MANAGEMENT REVIEW MODULE.............................................................................
4.1 SCOPE OF REVIEW................................................................................................................
4.2 SUPPORTING DOCUMENTATION..........................................................................................
5. HUMAN RESOURCES MANAGEMENT REVIEW MODULE..............................................................
5.1 SCOPE OF REVIEW................................................................................................................
5.2 SUPPORTING DOCUMENTATION..........................................................................................
6. PROCUREMENT REVIEW MODULE..............................................................................................
6.1 SCOPE OF REVIEW................................................................................................................
6.2 SUPPORTING DOCUMENTATION..........................................................................................
7. PROPERTY MANAGEMENT REVIEW MODULE.............................................................................
7.1 SCOPE OF REVIEW................................................................................................................

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TABLE OF CONTENTS

7.2 SUPPORTING DOCUMENTATION..........................................................................................
APPENDIX A: LIST OF REFERENCES AND QUESTIONS.......................................................................
A-1. GENERAL MANAGEMENT PRINCIPLES AND PRACTICES......................................................
A-2. AWARD MANAGEMENT PRINCIPLES AND PRACTICES........................................................
A-3. BUDGET PLANNING AND EXECUTION PRINCIPLES AND PRACTICES...................................
A-4. FINANCIAL MANAGEMENT PRINCIPLES AND PRACTICES...................................................
A-5. HUMAN RESOURCES MANAGEMENT PRINCIPLES AND PRACTICES...................................
A-6. PROCUREMENT PRINCIPLES AND PRACTICES.....................................................................
A-7. PROPERTY MANAGEMENT PRINCIPLES AND PRACTICES....................................................
APPENDIX B: LIST OF ACRONYMS...................................................................................................
APPENDIX C: GLOSSARY ................................................................................................................

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LIST OF FIGURES
Figure 1. Stakeholders...........................................................................................................................
Figure 2. Overview of the BSR Process..................................................................................................

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LIST OF TABLES
Table 1. BSR Stakeholders’ Roles and Responsibilities.......................................................................... 4
Table 2. Citations/References and Abbreviations used in Appendix A Matrices................................... 45

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PART I – BUSINESS SYSTEMS REVIEW PROCESS

PART I – BUSINESS SYSTEMS REVIEW PROCESS

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PART I – BUSINESS SYSTEMS REVIEW PROCESS

1. INTRODUCTION

1. INTRODUCTION
The projects subject to a BSR are major multi-user research facilities (Major Facilities) as defined in
Section 1.4 of the Major Facilities Guide.
The inherent risks associated with funding Major Facility awards come from the operational complexity,
the regulatory environment, and long-term funding commitment. As a result, greater controls and more
complex business systems are necessary for the Recipient. Due to the complex nature of these awards,
NSF recognized that there was a need to provide additional business oversight to monitor the
Recipient’s stewardship of the appropriated funds and give assistance with compliance. The BSR process
was developed to meet these needs.
NSF has identified administrative business systems across seven core functional areas (CFAs) that
support a Major Facility:
•
•
•
•
•
•
•

General Management (GM)
Award Management (AM)
Budget Planning and Execution (BPE)
Financial Management (FM)
Human Resources Management (HRM)
Procurement (PR)
Property Management (PM)

However, each Major Facility is distinct, presenting a variety of challenges and concerns. The BSR
process is flexible and takes these differences into consideration. Each BSR is tailored to address the
unique aspects of the business arrangements used to support the Facility, although not all Facilities
receive the same level of scrutiny. The scope and level of review for each core functional area are based
on consideration of the risks identified. NSF works with experts to refine the review strategy that will be
used to examine the complexities of the administrative business systems employed.

1.1 BSR Benefits
The BSR helps the Recipient implement and maintain compliant business systems supporting the Major
Facility. Specifically, a BSR: verifies that administrative, including financial, policies and procedures, are
written; evaluates the extent to which these policies and procedures conform to OMB requirements,
NSF expectations, and other applicable Federal regulations; and validates they are being used to
administratively manage the Major Facility in each of the core functional areas. Concerns that are
identified during the review are shared immediately with the Recipient so that actions can be initiated
quickly to address the issues and implement recommendations to improve the processes.
BSRs are also intended to provide an opportunity for cross-fertilization of ideas through the
identification of best practices and serve to refocus Recipients on the importance of administrative
quality.
The BSR perspective differs substantially from an NSF programmatic review or financial audit. The focus
of the review is on the business infrastructure that supports the daily administrative management of the
Major Facility rather than on the scientific activity. From a financial perspective, BSRs are not intended
to certify or provide any type of assurance concerning the Recipient’s business systems to third parties
and do not follow the Government Accountability Office (GAO) Yellow Book standards. BSRs are also not
part of the NSF Audit Resolution process, which is handled by the Resolution and Advanced Monitoring
(RAM) Branch in the Division of Institution and Award Support (DIAS). Rather, they are a due diligence
effort designed to give NSF stakeholders reasonable assurance that the business systems in place are

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PART I – BUSINESS SYSTEMS REVIEW PROCESS

1. INTRODUCTION

capable of administratively supporting Major Facilities and have met all NSF award and OMB compliance
requirements.
The BSR also serves as a forum for NSF and the Recipient to discuss administrative and compliance
issues and exchange information and ideas. Exceptionally good Major Facility business practices are
noted and may be shared with other NSF Facility managers to help them improve their respective
systems. This collaboration is intended to strengthen the relationship between NSF and the Facility/
Recipient and support NSF’s monitoring responsibilities.

1.2 BSR Focus: Administrative Business Systems Supporting the Major Facility
NSF makes awards to a variety of institutions—universities, consortia of institutions, and nonprofit
organizations—to design, construct or acquire, operate, and manage Major Facilities. These NSF
Recipients assume legal and financial responsibility for the stewardship of the Federal funds which are
provided to support the Facility infrastructure and operating activities.
The BSR focus is on the specific administrative business systems that support the Major Facility. For the
most part, these are the existing business infrastructures that are already in place at an institution.
However, there are situations when systems are designed to support a unique business operation or to
address the needs of multiple institutions that partner in the management of the Major Facility. In these
cases, the BSR focuses primarily on the integration of the specific system into the management of the
Recipient’s overall business structure.

1.3 Frequency of BSR
The need for a BSR is based on NSF’s internal annual Major Facility Portfolio Risk Assessment, including
the risks associated with readiness for construction. As a result, the BSR can be considered as a means of
strengthening institutional capacity in advance of a construction award. Risk factors reviewed during the
annual Major Facility Portfolio Risk Assessment typically include:
• The timing and associated findings of other related reviews or audits of administrative business
systems
• Management structure providing administrative business systems support
• Significant changes in funding levels or the Recipient’s award administration

1.4 Duration of the BSR1
Generally, each BSR requires three to four months to complete and spans the period from Recipient
notification through issuance of the final BSR Report, although duration may vary depending on the
complexity of the review. Additionally, a period of approximately one year, commencing with issuance
of the final BSR Report, is allotted for follow-up and monitoring prior to Administrative Closeout. Each
phase in the review process is designed to build upon the preceding phase so that, at the end of the
review, the Recipient clearly understands and adheres to governing Federal and NSF requirements.

1

There may be extenuating circumstances that require an adjustment to the draft BSR Report deadlines. In these situations, the
BSR Manager will propose a revised timeline to the Head of LFO with a justification for the need to deviate and will seek
concurrence.

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PART I – BUSINESS SYSTEMS REVIEW PROCESS

2. ROLES AND RESPONSIBILITIES

2. ROLES AND RESPONSIBILITIES
Each BSR has a number of internal and external stakeholders involved in the review process to ensure
that the assessment is complete, and areas of non-compliance are addressed. An organizational
structure showing these stakeholders is shown in Figure 1 below.
Figure 1. Stakeholders

Table 1 summarizes the BSR Stakeholders’ roles and responsibilities.
Table 1. BSR Stakeholders’ Roles and Responsibilities
STAKEHOLDERS

ROLES AND RESPONSIBILITIES
NSF STAKEHOLDERS
•

Office Head, Large
Facilities

Approves annual BSR schedule with Division Director, Division of Acquisition and
Cooperative Support (DACS)
• Approves BSR Guide Revisions, Standard Operating Guidance (SOG) and Standard
Operating Procedures (SOP)
• Documents final resolution of BSR recommendation through memo to Program
•

BSR Manager

BSR Lead

BSR Guide, NSF FY21-XX

•
•
•
•
•

Develops BSR schedule based on the annual Major Facility Portfolio Risk
Assessment
Maintains document control over BSR Guide, BSR SOG, and SOPs
Monitors BSR progress and closeout of recommendations with BSR Leads
Coordinates BSRs with other NSF oversight (e.g., Office of Inspector General [OIG])
Approves final BSR scope
Confirms sufficiency of BSR Core Team

•
•
•
•
•
•

Serves as the primary NSF administrative point of contact with Recipient
Coordinates BSR and leads BSR Core Team
Recommends final BSR scope to BSR Manager
Develops and refines the review strategy
Approves draft and final report and associated coordination with Recipient
Develops and works Implementation Plan for resolution of recommendations

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PART I – BUSINESS SYSTEMS REVIEW PROCESS

Content Specialist

Science Directorates
(Program Officer)

BFA Division Staff

Grants and
Agreements Officer
(G/AO)

Contractor
Operational Lead

•
•
•
•
•
•
•
•
•

2. ROLES AND RESPONSIBILITIES

Makes recommendations on the BSR scope as requested by BSR Lead
Analyzes documentation and highlights compliance issues, concerns and gaps
Maintains supporting review documentation
Makes recommendations to refine review strategy based on desk review
Authors CFA sections of draft and final BSR Reports
Explores issues and concerns with Recipient during teleconference and/or onsite
Suggests remedial action on issues of non-compliance
Makes recommendations for improvement
Provides expert advice on Implementation Plan or resolution of recommendations
as requested by BSR Lead

• Advises on BSR scheduling/timeline
• Provides programmatic background/context and risk perspectives
• Reviews draft BSR Report and Implementation Plan
• Recommends any needed award actions to the G/AO
• Serve as resource to the BSR Core Team
• Provide background information and other risk/business perspectives
• Provides insight on administrative management and Recipient compliance with
terms and conditions
• Notifies BSR Core Team of pending award actions
• Identifies and outlines special award terms and conditions
• Reviews draft BSR Report and Implementation Plan
• Participates in monitoring and resolution of recommendations
• Directs any necessary actions by the Recipient as part of on-going award
management, particularly around any areas of non-compliance.
• Provides administrative and logistical support to ensure effective and efficient
implementation of the BSR process
• Works with BSR Lead in assigning reviews and administrative duties on the BSR
Core Team

RECIPIENT STAKEHOLDERS
Principal
Investigator (Project
Director)

• Determines the scientific and technical direction of the Major Facility
• Designates a BSR Point of Contract (POC) and AOR
• Provides scientific/technical background on the Facility

Authorized
Organizational
Representative
(AOR)

• Oversees Recipient compliance with Federal award requirements
• Monitors resolution of BSR recommendations
• May also serve as the BSR POC

Recipient BSR Point
of Contact (POC)

Core Functional Area
Representatives

BSR Guide, NSF FY21-XX

•
•
•
•
•
•
•
•

Designates CFA representatives
Facilitates onsite review activities and logistics working with BSR Lead
Consolidates comments on draft BSR report and interfaces with BSR Lead
Coordinates resolution of recommendations in coordination with BSR Lead
Provides requested documentation
Participates in teleconferences
Supports BSR Core Team onsite
Consulted with or implements corrective actions or recommendations

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PART I – BUSINESS SYSTEMS REVIEW PROCESS

2. ROLES AND RESPONSIBILITIES

2.1 NSF Stakeholders
2.1.1 Large Facilities Office
The Large Facilities Office (LFO) is responsible for leading the BSR process. The Head of LFO manages the
NSF staff responsible for conducting and closing out the BSRs. With the Division Director for Acquisition
and Cooperative Support, the Head of LFO recommends the BSRs to be conducted in a given year, to the
Chief Financial Officer (CFO) and Chief Officer for Research Facilities. The Head of LFO is supported in
this process by the BSR Manager, who co-leads the annual Major Facilities Annual Portfolio Risk
Assessment, develops the annual BSR schedule, confirms the capabilities of the BSR Team members, and
monitors BSR report delivery and closeout activities. Each BSR is planned and organized by the BSR Lead,
who is typically the LFO Liaison assigned to the Major Facility and serves as the principal Point of Contact
(POC) with the Recipient throughout the process.
The BSR is conducted by a team of government and contractor personnel (Contractor Operational Lead
and Content Specialists) that executes all phases of the BSR process, including operational logistics,
scoping, document requests, desk reviews, site visits, and development of draft and final reports. NSF
makes all inherently governmental final approvals of the various work products developed.
The BSR Manager reviews the make-up of the BSR Team, with input from the BSR Lead and Contractor
Operational Lead. The BSR Manager ensures that the Content Specialists assigned to each CFA have the
necessary skills, background, and competencies to deliver the final BSR report. The Content Specialists
are selected based on their specialized knowledge in the core functional areas as well as their
understanding of applicable OMB Uniform Guidance and circulars, and NSF award requirements. They
should also be skilled technical writers who can complete their reports within the required time frame
and have an “assistance” mindset. Content Specialists can be NSF staff, other government agency
representatives, or contractor personnel. The BSR Lead can serve as a Content Specialist, but this is
generally not preferable.
The BSR Team conduct the desk review by performing an analysis of the written policies, procedures,
and practices provided by the Recipient, to identify any potential compliance or risk issues. At the end of
the site visit, the BSR Team conducts an out-brief to explain any compliance concerns to Recipient’s
senior management and summarize potential recommendations for improvement. Following the site
visit, the BSR Lead engages with the Content Specialists on completing their assigned CFA assessment
and documenting their observations in the preliminary draft report.

2.1.2 Other NSF Stakeholders
Other NSF staff play important roles in the BSR process. For example, the Program Officer is a key
resource for critical background information on Major Facility operations and administrative business
systems and provides input during the annual Major Facility Portfolio Risk Assessment. Other staff in the
Science Directorates may contribute additional background information. The Grants and Agreements
Officer (G/AO) provides background on award management issues and may also participate as one of
the Content Specialists supporting the BSR Team. Other BFA Divisions may also provide valuable
information on the Recipient’s business systems from a historical perspective and, on occasion, may also
participate as one of the experts in the BSR. These other NSF stakeholders are often relied upon to assist
the BSR Team in gathering information for the scoping process and may be called upon to provide their
insights on the draft BSR Report.

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PART I – BUSINESS SYSTEMS REVIEW PROCESS

2 ROLES AND RESPONSIBILITIES

2.2 Recipient Stakeholders
It is critical that the Recipient assign adequate staff who are directly involved in the management of the
business systems supporting the Major Facility and can provide the time necessary to interact with the
BSR Team in all aspects of the review. Specifically, Recipient staff are called upon at the pre-site visit
teleconferences to answer questions raised by the Content Specialists and to work with their CFA
counterparts onsite to explain and demonstrate the various processes. The Recipient’s staff are normally
led by an Authorized Organizational Representative (AOR), who may be the Chief Financial Officer (CFO),
or the Head of the Sponsored Research Office, or the Facility Business Manager, who may also serve as
the Recipient POC. This individual works with the BSR Lead to coordinate the scheduling process and
provide the logistical support to the team if a site visit is necessary.

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PART I – BUSINESS SYSTEMS REVIEW PROCESS

3. BSR PROCESS PHASES

3. BSR PROCESS PHASES
There are several phases in the BSR process. The schedule is developed by the BSR Manager for the
upcoming fiscal year and once the Facilities have been selected, the BSR Leads begin the process to plan
and scope their assigned BSR. The BSR Lead is responsible for ensuring that the entire process follows
internal standard operating guidance and procedures. The following provides an overview of each phase
in the process.
Figure 2. Overview of the BSR Process

3.1 Scheduling and Planning
Whenever possible, BSRs are scheduled according to the approved NSF internal administrative review
and oversight plan, although it may not always be possible to meet these goals. For example, scheduling
may be deferred when the Recipient is involved in another audit or review because a BSR, if conducted,
might burden the Recipient or compromise the independence of the other ongoing review process. To
stay current on factors that may have an impact on proposed BSRs, the BSR Manager holds regular
discussions with the LFO Head and BSR Leads. The BSR Manager monitors Office of Inspector General
(OIG) plans to minimize possible conflicts with any OIG active or planned work at the Recipient site. As a
result, BSR scheduling is an on-going process that is continuously reevaluated as circumstances change.
Once the initial schedule is established, the BSR Lead can initiate the review, including scoping and
formation of the BSR Team. The BSR Lead then coordinates with the BSR Manager to share information
on the planning process or to gain approvals for each step of the BSR.

3.2 Scoping
The first step in the phase is for the BSR Lead to draft the scope of the review. This is an iterative process
and starts with the broad review strategy which is informed by core NSF Integrated Project Team (IPT)
discussions held during the Major Facility Annual Risk Assessment. Each Major Facility is unique

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PART I – BUSINESS SYSTEMS REVIEW PROCESS

3. BSR PROCESS PHASES

regarding the risks identified and each BSR is scoped accordingly to take these differences into
consideration. The scoping process objectives are shown in the table below.
Objectives of the Scoping Process
•
•
•

Tailor the BSR to the specific Major Facility by aligning the BSR activities with the highest risks identified
using a systematic approach.
Leverage and build on recent audits and other assessments of the Major Facility’s business systems to
enhance the BSR and avoid duplication of effort and unnecessary administrative burden for NSF and the
Recipient.
Develop a comprehensive review plan, including the sampling strategy for each CFA, based on risk
factors.

As the BSR approaches, the BSR Lead meets with the other core members of the NSF IPT and discusses
additional information gathered since the Major Facility Annual Risk Assessment. Information from a
variety of sources listed below is assessed to finalize the scope for the review:2
Notification to the Recipient and Document Request – The Recipient is notified early by the BSR Lead,
and usually after the internal IPT scoping, discussions are held with Recipient to explain the process and
plan the upcoming review. Shortly thereafter, the Recipient is provided with an official document
request, outlining the background information requested by NSF, such as internal guidance documents,
policies, practices, and procedures, and any other materials deemed relevant. These are the documents
which will be evaluated during the desk review and will be used to further refine the review strategy and
scope of the BSR.
NSF and Recipient Kickoff Meeting Discussions – The NSF Program Officer provides high-level insights
into the unique aspects and administrative challenges. The G/AO shares his/her observations on the
administrative management of the Major Facility and identifies any upcoming award actions that might
affect the scope of the BSR. The BSR Lead uses the scoping discussion to develop and finalize the BSR
Team. Involvement of the Content Specialists in scoping discussions should be considered since they can
provide professional knowledge of OMB circulars, Uniform Guidance, and other Federal regulations that
might be beneficial.
Determination of Recipients and Awards – Most of NSF’s Major Facilities are managed by a single
Recipient, although some are administered by several Recipients under multiple awards. In these cases,
the specific roles and Recipient’s responsibilities pertaining to various aspects of construction and/or
operations and maintenance (O&M) activities are detailed in each Recipient’s cooperative agreements
or subaward agreements. Owing to limited resources, the BSR may not be able to review all Recipient’s
business systems supporting the Facility. In these instances, the BSR Lead will consult with the NSF
Program Officer and the G/AO for their guidance on conducting the review. Certain factors will be
considered in making the determination – e.g., risks identified, overall level of the Recipient’s fiduciary
responsibility for construction or operation of the Facility, or oversight responsibilities for the
management of multiple contract/subaward activities.
Coordination with the Resolution and Advanced Monitoring (RAM) Branch and the NSF OIG – The LFO
Head notifies the NSF OIG of the planned BSRs to facilitate coordination of NSF oversight activities. The
BSR Lead or the G/AO requests from RAM any pertinent or more recent audit reports that are available,
which will be evaluated to determine if the findings overlap with any of the proposed CFAs principles or
practices. If so, the findings may inform the review strategy and final scope. The BSR Lead will highlight
the significant reporting findings for the Content Specialists to consider as they conduct their
independent reviews.
2

These activities are not necessarily performed in the order listed here.

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Consideration of Potential Site Visit Locations – When a site visit is deemed necessary, the onsite
reviews are typically conducted at Recipient headquarters or the primary business offices of the Major
Facility. However, some Facilities have remote sites or business functions conducted in other locations.
In these instances, the BSR Lead will consult with the other core IPT members and the Recipient to
determine the value of visiting these sites in order to better understand the business systems and
complete the assessment. For example, other sites would be considered if there were specific business
systems in place designed to accommodate the special needs of a remote site. If additional sites were to
be reviewed, the visits would generally occur immediately prior to or after the main site visit in
conjunction with the other BSR activities.

3.2.1 IPT Kickoff
To begin the review process, a kickoff meeting is held with the Program Officer, the G/AO, and other BSR
Team members to discuss the review expectations. The BSR Lead explains the BSR process, discusses the
review strategy, and identifies the proposed milestones. The Program Officer provides a brief overview
of the scientific activities at the Major Facility and describes the management structure in place that
supports Facility administration. The G/AO provides a briefing on the relevant awards. After the session,
CFA responsibilities are assigned to Content Specialists and BSR Team members, logistical arrangements
are clarified, and the dates to begin the desk review process are confirmed.

3.3 Desk Review
The purpose of the desk review is to conduct an initial assessment of the written administrative business
systems, policies, practices, and procedures that support the Major Facility, to identify compliance gaps
with the OMB Circulars, Uniform Guidance and other Federal regulations, and NSF award terms and
conditions. The Content Specialists review the documentation made available electronically by the
Recipient.

3.3.1 Desk Review Logistics
The desk review normally takes place over a one-week period; either combined sessions for the entire
BSR Team or separately. Content Specialists focus their attention on independently analyzing the
materials collected from the various sources to understand the business systems applicable to their
respective CFAs and to identify any additional risks, potential problems, or gaps with compliance. This
assessment can only be based on the quality of the documentation available at the time. The Content
Specialists document any issues, concerns, or omissions.

3.3.2 Desk Review Debrief
When the desk review is complete, the Content Specialists debrief the BSR Lead, Program Officer, and
the G/AO on the results of their independent assessment, noting any issues, concerns, or gaps. These
working files are annotated, organized, and stored in an internal repository. At this point, the desk
review process is complete. The findings may be used by the BSR Lead to further refine the review
strategy.

3.4 Teleconference
Shortly before the site visit, teleconferences may be arranged between the Content Specialists and the
Recipient CFA representatives, to clarify initial observations and issues identified during the desk review
and to gain a better understanding of the applicable policies, procedures, and processes for the CFA
under review. For example, the Content Specialists may ask the Recipient to walk through a process or
procedure that may not be well explained, or request forms or tools that support the process. If there

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were any issues of non-compliance identified during the desk review, the Content Specialists would
share these issues with the Recipient so that they could begin taking action to address the issues.

3.5 Site Visit
The site visit is conducted to gain a more detailed understanding of the business operations supporting
the Major Facility, to clarify issues identified during the desk review, and to test business processes to
ensure appropriate internal controls are in place. Onsite activities include an entrance conference,
interviews, and exit debriefing, may include a Facility tour, and typically take three to five days.

3.5.1 Site Visit Preparation
The BSR Lead determines, based on the results of the desk review and the BSR Team resources available,
if a site visit is necessary and, if so, identifies the Content Specialists who should participate in the site
visit. The Content Specialists review the desk review results to determine which principles and practices
of the CFA have been addressed and which areas require further evaluation, so that a strategy can be
developed to assess any outstanding issues. For example, if there are gaps in documentation, the
Content Specialists will provide a list of missing documentation to the BSR Lead, who will forward it to
the Recipient. There may also be a need to test the Recipient’s practices by sampling transactions, to
ensure that policies and procedures are followed. In these cases, the Content Specialists will choose a
selected period (e.g., the last quarter of the fiscal year) and will request that the Recipient provide a
listing of transactions (also known as a “sampling universe”). Sample transactions will be selected from
the list and the Recipient will be requested to provide source-supporting documentation to support the
specific expenditures.
The review strategy and scope are periodically evaluated by the BSR Lead with input from the Content
Specialists and updated as additional materials become available. There may also be occasions where
the review may be expanded to assess items that have been identified by NSF staff for special
consideration.

3.5.2 Final Preparations and Logistics
The BSR Lead meets with the BSR Team to finalize plans, address logistical issues, and discuss the main
areas and concerns that will be addressed onsite. Final logistics are coordinated with the Recipient and
the site visit agenda is set. The Recipient POC is contacted to verify that a conference room is available
for the BSR Team and other participants to meet privately throughout the week and that a separate
room is accessible to conduct interviews and other BSR-related activities. Teleconference and internet
access also should be available, as well as print, copy, and scan capabilities.

3.5.3 Entrance Conference
An entrance conference is held on the first day of the site visit with the BSR Team, other NSF
participants, Content Specialists, and the Recipient POC, Facility Director, and Recipient CFA
representatives. The BSR Lead reiterates the purpose of the BSR and provides a brief overview of the
planned activities. The Recipient BSR POC or Facility Director is invited to provide a high-level overview
of the Major Facility activities and describe the administrative management structure.

3.5.4 Facility Tour
A Facility tour may be arranged for BSR Participants if the BSR Lead and Recipient POC determine that
the tour would provide insight into the business systems required to support the operations.

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3.5.5 Individual Interviews and Group Discussions
The Content Specialists interview their Recipient counterparts to gain insight into issues identified during
the desk review process, to clarify the application of the policies and procedures on the existing business
systems, and to gather additional information that may be necessary to support the conclusions in the
draft BSR Report. The schedule is set in advance and takes into consideration the time required to
conduct the CFA review and sample analysis, the availability of the Recipient’s CFA representatives, and
the instances when the Content Specialists may be reviewing multiple CFAs. Additional sample
transactions may be requested to identify if there were multiple occurrences of the questioned activity
or whether the occurrence was an anomaly with mitigating factors.

3.5.6 Daily Assessments
Time is set aside at the end of each day for the BSR Team to meet privately and discuss their results and
observations. This time is also used to organize meeting notes, prepare for the next day’s activities,
consolidate supporting documentation, and draft the BSR report sections. Near the end, the Recipient is
invited to join the BSR Team for a debrief on the status of the BSR and the needs for the next day.

3.5.7 Exit Conference
An exit conference is held on the final day to present the preliminary observations and findings and to
discuss plans for post-site visit activities. The BSR Lead presents a general overview of the BSR and
provides the Recipient with a high-level summary of the issues of non-compliance and other significant
issues that were found during the review. Each Content Specialist may also present a brief oral summary
of his/her preliminary CFA results. The Recipient staff have an opportunity to ask questions and clarify
any items. At the close, the BSR Lead explains the next steps in the process and provides the timeline for
issuing the draft BSR Report and, if necessary, an Implementation Plan which will be used to track
resolution of any non-compliance issues and other recommendations. The Recipient should be prepared
to respond in writing to the findings when formally conveyed Implementation Plan which is drafted by
NSF and delivered after the Final BSR report is issued.

3.6 Report Generation and Follow-up and Monitoring
Shortly after the site visit, the BSR Team drafts its report identifying the high priority areas,
recommendations for improvement, and any good practices observed. These observations are shared
with the Program Officer and G/AO. The draft report is provided to the Recipient shortly after
completion of the site visit so that action to address any high priority areas identified can be initiated as
soon as possible.
Report from BSR Team
Draft BSR Report
Final BSR Report

Delivery to Recipient
33 days after last day of site visit
18 days after delivery of Draft BSR Report

3.6.1 Draft BSR Report Preparation
Each Content Specialist develops his/her CFA section of the draft BSR Report based on an assessment of
the reviewed materials from the desk review, teleconferences, and site visit observations. The BSR Lead
reviews the draft submissions and works with the other core IPT members to compile the draft BSR
Report. Areas of non-compliance are automatically classified as high priority for resolution by the
Recipient. This draft report is sent to the Recipient for comment within 33 business days of the final day
of the last site visit.

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3.6.2 Final BSR Report Preparation
The BSR Final Report serves as an historical record and is normally completed and released to the
Recipient approximately 18 business days following the issuance of the draft BSR Report. The report
summarizes the entire BSR procedure and contains the following key sections:
BSR Report Section

Section Contents

Executive Summary
1.0 Background

Overview of the BSR and a summary of the results
Synopsis of the key scientific activities, business structure, and roles and
responsibilities of Recipient stakeholders supporting the Major Facility
2.0 Scoping
The process used and materials examined to develop the review strategy
3.0 Review Strategy
The overview approach, activities, and methods used to develop the extent
of the review
4.0 Cross-Cutting Themes The themes, issues or items identified for at least two core functional areas.
For Major Facilities with distributed sites, the themes, issues, or items
common to at least two of their sites
5.0 Core Functional Areas The specific observations and results for each CFA, addressing principles and
practices. Detailed results highlight the issues of non-compliance (critical
requirements), recommended areas for improvement, and best practices
observed that exceed expectations of a proficient business system
6.0 Follow-up and
Monitoring Activities

Follow-up to ensure that the issues of non-compliance and other items are
considered as high priority

7.0 Summary and
Conclusions
Appendices A and B

NSF’s overall impressions of the administrative business systems supporting
the Major Facility and the results of the BSR
Tabular summary of the supporting documentation used in the review along
with a consolidated list of findings, presented in the Oversight Tracking List,
which is used to develop the Implementation Plan

3.6.3 Implementation Plan Formulation
After the draft BSR Report is distributed, the BSR Lead works collaboratively with the other core IPT
members to develop and reach consensus on the Implementation Plan, which prioritizes the
recommendations based on NSF’s judgment. This Plan becomes the blueprint for resolving any issues
and recommendations over the coming year. The Plan includes assigned responsibilities, due dates, and
deliverables and is typically completed shortly after issuance of the draft BSR report. The draft
Implementation Plan is sent to the Recipient to ensure that the associated timelines and milestones for
each resolution action are practicable. Reasonable adjustments are made before the final
Implementation Plan is issued and implementation begins. Any specific actions resulting from the
Implementation Plan, particularly those that are a result of non-compliance, will be directed by either
the PO or G/AO based on their responsibilities for award management under the Uniform Guidance and
the terms and conditions of the award (See also Section 2 of the Major Facilities Guide).
Areas of non-compliance with Federal regulation are automatically categorized as high-priority items
and must be resolved within two (2) months (45 business days) following the issuance of the draft BSR
Report. With respect to all other findings and recommendations, prioritization for resolution and the
acceptability of the method of resolution will be established by NSF in consultation with the Recipient,
based on experience and knowledge of applicable practices. These items are required to be resolved in
some mutually agreeable fashion within one (1) year from issuance of the Final BSR Report. The primary
point of contact for coordinating the resolution of the findings and recommendations is the BSR Lead.
The Recipient should assign a similar primary point of contact to aid in the resolution process.

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3.6.4 Follow-up and Monitoring
The BSR Lead and other core IPT members monitor progress against the Implementation Plan during
follow-up and monitoring to ensure that all high priority items/areas identified are appropriately
resolved. The core IPT members play a key role in the monitoring and resolution process, along with
other subject matter experts as needed. Based on the agreed-on schedule, the Recipient provides
periodic updates and supporting documentation reflecting progress made in resolving the outstanding
issues. The reports and documents are reviewed to ensure that NSF and the Recipient have a mutual
understanding of the finding/recommendation, its resolution, and that progress is consistent with the
Implementation Plan. This process continues until all outstanding issues have been addressed.

3.6.5 Administrative Closeout
Administrative closeout is the final step in the BSR process. The supporting deliverables and
documentation identified in the Implementation Plan are tracked and monitored by the LFO Liaison until
all findings and recommendation have been resolved. Based on the recommendation of the LFO Liaison,
the Head of LFO will send a memorandum to the Program Officer confirming that the BSR is completed
once all issues have been satisfactorily resolved. At this point, the Program Officer will upload the Final
BSR Report and completed Implementation Plan into the NSF eJacket system and may share LFO’s
closure memorandum with the Recipient or other stakeholders. The LFO Liaison, supported by the BSR
Support Contractor, will cross-check references in the Final BSR Report with the available electronic files
to ensure that all of the files and documentation are available, indexed and retrievable for future review
or audit.
If resolution cannot be reached within one year, the Head of LFO is notified and the Implementation
Plan is reevaluated.

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4. PROGRAM MANAGEMENT AND OVERSIGHT

4. PROGRAM MANAGEMENT AND OVERSIGHT
There may be some recommendations that require longer periods to implement than the one year
noted above. Once the BSR is administratively closed, post-BSR monitoring becomes the responsibility of
the NSF IPT, whose members may raise issues in future Major Facility Portfolio annual risk assessments.

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PART II – CORE FUNCTIONAL AREA REVIEW MODULES

PART II – CORE FUNCTIONAL AREA REVIEW MODULES
Part II is intended for use by all BSR participants but particularly those who are engaged in the desk
review and/or site visit activities.
Each module contains the following sections:
•

Scope of Review – Highlights the key topics and issues that are assessed for each particular CFA
module.

•

Supporting Documentation – Lists examples of specific CFA supporting materials that are obtained
from the Recipient and evaluated during the desk review phase of the process. If additional
documents are required by the Content Specialists in order to complete the scope of the review,
these will be obtained by the BSR Lead prior to the site visit or provided by the Recipient onsite.

•

Procedures – Outlines the framework of principles and practices that is used by the BSR participants
to cover each CFA module.

Desk Review (Content Specialists)
•

Comprehend Uniform Guidance and other applicable Federal regulations and guidance.

•

Conduct the desk review for one or more CFA Modules.

•

Assess the various CFA policy, procedural, and process documentation for compliance with
governing regulations and use in support of the Major Facility.

•

Note any observations, issues, or concerns for each principle/practice included in the scope of the
CFA module.

•

Organize and index supporting documentation used in the desk review.

•

Provide input on the draft BSR Report and Implementation Plan, as necessary.

Pre-Site and Site Visit (Content Specialists)
•

Comprehend Uniform Guidance and other applicable Regulations and Guidance.

•

Formulate a strategy (e.g., personnel to interview, additional documentation to obtain) to
investigate and address issues requiring onsite follow-up.

•

Review supporting materials and noting any gaps or additional concerns.

•

Prepare a list of questions for discussion during the Recipient teleconference session in order to
obtain clarification on any outstanding issues noted during the desk review.

•

Participate in site visit review and compare practices to desk review observations. Note and discuss
reasons for inconsistencies.

•

Retain and organize supporting documentation collected during the site visit.

•

Explore issues and concerns with Recipient during teleconference and/or onsite.

•

Suggest remedial action on issues of non-compliance and make recommendations for
improvements.

•

Author CFA sections of draft BSR Report and Implementation Plan if requested.

For select CFAs, the Content Specialist may need to sample some transactions and reports in order to
assess whether outlined policies and procedures are being followed. If necessary, the Content Specialist
will choose a sample from a list of transactions provided by the Recipient and notify the BSR Lead of the

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selection. The BSR Lead will forward the list to the Recipient and ask them to have the source supporting
material available for review by the BSR participants during the site visit. The Content Specialist is
expected to document the sampling methodology used in his/her review, note the transactions tested,
and include these observations in the final CFA report.
• Review Framework – Includes focused principles and practices that are assessed for the specific
CFA, using guidance contained in the review focus areas and the desk review and site visit
procedures.
Document Area
To view the review module relevant to •
your area, click on the appropriate
•
link:
•
•
•
•
•
To view the references relevant to
•
your area, click on the appropriate
•
link:
•
•
•
•
•
To view the review questions relevant •
to your area, click on the appropriate •
link:
•
•
•
•
•
To view the Acronym List:
•
To view the Glossary:
•

BSR Guide, NSF FY21-XX

Links to Document Area
General Management Review Module
Award Management Review Module
Budget Planning and Execution Review Module
Financial Management Review Module
Human Resources Management Review Module
Procurement Review Module
Property Management Review Module
General Management Review References
Award Management Review References
Budget Planning and Execution Review References
Financial Management Review References
Human Resources Management Review References
Procurement Review References
Property Management Review References
General Management Review Questions
Award Management Review Questions
Budget Planning and Execution Review Questions
Financial Management Review Questions
Human Resources Management Review Questions
Procurement Review Questions
Property Management Review Questions
List of Acronyms
Glossary

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1. GENERAL MANAGEMENT REVIEW
MODULE

1. GENERAL MANAGEMENT REVIEW MODULE
This module is used by the Content Specialist to assess the administrative business systems supporting
general management for the Major Facility. It includes areas which are organized in a framework
consisting of several overarching principles, each of which is broken down into detailed practices. A
mapping of the corresponding sources used as references is provided along with a list of focus topics
and key sample questions to facilitate consistent interpretation of the practices by the reader.

1.1 Scope of Review
The scope of this review covers the administrative business system that provides general management
support for the Major Facility and covers the execution through and communication by the people,
policies and processes, and information technology. It involves elements of the Recipient’s control
environment such as ethics, conflicts of interest, and advice gathered through autonomous committees,
Recipient’s risk assessment, records retention and physical safety. The Recipient’s and Major Facility’s
management structure specific to this functional area is also assessed along with the alignment of the
policies, processes and procedural documentation with Federal regulations, and the coordination and
use in supporting the Facility construction and/or operations. The breadth and depth of the review is
tailored to the unique aspects of the Major Facility and determined through a scoping process. Findings
of previous internal and external reviews and audits are considered to avoid duplication of effort.

1.2 Supporting Documentation
Early in the process, the Recipient submits “end-to-end” business process materials that are made
available to the BSR Review Team. Examples of commonly requested information are outlined in the
bulleted list below. This list is not comprehensive and does not replace the formal BSR Document
Request.
Examples of Supporting Materials
• Names and titles of key personnel listed in the Terms and Conditions and personnel that have
significant responsibilities for elements of general management
• Description of functional duties and responsibilities of the personnel associated with general
management supporting the Major Facility
• Organizational charts specific to general management functions
• Information on continuing education for staff members responsible for general management on
matters such as ethics (e.g., standards of conduct, conflict of interest [COI], records retention and
Whistleblower policy)
• Policies and procedural documents such as flowcharts, templates, and forms related to the general
management functions, highlighting the roles and responsibilities specific to the support of the
Major Facility
• Description of mechanism for tracking and monitoring the reports and other general managementrelated requirements and/or deliverables specified in the cooperative agreement terms and
conditions
• Published statement of the Recipient’s key entities and Major Facility’s objectives
• Documentation on the powers that have been granted to the Recipient to enter into contractual
relationships (e.g., articles of incorporation, by-laws)
• Delegated authority information
• Strategic planning process maps and other materials

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1. GENERAL MANAGEMENT REVIEW
MODULE

•

Copies of performance reports that address administrative business capabilities

•

Description of the Major Facility’s advisory structure or Board of Directors

•

Summaries of the advisory groups and meetings

•

Any other documentation identified by the Recipient as pertinent to this core functional area

1.2.1 Procedures
The common desk review and site visit procedures for each module are listed in the introductory section
of the BSR Guide Part I, above.

1.2.2 Framework Contents
PRINCIPLE 1. A COMPLIANT STRUCTURE OF GENERAL MANAGEMENT FUNCTIONS SUPPORTS
THE MAJOR FACILITY.
Practice 1.1. Documented policies and procedures clearly outline the Recipient’s and Major Facility’s
organizational structure responsible for general management.
Practice 1.2. Documented policies and procedures clearly define the collective positions in the general
management organizational structure and for each, the role, duties, authorities and reporting lines.
Practice 1.3. Documented policies and procedures ensure that staff with significant responsibilities in
general management receive continuing education and development opportunities to allow them to
successfully support the functions.

PRINCIPLE 2. A COMPLIANT CONTROL ENVIRONMENT SUPPORTS THE MAJOR FACILITY.
Practice 2.1. Documented policies and procedures address integrity, ethical values and conflicts of
interest.
Practice 2.2. Documented policies and procedures outline the autonomous entities that provide
oversight on the development and performance of internal control.
Practice 2.3. Documented policies and procedures specify the establishment of internal entities or
structures with clear reporting lines, authorities and responsibilities.
Practice 2.4. Documented policies and procedures address the information necessary to carry-out dayto-day controls through internal and external communications.
Practice 2.5. Documented policies and procedures address the monitoring and assessment of internal
control components.

PRINCIPLE 3. A COMPLIANT RISK ASSESSMENT IS CONDUCTED AND SUPPORTS THE MAJOR
FACILITY.
Practice 3.1. Documented policies and procedures specify the identification, management, and
assessment of risk.
Practice 3.2. Documented policies and procedures address the control activities (broad actions) taken to
mitigate risks.
Practice 3.3. Documented policies and procedure highlight that confidential expressions of concern
about fraud, waste, or abuse can be made without fear of reprisal.

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1. GENERAL MANAGEMENT REVIEW
MODULE

PRINCIPLE 4. A COMPLIANT SYSTEM FOR RECORDS RETENTION AND ACCESS SUPPORTS THE
MAJOR FACILITY.
Practice 4.1. Documented policies and procedures address the handling and retention of financial
records, supporting documents, statistical records and all other records pertinent to Federal awards,
and address with the exceptions.
Practice 4.2. Documented policies and procedures address records transfer from Federal awarding
agency to non-Federal entity, and arrangements for the records needed for continuous joint-use.
Practice 4.3. Documented policies and procedures specify the Recipient’s methods for collecting,
transmitting and storing Federal award-related information.
Practice 4.4. Documented policies and procedures address the right of timely and reasonable access to
documents, papers or other records pertinent to the Federal award and to non-Federal entity’s
personnel for interviews or discussions of documents.
Practice 4.5. Documented policies and procedures address public access to the records pertinent to the
Federal award.

PRINCIPLE 5. OTHER COMPLIANT GENERAL MANAGEMENT AREAS SUPPORT THE MAJOR
FACILITY.
Practice 5.1. Documented policies and procedures to address technology needs associated with internal
controls.
Practice 5.2. Documented policies and procedures assure the safety and security of buildings,
equipment, information systems, and employee and public.
Practice 5.3. Documented policies and procedures demonstrate emergency preparedness related to
catastrophic events and natural disasters, and address how the related plans are created, monitored
and evaluated.

PRINCIPLE 6. INTERNAL CONTROLS FOR GENERAL MANAGEMENT ARE COMPLIANT AND
SUPPORT THE MAJOR FACILITY.
Practice 6.1. Documented policies and procedures outline transaction-level actions and reporting to
assure compliance with Federal statutes, and the terms and conditions of awards and other general
management responsibilities.
Practice 6.2. Documented policies and procedures explain the evaluation and monitoring and timely
actions for instances of non-compliance.

OTHER REVIEW AREAS
As part of scoping or during execution of the review, the BSR Team may need to explore additional
administrative business topics which are not included in the module. For these cases, the BSR Lead
evaluates the expanded scope. If agreed upon, the review of the additional issue/s follows the same
approach used for the other focus areas. This includes documentation of the observations and results in
the core functional area report.
* * * * *

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MODULE

Click the Appendix A link to view the references and sample review questions for this module.
To view the Acronym List, click the Appendix B link. To view the Glossary, click the Appendix C link.

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2. AWARD MANAGEMENT REVIEW
MODULE

2. AWARD MANAGEMENT REVIEW MODULE
This module is used by the Content Specialist to assess the administrative business systems supporting
award management for the Major Facility. It includes areas covered which are organized in a framework
consisting of several overarching principles, each of which is broken down into detailed practices. A
mapping of the corresponding sources used as references is provided, along with a list of focus topics
and key sample questions to facilitate consistent interpretation of the practices by the reader.

2.1 Scope of Review
The scope of this review covers the administrative business system that provides award management
support for the Major Facility and covers the execution through and communication by the people,
policies and processes, and information technology. It involves award administration, subrecipient
oversight, and the monitoring of the terms and conditions specific to the award/s. The Recipient’s and
Major Facility’s management structure specific to this functional area is also assessed, along with the
alignment of the policies, processes and procedural documentation with Federal regulations, and the
coordination and use in supporting the Major Facility’s construction and/or operations. The breadth and
depth of the review is tailored to the unique aspects of the Major Facility and determined through a
scoping process. Findings of previous internal and external reviews and audits are considered to avoid
duplication of effort.

2.2 Supporting Documentation
Early in the process, the Recipient submits materials that are made available to the BSR Review Team.
Examples of commonly requested information are outlined in the bulleted list below. This list is not
comprehensive and does not replace the formal BSR Document Request.
Examples of Supporting Materials
•

Names and titles of personnel with significant responsibilities for administering the NSF award

•

Description of functional duties and responsibilities of the personnel associated with award
management supporting the Major Facility

•

Organizational charts specific to award management functions

•

Information on continuing education opportunities for staff members responsible for award
management functions

•

Policies and procedural documents such as flowcharts, templates, forms related to the award
management functions (e.g., pre-award, post award, closeout, subrecipient monitoring), highlighting
the roles and responsibilities specific to the support of the Major Facility

•

Description of mechanism for tracking and monitoring the reports and other award managementrelated requirements and/or deliverables specified in the cooperative agreement terms and
conditions

•

Any other documentation identified by the Recipient as pertinent to this core functional area

2.2.1 Procedures
The common desk review and site visit procedures for each module are listed in the introductory section
of the BSR Guide Part I, above.

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2. AWARD MANAGEMENT REVIEW
MODULE

2.2.2 Framework Contents
PRINCIPLE 1. A COMPLIANT STRUCTURE OF AWARD MANAGEMENT FUNCTIONS SUPPORTS
THE MAJOR FACILITY.
Practice 1.1. Documented policies and procedures clearly outline the organizational structures
responsible for award management including administration.
Practice 1.2. Documented policies and procedures clearly define the collective positions in the award
management organizational structure and for each, the role, duties, authorities and reporting lines.
Practice 1.3. Documented policies and procedures ensure that staff with significant responsibilities in
managing awards receive continuing education and development opportunities to allow them to
successfully support the functions.

PRINCIPLE 2. A COMPLIANT MANAGEMENT APPROACH FOR ALL AWARD/S LIFECYCLE
STAGES SUPPORTS THE MAJOR FACILITY.
Practice 2.1. Documented policies and procedures specify pre-award management requirements.
Practice 2.2. Documented policies and procedures address post-award management requirements.
Practice 2.3. Documented policies and procedures address closeout requirements, and the postcloseout adjustments and continuing responsibilities.

PRINCIPLE 3. MANAGEMENT AND MONITORING OF SUBRECIPIENTS IS COMPLIANT AND
SUPPORTS THE MAJOR FACILITY.
Practice 3.1. Documented policies and procedures specify the considerations for appropriately
classifying award agreements.
Practice 3.2. Documented policies and procedures outline all information to be included such as the
data elements, requirements on use, support of financial and performance reporting, approved
indirect cost rate, applicable flow-down requirements, record access by auditors and closeout terms.
Practice 3.3. Documented policies and procedures outline the steps and factors used to assess the risk
of noncompliance.
Practice 3.4. Documented policies and procedures specify the monitoring and tools used to ensure
award is used for authorized purposes, accountability and compliance with program requirements
and achievement of performance goals.
Practice 3.5. Documented policies and procedures specify requirements for audits, the conditions
necessary to adjust pass-through entity’s records, and enforcement actions for noncompliance.
Practice 3.6. Documented policies and procedures explain the requirements and process to provide
fixed amount subawards.

PRINCIPLE 4. INTERNAL CONTROLS FOR AWARD MANAGEMENT ARE COMPLIANT AND
SUPPORT THE MAJOR FACILITY.
Practice 4.1. Documented policies and procedures outline transaction-level actions and reporting to
assure compliance with Federal statutes, and the terms and conditions of awards and other award
management responsibilities.

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2. AWARD MANAGEMENT REVIEW
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Practice 4.2. Documented policies and procedures explain the evaluation and monitoring and timely
actions for instances of noncompliance.

OTHER REVIEW AREAS
As part of scoping or during execution of the review, the BSR Team may need to explore additional
administrative business topics which are not included in the module. For these cases, the BSR Lead
evaluates the expanded scope. If agreed upon, the review of the additional issue/s follows the same
approach used for the other focus areas. This includes documentation of the observations and results in
the core functional area report.
* * * * *
Click the Appendix A link to view the references and sample review questions for this module.
To view the Acronym List, click the Appendix B link. To view the Glossary, click the Appendix C link.

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PART II – CORE FUNCTIONAL AREA REVIEW MODULES 3. BUDGET PLANNING AND EXECUTION
REVIEW MODULE

3. BUDGET PLANNING AND EXECUTION REVIEW MODULE
This module is used by the Content Specialist to assess the administrative business systems supporting
budget planning and execution supporting the Major Facility. It includes areas which are organized in a
framework consisting of several overarching principles, each of which is broken down into detailed
practices. A mapping of the corresponding sources used as references is provided along with a list of
focus topics and key sample questions to facilitate consistent interpretation of the practices by the
reader and Content Specialist.

3.1 Scope of Review
The scope of this review covers the administrative business system that provides budget planning and
execution support for the Major Facility and covers the execution through and communication by the
people, policies and processes, and information technology. It involves cost estimation and schedule
during formulation, and the tracking and reconciliation of expenditures during execution. The
Organization’s and Major Facility’s management structure specific to this functional area is also assessed
along with the alignment of the policies, processes and procedural documentation with Federal
regulations, and the coordination and use in supporting the Facility construction and/or operations. The
breadth and depth of the review is tailored to the unique aspects of the Major Facility and determined
through a scoping process. Findings of previous internal and external reviews and audits are considered
to avoid duplication of effort.

3.2 Supporting Documentation
Early in the process, the Recipient submits materials that are made available to the BSR Review Team.
Examples of commonly requested information are outlined in the bulleted list below. This list is not
comprehensive and does not replace the formal BSR Document Request.
Examples of Supporting Materials
•

Names and titles of personnel with significant responsibilities for the budget planning and execution
process support the Major Facility

•

Description of functional duties and responsibilities of the personnel associated with budget
planning and execution supporting the Major Facility

•

Organizational charts specific to budget planning and execution functions supporting the Major
Facility

•

Information on continuing education opportunities for staff members responsible for budget
planning and execution functions supporting the Major Facility

•

Policies and procedural documents related to the budget planning and execution functions,
highlighting the roles and responsibilities specific to the support of the Major Facility

•

Description of mechanism for tracking and monitoring the reports and other budget planning and
execution-related requirements and/or deliverables specified in the cooperative agreement terms
and conditions

•

Processes, procedures, templates and flowcharts outlining the Major Facility’s internal budget
planning formulation activities (e.g., cost estimates development), allocation, and execution such as
tracking expenditures

•

A timeline of budget exercises performed throughout the fiscal year (e.g., future-year strategic
planning and formulation, periodic monitoring reviews, year-end)

•

Facility budgets for construction and/or operations for the specified period

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REVIEW MODULE
•

Documentation that illustrates the management and implementation of NSF-funded awards at the
Major Facility

•

Materials to illustrate the evolution of cost estimate reports/cost books and cost estimating plan
over the life cycle stages (e.g., construction design phases, transition to operations, operations etc.)

•

Project Execution Plan

•

Annual Project Reports

•

Any other documentation identified by the Recipient as pertinent to this core functional area

3.2.1 Procedures
The common desk review and site visit procedures for each module are listed in the introductory section
of the BSR Guide Part I, above.

3.2.2 Framework Contents
PRINCIPLE 1. A COMPLIANT STRUCTURE OF BUDGET PLANNING AND EXECUTION FUNCTIONS
SUPPORTS THE MAJOR FACILITY.
Practice 1.1. Documented policies and procedures clearly outline the organizational structure
responsible for budget planning and execution including administration.
Practice 1.2. Documented policies and procedures clearly define the collective positions in the budget
planning and execution organizational structure and for each, the role, duties, authorities and
reporting lines.
Practice 1.3. Documented policies and procedures ensure that staff with significant responsibilities in
budget planning and execution receive continuing education and development opportunities to
allow them to successfully support the functions.

PRINCIPLE 2. A COMPLIANT SYSTEM EXISTS FOR DEVELOPING A BUDGET TO SUPPORT THE
MAJOR FACILITY’S VARIOUS LIFE-CYCLE STAGES.
Practice 2.1. Documented strategic planning policies and procedures integrate and align process outputs with the
established scope, activities, objectives and performance of the Major Facility (e.g., completed templates, cost
categories).

Practice 2.2. Documented policies and procedures assure the reliability of the budget through the
identification and application of the appropriate formulation methodology.
Practice 2.3. Documented policies and procedures address the documentation, accuracy,
comprehensiveness and credibility of cost estimates.
Practice 2.4. Documented policies and procedures specify the format, structure and supporting
justification for all related budget process products.
Practice 2.5. Documented policies and procedures summarize the internal pre-submission reviews of the
Recipient’s and Subrecipient’s budget to assure accuracy and compliance with Federal regulations
and requirements and needed refinement.

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PRINCIPLE 3. A COMPLIANT SYSTEM EXISTS TO EXECUTE THE APPROVED BUDGET
SUPPORTING THE MAJOR FACILITY’S VARIOUS LIFE-CYCLE STAGES.
Practice 3.1. Documented policies and procedures require the tracking and reporting of expenditures
against each approved award budget including the identification and implementation of revisions.
Practice 3.2. Documented policies and procedures address deviations from the budget and the
conditions for obtaining prior approval.
Practice 3.3. Documented policies and procedures ensure that routinely scheduled and relevant reports
(budget and financial) are produced and used by the Major Facility and Recipient-level stakeholders
such as management, program, and budget personnel.
Practice 3.4. Documented policies and procedures specify the evaluation of approved budget and
actions taken on variances identified throughout (beginning to end) the annual award budget
period.

PRINCIPLE 4. INTERNAL CONTROLS FOR BUDGET PLANNING AND EXECUTION ARE
COMPLIANT AND SUPPORT THE MAJOR FACILITY.
Practice 4.1. Documented policies and procedures outline transaction-level actions and reporting to
assure compliance with Federal statutes, and the terms and conditions of awards and other budget
planning and execution responsibilities.
Practice 4.2. Documented policies and procedures explain the evaluation and monitoring and timely
actions for instances of non-compliance.

OTHER REVIEW AREAS
As part of scoping or during execution of the review, the BSR Team may need to explore additional
administrative business topics which are not included in the module. For these cases, the BSR Lead
evaluates the expanded scope. If agreed upon, the review of the additional issue/s follows the same
approach used for the other focus areas. This includes documentation of the observations and results in
the core functional area report.
* * * * *
Click the Appendix A link to view the references and sample review questions for this module.
To view the Acronym List, click the Appendix B link. To view the Glossary, click the Appendix C link.

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4. FINANCIAL MANAGEMENT REVIEW
MODULE

4. FINANCIAL MANAGEMENT REVIEW MODULE
This module is used by the Content Specialist to assess the administrative business systems supporting
financial management supporting the Major Facility. It includes areas which are organized in a
framework consisting of several overarching principles, each of which is broken down into detailed
practices. A mapping of the corresponding sources used as references is provided along with a list of
focus topics and key sample questions to facilitate consistent interpretation of the practices by the
reader and Content Specialist.

4.1 Scope of Review
The scope of this review covers the administrative business system that provides financial management
support for the Major Facility and covers the execution through and communication by the people,
policies and processes, and information technology. It involves cost allowability, financial reporting and
record keeping and cash management. The Recipient’s and Major Facility’s management structure
specific to this functional area is also assessed along with the alignment of the policies, processes and
procedural documentation with Federal regulations, and the coordination and use in supporting the
Facility construction and/or operations. The breadth and depth of the review is tailored to the unique
aspects of the Major Facility and determined through a scoping process. Findings of previous internal
and external reviews and audits are considered to avoid duplication of effort.

4.2 Supporting Documentation
Early in the process, the Recipient submits materials that are made available to the BSR Review Team.
Examples of commonly requested information are outlined in the bulleted list below. This list is not
comprehensive and does not replace the formal BSR Document Request.
Examples of Supporting Materials
• Names and titles of personnel with significant responsibilities for financial management of the Major
Facility, including the delegated authority levels
• Description of functional duties and responsibilities for the personnel with the financial
management supporting the Major Facility
• Organizational charts specific to financial management functions supporting the Major Facility
• Information on continuing education opportunities for staff members responsible for financial
management functions supporting the Major Facility
• Policies and procedural documents such as flowcharts, templates, forms related to the financial
management functions, highlighting the roles and responsibilities specific to the support of the
Major Facility
• Description of mechanism for tracking and monitoring the reports and other financial managementrelated requirements and/or deliverables specified in the cooperative agreement terms and
conditions
• Copies of the written policies and procedures for manual and/or computerized processing of
transactions from origination, authorization, approval, ordering, receipt and payment, ultimately
ending in charges to the sponsored Major Facility project/s
• Information on any recently implemented changes to the financial management system
• Chart of accounts and the accounting code(s) identified with the NSF award/s
• Explanation of cost classifications where more than one account code is used to track or monitor
expenses in the chart of accounts

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4. FINANCIAL MANAGEMENT REVIEW
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• Time and effort reporting policies and procedures, including documentation of employee base
salary, the threshold for making changes from budgeted to actual effort in the after-the-fact
verification, suitable means of verification (where reports are not signed by the employee or his/her
supervisor), and a definition of the types of activities that should not be charged to Federal awards
(e.g., Bid and Proposal costs)
• Copies of any recent internal audits or reviews of the recipient accounting and/or financial
management systems, including time and effort reporting
• Copies of any recent cognizant audit or oversight agency reports or review and analysis related to
accounting systems and financial management. Examples of accounting system reports,
spreadsheets, and other documents or subsystems used by the Recipient stakeholders to manage
and track expenditures and labor distribution for the Major Facility (e.g., monthly expense reports
provided to the Principal Investigator [PI] and/or Departmental Research Administrators)
• Summary of costs claimed, by expense category charged to the NSF award
• List of salary charges to the NSF award from the project cost summary for the last fiscal year by
amount and by employee name, position, and level of effort (e.g., percentage, hours)
• The recipient’s Cost Accounting Standard Board’s (CASB) disclosure statement or cost policy
statement
• Documents that the Recipient uses for managing the financial reporting and payment functions,
including a description of the internal control policies and procedures
• Summary of costs claimed by expense category for a specified time period
• List of accounting transactions from the general ledger related to the NSF award for a specified
period
• Any other documentation identified by the Recipient as pertinent to this core functional area

4.2.1 Procedures
The common desk review and site visit procedures for each module are listed in the introductory section
of the BSR Guide Part I, above.

4.2.2 Framework Contents
PRINCIPLE 1. A COMPLIANT STRUCTURE OF FINANCIAL MANAGEMENT FUNCTIONS
SUPPORTS THE MAJOR FACILITY.
Practice 1.1. Documented policies and procedures clearly outline the organizational structure
responsible for financial management.
Practice 1.2. Documented policies and procedures clearly define the collective positions in the financial
management organizational structure and for each, the role, duties, authorities and reporting lines.
Practice 1.3. Documented policies and procedures ensure that staff with significant responsibilities in
financial management receive continuing education and development opportunities to allow them
to successfully support the functions.

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4. FINANCIAL MANAGEMENT REVIEW
MODULE

PRINCIPLE 2. A COMPLIANT FINANCIAL MANAGEMENT SYSTEM SUPPORTS THE MAJOR
FACILITY.
Practice 2.1. Documented policies and procedures address the generation of required reports and
specify the use of detailed information related to the award.
Practice 2.2. Documented policies and procedures specify the identification components of Federal
awards received and expended, and the related Federal Programs under which they were received.
Practice 2.3. Documented policies and procedures specify how accurate, current and complete reporting
of the results of the Federal award or Program is generated.
Practice 2.4. Documented policies and procedures require that records identify the source and
application of funds for Federally-funded activities through the specified information fields.
Practice 2.5. Documented policies and procedures implement the required payment methods.
Practice 2.6. Documented policies and procedures explain how the allowability of cost is determined
and reviewed.

PRINCIPLE 3. A COMPLIANT SYSTEM TO CASH MANAGEMENT SUPPORTS THE MAJOR
FACILITY.
Practice 3.1. Documented policies and procedures discuss the handling of advance payments or
reimbursement requests from the Recipient.
Practice 3.2. Documented policies and procedures discuss program income and the related reporting
requirements.
Practice 3.3. Responsibilities for access and permissions to the financial functions of the award cash
management service (ACM$) are controlled and segregated.

PRINCIPLE 4. INTERNAL CONTROLS FOR FINANCIAL MANAGEMENT ARE COMPLIANT AND
SUPPORT THE MAJOR FACILITY.
Practice 4.1. Documented policies and procedures outline transaction-level actions and reporting to
assure compliance with Federal statutes, and the terms and conditions of awards and other financial
management responsibilities.
Practice 4.2. Documented policies and procedures explain the evaluation and monitoring and timely
actions for instances of non-compliance requirements are defined and documented.

OTHER REVIEW AREAS
As part of scoping or during execution of the review, the BSR Team may need to explore additional
administrative business topics which are not included in the module. For these cases, the BSR Lead
evaluates the expanded scope. If agreed upon, the review of the additional issue/s follows the same
approach used for the other focus areas. This includes documentation of the observations and results in
the core functional area report.
Below are examples of additional areas that could be considered for BSR review:
• Construction and Operations of NSF Funded Research Platforms (applicable for Major Research
Equipment and Facilities Construction [MREFC] funded projects). Some NSF facilities may be funded

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4. FINANCIAL MANAGEMENT REVIEW
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with different appropriated accounts which must be segregated. Typically, construction costs are
funded with MREFC appropriations whereas operational funding is through Research and Related
Activities (R&RA) accounts. Facility records would be reviewed to ensure that separate accounts are
established for construction (MREFC) and operations (R&RA) costs and funding are segregated.
• Post-Retirement Benefits (applicable for NSF Federally Funded Research and Development Centers
[FFRDCs]). Financial Accounting Standards Board (FASB) Statement 106 requires that recipients who
provide post-retirement healthcare benefits must accrue for this liability for both current employees
and retirees. In this situation, post-retirement benefit costs would be reviewed to determine how
these costs are accrued and noted on the recipient’s financial statements.
• Accrued Vacation Liability (applicable for NSF FFRDC). Determine whether there is any liability to NSF
for accrued vacation costs.
* * * * *
Click the Appendix A link to view the references and sample review questions for this module.
To view the Acronym List, click the Appendix B link. To view the Glossary, click the Appendix C link.

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PART II – CORE FUNCTIONAL AREA REVIEW MODULES

5. HUMAN RESOURCES MANAGEMENT
REVIEW MODULE

5. HUMAN RESOURCES MANAGEMENT REVIEW MODULE
This module is used by the Content Specialist to assess the administrative business systems supporting
human resources management supporting the Major Facility. It includes areas covered in the review
which are organized in a framework consisting of several overarching principles, each of which is broken
down into detailed practices. A mapping of the corresponding sources used as references is provided
along with a list of focus topics and key sample questions to facilitate consistent interpretation of the
practices by the reader and Content Specialist.

5.1 Scope of Review
The scope of this review covers the administrative business system that provides human resources
management support for the Major Facility and covers the execution through and communication by the
people, policies and processes, and information technology. It involves the expectations for nondiscrimination, a drug-free workplace, and the mechanisms to plan for, recruit, hire, employ, and
evaluate the workforce. The Recipient’s and Major Facility’s management structure specific to this
functional area is also assessed along with the alignment of the policies, processes and procedural
documentation with Federal regulations, and the coordination and use in supporting the Facility
construction and/or operations. The breadth and depth of the review is tailored to the unique aspects of
the Major Facility and determined through a scoping process. Findings of previous internal and external
reviews and audits are considered to avoid duplication of effort.

5.2 Supporting Documentation
Early in the process, the Recipient submits materials that are made available to the BSR Review Team.
Examples of commonly requested information are outlined in the bulleted list below. This list is not
comprehensive and does not replace the formal BSR Document Request.
Examples of Supporting Materials
• Names and titles of personnel responsible for providing a significant level of human resources
management support for the Major Facility
• Description of functional duties and responsibilities for the personnel with the human resources
management supporting the Major Facility
• Organizational charts or other documents specific to human resources management functions
• Information on continuing education opportunities for staff members responsible for human
resources management functions
• Policies and procedural documents such as flowcharts, templates, forms related to the human
resources management functions, highlighting the roles and responsibilities specific to the support
of the Major Facility
• Description of mechanism for tracking and monitoring the reports and other human resources
management-related requirements and/or deliverables specified in the cooperative agreement
terms and conditions
• HR policies and procedures, handbooks, manuals, or employee communications related to the
following:

• Drug-free workplace
• Non-discrimination regulations and policies:
▪
▪

Prohibition on basis of race, color, or national origin
Prohibition on basis of disability

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▪
▪

5. HUMAN RESOURCES MANAGEMENT
REVIEW MODULE

Prohibition on basis of sex in Federally assisted education programs or activities
Sexual Harassment

• Strategic human capital or workforce planning (i.e., strategic human capital or workforce
plans)

• Operational human capital or workforce planning (e.g., recruiting, hiring or staffing plans,
staff development plans)
▪ Applicant recruitment, screening, and selection (e.g., position requisitions,
advertisements/vacancy announcements, interview and selection guides, applicant
applications, hiring letter)
▪ Recognition and reward systems
▪ Vacation and sick leave benefits
▪ Employee development (e.g., course listings, training records)
▪ Whistleblowing protection policy
• Compensation and employee benefit descriptions and analyses
• Required government filings for the previous 3 years which may include:

• Employer Information Report EEO-1
• Form 5500 Annual Return/Report of Employee Benefit Plan
• Summary Plan Descriptions
• Discrimination complaints filed within the recent years, including subsequent notification to NSF’s
Office of Diversity and Inclusion (ODI) Equal Opportunity
• Employee convictions for violations related to the Recipient’s drug-free workplace policy, including
subsequent notifications to the NSF G/AO or designee
• Workplace accidents and how they were resolved and if any improvements were made to address
the situation
• Documentation describing recent trends in employee vacancies, hiring, and attrition
• Any other documentation identified by the Recipient as pertinent to this core functional area

5.2.1 Procedures
The common desk review and site visit procedures for each module are listed in the introductory section
of the BSR Guide Part I, above.

5.2.2 Framework Contents
PRINCIPLE 1. A COMPLIANT SYSTEM TO SUPPORT HUMAN RESOURCES MANAGEMENT
FUNCTIONS SUPPORTS THE MAJOR FACILITY.
Practice 1.1. Documented policies and procedures clearly outline the organizational structure
responsible for human resources management.
Practice 1.2. Documented policies and procedures clearly define the collective positions in the human
resources management organizational structure and for each, the role, duties, authorities and
reporting lines.
Practice 1.3. Documented policies and procedures ensure that staff with significant responsibilities in
human resources management receive continuing education and development opportunities to
allow them to successfully support the functions.

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PRINCIPLE 2. COMPLIANT MECHANISMS ENSURE THAT NO PERSON IS DISCRIMINATED
AGAINST BASED ON RACE, COLOR, NATIONAL ORIGIN, SEX, OR DISABILITY SUPPORT THE
MAJOR FACILITY.
Practice 2.1. Documented policies and procedures ensure applicants and employees are aware of the
Recipient’s non-discrimination policies and practices.
Practice 2.2. Documented policies and procedures train selection officials and managers in their
responsibilities in complying with non-discrimination policies and practices.
Practice 2.3. Documented policies and procedures specify and assure compliance with specific non-discrimination
practices as described in relevant Federal regulations (e.g., making reasonable accommodations for people
with disabilities, instituting policies and practices to resolve discrimination complaints).

PRINCIPLE 3. A COMPLIANT DRUG-FREE WORKPLACE SUPPORTS THE MAJOR FACILITY.
Practice 3.1. Documented policies and procedures provide each employee engaged in the performance
of the award, a published statement notifying employees of the requirements of the Recipient’s
policies and processes regarding a drug-free workplace.
Practice 3.2. Documented policies and procedures outlined the response to violations of the drug-free
workplace policy.
Practice 3.3. Documented policies and procedures specify the ongoing drug-free awareness program
that addresses key elements outlined in drug-free workplace certification.

PRINCIPLE 4. A COMPLIANT SYSTEM FOR WORKFORCE PLANNING SUPPORTS THE MAJOR
FACILITY.
Practice 4.1. Documented policies and procedures set the strategic direction by linking the workforce
planning process with the entity’s strategic plan, annual performance/business plan, and work
activities required to carry out the goals and objectives of the strategic plan (long term) and
performance plan (short term).
Practice 4.2. Documented policies and procedures address a workforce planning mechanism to analyze
the current and future workforce supply and determine the gaps and surpluses in achieving the
desired future state, based on an agile, balanced and capable mission-ready workforce in the
necessary geographic locations to accomplish the entity’s strategic requirements.
Practice 4.3. Documented policies and procedures address the process to prioritize gaps and surpluses
and develop an action plan with strategies and measurable outcomes to assess progress in support
of the Major Facility needs.
Practice 4.4. Documented policies and procures address a monitoring and evaluation process to assess
the effectiveness of the strategies and revisions of the plan, as needed.

PRINCIPLE 5. A COMPLIANT AND SYSTEMATIC MECHANISM FOR RECRUITMENT, HIRING,
AND EMPLOYMENT SUPPORTS THE MAJOR FACILITY.
Practice 5.1. Documented policies and procedure guide the recruitment, hiring and employment
supporting the human capital needs of the Major Facility.

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5. HUMAN RESOURCES MANAGEMENT
REVIEW MODULE

PRINCIPLE 6. A COMPLIANT MECHANISM FOR PERFORMANCE MANAGEMENT SUPPORTS
THE MAJOR FACILITY.
Practice 6.1 Documented policies and procedures address written performance goals, objectives and
metrics/expectations for the established performance period.
Practice 6.2. Documented policies and procedures address the communication and action taken in
relation to the results of performance evaluations reprisal.
Practice 6.3. Documented policies and procedures address the compensation practices including
rewards and the connection with the compensation philosophy of the Recipient and market pricing
information.

PRINCIPLE 7. INTERNAL CONTROLS FOR HUMAN RESOURCES MANAGEMENT ARE
COMPLIANT AND SUPPORT THE MAJOR FACILITY.
Practice 7.1. Documented policies and procedures outline transaction-level actions and reporting to assure

compliance with Federal statutes, and the terms and conditions of awards and other human resources
management responsibilities (e.g., notification when changes in key personnel, reporting of violations with
drug-free workplace or sexual harassment).

Practice 7.2. Documented policies and procedures explain the evaluation and monitoring and timely
actions for instances of non-compliance.

OTHER REVIEW AREAS
As part of scoping or during execution of the review, the BSR Team may need to explore additional
administrative business topics which are not included in the module. For these cases, the BSR Lead
evaluates the expanded scope. If agreed upon, the review of the additional issue/s follows the same
approach used for the other focus areas. This includes documentation of the observations and results in
the core functional area report.
Below is an example of an additional area that could be considered for review: Davis-Bacon Act
(applicable for construction projects). Some NSF Major Facilities may include funding for construction
requiring the Recipient to comply with the provisions of the Davis-Bacon Act. The Davis-Bacon Act (40
USC §§ 276a et seq.) establishes minimum wages to be paid to laborers and mechanics on construction
contracts to which the US is a party, involving public buildings or public works within the US. A number
of other statutes have extended this provision to specific Federal grant programs involving construction.
However, unless specifically stated in the grant, the Davis-Bacon Act does not normally apply to NSF
grants since grantees normally retain title to property acquired under the grant and the construction, if
any, is normally on non-Government land.
* * * * *
Click the Appendix A link to view the references and sample review questions for this module.
To view the Acronym List, click the Appendix B link. To view the Glossary, click the Appendix C link.

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6. PROCUREMENT REVIEW MODULE

6. PROCUREMENT REVIEW MODULE
This module is used by the Content Specialist to assess the administrative business systems supporting
procurement supporting the Major Facility. It includes areas which are organized in a framework
consisting of several overarching principles, each of which is broken down into detailed practices. A
mapping of the corresponding sources used as references is provided along with a list of focus topics
and key sample questions to facilitate consistent interpretation of the practices by the reader and
Content Specialist.

6.1 Scope of Review
The scope of this review covers the administrative business system that provides procurement support
for the Major Facility and covers the execution through and communication by the people, policies and
processes, and information technology. It involves procurement actions and methods, competition,
inclusion of small and disadvantaged businesses, contract costs and clauses, and pass-through entity
reviews. The Recipient’s and Major Facility’s management structure specific to this functional area is
also assessed along with the alignment of the policies, processes and procedural documentation with
Federal regulations, and the coordination and use in supporting the Facility construction and/or
operations. The breadth and depth of the review is tailored to the unique aspects of the Major Facility
and determined through a scoping process. Findings of previous internal and external reviews and audits
are considered to avoid duplication of effort.

6.2 Supporting Documentation
Early in the process, the Recipient submits materials that are made available to the BSR Review Team.
Examples of commonly requested information are outlined in the bulleted list below. This list is not
comprehensive and does not replace the formal BSR Document Request.
Examples of Supporting Materials
• Names and titles of personnel with significant responsibilities for procurement activities supporting
the Major Facility
• Description of functional duties and responsibilities for the personnel associated with procurement
supporting the Major Facility
• Organizational charts specific to procurement functions
• Information on continuing education opportunities for staff members responsible for procurement
functions supporting the Major Facility
• Policies and procedural documents such as flowcharts, templates, forms related to the procurement
functions, highlighting the roles and responsibilities specific to the support of the Major Facility
• List of procurement transactions: contracts, leases, purchasing card transactions, and purchase
orders awarded for the (specified) period for activities funded under the specified cooperative
agreement
• Description of mechanism for tracking and monitoring the reports and other procurement-related
requirements and/or deliverables specified in the cooperative agreement terms and conditions
• Any other documentation identified by the Recipient as pertinent to this core functional area

6.2.1 Procedures
The common desk review and site visit procedures for each module are listed in the introductory section
of the BSR Guide Part I, above.

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6. PROCUREMENT REVIEW MODULE

6.2.2 Framework Contents
PRINCIPLE 1. A COMPLIANT STRUCTURE OF PROCUREMENT FUNCTIONS SUPPORTS THE
MAJOR FACILITY.
Practice 1.1. Documented policies and procedures clearly outline the organizational structure
responsible for procurement.
Practice 1.2. Documented policies and procedures clearly define the collective positions in the
procurement organizational structure and for each, the role, duties, authorities and reporting lines.
Practice 1.3. Documented policies and procedures ensure that staff with significant responsibilities in
procurement receive continuing education and development opportunities to allow them to
successfully support the functions.

PRINCIPLE 2. GENERAL STANDARDS FOR PROCUREMENT ACTIONS SUPPORTING THE MAJOR
FACILITY ARE COMPLIANT.
Practice 2.1. Documented policies and procedures address the use of local procurement procedures and
reviews to assure compliance with governing regulations.
Practice 2.2. Documented policies and procedures specify oversight of contractors’ performance.
Practice 2.3. Documented policies and procedures outline the standards of conduct for employees who
are engaged in the selection, award and administration of contracts, and Organizational conflicts of
interest if applicable, and the disciplinary actions for violations of standards.
Practice 2.4. Documented policies and procedures address steps to avoid unnecessary purchases or
duplicative items, and appropriate analysis to determine the most economical approach.
Practice 2.5. Documented policies and procedures promote greater economy and efficiency through use
of shared goods and services, use of Federal excess and surplus property, and value engineering
clauses construction contracts.
Practice 2.6. Documented policies and procedures address the considerations for determining
responsible contractors.
Practice 2.7. Documented policies and procedures require the maintenance of records with details
required to show the procurement history.
Practice 2.8. Documented policies and procedures promote greater economy and efficiency through use
of shared goods and services, use of Federal excess and surplus property, and value engineering
clauses construction contracts.
Practice 2.9. Documented policies and procedures require settlement of all contractual and
administrative issues arising out of procurements.

PRINCIPLE 3. COMPLIANT PROCUREMENTS PROVIDE FULL AND OPEN COMPETITION TO
SUPPORT THE MAJOR FACILITY.
Practice 3.1. Documented policies and procedures ensure objective contractor performance and
eliminate unfair competitive advantage.

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6. PROCUREMENT REVIEW MODULE

Practice 3.2. Documented policies and procedures specify the prohibition of statutorily or
administratively imposed state, local, or tribal geographical preferences in the evaluation of bids or
proposals, except where mandated.
Practice 3.3. Documented policies and procedures transactions ensure that all solicitations incorporate a
description of technical requirements for the material, product or service to be procured, and
identify all requirements which offerors must fulfill and all other factors used in evaluating bids or
proposals.
Practice 3.4. Documented policies and procedures ensure that the prequalified lists of persons, firms or
products acquiring goods and services are current, include enough qualified sources to ensure
maximum open and free competition, and do not preclude the qualification of potential bidders.

PRINCIPLE 4. COMPLIANT PROCUREMENTS SUPPORTING THE MAJOR FACILITY FOLLOW ONE
OF THE SPECIFIED METHODS.
Practice 4.1. Documented policies and procedures for micro-purchases cover the acquisition of supplies
or services which do not exceed the published threshold and contain strategy for equitable
distribution strategy among qualified suppliers.
Practice 4.2. Documented policies and procedures for small purchases address the requirements around
securing of services, supplies or other property not costing more than the published acquisition
threshold.
Practice 4.3. Documented policies and procedures for sealed bids specify the conditions for use, the
award type and requirements of responsible bidders and bids.
Practice 4.4. Documented policies and procedures for competitive proposals address the conditions for
use and applicable requirements of proposals, technical evaluations, award selection and application
to architectural/engineering professional services.
Practice 4.5. Documented policies and procedures for noncompetitive proposals should address the
required circumstances for use.

PRINCIPLE 5. COMPLIANT CONTRACTING ACTIVITIES ASSURE THE USE OF SMALL AND
MINORITY BUSINESSES, WOMEN’S BUSINESS ENTERPRISES, AND LABOR SURPLUS AREA
FIRMS TO SUPPORT THE MAJOR FACILITY.
Practice 5.1. Documented policies and procedures address the affirmative steps that must be taken to
assure that diverse resources for procuring and acquiring goods and services are sought.

PRINCIPLE 6. COMPLIANT FLOW-DOWN PROVISIONS AND FUNDING ENTITY-SPECIFIC
AWARD TERMS AND CONDITIONS ARE USED IN CONTRACTS TO SUPPORT THE MAJOR
FACILITY.
Practice 6.1. Documented policies and procedures address procurement of items in compliance with the
Solid Waste Disposal Act.
Practice 6.2. Documented policies and procedures address the inclusion of applicable provisions in
contracts.
Practice 6.3. Documented policies and procedures address bonding requirements, including award flowdown provisions, for construction or facility improvement contracts or subcontracts exceeding the
simplified acquisition threshold.

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6. PROCUREMENT REVIEW MODULE

PRINCIPLE 7. COMPLIANT CONTRACT COSTS AND PRICES SUPPORT THE MAJOR FACILITY.
Practice 7.1. Documented policies and procedures address cost or price analyses for procurements in
excess of the simplified acquisition threshold including contract modifications.
Practice 7.2. Documented policies and procedures address the negotiation of profit for contracts in
which there is no price competition, and in all cases where cost analysis is performed.
Practice 7.3. Documented policies and procedures address the allowability of using estimated costs for
contracts.
Practice 7.4. Documented policies and procedures address the exclusion of cost plus a percentage of
cost and percentage of construction costs contracting methods.

PRINCIPLE 8. COMPLIANT SUBMISSIONS TO FEDERAL AWARD AGENCY OR PASS-THROUGH
ENTITY REVIEWS SUPPORT THE MAJOR FACILITY.
Practice 8.1. Documented policies and procedures address the availability of technical specifications on
proposed procurements when requested.
Practice 8.2. Documented policies and procedures specify the deliverables to the Federal agency per the
award terms and conditions.
Practice 8.3. Documented policies address the management review and approval of deliverables prior to
submission to the Federal award agency.

PRINCIPLE 9. INTERNAL CONTROLS FOR PROCUREMENT ARE COMPLIANT AND SUPPORT THE
MAJOR FACILITY.
Practice 9.1. Documented policies and procedures outline transaction-level actions and reporting to
assure compliance with Federal statutes, and the terms and conditions of awards and other
procurement responsibilities.
Practice 9.2. Documented policies and procedures explain the evaluation and monitoring and timely
actions for instances of non-compliance.

OTHER REVIEW AREAS
As part of scoping or during execution of the review, the BSR Team may need to explore additional
administrative business topics which are not included in the module. For these cases, the BSR Lead
evaluates the expanded scope. If agreed upon, the review of the additional issue/s follows the same
approach used for the other focus areas. This includes documentation of the observations and results in
the core functional area report.
* * * * *
Click the Appendix A link to view the references and sample review questions for this module.
To view the Acronym List, click the Appendix B link. To view the Glossary, click the Appendix C link.

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PART II – CORE FUNCTIONAL AREA REVIEW MODULES

7. PROPERTY MANAGEMENT REVIEW
MODULE

7. PROPERTY MANAGEMENT REVIEW MODULE
This module is used by the Content Specialist to assess the administrative business systems associated
with the property management supporting the Major Facility. It includes areas which are organized in a
framework consisting of several overarching principles, each of which is broken down into detailed
practices. A mapping of the corresponding sources used as references is provided along with a list of
focus topics and key sample questions to facilitate consistent interpretation of the practices by the
reader and Content Specialist.

7.1 Scope of Review
The scope of this review covers the administrative business system that relates to property management
and oversight which consists of real and personal/equipment, supporting the Major Facility and covers
the execution through and communication by the people, policies and processes, and information
technology. It involves acquisition, use and disposition, security and maintenance, and record keeping.
specific to the property supported by the award/s. The Recipient’s and Major Facility’s management
structure specific to this functional area is also assessed along with the alignment of the policies,
processes and procedural documentation with Federal regulations, and the coordination and use in
supporting the Facility construction and/or operations. The breadth and depth of the review is tailored
to the unique aspects of the Major Facility and determined through a scoping process. Findings of
previous internal and external reviews and audits are considered to avoid duplication of effort.

7.2 Supporting Documentation
Early in the process, the Recipient submits materials that are made available to the BSR Review Team.
Examples of commonly requested information are outlined in the bulleted list below. This list is not
comprehensive and does not replace the formal BSR Document Request.
Examples of Supporting Materials
• Names and titles of personnel with significant responsibilities for supporting the management and
oversight of property supporting the Major Facility
• Description of functional duties and responsibilities for the personnel associated with property
management and oversight supporting the Major Facility
• Organizational charts specific to property management and oversight functions
• Information on continuing education opportunities for staff members responsible for property
management and oversight
• Policies and procedural documents such as flowcharts, templates, checklists and forms related to
the property management and oversight functions, highlighting the roles and responsibilities specific
to the support of the Major Facility
• Description of mechanism for tracking and monitoring the reports and other property management
and oversight -related requirements and/or deliverables specified in the cooperative agreement
terms and conditions
• Recipient’s property classification and definitions to illustrate alignment with NSF's lexicon for terms
such as Federally-owned, Recipient-titled and Recipient-owned
• Screenshots or electronic system data dictionaries that may be helpful in understanding the IT
application system
• List of personnel authorized to review, approve, and purchase property

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7. PROPERTY MANAGEMENT REVIEW
MODULE

• Electronic download from property IT system showing roles and assigned personnel authorized to
enter, modify, or alter Major Facility’s property records
• Recent reports for reviews conducted by other Federal agencies (e.g., property system reviews
conducted by the Defense Contract Audit Agency (DCAA), Office of Naval Research (ONR))
• Recent internal audits or reviews of property management systems
• A listing of all property, both Recipient-titled and Federally-Owned property with information fields
required by Uniform Guidance (UG) such as acquisition document identifier, acquisition date,
physical location, and cost
• Reports of lost, damaged, or destroyed property (LDD)
• Most recent annual Federally-owned property inventory report submissions for the Major Facility
• Most recent fiscal year real property inventory report
• Most recent submission to GSA Federal Automotive Statistical Tool (FAST)
• Any other documentation identified by the Recipient as pertinent to this core functional area

7.2.1 Procedures
The common desk review and site visit procedures for each module are listed in the introductory section
of the BSR Guide Part I, above.

7.2.2

Framework Contents

PRINCIPLE 1. A COMPLIANT SYSTEM OF PROPERTY SUPPORTS THE MAJOR FACILITY.
Practice 1.1. Documented policies and procedures clearly outline the organizational structure
responsible for property management.
Practice 1.2. Documented policies and procedures clearly define the collective positions in the property
management organizational structure and for each, the role, duties, authorities and reporting lines.
Practice 1.3. Documented policies and procedures ensure that staff with significant responsibilities in
property management receive continuing education and development opportunities to allow them
to successfully support the functions.

PRINCIPLE 2. ACQUISITION OF PROPERTY TO SUPPORT THE MAJOR FACILITY IS COMPLIANT.
Practice 2.1. Documented policies and procedures classify the types of property and supplies.
Practice 2.2. Documented policies and procedures ensure acquisition requirements are met and the
property trust relationship is established.
Practice 2.3. Documented policies and procedures require the maintenance of documentation for new
acquisitions, replacement and/or improvement of property and assure that information on the title
and ownership is captured.

PRINCIPLE 3. COMPLIANT USE AND DISPOSITION MECHANISMS ASSOCIATED WITH
PROPERTY SUPPORT THE MAJOR FACILITY.
Practice 3.1. Documented policies and procedures address the proper use of property.

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7. PROPERTY MANAGEMENT REVIEW
MODULE

Practice 3.2. Documented policies and procedures address disposition of property.

PRINCIPLE 4. PROPERTY SUPPORTING THE MAJOR FACILITY IS SECURED AND MAINTAINED
IN A COMPLIANT MANNER.
Practice 4.1. Documented policies and procedures ensure that the property is maintained in good
condition.
Practice 4.2. Documented policies and procedures address safeguards to prevent loss, damage or theft,
and in instances of occurrence assure the required reporting and investigation of lost, damaged, or
stolen property.
Practice 4.3. Documented policies and procedures should include information on the process for sharing
property maintenance expectations and security requirements, with subrecipients.

PRINCIPLE 5. INVENTORY AND RECORD KEEPING MECHANISMS OF PROPERTY SUPPORTING
THE MAJOR FACILITY ARE COMPLIANT.
Practice 5.1. Documented policies and procedures address the capture and maintenance of information
and data elements.
Practice 5.2. Documented policies and procedures address the required frequency of conducting the
physical inventory review, and the reconciling of the results with the inventory records and
reporting.

PRINCIPLE 6. INTERNAL CONTROLS FOR PROPERTY ARE COMPLIANT AND SUPPORT THE
MAJOR FACILITY.
Practice 6.1. Documented policies and procedures outline transaction-level actions and reporting
specific to property management required to assure compliance with Federal statutes and the terms and
conditions of awards.
Practice 6.2. Documented policies and procedures explain the evaluation and monitoring and timely
actions for instances of non-compliance.

OTHER REVIEW AREAS
As part of scoping or during execution of the review, the BSR Team may need to explore additional
administrative business topics which are not included in the module. For these cases, the BSR Lead
evaluates the expanded scope. If agreed upon, the review of the additional issue/s follows the same
approach used for the other focus areas. This includes documentation of the observations and results in
the core functional area report.
* * * * *
Click the Appendix A link to view the references and sample review questions for this module.
To view the Acronym List, click the Appendix B link. To view the Glossary, click the Appendix C link.

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APPENDICES

APPENDICES

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APPENDIX A

LIST OF REFERENCES AND QUESTIONS

APPENDIX A: LIST OF REFERENCES AND QUESTIONS
This appendix identifies the hierarchy and key documents that have been used to develop the modules
which are used by the experts in performing their review.

Hierarchy of Primary Policies, Procedures, and other Guidance
The BSR requirements flow from other NSF policies and statutory requirements. The hierarchy of
documentation, in order of precedence, is as follows:
•

2 CFR, Part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirement
for Federal Awards (Uniform Guidance) which incorporates COSO Internal Control-Integrated
Framework

•

41 CFR, Part 101-39: Interagency Fleet Management Systems

•

NSF Proposal & Award Policies and Procedures Guide (PAPPG): The PAPPG is comprised of
documents relating to the Foundation's proposal and award process for the assistance programs
of NSF. The PAPPG, in conjunction with NSF’s Grant General Conditions, serves as the
Foundation’s implementation of the Uniform Guidance

•

Major Facilities Guide (MFG): Referenced in Chapter II.E.11 Research Infrastructure Proposal of
the PAPPG, NSF 20-1
Table 2. Citations/References and Abbreviations used in Appendix A Matrices
Full Title of Citation/Reference

Citation/Abbreviations
Used in Matrices

United States Code of Federal Regulations: Title 2, Subtitle A, Chapter II, Part 200 Uniform Guidance
– Uniform Administrative Requirements, Cost Principles, and Audit Requirements
for Federal Awards
United States Code of Federal Regulations: Title 2, Subtitle A, Chapter II, XX (other 2 CFR xxx
than the Uniform Guidance)
Federal Property Management Systems: Title 41, Subtitle C, Chapter 101,
41 CFR Part 101-39 –
Subchapter G, Part 101-39
Interagency Fleet
Management Systems
Cooperative Agreement Financial and Administrative Terms and Conditions
Cooperative Agreement
Modifications and Supplemental Financial & Administrative Terms and Conditions
for Major Multi-User Research Facility Projects and Federally Funded Research
and Development Centers
NSF Award Specific Terms and Conditions
NSF Terms and Conditions
NSF Major Facilities Guide
NSF Proposal and Award Policies and Procedures Guide
The Committee of Sponsoring Organizations of the Treadway Commission (COSO)
Internal Control – Integrated Framework
Federal Acquisition Regulation, Contract Cost Principles and Procedures

CAFATC
CA Mod & Supp FATC for
Major Facilities & FFRDC
NSF Award Specific T&C
NSF T&C
MFG NSFxx-x
PAPPG NSFxx-x
COSO
FAR

A matrix with relevant citations/references specific to each principle/practice is provided. A list with
example questions is also included to illustrate the intended focus of the practice and overarching
principle. To view these matrices, click on the appropriate link:

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APPENDIX A

LIST OF REFERENCES AND QUESTIONS

•

General Management Review References and Questions

•

Award Management Review References and Questions

•

Budget Planning and Execution Review References and Questions

•

Financial Management Review References and Questions

•

Human Resources Management Review References and Questions

•

Procurement Review References and Questions

•

Property Management Review References and Questions

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APPENDIX A

A-1. GENERAL MANAGEMENT REVIEW REFERENCES AND QUESTIONS

A-1. General Management Principles and Practices
General Management
Citation/Reference
PRINCIPLE 1. A COMPLIANT STRUCTURE OF GENERAL MANAGEMENT FUNCTIONS SUPPORTS
THE MAJOR FACILITY.
Practice 1.1 Documented policies and procedures
• COSO Control Environment Principle 3
clearly outline the Recipient’s and Major Facility’s
organizational structure responsible for general
management.
Practice 1.2 Documented policies and procedures
• COSO Control Environment Principle 3
clearly define the collective positions in the general
management organizational structure and for each, the
role, duties, authorities and reporting lines.
Practice 1.3 Documented policies and procedures
• COSO Control Environment Principle 4
ensure that staff with significant responsibilities in
general management receive continuing education and
development opportunities to allow them to
successfully support the functions.

QUESTIONS/FOCUS AREAS PRINCIPLE 1.
• How are the general management functions distributed at each of the levels, (central)
Recipient and (local) Major Facility?
• Demonstrate through use of organization charts, or other related documents, the depiction of
the general management functions at each of the levels—Recipient and Major Facility—and
how they support of the necessary functions, lines of authorities, and positions with reporting
lines.
• To what extent do individuals responsible for general management have the appropriate level
of authority required to accomplish their duties?
• How clear are the responsibilities of the Major Facility’s PI, Project Manager (if construction),
and other key personnel in the documentation?
• Does the distribution of positions between the Recipient and Major Facility for this business
function provide for sufficient support?
• What tools are used to capture the position definitions and responsibilities?
• Does every position, including those in senior management, have a position description that
aligns with the position’s responsibilities associated with supporting the Major Facility rather
than the individual’s appointment type?
• How is the staff providing general management support made aware of NSF expectations and
changes to the NSF award in relation to their specific duties and responsibilities?
• What requirements or expectations does the Recipient or Major Facility have for continuing
training to support this administrative business function?
• If there are no requirements for continuing training for the administrative business function,
how do the staff stay up-to-date on Federal requirements?
• How do the requirements or expectations determine what action is taken if they are not met?

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APPENDIX A

A-1. GENERAL MANAGEMENT REVIEW REFERENCES AND QUESTIONS

General Management
Citation/Reference
PRINCIPLE 2. A COMPLIANT CONTROL ENVIRONMENT SUPPORTS THE MAJOR FACILITY.
Practice 2.1 Documented policies and procedures
address integrity, ethical values and conflicts of
interest.

• Uniform Guidance 2 CFR §200.303, Internal
Controls
• Uniform Guidance 2 CFR §200.112, Conflict
of Interest
• COSO, Control Environment Principle 1
• PAPPG Chapter IX Grantee Standards A.
Conflicts of Interest Policies and B.
Responsible conduct of research
Practice 2.2 Documented policies and procedures
• Uniform Guidance 2 CFR §200.303, Internal
outline the autonomous entities that provide oversight Controls
on the development and performance of internal
• COSO, Control Environment Principle 2
control.
Practice 2.3 Documented policies and procedures
• Uniform Guidance 2 CFR §200.303, Internal
specify the establishment of internal entities or
Controls
structures with clear reporting lines, authorities and
• COSO, Control Environment Principle 3
responsibilities.
Practice 2.4 Documented policies and procedures
• COSO Information and Communication,
address the information necessary to carry-out day-toPrinciple 13
day controls through internal and external
communications.
Practice 2.5 Documented policies and procedures
• Uniform Guidance 2 CFR §200.501, Audit
address the monitoring and assessment of internal
requirements
control components.
• Uniform Guidance 2 CFR §200.502, Basis for
determining Federal awards expended

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APPENDIX A

A-1. GENERAL MANAGEMENT REVIEW REFERENCES AND QUESTIONS

General Management
QUESTIONS/FOCUS AREAS PRINCIPLE 2.

Citation/Reference

• How are employees apprised of the standards of conduct?
• How is adherence to the standards of conduct measured, and deviations addressed?
• What independent entities such as Committee or a Board have been established to support the
Major Facility?
• How do these Committee or Board entities maintain their independence to provide advice and
guidance?
• How are members selected to assure that they have and exercise relevant expertise?
• How have the Recipient and Major Facility evaluated the current internal Recipient entities’
reporting lines authorities and responsibilities at every level (Board, Senior Management,
Management, Personnel, and external service provider)?
• When was the last evaluation conducted for the Major Facility, what was the outcome and
associated adjustments?
• What broad philosophy guides the Recipient and Major Facility’s policies on internal and
external communications?
• What entities within the Recipient or Major Facility are responsible for evaluating the
effectiveness of the Recipient or Major Facility’s communication strategies?
• How does the Recipient fulfill its audit requirements?
• How does the Major Facility engage in the Recipient’s audits?
• What support does the Recipient provide to the Major Facility to help support its participation
in an audit?
• What Recipient or Major Facility entity is responsible for the monitoring and assessment of
various internal control components?
• How does the entity/ies responsible for monitoring and assessing internal controls convey the
results and expectations to the Major Facility?
• How does the Recipient or Major Facility handle the monitoring and assessment of internal
controls at its remote locations?

PRINCIPLE 3. A COMPLIANT RISK ASSESSMENT IS CONDUCTED AND SUPPORTS THE MAJOR
FACILITY.
Practice 3.1 Documented policies and procedures
specify the identification, management, and
assessment of risk.
Practice 3.2 Documented policies and procedures
address the control activities (broad actions) taken to
mitigate risks.

• COSO Risk Assessment Principle 6, 7 and 8
• COSO Control Activities Principle 10, Risk
Assessment Principle 8

Practice 3.3 Documented policies and procedure
• COSO Framework Principles 1, 14, and 15
highlight that confidential expressions of concern
about fraud, waste, or abuse can be made without fear
of reprisal.

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APPENDIX A

A-1. GENERAL MANAGEMENT REVIEW REFERENCES AND QUESTIONS

General Management
QUESTIONS/FOCUS AREAS PRINCIPLE 3.

Citation/Reference

• How do the Recipient and Major Facility assure that its administrative business objectives are
sufficiently clear to enable the identification and assessment of related risks?
• What entity in the Recipient and Major Facility is responsible for identifying, managing and
assessing the administrative business risks, both at the entity and transaction level?
• How and what administrative business performance measures are used to help the Recipient
and Major Facility operate within the established risk tolerance?
• How is the potential for various types of fraud (e.g., fraudulent reporting, safeguarding of
assets, corruption) incorporated into the Recipient and Major Facility’s risk assessment?
• How do the policies and procedures treat confidential expressions about fraud, waste, or abuse
to assure they can be made without fear of reprisal?
• How does the Major Facility assure that its control activities are aligned with the established
risk assessment for the Recipient?
• In determining the needed control activities, how does the Recipient communicate changes to
the broad ones that affect the Major Facility?

PRINCIPLE 4. A COMPLIANT SYSTEM FOR RECORDS RETENTION AND ACCESS SUPPORTS THE
MAJOR FACILITY.
Practice 4.1 Documented policies and procedures
address the handling and retention of financial records,
supporting documents, statistical records and all other
records pertinent to Federal awards, and address with
the exceptions.

• Uniform Guidance 2 CFR §200.333
• Uniform Guidance 2 CFR §200.334
• Uniform Guidance 2 CFR §200.335
• Uniform Guidance 2 CFR §200.336
• Uniform Guidance 2 CFR §200.337
Practice 4.2 Documented policies and procedures
• Uniform Guidance 2 CFR §200.333
address records transfer from Federal awarding agency • Uniform Guidance 2 CFR §200.334
to non-Federal entity, and arrangements for the
• Uniform Guidance 2 CFR §200.335
records needed for continuous joint-use.
• Uniform Guidance 2 CFR §200.336
• Uniform Guidance 2 CFR §200.337
Practice 4.3 Documented policies and procedures
• Uniform Guidance 2 CFR §200.333
specify the Recipient’s methods for collecting,
• Uniform Guidance 2 CFR §200.334
transmitting and storing Federal award-related
• Uniform Guidance 2 CFR §200.335
information.
• Uniform Guidance 2 CFR §200.336
• Uniform Guidance 2 CFR §200.337
Practice 4.4 Documented policies and procedures
• Uniform Guidance 2 CFR §200.333
address the right of timely and reasonable access to
• Uniform Guidance 2 CFR §200.334
documents, papers or other records pertinent to the
• Uniform Guidance 2 CFR §200.335
Federal award and to non-Federal entity’s personnel
• Uniform Guidance 2 CFR §200.336
for interviews or discussions of documents.
• Uniform Guidance 2 CFR §200.337
Practice 4.5 Documented policies and procedures
• Uniform Guidance 2 CFR §200.333
address public access to the records pertinent to the
• Uniform Guidance 2 CFR §200.334
Federal award.
• Uniform Guidance 2 CFR §200.335
• Uniform Guidance 2 CFR §200.336
• Uniform Guidance 2 CFR §200.337

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APPENDIX A

A-1. GENERAL MANAGEMENT REVIEW REFERENCES AND QUESTIONS

General Management
QUESTIONS/FOCUS AREAS PRINCIPLE 4.

Citation/Reference

• How does the Recipient convey the records retention requirements and assure that its entities,
such as the Major Facility, are aware of and properly trained on the requirements?
• How does the Major Facility reconcile the retention record requirements during development,
design and construction against the Recipient’s written requirements?
• What kind of exceptions, to the three-year records’ retention requirements, has its Federal
award agency (NSF) imposed on the Major Facility?
• What discussions has the Major Facility had with Federal award agency (NSF) regarding its
records?
• What considerations does the Major Facility take in determining the long-term retention value
of its records?
• What are the unique challenges that the Major Facility has with regard to its records retention
practices?
• Approximately what percentage of the Recipient’s records are available in full electronic
format?
• What challenges has the Recipient and Major Facility experienced in meeting the Federal
Government’s Executive Order on “Making Open and Machine-Readable Government
Information”?
• How does the Recipient and Major Facility handle a request for paper copies?
• What steps do the Recipient and Major Facility take to assure that the Federal award agency,
IG, Comptroller General of the United States, and the pass-through entity or their authorized
representative has access to the Recipient’s documents, papers or other records pertinent to
the Federal award?
• In practice, how does the Major Facility handle records access requests from a Federal award
agency, IG, Comptroller General of the United States, and the pass-through entity or their
authorized representatives?
• What are the most challenging aspects of providing access, and how have the Recipient and
Major Facility addressed these challenges?
• How do the Recipient and Major Facility protect sensitive information and assure that it is
aligned with governing regulations?
• What steps has the Recipient and Major Facility taken to protect personally identifiable
information (PII)?
• How do the Recipient and Major Facility discern personally identifiable information (PII)?
• How do the Recipient and Major Facility handle FOIA requests?

PRINCIPLE 5. OTHER COMPLIANT GENERAL MANAGEMENT AREAS SUPPORT THE MAJOR
FACILITY.
Practice 5.1 Documented policies and procedures to
• COSO Control Activities Principle 11
address technology needs associated with internal
controls.
Practice 5.2 Documented policies and procedures
• COSO Control Activities Principle 11
assure the safety and security of buildings, equipment,
information systems, and employee and public.
Practice 5.3 Documented policies and procedures
• NSF Terms and Conditions
demonstrate emergency preparedness related to
catastrophic events and natural disasters, and address
how the related plans are created, monitored and
evaluated.

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APPENDIX A

A-1. GENERAL MANAGEMENT REVIEW REFERENCES AND QUESTIONS

General Management
QUESTIONS/FOCUS AREAS PRINCIPLE 5.

Citation/Reference

• How does the Major Facility systematically address its technology needs and integrate with its
annual budget planning process?
• To what extent does the Recipient get involved in determining and assessing the Major
Facility’s information technology needs?
• What Recipient entities are responsible for assuring that the information technology
adequately supports the execution of entity and/or transactional-level internal controls?
• What entity-level business process control activities are in-place to assess the Recipient’s
success at assuring the safety and security of buildings, equipment, information systems etc.?
• Does the Major Facility also have business process control activities to measure its success at
assuring the safety and security of buildings, equipment, etc.?
• What kinds of challenges have the Recipient and Major Facility experienced with historical
control activities, and how were they modified to improve upon them?
• How and when are safety and security systems reviewed and by whom?
• How does the Recipient protect itself or others through insurance as noted in the terms and
conditions?
• How do the Recipient’s policies and procedures address notification of suits or actions filed?
• What kinds of health and safety reviews are conducted by the Major Facility or Recipient, and
how are these determined?

PRINCIPLE 6. INTERNAL CONTROLS FOR GENERAL MANAGEMENT ARE COMPLIANT AND
SUPPORT THE MAJOR FACILITY.
Practice 6.1 Documented policies and procedures
• Uniform Guidance 2 CFR §200.303, Internal
outline transaction-level actions and reporting to
Controls
assure compliance with Federal statutes, and the terms
and conditions of awards and other general
management responsibilities.
Practice 6.2 Documented policies and procedures
• Uniform Guidance 2 CFR §200.303, Internal
explain the evaluation and monitoring and timely
Controls
actions for instances of non-compliance.

QUESTIONS/FOCUS AREAS PRINCIPLE 6.
• How does the Recipient maintain an awareness of and get involved in taking action on
instances of noncompliance with the Major Facility?
• What local steps are taken by the Major Facility to evaluate and monitor the transaction-level
and reporting of internal controls related to award terms and conditions?
• How is information technology used, either automated or manually implemented, to facilitate
the distribution of responsibilities between the Recipient and Major Facility?
• How do the Recipient and Major Facility use formal feedback from various stakeholder entities
(e.g., internal audit, funding agency reviews, etc.) to understand possible systemic problems?
• How does the Major Facility assure that the information used to monitor its awards is
accurate?
To return to the module review, click General Management Review Module.

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APPENDIX A

A-2. AWARD MANAGEMENT REVIEW REFERENCES AND QUESTIONS

A-2. Award Management Principles and Practices
Award Management

Citation/Reference

PRINCIPLE 1. A COMPLIANT STRUCTURE OF AWARD MANAGEMENT FUNCTIONS SUPPORTS
THE MAJOR FACILITY.
Practice 1.1 Documented policies and procedures
clearly outline the organizational structures
responsible for award management including
administration.
Practice 1.2 Documented policies and procedures
clearly define the collective positions in the award
management organizational structure and for each,
the role, duties, authorities and reporting lines.
Practice 1.3 Documented policies and procedures
ensure that staff with significant responsibilities in
managing awards receive continuing education and
development opportunities to allow them to
successfully support the functions.

• COSO Control Environment Principle 3

• COSO Control Environment Principle 3

• COSO Control Environment Principle 4

QUESTIONS/FOCUS AREAS PRINCIPLE 1.
• How are the award management functions distributed at each of the levels, Recipient and
Major Facility?
• Demonstrate through use of organization charts, or other related documents, the depiction of
the award management functions at each of the levels, Recipient and Major Facility, and how
they support the necessary functions, lines of authorities, and positions with reporting lines.
• Where does the authority to commit the Recipient lie, at the Major Facility level or is it vested
only in one of the “central” Administrative Business Offices?
• To what extent do individuals responsible for award management have the appropriate level of
authority required to accomplish their duties?
• How clear are the responsibilities of the Major Facility’s PI, Project Manager (if construction),
and other key personnel in the documentation?
• Does the distribution of positions between the Recipient and Major Facility for this business
function provide for sufficient support?
• What tools are used to capture the position definitions and responsibilities?
• Does every position, including those in senior management, have a position description that
aligns with the position’s responsibilities associated with supporting the Major Facility rather
than the individual’s appointment type?
• How are staff members made aware of their specific duties and responsibilities?
• How is the staff providing award management support made aware of NSF expectations and
changes to the NSF award?
• What requirements or expectations do the Recipient or Major Facility have for continuing
training to support this administrative business function?
• If there are no requirements for continuing training for the administrative business function,
how do the staff stay up-to-date on Federal requirements?
• How do the requirements or expectations determine what action is taken if they are not met?
• Do individuals responsible for award management have the appropriate level of authority
required to accomplish their duties?

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APPENDIX A

A-2. AWARD MANAGEMENT REVIEW REFERENCES AND QUESTIONS

Award Management

Citation/Reference

PRINCIPLE 2. A COMPLIANT MANAGEMENT APPROACH FOR ALL AWARD/S LIFECYCLE
STAGES SUPPORTS THE MAJOR FACILITY.
Practice 2.1 Documented policies and procedures
specify pre-award management requirements.

• Uniform Guidance 2 CFR §200.12, Reporting
a determination that a non-Federal entity is
not qualified for a Federal Award
• Uniform Guidance 2 CFR §200.213,
Suspension and debarment
• Uniform Guidance 2 CFR §200.458,
Pre-award costs
• Uniform Guidance 2 CFR §200.300, Statutory
and national policy requirements
• Uniform Guidance 2 CFR §25.205, Effect of
noncompliance with a requirement to obtain
a unique entity identified or register in SAM
• Uniform Guidance 2 CFR §25.300,
Requirements for program announcements,
regulations, and application instructions
• Uniform Guidance 2 CFR Appendix A to Part
25 – Award Term
Practice 2.2 Documented policies and procedures
• Uniform Guidance 2 CFR Appendix A to Part
address post-award management requirements.
25 – Award Term, B. Requirement for unique
entity identified
• Uniform Guidance 2 CFR §25.302, Financial
management
• Uniform Guidance 2 CFR §200.308, Revision
of budget and program plans
Practice 2.3 Documented policies and procedures
• Uniform Guidance 2 CFR §200.208,
address closeout requirements, and the post-closeout Certifications representations
adjustments and continuing responsibilities.
• Uniform Guidance 2 CFR §200.343, Closeout
adjustments and continuing responsibilities
• Uniform Guidance 2 CFR §200.344, Postcloseout adjustments and continuing
responsibilities
• Uniform Guidance 2 CFR §200.345,
Collection of amounts due

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APPENDIX A

A-2. AWARD MANAGEMENT REVIEW REFERENCES AND QUESTIONS

Award Management

Citation/Reference

QUESTIONS/FOCUS AREAS PRINCIPLE 2.
•
•
•
•
•
•
•
•

•
•
•
•
•
•

•
•
•

What mechanisms does the Recipient have in place to review and negotiate award terms and
conditions?
Where in the process do the Recipient and Major Facility stakeholders verify that they are not
making an award or subaward with parties that have been debarred, suspended or excluded
from participation in Federal assistance programs or activities?
If the Recipient serves as a pass-through entity, how are requirements for certification and
representation submissions determined?
With what frequency does the Recipient access the System of Award Management (SAM)
through the “recipient integrity and performance portal” and review comments about itself
and ensure it is current, accurate and complete?
What internal interactions do the Major Facility stakeholders have with the Recipient on
performance goals, indicators, and milestones contained in its awards to present cohesive
picture?
What mechanisms does the Recipient have in place to monitor the NSF award, websites,
publications, and policy issuances to keep current? What is the process for distributing the
information on the award compliance issues within the Major Facility?
What level of participation does the Recipient have with the Federal Demonstration
Partnership and how does this impact its ability to leverage templates etc. for administrative
business activities?
Where would the Major Facility stakeholders find guidance on award-related information such
as deviations from the approved budget or project scope or objective, prior approvals, waivers,
incurrence of pre-award costs, one-time extension of period of performance, and carry
forwards?
Who is responsible for coordinating the prior approval submissions? Do they have the
delegated authority to submit these requests on behalf of the Recipient?
How does the Recipient keep track of report deadlines to ensure that all reports are submitted
in a timely manner?
What are the Recipient’s review and approval procedures for reports and other required
requests prior to submission to NSF?
How does the Recipient track the required posting (by the Federal Funding Accountability and
Transparency Act of 2006 [FFATA]) of its Federal awards, specifically the subaward activity and
executive compensation information?
Does the Recipient verify that the Major Facility’s internal financial management and other
systems are able to record compliance with the governing statutes, and terms and conditions
of the awards?
Does the Recipient have an automated alert that reminds stakeholders of impending deadlines
and deliverables due in relation to closeout? Examples include: submission no later than 90
calendar days after the end date of performance; all reports required by T/Cs, and liquidations
of obligations incurred under the Federal award no later than 90 days after the end date of the
period of performance.
Has the Recipient refunded any balance of unobligated and unapproved cash paid in advance,
and how was it accomplished?
How do the stakeholders involved in award management learn about funds returned to the
funding Agency?
Is the collection of amounts due handled in a special fashion by either the Recipient or the
Major Facility?

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APPENDIX A

A-2. AWARD MANAGEMENT REVIEW REFERENCES AND QUESTIONS

Award Management

Citation/Reference

PRINCIPLE 3. MANAGEMENT AND MONITORING OF SUBRECIPIENTS IS COMPLIANT AND
SUPPORTS THE MAJOR FACILITY.
Practice 3.1 Documented policies and procedures
specify the considerations for appropriately classifying
award agreements.
Practice 3.2 Documented policies and procedures
outline all information to be included such as the data
elements, requirements on use, support of financial
and performance reporting, approved indirect cost
rate, applicable flow-down requirements, record
access by auditors and closeout terms.
Practice 3.3 Documented policies and procedures
outline the steps and factors used to assess the risk of
noncompliance.
Practice 3.4 Documented policies and procedures
specify the monitoring and tools used to ensure award
is used for authorized purposes, accountability and
compliance with program requirements and
achievement of performance goals.
Practice 3.5 Documented policies and procedures
specify requirements for audits, the conditions
necessary to adjust pass-through entity’s records, and
enforcement actions for noncompliance.
Practice 3.6 Documented policies and procedures
explain the requirements and process to provide fixed
amount subawards.

• Uniform Guidance 2 CFR §200.330,
Subrecipient and contractor determinations
• Uniform Guidance 2 CFR §200.331,
Requirements for pass-through entities

• Uniform Guidance 2 CFR §200.331,
Requirements for pass-through entities
• Uniform Guidance 2 CFR §200.331,
Requirements for pass-through entities

• Uniform Guidance 2 CFR §200.331,
Requirements for pass-through entities
• Uniform Guidance 2 CFR §200.332,
Fixed amount subawards

QUESTIONS/FOCUS AREAS PRINCIPLE 3.
•
•
•
•
•
•
•
•
•
•

How much judgement are stakeholders permitted to use in classifying an agreement as a
subaward or procurement?
Who is responsible for alerting subrecipients that they must provide unique entity identifiers to
the Recipient?
In its capacity as a pass-through entity, how does the Recipient carry out the various
requirements with its subrecipients?
How do the Recipient and Major Facility stakeholders coordinate the assessment of risk of
noncompliance for potential subrecipients?
How does the Recipient learn about the timeliness/not submission of required reports
(monthly status, annual progress, or final technical)?
How are Major Facility stakeholders involved in the oversight and monitoring of subrecipients
Which of the tools available for monitoring, training and technical assistance, onsite reviews of
program operations, or procedures engagements, has the Recipient or Major Facility used in
monitoring or assessing risk?
Is there documentation that demonstrates that the subrecipient monitoring plan is being
implemented?
How does the Recipient verify when an audit is required?
Does the Recipient have any fixed amount subawards? How do these align with the published
conditions for them?

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APPENDIX A

A-2. AWARD MANAGEMENT REVIEW REFERENCES AND QUESTIONS

Award Management

Citation/Reference

PRINCIPLE 4. INTERNAL CONTROLS FOR AWARD MANAGEMENT ARE COMPLIANT AND
SUPPORT THE MAJOR FACILITY.
Practice 4.1 Documented policies and procedures
outline transaction-level actions and reporting to
assure compliance with Federal statutes, and the
terms and conditions of awards and other award
management responsibilities.
Practice 4.2 Documented policies and procedures
explain the evaluation and monitoring and timely
actions for instances of noncompliance.

• Uniform Guidance 2 CFR §200.303, Internal
Controls

• Uniform Guidance 2 CFR §200.303, Internal
Controls

QUESTIONS/FOCUS AREAS PRINCIPLE 4.
• How does the Recipient maintain an awareness of and get involved in taking action on
instances of noncompliance with the Major Facility?
• What local steps are taken by the Major Facility to evaluate and monitor the transaction-level
and reporting internal controls related to award terms and conditions?
• How is information technology used, either automated or manually implemented, to facilitate
the distribution of responsibilities between the Recipient and Major Facility?
• How does the Recipient and Major Facility use formal feedback from various stakeholder
entities (e.g., internal audit, funding agency reviews etc.) to understand possible systemic
problems?
• How does the Major Facility assure that the information used to monitor its awards is
accurate?
To return to the module review, click Award Management Review Module

BSR Guide, NSF FY21-XX

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APPENDIX A

A-3. BUDGET PLANNING AND EXECUTION REVIEW REFERENCES AND QUESTIONS

A-3. Budget Planning and Execution Principles and Practices
Citation/Reference
Budget Planning and Execution
PRINCIPLE 1. A COMPLIANT STRUCTURE OF BUDGET PLANNING AND EXECUTION FUNCTIONS
SUPPORTS THE MAJOR FACILITY.
Practice 1.1 Documented policies and procedures
clearly outline the organizational structure
responsible for budget planning and execution
including administration.
Practice 1.2 Documented policies and procedures
clearly define the collective positions in the budget
planning and execution organizational structure and
for each, the role, duties, authorities and reporting
lines.
Practice 1.3 Documented policies and procedures
ensure that staff with significant responsibilities in
budget planning and execution receive continuing
education and development opportunities to allow
them to successfully support the functions.

• COSO Control Environment Principle 3

• COSO Control Environment Principle 3

• COSO Control Environment Principle 4

QUESTIONS/FOCUS AREAS PRINCIPLE 1.
• How are the budget planning and execution functions distributed at each of the levels,
Recipient and Major Facility?
• Demonstrate through use of organization charts, or other related documents, the depiction of
the budget planning and execution functions at each of the levels, Recipient and Major Facility,
and how they support of the necessary functions, lines of authorities, and positions with
reporting lines.
• To what extent do individuals responsible for budget planning and execution have the
appropriate level of authority required to accomplish their duties?
• How clear are the responsibilities of the Major Facility’s PI, Project Manager (if construction),
and other key personnel in the documentation?
• Does the distribution of positions between the Recipient and Major Facility for this business
function provide for sufficient support?
• What tools are used to capture the position definitions and responsibilities?
• Does every position, including those in senior management, have a position description that
aligns with the position’s responsibilities associated with supporting the Major Facility rather
than the individual’s appointment type?
• How is the staff providing budget planning and execution support made aware of NSF
expectations and changes to the NSF award in relation to their specific duties and
responsibilities?
• What requirements or expectations do the Recipient or Major Facility have for continuing
training to support this administrative business function?
• If there are no requirements for continuing training for the administrative business function,
how do the staff stay up-to-date on Federal requirements?
• How do the requirements or expectations determine what action is taken if they are not met?

BSR Guide, NSF FY21-XX

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APPENDIX A

A-3. BUDGET PLANNING AND EXECUTION REVIEW REFERENCES AND QUESTIONS

Citation/Reference
Budget Planning and Execution
PRINCIPLE 2. A COMPLIANT SYSTEM EXISTS FOR DEVELOPING A BUDGET TO SUPPORT THE
MAJOR FACILITY’S VARIOUS LIFE-CYCLE STAGES.
Practice 2.1 Documented strategic planning policies
and procedures integrate and align process outputs
with the established scope, activities, objectives and
performance of the Major Facility (e.g., completed
templates, cost categories).
Practice 2.2 Documented policies and procedures
assure the reliability of the budget through the
identification and application of the appropriate
formulation methodology.
Practice 2.3 Documented policies and procedures
address the documentation, accuracy,
comprehensiveness and credibility of cost estimates.

• GAO Cost Estimating Guide
• LFM Section 4.2
• PAPPG Chapter II C2. g. Budget and Budget
Justification
• PAPPG Chapter II E 11. Research
Infrastructure Proposal
• Uniform Guidance 2 CFR §200.308
• MFG Section 4.2.1

• GAO Cost Estimating Guide
• MFG 4.2.2.6 OMB Inflators
• MFG 4.2.3 Additional Cost Estimating and
Analysis Guidance for Construction Awards
• MFG 4.2.4 Addition Cost Estimating and
Analysis for Operations Awards
Practice 2.4 Documented policies and procedures
• PAPPG Chapter II C2. g. Budget and Budget
specify the format, structure and supporting
Justification
justification for all related budget process products.
• MFG 4.2.2 Relevant Guidance and Reporting
Format
◦ 4.2.2.1 Cost Estimating Plan
◦ 4.2.2.2 NSF Budget Categories
◦ 4.2.2.4 Supplementary Guidance
◦ 4.2.2.5 Fee
◦ 4.2.2.7 Work Breakdown Structure
(WBS)
Practice 2.5 Documented policies and procedures
• Uniform Guidance 2 CFR §200.302, Financial
summarize the internal pre-submission reviews of the
management
Recipient’s and Subrecipient’s budget to assure
accuracy and compliance with Federal regulations and
requirements and needed refinement.

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APPENDIX A

A-3. BUDGET PLANNING AND EXECUTION REVIEW REFERENCES AND QUESTIONS

Budget Planning and Execution
QUESTIONS/FOCUS AREAS PRINCIPLE 2.

Citation/Reference

• What are the primary outputs in Major Facility’s budget process (e.g., refinement of goals,
completed templates, updates to historical cost records, identification of new initiatives with
cost estimates, descriptive narratives)?
• When in the budget process does the Major Facility verify that its budget aligns with the
published scope, activities and performance, and how is this alignment accomplished?
• When discrepancies are identified, how do they get resolved?
• How has the process incorporated the best practices within the GAO Cost Estimating and
Assessment Guide and GAO Schedule Assessment Guide incorporated into the Recipient’s and
Major Facility formulation activities?
• What kinds of procedural departures from the GAO Guides are permitted?
• What kind of budgeting method is used by the Major Facility, and how does this assure the
reliability of the budget?
◦ Incremental budgeting
◦ Activity-based budgeting
◦ Value proposition budgeting
◦ Zero-based budgeting
• What steps are taken to assure that the formulation methodology is applied in a consistent
manner?
• Do the procedures encourage the inclusion of resources to provide a continuing program of
advanced research and development (R&D)?
• What kind of systematic data and information gathering, including the use of and access to
expert input, information technology systems, historical information, assumptions, and
uncertainties, is used?
• How does the Recipient’s structure reconcile initial estimate with independent estimates or
reviews?
• What steps are taken to protect against cost duplication and omissions?
• How has the Recipient incorporated the use of a Cost Estimating Plan, Cost Model Data Set,
Work Breakdown Structure (WBS) and WBS Dictionary, Basis of Estimate and supporting
information?
• Is the cost estimating plan informed by the budget information in the previously developed
project execution plan (PEP)?
• How are the Recipient entities (central administration) involved in the review process?
• How does the process assure for the timely correction of errors?
• How and who was involved in the development of the Segregation of Funding Plan?

PRINCIPLE 3. A COMPLIANT SYSTEM EXISTS TO EXECUTE THE APPROVED BUDGET
SUPPORTING THE MAJOR FACILITY’S VARIOUS LIFE-CYCLE STAGES.
Practice 3.1 Documented policies and procedures
• Uniform Guidance 2 CFR §200.302, Financial
require the tracking and reporting of expenditures
management
against each approved award budget including the
identification and implementation of revisions.
Practice 3.2 Documented policies and procedures
• Uniform Guidance 2 CFR §200.308, Revision
address deviations from the budget and the
of budget and program plans
conditions for obtaining prior approval.
Practice 3.3 Documented policies and procedures
• Uniform Guidance 2 CFR §200.301,
ensure that routinely scheduled and relevant reports
Performance measurement
(budget and financial) are produced and used by the
Major Facility and Recipient-level stakeholders such as
management, program, and budget personnel.

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APPENDIX A

A-3. BUDGET PLANNING AND EXECUTION REVIEW REFERENCES AND QUESTIONS

Budget Planning and Execution

Citation/Reference

Practice 3.4 Documented policies and procedures
• Uniform Guidance 2 CFR §200.302, Financial
specify the evaluation of approved budget and actions management
taken on variances identified throughout (beginning
to end) the annual award budget period.

QUESTIONS/FOCUS AREAS PRINCIPLE 3.
• What are the primary (automated or manual) tools used to track and report expenditures?
• How quickly could the Major Facility identify a problem with an expenditure and correct it?
• When revisions to the budget are needed for the Major Facility, how do they get initiated and
who are the stakeholders that get involved in the process?
• How does the Major Facility address Recipient or NSF requirements for prior approval?
• How does the Major Facility address GAO requirements for use of schedule monitoring?
• How do the procedures address the approval differences in requirements related to
construction and non-construction awards?
• How have the differences in prior approval conditions for construction and operations budgets
been captured?
• Which of the stakeholders are involved in the production and use of budget and financial
reports, what kinds of roles do they play, and how is the overall process supervised?
• How are the reports on the budget integrated with the Recipient’s financial system?
• How are out-years handled in the process?
• How is the Segregation of Funding Plan incorporated into execution of the Major Facility
budget?

PRINCIPLE 4. INTERNAL CONTROLS FOR BUDGET PLANNING AND EXECUTION ARE
COMPLIANT AND SUPPORT THE MAJOR FACILITY.
Practice 4.1 Documented policies and procedures
outline transaction-level actions and reporting to
assure compliance with Federal statutes, and the
terms and conditions of awards and other budget
planning and execution responsibilities.
Practice 4.2 Documented policies and procedures
explain the evaluation and monitoring and timely
actions for instances of non-compliance.

• Uniform Guidance 2 CFR §200.303, Internal
Controls

• Uniform Guidance 2 CFR §200.303, Internal
Controls

QUESTIONS/FOCUS AREAS PRINCIPLE 4.
• How does the Recipient maintain an awareness of and get involved in taking action on
instances of noncompliance with the Major Facility?
• What local steps are taken by the Major Facility to evaluate and monitor the transaction-level
and reporting internal controls related to award terms and conditions?
• How is information technology used, either automated or manually implemented, to facilitate
the distribution of responsibilities between the Recipient and Major Facility?
• How do the Recipient and Major Facility use formal feedback from various stakeholder entities
(e.g., internal audit, funding agency reviews etc.) to understand possible systemic problems?
• How does the Major Facility assure that the information used to monitor its awards is
accurate?
To return to the module review, click Budget Planning and Execution Review Module.

BSR Guide, NSF FY21-XX

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APPENDIX A

A-4. FINANCIAL MANAGEMENT REVIEW REFERENCES AND QUESTIONS

A-4. Financial Management Principles and Practices
Citation/Reference
Financial Management
PRINCIPLE 1. A COMPLIANT STRUCTURE OF FINANCIAL MANAGEMENT FUNCTIONS
SUPPORTS THE MAJOR FACILITY.
Practice 1.1 Documented policies and procedures
clearly outline the organizational structure
responsible for financial management.
Practice 1.2 Documented policies and procedures
clearly define the collective positions in the financial
management organizational structure and for each,
the role, duties, authorities and reporting lines.
Practice 1.3 Documented policies and procedures
ensure that staff with significant responsibilities in
financial management receive continuing education
and development opportunities to allow them to
successfully support the functions.

• COSO Control Environment Principle 3
• COSO Control Environment Principle 3

• COSO Control Environment Principle 4

QUESTIONS/FOCUS AREAS PRINCIPLE 1.
• How are the financial management functions distributed at each of the levels, Recipient and
Major Facility?
• Demonstrate through use of organization charts, or other related documents, the depiction of
the financial management functions at each of the levels Recipient and Major Facility and how
they support of the necessary functions, lines of authorities, and positions with reporting lines.
• To what extent do individuals responsible for financial management have the appropriate level
of authority required to accomplish their duties?
• How clear are the responsibilities of the Major Facility’s PI, Project Manager (if construction),
and other key personnel in the documentation?
• Does the distribution of positions between the Recipient and Major Facility for this business
function provide for sufficient support?
• How are the financial management responsibilities (e.g., accounts payable and cash
disbursement) segregated from the entity requesting and receiving the item/service?
• What tools are used to capture the position definitions and responsibilities?
• Does every position, including those in senior management have a position description that
aligns with the position’s responsibilities associated with supporting the Major Facility rather
than the individual’s appointment type?
• How is the staff providing financial management support made aware of NSF expectations and
changes to the NSF award in relation to their specific duties and responsibilities?
• What requirements or expectations do the Recipient or Major Facility have for continuing
training to support this administrative business function?
• If there are no requirements for continuing training for the administrative business function,
how do the staff stay up-to-date on Federal requirements?
• How do the requirements or expectations determine what action is taken if they are not met?

PRINCIPLE 2. A COMPLIANT FINANCIAL MANAGEMENT SYSTEM SUPPORTS THE MAJOR
FACILITY.
Practice 2.1 Documented policies and procedures
address the generation of required reports and
specify the use of detailed information related to the
award.

BSR Guide, NSF FY21-XX

• Uniform Guidance 2 CFR §200.301,
Performance measurement
• Uniform Guidance 2 CFR §200.302, Financial
Management
• FAR Part 31

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APPENDIX A

A-4. FINANCIAL MANAGEMENT REVIEW REFERENCES AND QUESTIONS

Financial Management

Citation/Reference

Practice 2.2 Documented policies and procedures
specify the identification components of Federal
awards received and expended, and the related
Federal Programs under which they were received.
Practice 2.3 Documented policies and procedures
specify how accurate, current and complete reporting
of the results of the Federal award or Program is
generated.
Practice 2.4 Documented policies and procedures
require that records identify the source and
application of funds for Federally-funded activities
through the specified information fields.
Practice 2.5 Documented policies and procedures
implement the required payment methods.
Practice 2.6 Documented policies and procedures
explain how the allowability of cost is determined and
reviewed.

• Uniform Guidance 2 CFR §200.302, Financial
Management
• Uniform Guidance 2 CFR §200.302, Financial
Management
• Uniform Guidance 2 CFR §200.302, Financial
Management
• Uniform Guidance 2 CFR §200.305, Payment
• Uniform Guidance 2 CFR §200.302, Financial
Management

QUESTIONS/FOCUS AREAS PRINCIPLE 2.
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•

Does the Major Facility in construction have a cost segregation plan and have they followed it?
If the Major Facility is not under construction, how does the Recipient assure that funds are
segregated per the terms/conditions of the award.
How does the accounting or other information technology system handle the generation of
reports?
How does the process with the information technology systems support the tracing of funds at
the expenditure level and demonstrate that funds have been used according to Federal
requirements?
Where are the relevant data fields outlined and defined for users? (Federal program, Federal
award identification, the CFDA title and number, Federal award identification number and year,
name of the Federal agency, and name of the pass-through entity, if any).
How does the Recipient/Subrecipient obtain and verify the accuracy and completeness of the
financial results of the Federal awards?
How does the Recipient/Subrecipient use documentation on-hand and develop accrual data (if
required by Federal requirement) if it doesn’t maintain its records on an “other than accrual
basis”?
How do users learn about the required information related to Federal award authorizations,
obligations, unobligated balances, assets and expenditures?
How does the Recipient comply with the requirement that time be minimized between transfer
from Federal entity and disbursement to non-Federal entity?
How does the Major Facility determine its cash needs?
What kinds of manual and electronic tools are used in the process of determining cash needs
for the Major Facility?
Does the Recipient operate on an advanced or reimbursement basis?
If the Recipient operates on an advanced basis, what kind of bank account does the Recipient
and/or Major Facility have?
When, and how do stakeholders verify that the allowability of costs is in alignment with the
Cost Principles in the Uniform Guidance or other applicable guidance?
What key internal controls are in place to assure accountability and safeguard funds?

BSR Guide, NSF FY21-XX

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APPENDIX A

A-4. FINANCIAL MANAGEMENT REVIEW REFERENCES AND QUESTIONS

Citation/Reference
Financial Management
PRINCIPLE 3. A COMPLIANT SYSTEM TO CASH MANAGEMENT SUPPORTS THE MAJOR
FACILITY.
Practice 3.1 Documented policies and procedures
discuss the handling of advance payments or
reimbursement requests from the Recipient.
Practice 3.2 Documented policies and procedures
discuss program income and the related reporting
requirements.

Practice 3.3 Responsibilities for access and
permissions to the financial functions of the award
cash management service (ACM$) are controlled and
segregated.

• Uniform Guidance 2 CFR §200.305, Payment
• PAPPG VIII. Financial Requirements and
Payments
• Uniform Guidance 2 CFR §200.80,
Program Income
• Uniform Guidance 2 CFR §200.307, Program
Income
• PAPPG, VIII. Financial Requirements
• PAPPG, VIII. Financial Requirements

QUESTIONS/FOCUS AREAS PRINCIPLE 3.
• How are the amounts on the Federal Financial Report linked to the Recipient’s general ledger?
• Do the documented policies and procedures align with the payment type of the Recipient
(working capital advanced or reimbursement) basis?
• How are payments submitted for all NSF awards supporting the Major Facility?
• How does the Recipient manage transactions in the Award Cash Management Service?
• How frequently does the Recipient request payment?
• How does the Recipient minimize the time elapsing between the transfer of funds and
disbursement by the Recipient?
• How are the immediate cash needs of the Major Facility determined and timed?
• What steps are taken to assure timely payment to contractors, and how is this integrated with
the timing of cash needs?
• When and how was the last evaluation done to assess the current process to request cash?
• How do the procedures assure that the program income is expended in accordance with NSF
standard policy or other approach if specified in the award?
• How does the Recipient determine and manage permissions to key information technology
systems such as FastLane or Research.gov?
• Given the likely multitude of information technology systems in research administration, how
does the Recipient assure that segregation of duties is maintained?
• When is the last time that an evaluation of permissions, for segregation of duties, alignment
with roles etc., was conducted?

PRINCIPLE 4. INTERNAL CONTROLS FOR FINANCIAL MANAGEMENT ARE COMPLIANT AND
SUPPORT THE MAJOR FACILITY.
Practice 4.1 Documented policies and procedures
• Uniform Guidance 2 CFR §200.303, Internal
outline transaction-level actions and reporting to
Controls
assure compliance with Federal statutes, and the
terms and conditions of awards and other financial
management responsibilities.
Practice 4.2 Documented policies and procedures
• Uniform Guidance 2 CFR §200.303, Internal
explain the evaluation and monitoring and timely
Controls
actions for instances of non-compliance requirements
are defined and documented.

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APPENDIX A

A-4. FINANCIAL MANAGEMENT REVIEW REFERENCES AND QUESTIONS

Financial Management
QUESTIONS/FOCUS AREAS PRINCIPLE 4.

Citation/Reference

• How does the Recipient maintain an awareness of and get involved in taking action on
instances of noncompliance with the Major Facility?
• What local steps are taken by the Major Facility to evaluate and monitor the transaction-level
and reporting internal controls related to award terms and conditions?
• How is information technology used, either automated or manually implemented, to facilitate
the distribution of responsibilities between the Recipient and Major Facility?
• How do the Recipient and Major Facility use formal feedback from various stakeholder entities
(e.g., internal audit, funding agency reviews etc.) to understand possible systemic problems?
• How does the Major Facility assure that the information used to monitor its awards is
accurate?
To return to the module review, click Financial Management Review Module.

BSR Guide, NSF FY21-XX

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APPENDIX A

A-5. HUMAN RESOURCES MANAGEMENT REVIEW REFERENCES AND QUESTIONS

A-5. Human Resources Management Principles and Practices
Citation/Reference
Human Resources Management
PRINCIPLE 1. A COMPLIANT SYSTEM TO SUPPORT HUMAN RESOURCES MANAGEMENT
FUNCTIONS SUPPORTS THE MAJOR FACILITY.
Practice 1.1 Documented policies and procedures
clearly outline the organizational structure
responsible for human resources management.
Practice 1.2 Documented policies and procedures
clearly define the collective positions in the human
resources management organizational structure and
for each, the role, duties, authorities and reporting
lines.
Practice 1.3 Documented policies and procedures
ensure that staff with significant responsibilities in
human resources management receive continuing
education and development opportunities to allow
them to successfully support the functions.

• COSO Control Environment Principle 3
• COSO Control Environment Principle 3

• COSO Control Environment Principle 4

QUESTIONS/FOCUS AREAS PRINCIPLE 1.
• How are the human resources management functions distributed at each of the levels,
Recipient and Major Facility?
• Demonstrate through use of organization charts, or other related documents, the depiction of
the human resources management functions at each of the levels, Recipient and Major Facility,
and how they support of the necessary functions, lines of authorities, and positions with
reporting lines.
• To what extent do individuals responsible for human resources management have the
appropriate level of authority required to accomplish their duties?
• How clear are the responsibilities of the Major Facility’s PI, Project Manager (if construction),
and other key personnel in the documentation?
• Does the distribution of positions between the Recipient and Major Facility for this business
function provide for sufficient support?
• What tools are used to capture the position definitions and responsibilities?
• Does every position, including those in senior management have a position description that
aligns with the position’s responsibilities associated with supporting the Major Facility rather
than the individual’s appointment type?
• How is the staff providing human resources management support made aware of NSF
expectations and changes to the NSF award in relation to their specific duties and
responsibilities?
• What requirements or expectations do the Recipient or Major Facility have for continuing
training to support this administrative business function?
• If there are no requirements for continuing training for the administrative business function,
how do the staff stay up-to-date on Federal requirements?
• How do the requirements or expectations determine what action is taken if they are not met?

PRINCIPLE 2. COMPLIANT MECHANISMS ENSURE THAT NO PERSON IS DISCRIMINATED
AGAINST BASED ON RACE, COLOR, NATIONAL ORIGIN, SEX, OR DISABILITY SUPPORT THE
MAJOR FACILITY.
Practice 2.1 Documented policies and procedures
ensure applicants and employees are aware of the
Recipient’s non-discrimination policies and practices.

BSR Guide, NSF FY21-XX

• PAPPG Chapter II, C – proposal contents, d
Certifications
• PAPPG Chapter XI, Other Post Award
Requirements and Considerations
A. Non-Discrimination

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APPENDIX A

A-5. HUMAN RESOURCES MANAGEMENT REVIEW REFERENCES AND QUESTIONS

Human Resources Management
Practice 2.2 Documented policies and procedures
train selection officials and managers in their
responsibilities in complying with non-discrimination
policies and practices.
Practice 2.3 Documented policies and procedures
specify and assure compliance with specific nondiscrimination practices as described in relevant
Federal regulations (e.g., making reasonable
accommodations for people with disabilities,
instituting policies and practices to resolve
discrimination complaints).

Citation/Reference
• PAPPG Chapter II, C – proposal contents, d
Certifications
• PAPPG Chapter XI, Other Post Award
Requirements and Considerations
A. Non-Discrimination
• PAPPG Chapter II, C – proposal contents, d
Certifications
• PAPPG Chapter XI, Other Post Award
Requirements and Considerations
A. Non-Discrimination

QUESTIONS/FOCUS AREAS PRINCIPLE 2.
•
•
•
•
•
•
•

What are the routine activities that the Major Facility takes to assure that applicants and
employees are well informed about non-discrimination policies and procedures?
How does the Major Facility receive updates on new requirements such as the new NSF term
and agreement on sexual harassment?
What kind of training do officials and managers receive on non-discrimination?
Of the training provided, which items are mandatory and for whom at the Major Facility?
Where do employees and applicants learn about non-discrimination policies and procedures?
How does the Recipient assure that the Major Facility is compliance with the nondiscrimination requirements?
What kinds of Recipient resources are available to assist with Major Facility locations are that
are “off-campus” or located away from the prime location?

PRINCIPLE 3. A COMPLIANT DRUG-FREE WORKPLACE SUPPORTS THE MAJOR FACILITY.
Practice 3.1 Documented policies and procedures
• PAPPG, Exhibit II-3 Drug-Free Workplace
provide each employee engaged in the performance
Certification
of the award, a published statement notifying
employees of the requirements of the Recipient’s
policies and processes regarding a drug-free
workplace.
Practice 3.2 Documented policies and procedures
• PAPPG, Exhibit II-3 Drug-Free Workplace
outlined the response to violations of the drug-free
Certification
workplace policy.
Practice 3.3 Documented policies and procedures
• PAPPG, Exhibit II-3 Drug-Free Workplace
specify the ongoing drug-free awareness program that Certification
addresses key elements outlined in drug-free
workplace certification.

QUESTIONS/FOCUS AREAS PRINCIPLE 3.
• When and how routinely do employees receive the published information on drug-free
workplace requirements?
• How does the Major Facility track the notifications given to employees?
• What steps are taken if individuals violate the drug-free workplace policy?
• What challenges does the Major Facility see with the current drug-free policies and how they
are implemented by the Recipient?
• How does the Major Facility integrate the awareness Program into its operations?
• How often does the Recipient update its drug-free workplace program?
• How do stakeholders provide input into the drug-free awareness program?

BSR Guide, NSF FY21-XX

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APPENDIX A

A-5. HUMAN RESOURCES MANAGEMENT REVIEW REFERENCES AND QUESTIONS

Citation/Reference
Human Resources Management
PRINCIPLE 4. A COMPLIANT SYSTEM FOR WORKFORCE PLANNING SUPPORTS THE MAJOR
FACILITY.
Practice 4.1 Documented policies and procedures set
the strategic direction by linking the workforce
planning process with the entity’s strategic plan,
annual performance/business plan, and work
activities required to carry out the goals and
objectives of the strategic plan (long term) and
performance plan (short term).
Practice 4.2 Documented policies and procedures
address a workforce planning mechanism to analyze
the current and future workforce supply and
determine the gaps and surpluses in achieving the
desired future state, based on an agile, balanced and
capable mission-ready workforce in the necessary
geographic locations to accomplish the entity’s
strategic requirements.
Practice 4.3 Documented policies and procedures
address the process to prioritize gaps and surpluses
and develop an action plan with strategies and
measurable outcomes to assess progress in support of
the Major Facility needs.
Practice 4.4 Documented policies and procures
address a monitoring and evaluation process to assess
the effectiveness of the strategies and revisions of the
plan, as needed.

BSR Guide, NSF FY21-XX

• COSO Control Environment Principle 4

• COSO Control Environment Principle 4

• COSO Control Environment Principle 4

• COSO Control Environment Principle 4

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APPENDIX A

A-5. HUMAN RESOURCES MANAGEMENT REVIEW REFERENCES AND QUESTIONS

Human Resources Management
QUESTIONS/FOCUS AREAS PRINCIPLE 4.

Citation/Reference

• How does the Major Facility coordinate its strategic planning processes with its workforce
planning?
• Where in the process does the Recipient provide expert input to the Major Facility on
workforce planning?
• How frequently does the Major Facility assess its workforce?
• What challenges has the Major Facility experienced with its current workforce planning
process?
• How does the Recipient get involved the Major Facility’s workforce planning?
• What kinds of centralized Recipient resources are available to facilitate the Major Facility’s
workforce planning?
• What expectations does the Recipient have for the Major Facility to conduct workforce
planning, and how are they enforced?
• What ongoing evaluations does the Major Facility conduct to understand the gaps and
surpluses in its workforce?
• How does the Major Facility engage the Recipient in analyzing its workforce demands?
• How does the Major Facility prioritize its staffing needs?
• When was the last action plan development for workforce planning and how was the progress
assessed?
• Who is responsible for leading development and maintenance of the Major Facility’s succession
plan?
• How do the workforce planning activities inform the succession planning?
• What challenges does the Major Facility have with monitoring its workforce plan?
• How does the Recipient take the information from the Major Facility and incorporate into
broader plans?
• When is the last time and how has the Recipient and Major Facility worked together on a
monitoring and evaluation process?

PRINCIPLE 5. A COMPLIANT AND SYSTEMATIC MECHANISM FOR RECRUITMENT, HIRING,
AND EMPLOYMENT SUPPORTS THE MAJOR FACILITY.
Practice 5.1 Documented policies and procedure
guide the recruitment, hiring and employment
supporting the human capital needs of the Major
Facility.

• COSO Control Environment Principle 4

QUESTIONS/FOCUS AREAS PRINCIPLE 5.
• How does the Recipient convey its broad requirements for recruitment, hiring and employment
to the Major Facility?
• What kinds of challenges has the Major Facility experienced with the Recipient’s required
hiring and employment policies and procedures?
• What mechanisms does the Recipient have for addressing the Major Facility’s specialized
needs?

PRINCIPLE 6. A COMPLIANT MECHANISM FOR PERFORMANCE MANAGEMENT SUPPORTS
THE MAJOR FACILITY.
Practice 6.1 Documented policies and procedures
• COSO Control Environment Principle 5
address written performance goals, objectives and
metrics/expectations for the established performance
period.

BSR Guide, NSF FY21-XX

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APPENDIX A

A-5. HUMAN RESOURCES MANAGEMENT REVIEW REFERENCES AND QUESTIONS

Human Resources Management

Citation/Reference

Practice 6.2 Documented policies and procedures
• COSO Control Environment Principle 5
address the communication and action taken in
relation to the results of performance evaluations
reprisal.
Practice 6.3 Documented policies and procedures
• COSO Control Environment Principle 5
address the compensation practices including rewards
and the connection with the compensation
philosophy of the Recipient and market pricing
information.

QUESTIONS/FOCUS AREAS PRINCIPLE 6.
•
•
•
•
•
•
•

How does the Major Facility incorporate performance goals that align with the performance
management?
How is information cascaded through the Recipient and to the Major Facility staff?
What is the Major Facility’s compensation policy and general practices?
What steps does the Major Facility take to assure that compensation is applied fairly to all staff,
and is based on performance evaluation, competencies and skill acquisition, with the goal to
retain high performers and encourage the attrition of low performers?
What kinds of flexibility does the Recipient allow for the Major Facility to establish its own
compensation practices?
How are the Major Facility financial management and/or budget stakeholders brought into the
discussion and determination of compensation and providing key information such as market
pricing?
Does the Major Facility incorporate a discussion of compensation practices during budget
formulation?

PRINCIPLE 7. INTERNAL CONTROLS FOR HUMAN RESOURCES MANAGEMENT ARE
COMPLIANT AND SUPPORT THE MAJOR FACILITY.
Practice 7.1 Documented policies and procedures
• Uniform Guidance 2 CFR §200.303, Internal
outline transaction-level actions and reporting to
Controls
assure compliance with Federal statutes, and the
terms and conditions of awards and other human
resources management responsibilities (e.g.,
notification when changes in key personnel, reporting
of violations with drug-free workplace or sexual
harassment).
Practice 7.2 Documented policies and procedures
• Uniform Guidance 2 CFR §200.303, Internal
explain the evaluation and monitoring and timely
Controls
actions for instances of non-compliance.

QUESTIONS/FOCUS AREAS PRINCIPLE 7.
• How does the Recipient maintain an awareness of and get involved in taking action on
instances of noncompliance with the Major Facility?
• What local steps are taken by the Major Facility to evaluate and monitor the transaction-level
and reporting internal controls related to award terms and conditions?
• How is information technology used, either automated or manually implemented, to facilitate
the distribution of responsibilities between the Recipient and Major Facility?
• How do the Recipient and Major Facility use formal feedback from various stakeholder entities
(e.g., internal audit, funding agency reviews etc.) to understand possible systemic problems?
• How does the Major Facility assure that the information used to monitor its awards is
accurate?
To return to the module review, click Human Resources Management Review Module.

BSR Guide, NSF FY21-XX

Page 70 of 86

APPENDIX A

A-6. PROCUREMENT REVIEW REFERENCES AND QUESTIONS

A-6. Procurement Principles and Practices
Citation/Reference
Procurement
PRINCIPLE 1. A COMPLIANT STRUCTURE OF PROCUREMENT FUNCTIONS SUPPORTS THE
MAJOR FACILITY.
Practice 1.1 Documented policies and procedures clearly outline the
organizational structure responsible for procurement.

• COSO Control Environment
Principle 3

Practice 1.2 Documented policies and procedures clearly define the
collective positions in the procurement organizational structure and
for each, the role, duties, authorities and reporting lines.

• COSO Control Environment
Principle 3

Practice 1.3 Documented policies and procedures ensure that staff
with significant responsibilities in procurement receive continuing
education and development opportunities to allow them to
successfully support the functions.

• COSO Control Environment
Principle 4

QUESTIONS/FOCUS AREAS PRINCIPLE 1.
• How are the procurement functions distributed at each of the levels, Recipient and Major
Facility?
• Demonstrate through use of organization charts, or other related documents, the depiction of
the procurement functions at each of the levels, Recipient and Major Facility, and how they
support of the necessary functions, lines of authorities, and positions with reporting lines.
• To what extent do individuals responsible for procurement have the appropriate level of
authority required to accomplish their duties?
• How are procurement responsibilities segregated from the entity requesting and receiving the
item/service and from the entity with financial management responsibilities (e.g., accounts
payable and cash disbursement)?
• How clear are the responsibilities of the Major Facility’s PI, Project Manager (if construction),
and other key personnel in the documentation?
• Does the distribution of positions between the Recipient and Major Facility for this business
function provide for sufficient support?
• What tools are used to capture the position definitions and responsibilities?
• How do the position descriptions and related information for this function align with the
requirements related to approval thresholds and related delegations of authority?
• How do the technologies enforce roles and responsibilities specific to procurement, such as
delegated authorities, approval thresholds, etc.?
• Does every position, including those in senior management have a position description that
aligns with the position’s responsibilities associated with supporting the Major Facility rather
than the individual’s appointment type?
• How is the staff providing procurement support made aware of NSF expectations and changes
to the NSF award in relation to their specific duties and responsibilities?
• What requirements or expectations do the Recipient or Major Facility have for continuing
training to support this administrative business function?
• If there are no requirements for continuing training for the administrative business function,
how do the staff stay up-to-date on Federal requirements?
• How do the requirements or expectations determine what action is taken if they are not met?

BSR Guide, NSF FY21-XX

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APPENDIX A

A-6. PROCUREMENT REVIEW REFERENCES AND QUESTIONS

Citation/Reference
Procurement
PRINCIPLE 2. GENERAL STANDARDS FOR PROCUREMENT ACTIONS SUPPORTING THE MAJOR
FACILITY ARE COMPLIANT.
Practice 2.1 Documented policies and procedures address the use of • Uniform Guidance 2 CFR
local procurement procedures and reviews to assure compliance with §200.318 General
governing regulations.
Procurement standards
Practice 2.2 Documented policies and procedures specify oversight of • Uniform Guidance 2 CFR
contractors’ performance.
§200.318, General
Procurement Standards
Practice 2.3 Documented policies and procedures outline the
• Uniform Guidance 2 CFR
standards of conduct for employees who are engaged in the
§200.318, General
selection, award and administration of contracts, and Organizational
Procurement Standards
conflicts of interest if applicable, and the disciplinary actions for
violations of standards.
Practice 2.4 Documented policies and procedures address steps to
• Uniform Guidance 2 CFR
avoid unnecessary purchases or duplicative items, and appropriate
§200.318, General
analysis to determine the most economical approach.
Procurement Standards
Practice 2.5 Documented policies and procedures promote greater
• Uniform Guidance 2 CFR
economy and efficiency through use of shared goods and services,
§200.318, General
use of Federal excess and surplus property, and value engineering
Procurement Standards
clauses construction contracts.
Practice 2.6 Documented policies and procedures address the
• Uniform Guidance 2 CFR
considerations for determining responsible contractors.
§200.318, General
Procurement Standards
Practice 2.7 Documented policies and procedures require the
• Uniform Guidance 2 CFR
maintenance of records with details required to show the
§200.318, General
procurement history.
Procurement Standards
Practice 2.8 Documented policies and procedures specify conditions • Uniform Guidance 2 CFR
for use of time and materials contract types.
§200.318, General
Procurement Standards
Practice 2.9 Documented policies and procedures require settlement • Uniform Guidance 2 CFR
of all contractual and administrative issues arising out of
§200.318, General
procurements.
Procurement Standards

BSR Guide, NSF FY21-XX

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APPENDIX A

A-6. PROCUREMENT REVIEW REFERENCES AND QUESTIONS

Procurement
QUESTIONS/FOCUS AREAS PRINCIPLE 2.

Citation/Reference

• What steps are taken and how frequently does the Recipient assess the compliance and
alignment of its local procurement procedures?
• How are contractors overseen to assure compliance with terms and conditions of contracts or
purchase orders?
• How does the Recipient assure that the necessary stakeholders receive, review and understand
the standards of conduct applicable for the Recipient?
• With what kind of frequency are the assurance checks conducted?
• In addition to lease versus purchase alternatives, what other types of analyses are available for
stakeholders to consider using?
• What guidance is provided to assist the individual in determining the best approach?
• Does the Recipient have a broad strategy for employing the economic and efficiency measures
such as local intergovernmental or inter-entity agreements or value engineering clauses?
• How is an assessment done to assure that economic and efficient measures are being taken?
• How are integrity, compliance with public policy, past performance records, and financial and
technical resources considered when selecting contractors?
• How does the Recipient assure that the contractor has not been debarred, suspended or
excluded from or is ineligible for participation?
• What checks are conducted to assure that procurement records contain information on the
rationale for the method of procurement, selection of contract type, contractor selection or
rejection and the basis for the contract price?
• What kind of assessment is done to evaluate the suitability of a time and materials type
contract and check for the inclusion of a ceiling price?
• How does the degree of oversight differ for these in comparison to other types of contracts?
• What is the guidance on issues such as source evaluation, protests, disputes, claims and other
issues?

PRINCIPLE 3. COMPLIANT PROCUREMENTS PROVIDE FULL AND OPEN COMPETITION TO
SUPPORT THE MAJOR FACILITY.
Practice 3.1 Documented policies and procedures ensure objective
contractor performance and eliminate unfair competitive advantage.
Practice 3.2 Documented policies and procedures specify the
prohibition of statutorily or administratively imposed state, local, or
tribal geographical preferences in the evaluation of bids or proposals,
except where mandated.
Practice 3.3 Documented policies and procedures transactions ensure
that all solicitations incorporate a description of technical
requirements for the material, product or service to be procured, and
identify all requirements which offerors must fulfill and all other
factors used in evaluating bids or proposals.
Practice 3.4 Documented policies and procedures ensure that the
prequalified lists of persons, firms or products acquiring goods and
services are current, include enough qualified sources to ensure
maximum open and free competition, and do not preclude the
qualification of potential bidders.

BSR Guide, NSF FY21-XX

• Uniform Guidance 2 CFR
§200.319, Competition
• Uniform Guidance 2 CFR
§200.319, Competition
• Uniform Guidance 2 CFR
§200.319, Competition

• Uniform Guidance 2 CFR
§200.319, Competition

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APPENDIX A

A-6. PROCUREMENT REVIEW REFERENCES AND QUESTIONS

Procurement
QUESTIONS/FOCUS AREAS PRINCIPLE 3.

Citation/Reference

• When a competition-restrictive situation, such as: unreasonable requirements on firms,
requiring unnecessary experience and excessive bonding, noncompetitive pricing practices
between firms, noncompetitive contractors to consultants on retainer contracts,
organizational conflicts, specifying brand-name products, or arbitrary actions in procurement
process is identified, what steps are taken to exclude the contractors?
• Does the Recipient have any instances of administratively imposed state, local or tribal
geographical preferences, and how is the Major Facility made aware of these?
• How frequently does the Recipient’s policy/procedures get updated?
• What drives updates by the Recipient?
• Have there been instances of the Major Facility identifying additional requirements that the
Recipient was not aware of, and if so, how are these handled?
• What checks are conducted to assure that the description of technical requirements does not
unduly restrict competition?
• What guidance is given to develop factors for evaluating bids or proposals?
• What steps does the Recipient take to assure that the prequalified list of persons, firms or
products is current?
• How frequently is the prequalified list updated?
• How does the Major Facility assure that its stakeholders are aware of and trained on the
requirements associated with application of prequalified list in procurements?
• What routine evaluations are done to assess the use of small and minority businesses,
women’s business enterprises, and labor surplus area firms?

PRINCIPLE 4. COMPLIANT PROCUREMENTS SUPPORTING THE MAJOR FACILITY FOLLOW ONE
OF THE SPECIFIED METHODS.
Practice 4.1 Documented policies and procedures for micropurchases cover the acquisition of supplies or services which do not
exceed the published threshold and contain strategy for equitable
distribution strategy among qualified suppliers.
Practice 4.2 Documented policies and procedures for small purchases
address the requirements around securing of services, supplies or
other property not costing more than the published acquisition
threshold.
Practice 4.3 Documented policies and procedures for sealed bids
specify the conditions for use, the award type and requirements of
responsible bidders and bids.
Practice 4.4 Documented policies and procedures for competitive
proposals address the conditions for use and applicable requirements
of proposals, technical evaluations, award selection and application
to architectural/engineering professional services.
Practice 4.5 Documented policies and procedures for noncompetitive
proposals should address the required circumstances for use.

BSR Guide, NSF FY21-XX

• Uniform Guidance 2 CFR
§200.320, Methods of
procurement to be followed
• Uniform Guidance 2 CFR
§200.320, Methods of
procurement to be followed
• Uniform Guidance 2 CFR
§200.320, Methods of
procurement to be followed
• Uniform Guidance 2 CFR
§200.320, Methods of
procurement to be followed
• Uniform Guidance 2 CFR
§200.320, Methods of
procurement to be followed

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APPENDIX A

A-6. PROCUREMENT REVIEW REFERENCES AND QUESTIONS

Procurement
QUESTIONS/FOCUS AREAS PRINCIPLE 4.
•
•
•

•
•
•
•

Citation/Reference

In situations where competitive quotations are not solicited, how is price reasonableness
evaluated?
When obtaining price or rate quotations, how many qualified sources are required?
What resources are used to check that conditions (following) are met: Availability of complete,
adequate, and realistic specification or purchase description; two or more willing and
responsible bidders to compete effectively; procurement that lends itself to a firm fixed price
contract; and selection that can be made principally on the basis of price?
How are the collective sealed bid requirements met?
How does the Recipient determine that an adequate number of qualified sources has been
received in response to the publicized request for proposals?
What role do Major Facility stakeholders have in the technical evaluations?
How do stakeholders verify that the required circumstances (following) are met: Available
from only a single source; public exigency or emergency for requirement will not permit a
delay; written request and permissions are granted from Federal awarding agency or passthrough entity; and inadequate competition after solicitation of sources.

PRINCIPLE 5. COMPLIANT CONTRACTING ACTIVITIES ASSURE THE USE OF SMALL AND
MINORITY BUSINESSES, WOMEN’S BUSINESS ENTERPRISES, AND LABOR SURPLUS AREA
FIRMS TO SUPPORT THE MAJOR FACILITY.
Practice 5.1 Documented policies and procedures address the
• Uniform Guidance 2 CFR
affirmative steps that must be taken to assure that diverse resources
§200.321, Contracting with
for procuring and acquiring goods and services are sought.
small and minority business,
women’s business
enterprises, and labor
surplus area firms

QUESTIONS/FOCUS AREAS PRINCIPLE 5.
•
•
•
•

How do the Recipient or Major Facility stakeholders determine the correct contract provisions?
What is the Recipient’s requirement on bonding?
How does the Major Facility make its staff aware of the Recipient’s bonding requirements?
What training is required for staff who work with construction or Major Facility improvement
contracts/subcontracts, and is bonding addressed?

PRINCIPLE 6. COMPLIANT FLOW-DOWN PROVISIONS AND FUNDING ENTITY-SPECIFIC
AWARD TERMS AND CONDITIONS ARE USED IN CONTRACTS TO SUPPORT THE MAJOR
FACILITY.
Practice 6.1 Documented policies and procedures address
procurement of items in compliance with the Solid Waste Disposal
Act.

• Uniform Guidance 2 CFR
§200.322, Procurement of
recovered materials

Practice 6.2 Documented policies and procedures address the
inclusion of applicable provisions in contracts.

• Uniform Guidance 2 CFR
§200.323, Contract cost and
price

Practice 6.3 Documented policies and procedures address bonding
requirements, including award flow-down provisions, for
construction or facility improvement contracts or subcontracts
exceeding the simplified acquisition threshold.

• Uniform Guidance 2 CFR
§200.323, Contract cost and
price

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APPENDIX A

A-6. PROCUREMENT REVIEW REFERENCES AND QUESTIONS

Procurement
QUESTIONS/FOCUS AREAS PRINCIPLE 6.

Citation/Reference

• What checklists or tools are used to verify that procured items which meet specified
requirements align with the guidelines of the EPA?
• What analyses are used for procurements in excess of the simplified acquisition threshold?
• How are the considerations (following) incorporated into negations: Work complexity; Risk by
contractor; Contractor’s investment; Subcontracting amount; Record of past performance; and
industry profit rates in surrounding areas?
• What tools do stakeholder have to assess the allowability of and use of estimated costs in
contracts?
• What checks are conducted by either the Recipient or Major Facility to assure that the
contracting methods (cost plus a percentage of cost, and percentage of construction costs) are
not used?
• What guidance is given by the Recipient's requirements on bonding?
• How does the Major Facility correct mistakes regarding use of the Recipients bonding
requirements?
• What training is required for staff who work with construction or Major Facility improvement
contracts and is bonding addressed?

PRINCIPLE 7. COMPLIANT CONTRACT COSTS AND PRICES SUPPORT THE MAJOR FACILITY.
Practice 7.1 Documented policies and procedures address cost or
• Uniform Guidance 2 CFR
price analyses for procurements in excess of the simplified acquisition §200.323, Contract cost and
threshold including contract modifications.
price
Practice 7.2 Documented policies and procedures address the
negotiation of profit for contracts in which there is no price
competition, and in all cases where cost analysis is performed.
Practice 7.3 Documented policies and procedures address the
allowability of using estimated costs for contracts.
Practice 7.4 Documented policies and procedures address the
exclusion of cost plus a percentage of cost and percentage of
construction costs contracting methods.

• Uniform Guidance 2 CFR
§200.324, Federal awarding
agency or pass-through
entity review
• Uniform Guidance 2 CFR
§200.323, Contract cost and
price
• Uniform Guidance 2 CFR
§200.324, Federal awarding
agency or pass-through
entity review

QUESTIONS/FOCUS AREAS PRINCIPLE 7.
•
•
•
•

What degree of analysis is used for procurements in excess of the simplified acquisition
threshold?
How are the considerations (following) incorporated into negotiations: work complexity, risk
by contractor, contractor’s investment, contracting amount, record of past performance, and
industry profit rates in surrounding areas?
What tools do stakeholders have to assess the allowability of and use of estimated cost in
contracts?
What checks are conducted by either the Recipient or Major Facility to assure that the
contracting methods are not used (i.e., cost plus a percentage of cost, and percentage of
construction costs)?

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APPENDIX A

A-6. PROCUREMENT REVIEW REFERENCES AND QUESTIONS

Citation/Reference
Procurement
PRINCIPLE 8. COMPLIANT SUBMISSIONS TO FEDERAL AWARD AGENCY OR PASS-THROUGH
ENTITY REVIEWS SUPPORT THE MAJOR FACILITY.
Practice 8.1 Documented policies and procedures address the
availability of technical specifications on proposed procurements
when requested.

• Uniform Guidance 2 CFR
§200.324, Federal awarding
agency or pass-through
entity review
Practice 8.2 Documented policies and procedures specify the
• Uniform Guidance 2 CFR
deliverables to the Federal agency per the award terms and
§200.324, Federal awarding
conditions.
agency or pass-through
entity review
Practice 8.3 Documented policies address the management review
• Uniform Guidance 2 CFR
and approval of deliverables prior to submission to the Federal award §200.324, Federal awarding
agency.
agency or pass-through
entity review

QUESTIONS/FOCUS AREAS PRINCIPLE 8.
• If a review is requested, what documents are compiled for submission?
• How do the Major Facility and Recipient stakeholders stay informed of requests for and results
of pre-procurement reviews?
• Has your Recipient pursued self-certification of its procurement system, and if so when?

PRINCIPLE 9. INTERNAL CONTROLS FOR PROCUREMENT ARE COMPLIANT AND SUPPORT THE
MAJOR FACILITY.
Practice 9.1 Documented policies and procedures outline transaction- • Uniform Guidance 2 CFR
level actions and reporting to assure compliance with Federal
§200.303, Internal Controls
statutes, and the terms and conditions of awards and other
procurement responsibilities.
Practice 9.2 Documented policies and procedures explain the
evaluation and monitoring and timely actions for instances of noncompliance.

• Uniform Guidance 2 CFR
§200.303, Internal Controls

QUESTIONS/FOCUS AREAS PRINCIPLE 9.
• How does the Recipient maintain an awareness of and get involved in taking action on
instances of non-compliance with the Major Facility?
• What local steps are taken by the Major Facility to evaluate and monitor the transaction-level
and reporting internal controls related to award terms and conditions?
• How is information technology used, either automated or manually implemented, to facilitate
the distribution of responsibilities between the Recipient and Major Facility?
• How do the Recipient and Major Facility use formal feedback from various stakeholder entities
(e.g., internal audit, funding agency reviews etc.) to understand possible systemic problems?
• How does the Major Facility assure that the information used to monitor its awards is
accurate?

To return to the module review, click Procurement Review Module.

BSR Guide, NSF FY21-XX

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APPENDIX A

A-7. PROPERTY MANAGEMENT REVIEW REFERENCES AND QUESTIONS

A-7. Property Management Principles and Practices
Property Management

Citation/Reference

PRINCIPLE 1. A COMPLIANT SYSTEM OF PROPERTY SUPPORTS THE MAJOR FACILITY.
Practice 1.1 Documented policies and procedures
clearly outline the organizational structure
responsible for property management.
Practice 1.2 Documented policies and procedures
clearly define the collective positions in the property
management organizational structure and for each,
the role, duties, authorities and reporting lines.
Practice 1.3 Documented policies and procedures
ensure that staff with significant responsibilities in
property management receive continuing education
and development opportunities to allow them to
successfully support the functions.

• COSO Control Environment Principle 3
• COSO Control Environment Principle 3

• COSO Control Environment Principle 4

QUESTIONS/FOCUS AREAS PRINCIPLE 1.
• How are the property and equipment functions distributed at each of the levels, Recipient and
Major Facility?
• Demonstrate through use of organization charts, or other related documents, the depiction of
the property and equipment functions at each of the levels, Recipient and Major Facility, and
how they support of the necessary functions, lines of authorities, and positions with reporting
lines.
• To what extent do individuals responsible for property have the appropriate level of authority
required to accomplish their duties?
• How clear are the responsibilities of the Major Facility’s PI, Project Manager (if construction),
and other key personnel in the documentation?
• Does the distribution of positions between the Recipient and Major Facility for this business
function provide for sufficient support?
• What tools are used to capture the position definitions and responsibilities?
• How do the position descriptions and related information for this function align with the
requirements related to approval thresholds and related delegations of authority?
• How do the technologies enforce roles and responsibilities specific to property and
equipment, such as access to inventory records for editing, submission of external reports,
etc.?
• Does every position, including those in senior management have a position description that
aligns with the position’s responsibilities associated with supporting the Major Facility rather
than the individual’s appointment type?
• How is the staff providing property and equipment support made aware of NSF expectations
and changes to the NSF award in relation to their specific duties and responsibilities?
• What requirements or expectations do the Recipient or Major Facility have for continuing
training to support this administrative business function?
• If there are no requirements for continuing training for the administrative business function,
how do the staff stay up-to-date on Federal requirements?
• How do the requirements or expectations determine what action is taken if they are not met?

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APPENDIX A

A-7. PROPERTY MANAGEMENT REVIEW REFERENCES AND QUESTIONS

Property Management

Citation/Reference

PRINCIPLE 2. ACQUISITION OF PROPERTY TO SUPPORT THE MAJOR FACILITY IS COMPLIANT.
Practice 2.1 Documented policies and procedures
classify the types of property and supplies.

Practice 2.2 Documented policies and procedures
ensure acquisition requirements are met and the
property trust relationship is established.
Practice 2.3 Documented policies and procedures
require the maintenance of documentation for new
acquisitions, replacement and/or improvement of
property and assure that information on the title and
ownership is captured.

• Uniform Guidance 2 CFR §200.311 Real
property
• Uniform Guidance 2 CFR §200.312
Federally-owned and exempt property
• Uniform Guidance 2 CFR §200.313
Equipment
• Uniform Guidance 2 CFR §200.314 Supplies
• Uniform Guidance 2 CFR §200.315
Intangible property
• Uniform Guidance 2 CFR §200.316, Property
trust relationship
• Uniform Guidance 2 CFR §200.311, Real
property
• Uniform Guidance 2 CFR §200.313,
Equipment

QUESTIONS/FOCUS AREAS PRINCIPLE 2.
•

•
•

•
•

Where and how does the Major Facility determine the classification of and appropriate
guidelines for Federally-owned, Recipient-titled, Recipient-owned, real property, personal/
equipment property, exempt property, supplies, and intangible vs. tangible property?
How does the Major Facility align its documentation on property, particularly the definitions
of Federally-owned, Recipient-titled, and Recipient-owned, with the guidance provided by
NSF?
Does the financial disclosure statement show that the Recipient, as trustee for the
beneficiaries of the project or program under which the property was acquired or improved, is
holding the real property, personal property/equipment, and intangible property in trust?
Is the Recipient or Major Facility currently required to record liens or other notices of record
to indicate that personal property/equipment or real property has been acquired or improved
with Federal awards, and that disposition conditions apply to the property, and if so, what
does this entail?
How are replacement acquisitions typically handled by the Recipient or Major Facility (e.g.,
trade-in or sell)?
Who and how is the insurance coverage for property acquired, and improved with Federal
funds?

PRINCIPLE 3. COMPLIANT USE AND DISPOSITION MECHANISMS ASSOCIATED WITH
PROPERTY SUPPORT THE MAJOR FACILITY.
Practice 3.1 Documented policies and procedures
address the proper use of property.

BSR Guide, NSF FY21-XX

• Uniform Guidance 2 CFR §200.311, Real
property
• Uniform Guidance 2 CFR §200.312,
Federally-owned
• Uniform Guidance 2 CFR §200.313,
Equipment; Supplies; Intangible property

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APPENDIX A

A-7. PROPERTY MANAGEMENT REVIEW REFERENCES AND QUESTIONS

Property Management
Practice 3.2 Documented policies and procedures
address disposition of property.

Citation/Reference
• Uniform Guidance 2 CFR §200.311, Real
property
• Uniform Guidance 2 CFR §200.312,
Federally-owned
• Uniform Guidance 2 CFR §200.313,
Equipment

QUESTIONS/FOCUS AREAS PRINCIPLE 3.
• How does the Recipient assure that the property is used for its original intended purpose?
• Please provide an instance when the property was not being used as intended, and steps
taken to remedy.
• How does the Major Facility make the property available for use on other projects or
programs supported by the Federal government?
• How are fee structures determined to avoid charging less than private industry for supplies
and personal property/equipment?
• How are requests from the Federal awarding agency handled for copyrighted work under a
Federal award?
• How do stakeholders determine the disposition requirements for the various types of
property?
• What considerations are given by the Major Facility before determining that Federally-owned
property is no longer of use?

PRINCIPLE 4. PROPERTY SUPPORTING THE MAJOR FACILITY IS SECURED AND MAINTAINED
IN A COMPLIANT MANNER.
Practice 4.1 Documented policies and procedures
ensure that the property is maintained in good
condition.

• Uniform Guidance 2 CFR §200.311, Real
Property
• Uniform Guidance 2 CFR §200.313,
Equipment
• Uniform Guidance 2 CFR §200.313,
Equipment

Practice 4.2 Documented policies and procedures
address safeguards to prevent loss, damage or theft,
and in instances of occurrence assure the required
reporting and investigation of lost, damaged, or stolen
property.
Practice 4.3 Documented policies and procedures
• Uniform Guidance 2 CFR §200.331,
should include information on the process for sharing
Requirements for pass-through entities
property maintenance expectations and security
requirements, with subrecipients.

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APPENDIX A

A-7. PROPERTY MANAGEMENT REVIEW REFERENCES AND QUESTIONS

Property Management
QUESTIONS/FOCUS AREAS PRINCIPLE 4.

Citation/Reference

• How does the Major Facility verify the condition of the property?
• What steps are taken to assure that the requirements mandated by warranties are met?
• What specialized steps, if any, does the Major Facility take for its remote locations or
moveable Facilities like the research vessels?
• What additional precautions does the Major Facility take to put safeguards in place during
natural emergencies such as flooding, hurricanes etc.?
• How does the Recipient assist its Major Facility on its plans for and recovering from natural
emergencies such as flooding, hurricanes etc.?
• How are the responsibilities for sharing the Federally-mandated property maintenance/
security requirements distributed between the Recipient, Major Facility and its Subrecipients?
• Beyond a discussion of the Federally-mandated property maintenance/security requirements,
what formal evidence does the Recipient, Major Facility and its Subrecipients maintain on
these matters?
• What challenges do the Recipient, Major Facility and its Subrecipients have with implementing
the requirement to share Federally-mandated property maintenance/security requirements?
• What kinds of cross-walks or checks are done to verify that the information and data elements
align?
• How do geographically dispersed stakeholder entities learn about the needed information and
data elements, particularly where electronic integration cannot be done?

PRINCIPLE 5. INVENTORY AND RECORD KEEPING MECHANISMS OF PROPERTY SUPPORTING
THE MAJOR FACILITY ARE COMPLIANT.
Practice 5.1 Documented policies and procedures
address the capture and maintenance of information
and data elements.

Practice 5.2 Documented policies and procedures
address the required frequency of conducting the
physical inventory review, and the reconciling of the
results with the inventory records and reporting.

BSR Guide, NSF FY21-XX

• Uniform Guidance 2 CFR §200.312,
Federally-owned and exempt property
• Uniform Guidance 2 CFR §200.313,
Equipment
• 41 CFR 101-39 – Interagency Fleet
Management Systems
• Uniform Guidance 2 CFR §200.313,
Equipment
• Uniform Guidance 2 CFR §200.329,
Reporting on real property
• 41 CFR 101-39 – Interagency Fleet
Management Systems

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APPENDIX A

A-7. PROPERTY MANAGEMENT REVIEW REFERENCES AND QUESTIONS

Property Management
QUESTIONS/FOCUS AREAS PRINCIPLE 5.

Citation/Reference

• How does the Major Facility assure adherence to requirements under 41 CFR 101-39
Interagency Fleet Management Systems?
• How do geographically dispersed stakeholder entities learn about the needed information and
data elements, particularly where electronic integration cannot be done?
• What kinds of cross-walks or checks are done to verify that the information and data elements
align?
• How does the Recipient and Major Facility work together on addressing the physical inventory
review especially for the Major Facility’s remote locations?
• What entity and stakeholders are responsible for reporting to NSF on any of the following
items?
◦ EPACT 2005 Sec. 701 Waiver Requests (via FAST) as applicable
◦ Annual Motor Vehicle Report via FAST (AMVFR A-11)
◦ Motor Vehicle Inventory (via Federal Automotive Statistical Tool – FAST)
◦ Negotiated/Exchange Sales
◦ Construction in Progress/Work in Progress (CIP/WIP)
◦ Federally-owned Property Inventory Submissions
• What are your current reporting requirements for real property and how are the required
reports generated?

PRINCIPLE 6. INTERNAL CONTROLS FOR PROPERTY ARE COMPLIANT AND SUPPORT THE
MAJOR FACILITY.
Practice 6.1 Documented policies and procedures
• Uniform Guidance 2 CFR §200.303, Internal
outline transaction-level actions and reporting specific Controls
to property management required to assure
compliance with Federal statutes and the terms and
conditions of awards.
Practice 6.2 Documented policies and procedures
• Uniform Guidance 2 CFR §200.303, Internal
explain the evaluation and monitoring and timely
Controls
actions for instances of non-compliance.

QUESTIONS/FOCUS AREAS PRINCIPLE 6.
• How does the Recipient maintain an awareness of and get involved in taking action on
instances of noncompliance with the Major Facility?
• What local steps are taken by the Major Facility to evaluate and monitor the transaction-level
and reporting internal controls related to award terms and conditions?
• How is information technology used, either automated or manually implemented, to facilitate
the distribution of responsibilities between the Recipient and Major Facility?
• How do the Recipient and Major Facility use formal feedback from various stakeholder entities
(e.g., internal audit, funding agency reviews etc.) to understand possible systemic problems?
• How does the Major Facility assure that the information used to monitor its awards is
accurate?
To return to the module review, click Property Management Review Module.

BSR Guide, NSF FY21-XX

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APPENDIX B

LIST OF ACRONYMS

APPENDIX B: LIST OF ACRONYMS
AM

Award Management

AOR

Authorized Organizational Representative

BFA

Office of Budget, Finance and Award Management

BPE

Budget Planning and Execution

BSR

Business System Review

CA

Cooperative Agreement

CAP

Cost Analysis and Pre-Award Branch

CAP

Corrective Action Plan

CASB

Cost Accounting Standard Board

CFA

Core Functional Area

CFO

Chief Financial Officer

CFR

Code of Federal Regulations

CIP

Construction-in-Progress

COI

Conflict of Interest

COSO

The Committee of Sponsoring Organizations of the Treadway Commission

DACS

Division of Acquisition and Cooperative Support

DCAA

Defense Contract Audit Agency

DIAS

Division of Institution and Award Support

FASB

Financial Accounting Standards Board

FFR

Federal Financial Report

FFRDC

Federally Funded Research and Development Center

FM

Financial Management

GAO

Government Accountability Office

G/AO

Grants and Agreements Officer

GM

General Management

HRM

Human Resources Management

IPT

Integrated Project Team

MFG

Major Facilities Guide

LFO

Large Facilities Office

MREFC

Major Research Equipment and Facilities Construction

NSF

National Science Foundation

OIG

Office of Inspector General

OMB

Office of Management and Budget

PAPPG

Proposal and Award Policies and Procedures Guide

PI

Principal Investigator

PM

Property Management

BSR Guide, NSF FY21-XX

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APPENDIX B

LIST OF ACRONYMS

POC

Point of Contact

PR

Procurement

R&RA

Research and Related Activities

WIP

Work-in-Progress

BSR Guide, NSF FY21-XX

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APPENDIX C

GLOSSARY

APPENDIX C: GLOSSARY3
Content Specialist

A subject matter expert in any of the BSR core functional areas (CFA). In the BSR
context, the content specialist has several responsibilities with regard to
authoring assigned CFA modules and making recommendations on compliance
issues. The full suite of responsibilities is outlined in the Roles and
Responsibilities section of this Guide.4

Cooperative
Agreement

A legal instrument of financial assistance between NSF and a Recipient that,
consistent with 31 USC 6302–6305:
(1) Is used to enter into a relationship, the principal purpose of which is to
transfer anything of value from NSF to the grantee to carry out a public purpose
authorized by a law of the United States (see 31 USC 6101(3)); and not to
acquire property or services for NSF’s direct benefit or use;
(2) Is distinguished from a grant in that it provides for substantial involvement
between NSF and the grantee in carrying out the activity contemplated by the
NSF award.
In the case of NSF, assistance awards involve the support or stimulation of
scientific and engineering research, science and engineering education or other
related activities. NSF is authorized to use grants or cooperative agreements for
this purpose. Grants, however, are the primary mechanism of NSF support.5
In this context, the Integrated Project Team (IPT), chaired by the Program
Officer, is composed of three subgroups, with appointed Award Management
Group members from BFA, Science and Technology Group members from the
sponsoring program offices, and Strategic Group members from the Office of the
Director.6

Integrated Project
Team

Facility Life Cycle
Major Facility

Non-Federal entity

The sequence of steps or stages that characterize the lifetime of a facility from
beginning to end. For NSF, the stages are Development, Design, Construction,
Operations, and Divestment.7
Per Section 110 of the 2017 American Innovation and Competitiveness Act
(AICA), a major multi-user research facility project is a science and engineering
facility project that:
(A) exceeds the lesser of (i) 10 percent of a Directorate’s annual budget; or (ii)
$100,000,000 in total project costs; or
(B) is funded by the major research equipment and facilities construction
account, or any successor account.
For the purposes of this Guide, the term Major Facility is used throughout to
equate to the Congressional term Major Multi-User Research Facility Project.
NSF interprets this to mean the Total Project Costs (TPC) as defined by the
Construction Stage; NOT the full life-cycle cost. This aligns with the allowable use
of MREFC account which is for construction, acquisition and commissioning. This
interpretation applies to projects funded through MREFC or R&RA.8
A state, local government, Indian tribe, institution of higher education (IHE), or
nonprofit organization that carries out a Federal award as a recipient or
subrecipient.

3

Entries in italics reflect text in Uniform Guidance 2 CFR § 200 – Uniform Administrative Requirements, Cost Principles, and
Audit Requirements for Federal Awards (Uniform Guidance).
4
Business Systems Review Guide, NSF FY21-XX, Part I, Section 2, Table 1. BSR Stakeholders’ Roles and Responsibilities
5
Proposal and Award Policies and Procedure Guide, NSF 20-1
6
Major Facilities Guide, NSF 19-68, September 2019
7
Ibid.
8
Ibid.

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APPENDIX C

Recipient

Scoping
Subaward

Subrecipient

GLOSSARY

A non-Federal entity that receives a Federal award directly from a Federal
awarding agency to carry out an activity under a Federal program. The term
recipient does not include subrecipients. See also 2 CFR §200.69 Non-Federal
entity.
An iterative process used to develop the review strategy which is the overall
plan for conducting the BSR. Each Facility is unique regarding the risks identified
and each BSR is scoped accordingly to take these differences into consideration.
An award provided by a pass-through entity to a subrecipient for the subrecipient
to carry out part of a Federal award received by the pass-through entity. It does
not include payments to a contractor or payments to an individual that is a
beneficiary of a Federal program. A subaward may be provided through any form
of legal agreement, including an agreement that the pass-through entity
considers a contract.
A non-Federal entity that receives a subaward from a pass-through entity to
carry out part of a Federal program; but does not include an individual that is a
beneficiary of such program. A subrecipient may also be a recipient of other
Federal awards directly from a Federal awarding agency.

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