Business Systems Review Guide

BSR_Guide - Draft NSF 22-102 June 2022_For OMB Approval_1

Business Systems Review Guide

OMB: 3145-0255

Document [pdf]

Download: pdf | pdf

SIGNIFICANT CHANGES – BUSINESS SYSTEMS REVIEW GUIDE – NSF 22-102

Summary of Significant Changes
Business Systems Review Guide – NSF 22-102

Revisions to terminology have been made in response to promulgation of the 2 CFR 200 Uniform
Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform
Guidance).
Editorial changes have been made throughout the document to either clarify or enhance the intended
meaning of a sentence or section to improve the assistive nature of the BSR Guide for targeted users. A
summary of the significant changes for this revision is given below.
Part I – Business Systems Review Process
•

In Section 1.1, BSR Benefits, narrative was added to include knowledge management.

•

In Section 1.4, Duration of the BSR, the narrative was clarified to align with the timeline shown
in Figure 2.

•

In Figure 1, Stakeholders, the figure was revised to include the Recipient stakeholders and to
illustrate the BSR Stakeholders' working relationships to one another.

•

In Table 1, BSR Stakeholders’ Roles and Responsibilities, the responsibilities of the BSR Lead,
Contractor Operational Lead and Content Specialists were clarified.

•

In Section 2.2, Recipient Stakeholders, the narrative of Recipient roles was expanded to more
fully explain Recipient activity throughout the BSR.

•

In Figure 2, Overview of the BSR Process, the image was updated to identify revised names of
BSR process phases and to align the milestones and major process steps within each BSR phase.

•

In Section 3.1, Scheduling and Planning, the narrative was realigned to more fully identify the
BSR roles and activities involved in developing an annual schedule for the BSRs, including
coordination within NSF and providing notification to the Recipient.

•

In Section 3.2, Scoping, and Section 3.3, Desk Review, the narrative was revised to clarify the
activities that occur in each of the two phases.

•

In Section 3.6, Report Generation, the timeframe for resolving high-priority items was clarified.

•

Section 3.7, Develop and Execute Implementation Plan, replaces the previous "Follow-up and
Monitoring" section to identify this as a separate phase of the BSR process. The narrative was
revised to clarify the process and timing for development and execution of the Implementation
Plan.

•

Section 3.8, Administrative Closeout, was renumbered to identify this as a separate BSR phase
and the narrative was revised to clarify the associated activities.

•

Section 4.0, Program Management and Oversight was removed, as this is part of NSF's normal
oversight activities and is not specific to the BSR process as part of NSF's advanced monitoring
program.

Part II – Core Functional Area Review Modules
•

The introductory narrative was clarified to align with Part I.

•

In Section 4. Financial Management Review Module, Practice 2.7 was added to address the
application of Federally negotiated indirect cost rates (2 CFR §200.414 Indirect (F&A) Costs and
Appendices to Part 200).

•

In Section 6. Procurement Review Module, Principle 5 and Practice 5.1 were revised to include
domestic preference requirements (2 CFR §200.322 Domestic preferences for procurements).

BSR Guide, NSF 22-102

Appendices

SIGNIFICANT CHANGES – BUSINESS SYSTEMS REVIEW GUIDE – NSF 22-102

•

Appendix A was updated to add or modify principles, practices, and citations to align with the
Uniform Guidance, NSF terms and conditions, and the changes in Part II of this Guide.

•

In Appendix A, Table 2, Citations/References and Abbreviations Used in Matrices, references to
authorities were updated.

•

In Appendix A, a question under Principle 1 for each of the CFAs was revised to include the
sharing of lessons learned as part of continued training (CA-FATC Knowledge Management).

•

In Appendix A, under Principle 2 of General Management, a question was added regarding the
standards for internal control (2 CFR §200.303 Internal controls).

•

In Appendix A, under Principle 2 of Award Management, a question was added regarding
relating data to performance goals (2 CFR §200.329 Monitoring and reporting program
performance).

•

In Appendix A, under Principle 4 of Award Management, a question was moved from Principle 2
of Award Management into Principle 4 and modified to include compliance with “statutory and
national policy requirements for federal awards.”

•

In Appendix A, under Principle 4 of Award Management, three questions were added related to
partnerships with foreign collaborations (CA-FATC Partnerships with Foreign Collaborators).

•

In Appendix A, under Principle 2 of Financial Management, a question was added associated
with the new Practice 2.7 on indirect rates (2 CFR §200.414 Indirect (F&A) Costs and Appendices
to Part 200).

•

In Appendix A, under Principle 4 of Human Resources, a question was added regarding
professional competencies (CA-FATC Project Personnel and Competencies).

•

In Appendix A, under Practices 2.7, 5.1, and 6.2 of Procurement, the Infrastructure Investment
and Jobs Act (IIJA), Title IX Build America, Buy America Uniform Guidance was added to the list
of citations.

•

In Appendix A, under Principle 5 of Procurement, three questions on bonding requirements
were moved to Principal 6 of Procurement.

•

In Appendix A, under Principle 5 of Procurement, one question was added to address the
requirements of Uniform Guidance 2 CFR 200.321.

•

In Appendix A, under Principle 5 of Procurement, two questions were added associated with the
revised Principle 5 and Practice 5.1 on domestic preference procurement requirements (2 CFR
§200.322 Domestic preferences for procurements and CA-FATC Made in America).

•

In Appendix A, under Principle 5 of Procurement, one question was added associated with Build
America, Buy America waiver requests (IIJA and CA-FATC Build America, Buy America).

•

In Appendix A, under Principle 6 of Procurement, a question was added regarding the
prohibition on certain telecommunications (2 CFR §200.216 Prohibition on certain
telecommunications).

•

In Appendix A, under Principle 6 of Procurement, four questions were deleted because they
duplicated questions under Principle 7 of Procurement and one duplicate question was deleted
under Principle 6 of Procurement.

•

In Appendix A, under Principle 2 of Property Management, a question was added regarding
property valuation (CA-FATC Federally-owned Property).

•

In Appendix A, under Practice 3.2 of Property Management, Uniform Guidance 2 CFR 200.315
was added to the list of citations.

BSR Guide, NSF 22-102

SIGNIFICANT CHANGES – BUSINESS SYSTEMS REVIEW GUIDE – NSF 22-102

•

In Appendix A, under Principle 4 of Property Management, two questions were deleted because
they duplicated questions under Principle 5 of Property Management.

•

In Appendix A, under Principle 4 of Property Management, two questions were added regarding
insurance coverage and reporting on property (CA-FATCs Federally-owned Property and 68.
Recipient-titled Property).

•

In Appendix C, a glossary of terms and definitions was updated to align with the Uniform
Guidance and include property management terminology and classifications.

BSR Guide, NSF 22-102

iii

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 Facilities are an integral
part of NSF’s advanced monitoring program. The NSF Large Facilities Office (LFO) within the 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 and Award Policies and
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, 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 Major 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 conducting these reviews.
The BSR Guide defines the overall framework and summarizes the details outlined in the internal
operating guidelines and procedures used to execute the review process. Management principles and
practices are specified for seven core functional areas (CFA) and are used by NSF in performing these
evaluations. Roles and responsibilities of the NSF stakeholders involved in the process are outlined in the
BSR Guide, including 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
completion 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 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 the review. However,
these modules are designed to be flexible to allow opportunities to explore additional review
areas deemed necessary to complete the 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 Research Infrastructure Guide (RIG). The referenced Uniform Guidance sections
are accessible at Part 200—Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards. The referenced Federal Property Management Systems sections are
accessible at Part 101-39—Interagency Fleet Management Systems. NSF-related material, such as the
PAPPG and the financial and administrative terms and conditions of the award, are located on NSF’s
external website at Proposal and Award Policies and Procedures Guide (PAPPG). 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).

BSR Guide, NSF 22-102

TABLE OF CONTENTS

TABLE OF CONTENTS
PART I – BUSINESS SYSTEMS REVIEW PROCESS....................................................................................... 1
1. INTRODUCTION ................................................................................................................................. 2
1.1 BSR BENEFITS ................................................................................................................................ 2
1.2 BSR FOCUS: ADMINISTRATIVE BUSINESS SYSTEMS SUPPORTING THE MAJOR FACILITY ............. 3
1.3 FREQUENCY OF BSRs .................................................................................................................... 3
1.4 DURATION OF THE BSR ................................................................................................................. 3
2. ROLES AND RESPONSIBILITIES .......................................................................................................... 4
2.1 NSF STAKEHOLDERS ...................................................................................................................... 6
2.2 RECIPIENT STAKEHOLDERS ........................................................................................................... 7
3. BSR PROCESS PHASES ....................................................................................................................... 8
3.1 SCHEDULING AND PLANNING ...................................................................................................... 8
3.2 SCOPING ....................................................................................................................................... 9
3.3 DESK REVIEW ................................................................................................................................ 10
3.4 TELECONFERENCE ......................................................................................................................... 10
3.5 SITE VISIT ...................................................................................................................................... 10
3.6 REPORT GENERATION ................................................................................................................... 12
3.7 DEVELOP AND EXECUTE IMPLEMENTATION PLAN ....................................................................... 13
3.8 ADMINISTRATIVE CLOSEOUT ........................................................................................................ 13
PART II – CORE FUNCTIONAL AREA REVIEW MODULES .......................................................................... 14
1. GENERAL MANAGEMENT REVIEW MODULE.................................................................................... 16
1.1 SCOPE OF REVIEW ........................................................................................................................ 16
1.2 SUPPORTING DOCUMENTATION .................................................................................................. 16
1.3 PROCEDURES ................................................................................................................................ 17
1.4 FRAMEWORK CONTENTS.............................................................................................................. 17
2. AWARD MANAGEMENT REVIEW MODULE ...................................................................................... 19
2.1 SCOPE OF REVIEW ........................................................................................................................ 19
2.2 SUPPORTING DOCUMENTATION ................................................................................................. 19
2.3 PROCEDURES ................................................................................................................................ 19
2.4 FRAMEWORK CONTENTS.............................................................................................................. 20
3. BUDGET PLANNING AND EXECUTION REVIEW MODULE ................................................................ 22
3.1 SCOPE OF REVIEW ........................................................................................................................ 22
3.2 SUPPORTING DOCUMENTATION .................................................................................................. 22
3.3 PROCEDURES ................................................................................................................................ 23
3.4 FRAMEWORK CONTENTS ............................................................................................................. 23
4. FINANCIAL MANAGEMENT REVIEW MODULE ................................................................................. 25
4.1 SCOPE OF REVIEW ....................................................................................................................... 25
4.2 SUPPORTING DOCUMENTATION .................................................................................................. 25
4.3 PROCEDURES ............................................................................................................................... 26
4.4 FRAMEWORK CONTENTS ............................................................................................................. 26
5. HUMAN RESOURCES MANAGEMENT REVIEW MODULE ................................................................. 29
5.1 SCOPE OF REVIEW ........................................................................................................................ 29
5.2 SUPPORTING DOCUMENTATION .................................................................................................. 29

BSR Guide, NSF 22-102

TABLE OF CONTENTS

5.3 PROCEDURES ................................................................................................................................ 30
5.4 FRAMEWORK CONTENTS ............................................................................................................. 30
6. PROCUREMENT REVIEW MODULE ................................................................................................... 33
6.1 SCOPE OF REVIEW ........................................................................................................................ 33
6.2 SUPPORTING DOCUMENTATION .................................................................................................. 33
6.3 PROCEDURES ................................................................................................................................ 33
6.4. FRAMEWORK CONTENTS ............................................................................................................ 34
7. PROPERTY MANAGEMENT REVIEW MODULE .................................................................................. 37
7.1 SCOPE OF REVIEW ........................................................................................................................ 37
7.2 SUPPORTING DOCUMENTATION .................................................................................................. 37
7.3 PROCEDURES ................................................................................................................................ 38
7.4. FRAMEWORK CONTENTS ............................................................................................................ 38
APPENDIX A: LIST OF REFERENCES AND QUESTIONS .............................................................................. 41
A-1. GENERAL MANAGEMENT PRINCIPLES, PRACTICES, REFERENCES, AND QUESTIONS.................. 43
A-2. AWARD MANAGEMENT PRINCIPLES, PRACTICES, REFERENCES, AND QUESTIONS .................... 49
A-3. BUDGET PLANNING AND EXECUTION PRINCIPLES, PRACTICES, REFERENCES, AND
QUESTIONS ......................................................................................................................................... 55
A-4. FINANCIAL MANAGEMENT PRINCIPLES, PRACTICES, REFERENCES, AND QUESTIONS ............... 59
A-5. HUMAN RESOURCES MANAGEMENT PRINCIPLES, PRACTICES, REFERENCES, AND
QUESTIONS ......................................................................................................................................... 63
A-6. PROCUREMENT PRINCIPLES, PRACTICES, REFERENCES, AND QUESTIONS ................................. 68
A-7. PROPERTY MANAGEMENT PRINCIPLES, PRACTICES, REFERENCES, AND QUESTIONS ................ 75
APPENDIX B: LIST OF ACRONYMS ............................................................................................................ 80
APPENDIX C: GLOSSARY ........................................................................................................................... 81

LIST OF FIGURES
Figure 1. BSR Stakeholders........................................................................................................................ 4
Figure 2. Overview of the BSR Process ..................................................................................................... 8

LIST OF TABLES
Table 1. BSR Stakeholders' Roles and Responsibilities .............................................................................. 4
Table 2. Citations/References and Abbreviations Used in Matrices ......................................................... 41

BSR Guide, NSF 22-102

PART I – BUSINESS SYSTEMS REVIEW PROCESS

BSR Guide, NSF 22-102

Page 1 of 83

PART I – BUSINESS SYSTEMS REVIEW PROCESS

1. INTRODUCTION

The projects subject to a BSR are major multi-user research facilities (Major Facilities) as defined in
Section 1.4.3 of the Research Infrastructure Guide (RIG).
The inherent risks associated with funding Major Facility awards come from operational complexity, the
regulatory environment, and their 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 seven core functional areas (CFAs) that structure the review of the administrative
business systems supporting 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)
A BSR may include a combination of these CFAs and may cover multiple business functions of an
organization. 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 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 CFAs. 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.
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
capable of administratively supporting Major Facilities and have met Federal and NSF award
requirements.
BSRs are intended to provide an opportunity for cross-fertilization of ideas through the identification of
good practices and serve to refocus Recipients on the importance of administrative quality. 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 Facility managers to help them improve their respective systems. This collaboration
BSR Guide, NSF 22-102

Page 2 of 83

PART I – BUSINESS SYSTEMS REVIEW PROCESS

1. INTRODUCTION

is intended to strengthen the relationship between NSF and the Recipient and support NSF’s monitoring
responsibilities. Recipients should engage in knowledge management opportunities including sharing of
lessons learned and good practices in order to further improve the quality of business systems
supporting the Major Facility.

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 selected 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 BSRs
The need for BSRs is based on NSF’s internal annual Major Facility Portfolio Risk Assessment, including
the risks associated with readiness for construction. As a result, BSRs 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 BSR
Generally, each BSR requires four to five months to complete and spans the period from Recipient
notification or the Recipient Kickoff through issuance of the final BSR Report, although duration may vary
depending on the scope and complexity of the review. 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. Additionally, a period of approximately one year,
commencing with issuance of the final BSR Report, is allotted for completion of the Implementation Plan
prior to Administrative Closeout of the BSR. Agreement, prioritization and execution of the
Implementation Plan is coordinated with the Recipient by the Core Integrated Project Team (IPT)
Members 1 during the Develop and Execute Implementation Plan phase.

The Core IPT Members include the Program Officer, Grants and Agreements or Contracts Officer, and the LFO Liaison, who
typically serves as BSR Lead (RIG, NSF 21-107, December 2021, Section 2, Table 2.1.6-1 Summary of Principal Roles and
Responsibilities of the core members of the IPT (PO, G/AO or CO, and LFO Liaison) by Facility Life Cycle Stage).

BSR Guide, NSF 22-102

Page 3 of 83

PART I – BUSINESS SYSTEMS REVIEW PROCESS

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 BSR stakeholders is shown in Figure 1 below.
Figure 1. BSR Stakeholders

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

Head, Large Facilities
Office (HLFO)

BSR Manager

BSR Guide, NSF 22-102

ROLES AND RESPONSIBILITIES
NSF STAKEHOLDERS
• 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 the BSR through a Closure Memorandum to the
Program Officer
• Maintains document control over BSR Guide, BSR SOG, and SOPs
• Develops BSR schedule based on the annual Major Facility Portfolio Risk
Assessment
• Coordinates BSRs with other NSF oversight (e.g., Office of Inspector General
[OIG])
• Approves BSR scope
• Confirms assignment of BSR roles and responsibilities
• Monitors BSR progress and closeout of recommendations with BSR Leads

Page 4 of 83

PART I – BUSINESS SYSTEMS REVIEW PROCESS
STAKEHOLDERS

BSR Lead*†

Program Officer †

Grants and
Agreements Officer
(G/AO) †

Contractor
Operational
Lead*

ROLES AND RESPONSIBILITIES

•
•
•
•
•
•
•

Serves as the primary NSF administrative point of contact with Recipient
Facilitates and coordinates BSR activities and leads BSR Core Team
Liaises with Core IPT Members on BSR activities
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

•
•
•
•
•

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
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
Serves as the primary point of contact for the BSR Manager and the BSR Lead
Provides expert guidance throughout the BSR process
Provides administrative and operational support to facilitate effective and
efficient execution of an BSR process
Makes recommendations on the BSR scope or review strategy as requested by
BSR Lead
Coordinates contractor support for the BSR including oversight of the Content
Specialists
Serves as subject matter expert for one or more BSR CFAs on a BSR
Reviews BSR scope and develops the BSR Document Request
Analyzes documentation including sampling artifacts and highlights compliance
issues, concerns and gaps
Maintains supporting review documentation
Explores themes or concerns with Recipient during teleconference or onsite
Authors assigned CFA sections of draft and final BSR Reports
Suggests remedial action on issues of non-compliance, if any
Makes recommendations for improvement of Recipient Business Systems
supporting the Major Facility
Provides advice on Implementation Plan or resolution of recommendations as
requested by BSR Lead

•
•
•
•
•
•
•
•
•
•
•
•
•

Content Specialist(s)

2. ROLES AND RESPONSIBILITIES

•
•
•
•
•
•

RECIPIENT STAKEHOLDERS
Principal Investigator
Authorized
Organizational
Representative
(AOR)
BSR Point of Contact
(POC)

BSR Guide, NSF 22-102

•
•
•
•
•
•

Determines the scientific and technical direction of the Major Facility
Designates a BSR Point of Contract (POC)
Provides scientific/technical background on the Facility
Oversees Recipient compliance with Federal award requirements
Monitors resolution of BSR recommendations
May also serve as the BSR POC

•
•
•
•

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

Page 5 of 83

PART I – BUSINESS SYSTEMS REVIEW PROCESS
STAKEHOLDERS

2. ROLES AND RESPONSIBILITIES

ROLES AND RESPONSIBILITIES

• Explains Recipient business processes to the BSR Core Team
• Provides requested documentation
Core Functional Area
• Participates in teleconferences and site visits
Representative
• Supports BSR Core Team onsite
• Consulted with or implements corrective actions or recommendations
* BSR Core Team Member; † Core IPT Member

2.1 NSF Stakeholders
2.1.1 Large Facilities Office
The NSF Large Facilities Office (LFO) is responsible for leading the BSR process. The Head of LFO (HLFO)
manages the NSF staff responsible for conducting and closing out the BSRs. With the Division Director
for Acquisition and Cooperative Support, the HLFO recommends the BSRs to be conducted, in a given
year, to the Chief Financial Officer (CFO) and Chief Officer for Research Facilities. The HLFO is supported
in this process by the BSR Manager, who develops the annual BSR schedule, approves BSR scopes,
confirms assignment of BSR roles and responsibilities, 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, teleconferences, site visits, and generation of draft and final
reports. The BSR Lead signals the end of each BSR process phase and progression to the next. NSF makes
all inherently governmental final approvals of the various work products developed.
The BSR Manager ensures that the Content Specialists assigned to each CFA have the necessary skills,
background, and competencies. The Content Specialists are selected based on their specialized
knowledge in the CFA as well as their understanding of applicable Uniform Guidance, other Federal
requirements, and NSF terms and conditions. They should also be skilled technical writers who can
complete their Reports in the required timeframe. 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 Core Team and Content Specialists execute the Desk Review phase by performing an analysis of
the written policies, procedures, and process documents provided by the Recipient, identifying any
potential compliance or risk issues. At the end of the Site Visit, the BSR Core Team and Content
Specialists conduct a Recipient debrief to explain any compliance concerns to the Recipient’s senior
management and to summarize potential recommendations for improvement.

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. 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
Content Specialists in the BSR. These other NSF stakeholders are often relied upon to assist the Core IPT
Members in gathering information for the scoping process and may be called upon to provide their
insights or participate in discussions during any phase of the BSR, including draft BSR Report review.

BSR Guide, NSF 22-102

Page 6 of 83

PART I – BUSINESS SYSTEMS REVIEW PROCESS

2.2 Recipient Stakeholders

2. ROLES AND RESPONSIBILITIES

NSF proactively engages with the Recipient to select a timeframe and coordinate the BSR. The Recipient
selects a POC to collaborate with the BSR Lead and Recipient stakeholders on planning for the review.
NSF provides notification of the BSR, to the Recipient. Timeframes for milestones and major process
steps are projected with consideration of internal and external reviews that may impact the Recipient.
It is critical that the Recipient assign adequate staff who are directly involved in the operations or
management of the business systems supporting the Major Facility and can provide the time necessary
to interact with the BSR Core Team, Core IPT Members, and Content Specialists in all aspects of the
review. The award Principal Investigator is a key role in the BSR process. The Recipient’s stakeholders
typically include 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, and 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 during a site visit. The Recipient POC
may coordinate identification of the Recipient's CFA Representatives to identify documents, answer
questions, or explain administrative business processes.
The Recipient is active in certain phases of the BSR process. The Recipient reviews, selects, and provides
appropriate documentation in alignment with the scope of the review. Recipient stakeholders are invited
to attend the Desk Review debriefing, when preliminary observations are presented to NSF. Typically,
Major Facility and Recipient staff (CFA Representatives) who are knowledgeable regarding business
processes are called upon at teleconferences or the site visit to explain or demonstrate processes and
answer questions raised by the Content Specialists. Recipient stakeholders are encouraged to review the
CFA modules in this BSR Guide to prepare for the BSR. The Recipient should seek opportunities to
maintain awareness of governing documents identified in Table 2 of this Guide and how their processes
meet the requirements. NSF asks the Recipient to review the draft BSR Report and to work with the Core
IPT Members on development and completion of the Implementation Plan following issuance of the final
BSR Report.

BSR Guide, NSF 22-102

Page 7 of 83

PART I – BUSINESS SYSTEMS REVIEW PROCESS

3. BSR PROCESS PHASES

The annual BSR program is informed by the outcomes from the internal NSF annual Major Facility
Portfolio Risk Assessment. The BSR Manager works with the BSR Core Teams to develop a preliminary
schedule of the BSRs for the upcoming fiscal year. The BSR Leads begin the process to plan and scope
their assigned BSR(s). Each BSR progresses through several phases and concludes with administrative
closeout. The BSR Lead is responsible for ensuring that the entire process of a BSR 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 reviews
and audits 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 HLFO and BSR Leads. The BSR Leads share information on the planning process with
the BSR Manager. 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. The location(s) of onsite
reviews are discussed to determine the impact on the Recipient and the BSR timeline. The BSR Manager,
BSR Leads, and Operational Lead then compile the preliminary BSR timeline. Once the preliminary BSR
timeline is established and approved by the BSR Manager, the BSR Leads work with the Operational Lead
to initiate each review, including articulation of the initial review strategy and assignment of BSR Content
Specialists. BSR scheduling is an on-going process and the BSR timeline is continuously reevaluated as
circumstances change.
The BSR Lead meets with the other Core IPT Members and gathers information from the variety of
sources discussed below. These activities may not necessarily be performed in the order listed here.

BSR Guide, NSF 22-102

Page 8 of 83

PART I – BUSINESS SYSTEMS REVIEW PROCESS

3. BSR PROCESS PHASES

Determination of Recipients and Award — 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 consults with the NSF Program
Officer and the G/AO for their guidance on conducting the review. Factors to be considered in making
the determination may include 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
contracts or subawards.
Coordination with the RAM Branch and the NSF OIG — The BSR Manager notifies the NSF OIG of the
planned BSRs to facilitate coordination of NSF oversight activities. The BSR Lead or the G/AO reviews
RAM's database for any pertinent or more recent audit reports that are available to determine if the
findings overlap with any of the proposed CFA’s principles or practices. If so, the findings may inform the
review strategy and final scope. The BSR Lead highlights the significant reporting findings for the Content
Specialists to consider as they conduct their independent reviews.
Notification to the Recipient — The Recipient is notified early by the BSR Lead of the planned review in
upcoming year and the proposed timeframe. Discussions are held with the Recipient to explain the BSR
process and to get feedback on the proposed high-level schedule. NSF provides the Recipient with the
BSR Guide, which should be reviewed by the Recipient in preparation for the BSR. The BSR Guide
explains the BSR, establishes the principles, practices, and questions for each CFA, and list examples of
supporting documentation.

3.2 Scoping
The first step in this phase is for the BSR Lead to draft the scope of the review. This is an iterative process
and starts with the initial review strategy which is informed by Core IPT discussions held during the
annual Major Facility Risk Assessment. Each Major Facility is unique 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 NSF IPT members and discusses
additional information gathered since the annual Major Facility Risk Assessment. Information from the
sources listed above is considered in defining the scope for the review.

3.2.1 IPT Kickoff
To begin the review process, a kickoff meeting is held with the BSR Core Team, BSR Core IPT Members,
and Content Specialists to discuss the review scope and expectations. The BSR Lead explains the BSR
process, facilitates a discussion to finalize the review strategy and scope, and identifies the proposed
milestones. The Program Officer provides a brief overview of the scientific activities at the Major Facility,
describes the management structure in place that supports Facility administration, and provides highlevel insights into any unique aspects and administrative challenges. The G/AO provides a briefing on the
relevant awards, shares observations on the administrative management of the Major Facility, and
identifies any upcoming award actions that might affect the scope of the BSR.

BSR Guide, NSF 22-102

Page 9 of 83

PART I – BUSINESS SYSTEMS REVIEW PROCESS

3. BSR PROCESS PHASES

The initial review strategy and scope are discussed, including the inclusion of CFA principles and
practices. Content Specialists should be involved in these scoping discussions to provide professional
knowledge of the Uniform Guidance and other Federal regulations that might be beneficial. After the
kickoff, the BSR Core Team may refine the scope of the BSR.

3.3 Desk Review
The purpose of the desk review is to conduct an initial assessment of the written administrative business
system's policies, procedures, and processes that support the Major Facility to identify compliance gaps
with the Uniform Guidance, other Federal regulations, and NSF award terms and conditions.

3.3.1 Desk Review Preparation
The BSR Lead facilitates a Recipient kickoff meeting to orient the Recipient to the BSR process, the scope
of the BSR, and the BSR timeline. Shortly after the Recipient kickoff meeting, the Recipient is provided
with an official document request, outlining the background information requested by NSF, such as
internal guidance documents, policies, procedures, and processes, and any other materials deemed
relevant. The Recipient POC, working with their CFA representatives as needed, collects documents that
respond to the document request and provides them electronically prior to the desk review.

3.3.2 Desk Review Execution
The desk review normally takes place over a one-week period, during which the documents provided by
the Recipient are evaluated. Content Specialists focus their attention on independently analyzing the
materials collected from 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 gaps, concerns, or common themes and frame questions for the Recipient to
clarify, as needed.
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, describing any issues, concerns, or gaps. At
this point, the Desk Review phase is complete. The initial observations are then shared with NSF and
may be used by the BSR Lead to further refine the review strategy.

3.4 Teleconference
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, or request forms or tools that support a business process. Recipient stakeholders are not
expected to provide written responses in advance of the scheduled meeting. The Recipient stakeholders’
responses may lead to a request for additional documents. If any issues of potential non-compliance
were identified during the desk review, the Content Specialists would share them with the Recipient so
that they could begin taking action.

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. It typically spans three to five business days. The BSR
Lead provides a site visit agenda to the Recipient in advance of the site visit. Onsite activities include an
entrance conference, interviews, and a Recipient debrief and may include a Facility tour. Core IPT
Members may attend.
Some Facilities have remote sites or business functions conducted in locations other than Recipient
headquarters or the primary business offices of the Major Facility. Additional sites may be considered if
there are specific business systems in place designed to accommodate the special needs of a remote
BSR Guide, NSF 22-102

Page 10 of 83

PART I – BUSINESS SYSTEMS REVIEW PROCESS

3. BSR PROCESS PHASES

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.

3.5.1 Site Visit Preparation
Initial Preparations — Given the results of the desk review and teleconferences, if held, and the
available BSR Core Team resources, the BSR Lead confirms that a site visit is necessary. If so, the BSR
Core Team identifies the Content Specialists who should participate in the site visit. The Content
Specialists review the desk review and teleconference 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 by the BSR Core Team 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 illustrate examples of the application of policies, procedures, or processes.
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.
Final Preparations — The BSR Core Team, Core IPT Members, and Content Specialists meet 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 private meetings throughout the site visit 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.

3.5.2 Site Visit Execution
Entrance Conference — The BSR Core Team leads an entrance conference on the first day of the site visit
with the Core IPT Members, Content Specialists, 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 POC or Facility Director is invited to provide a high-level overview of the
Major Facility activities and describe the administrative management structure.
Facility Tour — A Facility tour may be arranged if the BSR Lead and Recipient POC determine that the
tour would provide insight into the business systems required to support the operations.
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 agenda 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.
Daily Assessments — Time is set aside at the end of each day for the BSR Core Team, Core IPT Members,
and Content Specialists 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. The Recipient is invited to join the daily assessment
for a discussion of the status of the BSR and the needs for the next day.

BSR Guide, NSF 22-102

Page 11 of 83

PART I – BUSINESS SYSTEMS REVIEW PROCESS

3. BSR PROCESS PHASES

Exit Conference — At the end of the Site Visit, the BSR Core Team and Content Specialists provide
feedback to the Recipient on observations and preliminary findings. The BSR Recipient debrief document
is then provided to explain any compliance concerns and to summarize potential recommendations.

3.6 Report Generation
After the site visit, the Content Specialists draft the BSR report, identifying the high-priority areas,
recommendations for improvement, and any good practices observed. These observations are shared by
the BSR Core Team with the Program Officer and G/AO. The draft BSR Report is provided to the Recipient
after completion of the site visit so that action to address any high-priority areas identified can be
initiated as soon as possible. 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 delivery of the draft BSR Report.
Report Version

Delivery to Recipient

Draft BSR Report
Final BSR Report

33 business days after the last day of the site visit
18 business days after delivery of draft BSR Report

3.6.1 Draft BSR Report Preparation
Each Content Specialist develops the assigned 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 Core Team and Core IPT Members review the draft BSR Report. The draft BSR Report is sent to
the Recipient for comment approximately 33 business days after the last day of the site visit. Recipient
comments are expected within 10 business days of transmittal of the draft BSR Report to the Recipient.
The Recipient's review of the draft report is intended to identify major factual errors. NSF expects the
Recipient to address any BSR Report findings during the Implementation Plan phase.

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

Section Contents

Executive Summary

Overview of the BSR and a summary of the results

1.0 Background

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 in the review

4.0 Cross-Cutting Areas

The themes, issues or items impacting 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 any issues of non-compliance,
recommended areas for improvement, and good practices observed that
exceed expectations of a proficient business system

6.0 Implementation Plan

Description of the Implementation Plan for resolution of findings specified
in the Oversight Tracking List

7.0 Summary and
Conclusions

NSF’s overall impressions of the administrative business systems
supporting the Major Facility and the results of the BSR

Appendices A and B

Tabular summary of the supporting documentation used in the review
along with a consolidated list of findings, presented in the Oversight
Tracking List and used as the basis for the Implementation Plan

BSR Guide, NSF 22-102

Page 12 of 83

PART I – BUSINESS SYSTEMS REVIEW PROCESS

3. BSR PROCESS PHASES

3.7 Develop and Execute Implementation Plan
NSF delivers the draft Implementation Plan to the Recipient after the final BSR report is issued. The
Recipient should be prepared to respond to the findings, in writing, with resolution actions to establish
an agreed upon Implementation Plan with NSF.

3.7.1 Implementation Plan Development
After the final BSR Report is issued, the BSR Lead works collaboratively with the other Core IPT Members
to develop and reach consensus on the recommendations in the Oversight Tracking List. The Core IPT
Members prioritize these recommendations based on NSF’s judgment. This list forms the basis for the
Implementation Plan, which becomes the blueprint for resolving any issues and recommendations over
the coming year. The final Implementation Plan includes prioritization, assigned responsibilities, due
dates, and deliverables, and is typically agreed upon shortly after issuance of the final BSR report.
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.
The draft Implementation Plan is sent to the Recipient for input on resolution actions and completion
dates to ensure that the actions and associated timelines for each recommendation are practicable.
Based on discussions between NSF and the Recipient, reasonable adjustments are made before the final
Implementation Plan is issued and execution begins. Any specific actions resulting from the
Implementation Plan, particularly those that are a result of non-compliance, will be directed by either
the Program Officer 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 RIG).

3.7.2 Implementation Plan Execution
Areas of non-compliance with Federal regulation are automatically categorized as high-priority items and
must be resolved within two months (45 business days) following the delivery of the draft BSR Report.
With respect to all other findings and recommendations, these items are required to be resolved in
some mutually agreeable fashion within one 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.
The BSR Lead and other Core IPT Members monitor progress against the Implementation Plan to ensure
that all actions identified for resolution 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 or recommendation and
its resolution, and that progress is consistent with the Implementation Plan.

3.8 Administrative Closeout
Closeout is the final phase in the BSR process and commences once the resolution actions agreed upon
in the Implementation Plan have been completed by the Recipient and are considered resolved by NSF.
The BSR Lead notifies the BSR Manager that all the resolution actions have been appropriately resolved.
The BSR Manager reviews the Implementation Plan and the confirms the action items have been
resolved and determines the BSR is ready for administrative closeout. Once this review is completed, and
based upon the recommendation of the BSR Manager, the HLFO executes a Closure Memorandum to the
Program Officer. The Program Officer may share the Closure Memorandum with the Recipient or other
stakeholders, signaling the formal closure of the BSR.

BSR Guide, NSF 22-102

Page 13 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

Part II lists the core functional area review modules for use as a reference in the execution of desk
review, teleconference, and site visit activities. Supporting questions are provided for these modules in
Appendix A along with citations to Federal statutes, Federal regulations, NSF policies, and other
guidance.
Each module contains the following sections:
1. Scope of Review – Highlights the key topics and issues that are assessed for each particular CFA
module.
2. 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.
3. Procedures – Outlines the framework used by the BSR participants in reviewing each CFA module.
The responsibilities listed below are activities to be performed by the Content Specialist in the
execution of the desk review and site visit:
Desk Review Responsibilities (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 Responsibilities (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.

BSR Guide, NSF 22-102

Page 14 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES
Sampling Activities

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 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 the review, note the
transactions tested, and include these observations in the final BSR report.
4. Framework Contents – 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

Links to Document Area

To view the review module relevant to your area, click
on the appropriate link:

• 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
To view the references relevant to your area, click on the • General Management References
appropriate link:
• Award Management References
• Budget Planning and Execution References
• Financial Management References
• Human Resources Management References
• Procurement References
• Property Management References
To view the review questions relevant to your area, click • General Management Review Questions
on the appropriate link:
• 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
To view the Acronym List:
To view the Glossary:

BSR Guide, NSF 22-102

Glossary

Page 15 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

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, 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
The Recipient submits “end-to-end” business process materials that are made available for the BSR prior
to the desk review. Examples of commonly requested information are outlined in the bulleted list below.
This list of examples 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
management- related 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

•

Copies of performance reports that address administrative business capabilities

•

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

BSR Guide, NSF 22-102

Page 16 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

1. GENERAL MANAGEMENT
REVIEW MODULE

•

Summaries of the advisory groups and meetings

•

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

1.3 Procedures
The desk review and site visit procedures for each module are described in the BSR Guide Part I, above.

1.4 Framework Contents
PRINCIPLE 1. A COMPLIANT STRUCTURE OF GENERAL MANAGEMENT FUNCTIONS
SUPPORTS THE MAJOR FACILITY.
Practice 1.1. The Recipient’s and Major Facility’s organizational structure responsible for general
management is documented and clearly outlined.
Practice 1.2. The collective positions in the general management organizational structure are
documented, and for each, the role, duties, authorities and reporting lines are clearly defined.
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.

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.
BSR Guide, NSF 22-102

Page 17 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

1. GENERAL MANAGEMENT
REVIEW MODULE

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.

BSR Guide, NSF 22-102

Page 18 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

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
The Recipient submits business process materials that are made available for the BSR prior to the desk
review. Examples of commonly requested information are outlined in the bulleted list below. This list of
examples 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
management- 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

2.3 Procedures
The desk review and site visit procedures for each module are described in the BSR Guide Part I, above.

BSR Guide, NSF 22-102

Page 19 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

2.4 Framework Contents

2. AWARD MANAGEMENT
REVIEW MODULE

PRINCIPLE 1. A COMPLIANT STRUCTURE OF AWARD MANAGEMENT FUNCTIONS SUPPORTS
THE MAJOR FACILITY.
Practice 1.1. The Recipient’s and Major Facility’s organizational structure responsible for award
management is documented and clearly outlined.
Practice 1.2. The collective positions in the award management organizational structure are
documented, and for each, the role, duties, authorities and reporting lines are clearly defined.
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.
Practice 4.2. Documented policies and procedures explain the evaluation and monitoring and timely
actions for instances of noncompliance.

BSR Guide, NSF 22-102

Page 20 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

OTHER REVIEW AREAS

2. AWARD MANAGEMENT
REVIEW MODULE

As part of scoping or during execution of the review, NSF 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 BSR 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.

BSR Guide, NSF 22-102

Page 21 of 83

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 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.

3.2 Supporting Documentation
The Recipient submits business process materials that are made available for the BSR prior to the desk
review. Examples of commonly requested information are outlined in the bulleted list below. This list of
examples 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 budget period

•

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

BSR Guide, NSF 22-102

Page 22 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

3. BUDGET PLANNING AND EXECUTION
REVIEW MODULE

•

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

3.3 Procedures
The desk review and site visit procedures for each module are described in the BSR Guide Part I, above.

3.4 Framework Contents
PRINCIPLE 1. A COMPLIANT STRUCTURE OF BUDGET PLANNING AND EXECUTION
FUNCTIONS SUPPORTS THE MAJOR FACILITY.
Practice 1.1. The Recipient’s and Major Facility’s organizational structure responsible for budget
planning and execution is documented and clearly outlined.
Practice 1.2. The collective positions in the budget planning and execution organizational structure are
documented, and for each, the role, duties, authorities and reporting lines are clearly defined.
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/subrecipient’s budget to assure accuracy and compliance with Federal regulations
and requirements and needed refinement.

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.
BSR Guide, NSF 22-102

Page 23 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

3. BUDGET PLANNING AND EXECUTION
REVIEW MODULE

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.

BSR Guide, NSF 22-102

Page 24 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

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
The Recipient submits business process materials that are made available for the BSR prior to the desk
review. Examples of commonly requested information are outlined in the bulleted list below. This list of
examples 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
management- related 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
• 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 afterthe-fact verification, suitable means of verification (where reports are not signed by the
BSR Guide, NSF 22-102

Page 25 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

4. FINANCIAL MANAGEMENT
REVIEW MODULE

employee or the 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 or oversight agency for audit 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

4.3 Procedures
The desk review and site visit procedures for each module are described in the BSR Guide Part I, above.

4.4 Framework Contents
PRINCIPLE 1. A COMPLIANT STRUCTURE OF FINANCIAL MANAGEMENT FUNCTIONS
SUPPORTS THE MAJOR FACILITY.
Practice 1.1. The Recipient’s and Major Facility’s organizational structure responsible for financial
management is documented and clearly outlined.
Practice 1.2. The collective positions in the financial management organizational structure are
documented, and for each, the role, duties, authorities and reporting lines are clearly defined.
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.

PRINCIPLE 2. A COMPLIANT FINANCIAL MANAGEMENT SYSTEM SUPPORTS THE MAJOR
FACILITY.
Practice 2.1. Documented policies and procedures specify the identification of components of Federal
awards received and expended, and the related Federal Programs under which they were received.
Practice 2.2. Documented policies and procedures require that records identify the source and
application of funds for Federally-funded activities through a chart of accounts.
Practice 2.3. Documented policies and procedures address the generation of required reports and
specify the use of detailed receipt and expenditure of funds related to the award.
Practice 2.4. Documented policies and procedures specify how accurate, current and complete
reporting of the financial results of the Federal award or Program is assured.
BSR Guide, NSF 22-102

Page 26 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

4. FINANCIAL MANAGEMENT
REVIEW MODULE

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.
Practice 2.7. Documented policies and procedures address how the Recipient correctly applies current
Federally negotiated indirect cost rates.

PRINCIPLE 3. A COMPLIANT SYSTEM OF CASH MANAGEMENT SUPPORTS THE MAJOR
FACILITY.
Practice 3.1. Documented policies and procedures discuss the handling of advance payments or
reimbursement requests.
Practice 3.2. Documented policies and procedures discuss program income and the related reporting
requirements.
Practice 3.3. Documented policies and procedures discuss how 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.

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 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.

BSR Guide, NSF 22-102

Page 27 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES
*****

4. FINANCIAL MANAGEMENT
REVIEW 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.

BSR Guide, NSF 22-102

Page 28 of 83

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
The Recipient submits business process materials that are made available for the BSR prior to the desk
review. Examples of commonly requested information are outlined in the bulleted list below. This list of
examples 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

▪

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

BSR Guide, NSF 22-102

Page 29 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES
▪

Sexual harassment

5. HUMAN RESOURCES MANAGEMENT
REVIEW MODULE

◦ 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

5.3 Procedures
The desk review and site visit procedures for each module are described in the BSR Guide Part I, above.

5.4 Framework Contents
PRINCIPLE 1. A COMPLIANT SYSTEM TO SUPPORT HUMAN RESOURCES MANAGEMENT
FUNCTIONS SUPPORTS THE MAJOR FACILITY.
Practice 1.1. The Recipient’s and Major Facility’s organizational structure responsible for human
resources management is documented and clearly outlined.
Practice 1.2. The collective positions in the human resources management organizational structure are
documented, and for each, the role, duties, authorities and reporting lines are clearly defined.
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.

BSR Guide, NSF 22-102

Page 30 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

5. HUMAN RESOURCES MANAGEMENT
REVIEW MODULE

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 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).

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.

BSR Guide, NSF 22-102

Page 31 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

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, NSF 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 BSR 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 United States is a party, involving public buildings or public works within the
United States. 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.

BSR Guide, NSF 22-102

Page 32 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

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
The Recipient submits business process materials that are made available for the BSR prior to the desk
review. Examples of commonly requested information are outlined in the bulleted list below. This list of
examples 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 procurementrelated 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

6.3 Procedures
The desk review and site visit procedures for each module are described in the BSR Guide Part I, above.

BSR Guide, NSF 22-102

Page 33 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

6.4 Framework Contents

6. PROCUREMENT REVIEW MODULE

PRINCIPLE 1. A COMPLIANT STRUCTURE OF PROCUREMENT FUNCTIONS SUPPORTS THE
MAJOR FACILITY.
Practice 1.1. The Recipient’s and Major Facility’s organizational structure responsible for procurement
is documented and clearly outlined.
Practice 1.2. The collective positions in the procurement organizational structure are documented, and
for each, the role, duties, authorities and reporting lines are clearly defined.
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 address the considerations for determining
responsible contractors.
Practice 2.3. Documented policies and procedures specify oversight of contractors’ performance.
Practice 2.4. 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 2.5. Documented policies and procedures address steps to avoid unnecessary purchases or
duplicative items, and appropriate analysis to determine the most economical approach.
Practice 2.6. 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 2.7. Documented policies and procedures require the maintenance of records with details
required to show the procurement history.
Practice 2.8. Documented policies and procedures specify conditions for use of time and materials
contract types.
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 assessment of contractor
performance and elimination of 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.

BSR Guide, NSF 22-102

Page 34 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

6. PROCUREMENT REVIEW MODULE

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 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 procurement should address the
required circumstances for use.

PRINCIPLE 5. COMPLIANT CONTRACTING ACTIVITIES ASSURE THE USE OF SMALL AND
MINORITY BUSINESSES, WOMEN’S BUSINESS ENTERPRISES, LABOR SURPLUS AREA FIRMS,
AND DOMESTIC PREFERENCE REQUIREMENTS 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 and that
domestic preference requirements for the purchase, acquisition, or use of goods, products, or
materials are met.

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
flow-down provisions, for construction or facility improvement contracts or subcontracts exceeding
the simplified acquisition threshold.

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.

BSR Guide, NSF 22-102

Page 35 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

6. PROCUREMENT REVIEW MODULE

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 awarding
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 awarding 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.

BSR Guide, NSF 22-102

Page 36 of 83

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
The Recipient submits business process materials that are made available for the BSR prior to the desk
review. Examples of commonly requested information are outlined in the bulleted list below. This list of
examples 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

•

Electronic download from property IT system showing roles and assigned personnel authorized
to enter, modify, or alter Major Facility’s property records

BSR Guide, NSF 22-102

Page 37 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

7. PROPERTY MANAGEMENT
REVIEW MODULE

•

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)

•

Evidence of non-Federal entity insurance coverage for real property and equipment acquired or
improved with Federal funds equivalent to that provided for property owned by the non-Federal
entity

•

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

7.3 Procedures
The desk review and site visit procedures for each module are described in the BSR Guide Part I, above.

7.4 Framework Contents
PRINCIPLE 1. A COMPLIANT SYSTEM OF PROPERTY SUPPORTS THE MAJOR FACILITY.
Practice 1.1. The Recipient’s and Major Facility’s organizational structure responsible for property
management is documented and clearly outlined.
Practice 1.2. The collective positions in the property management organizational structure are
documented, and for each, the role, duties, authorities and reporting lines are clearly defined.
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.
Practice 3.2. Documented policies and procedures address disposition of property.

BSR Guide, NSF 22-102

Page 38 of 83

PART II – CORE FUNCTIONAL AREA REVIEW MODULES

7. PROPERTY MANAGEMENT
REVIEW MODULE

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.

BSR Guide, NSF 22-102

Page 39 of 83

APPENDICES

BSR Guide, NSF 22-102

Page 40 of 83

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 Federal statutes, Federal regulations, NSF policies, and other guidance.
The hierarchy of documentation, in order of precedence, is as follows:
•

2 CFR 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirement for
Federal Awards (Uniform Guidance)

•

41 CFR 101-39: Interagency Fleet Management Systems

•

NSF Proposal and Award Policies and Procedures Guide (PAPPG): The PAPPG comprises
documents relating to the NSF 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

•

Research Infrastructure Guide (RIG): Formerly known as the Major Facilities Guide (MFG),
Referenced in the PAPPG section, Research Infrastructure Proposal
Table 2. Citations/References and Abbreviations Used in 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 Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Awards
United States Code of Federal Regulations: Title 2, Subtitle A, Chapter II, XX (other
than the Uniform Guidance)
United States Code of Federal Regulations: Title 41, Subtitle C, Chapter 101,
Subchapter G, Part 101-39

Uniform Guidance

United States Government Accountability Office Cost Estimating and Assessment
Guide: Best Practices for Developing and Managing Program Costs

GAO Cost Estimating Guide

2 CFR XX.xxx

41 CFR 101-39 –
Interagency Fleet
Management
Systems
United States Code: Title 41, Subtitle IV, Chapter 81, §§8101-8106
41 USC 81 Drug-Free
Workplace
Federal Acquisition Regulation: Title 48, Chapter 1, Subchapter E, Part 31
FAR Part 31 (Contract Cost
Principles and Procedures)
Cooperative Agreement Financial and Administrative Terms and Conditions
CA-FATC
Cooperative Agreement Modifications and Supplemental Financial and Administrative CA Mod & Supp FATC
Terms and Conditions for Major Multi-User Research Facility Projects and Federally
for Major Facilities &
Funded Research and Development Centers
FFRDC
NSF Award Specific Terms and Conditions
NSF Award Specific Terms
and Conditions
NSF Programmatic Terms and Conditions
NSF Programmatic Terms
and Conditions
NSF Proposal and Award Policies and Procedures Guide, NSF 22-1
PAPPG
NSF Research Infrastructure Guide, NSF 21-107
RIG
The Committee of Sponsoring Organizations of the Treadway Commission (COSO)
COSO Control Environment
Internal Control – Integrated Framework

BSR Guide, NSF 22-102

Page 41 of 83

APPENDIX A

LIST OF REFERENCES AND QUESTIONS

A matrix with relevant citations/references specific to each principle/practice is provided. The
citations/references reflect the version of the Uniform Guidance that was in force at the time of
publication. Subsequent updates available after publication supersede those listed. 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:
•

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

BSR Guide, NSF 22-102

Page 42 of 83

APPENDIX A

A-1. GENERAL MANAGEMENT REFERENCES AND QUESTIONS

A-1. General Management Principles, Practices, References, and Questions
General Management

Citation/Reference/
Subsequent Update
PRINCIPLE 1. A COMPLIANT STRUCTURE OF GENERAL MANAGEMENT FUNCTIONS SUPPORTS
THE MAJOR FACILITY.
Practice 1.1. The Recipient’s and Major Facility’s
organizational structure responsible for general
management is documented and clearly outlined.
Practice 1.2. The collective positions in the general
management organizational structure are
documented, and for each, the role, duties,
authorities and reporting lines are clearly defined.
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.

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

• COSO Control Environment Principle 4

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 do the Recipient or Major Facility have for continuing
training to support this administrative business function, including sharing of lessons learned?
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 CONTROL ENVIRONMENT SUPPORTS THE MAJOR FACILITY.
Practice 2.1. Documented policies and procedures
address integrity, ethical values and conflicts of
interest.

BSR Guide, NSF 22-102

• Uniform Guidance 2 CFR §200.112, Conflict
of interest
• Uniform Guidance 2 CFR §200.303, Internal
controls
• COSO Control Environment Principle 1
• PAPPG Chapter IX A. Conflict of Interest
Policies
• PAPPG Chapter IX B. Responsible and Ethical
Conduct of Research (RECR)

Page 43 of 83

APPENDIX A

General Management

A-1. GENERAL MANAGEMENT REFERENCES AND QUESTIONS

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.

Citation/Reference/
Subsequent Update

• Uniform Guidance 2 CFR §200.303, Internal
controls
• COSO Control Environment Principle 2
• Uniform Guidance 2 CFR §200.303, Internal
controls
• COSO Control Environment Principle 3
• COSO Information and Communication
Principle 13

• Uniform Guidance 2 CFR §200.501, Audit
requirements
• Uniform Guidance 2 CFR §200.502, Basis for
determining Federal awards expended

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

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?
What standards (i.e., Standards for Internal Control, COSO) does the Recipient follow in
managing its entity level control activities?

BSR Guide, NSF 22-102

Page 44 of 83

APPENDIX A

General Management

A-1. GENERAL MANAGEMENT REFERENCES AND QUESTIONS

Citation/Reference/
Subsequent Update
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.

• COSO Risk Assessment Principle 6
• COSO Risk Assessment Principle 7
• COSO Risk Assessment Principle 8
• COSO Risk Assessment Principle 8
• COSO Control Activities Principle 10
• COSO Control Environment Principle 1
• COSO Information and Communication
Principle 14
• COSO Information and Communication
Principle 15

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

How does 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?

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.

BSR Guide, NSF 22-102

Page 45 of 83

APPENDIX A

General Management

A-1. GENERAL MANAGEMENT REFERENCES AND QUESTIONS

Practice 4.3. Documented policies and procedures
specify the Recipient’s methods for collecting,
transmitting and storing Federal award-related
information.

Practice 4.5. Documented policies and procedures
address public access to the records pertinent to the
Federal award.

BSR Guide, NSF 22-102

Citation/Reference/
Subsequent Update

• Uniform Guidance 2 CFR §200.334,
Retention requirements for records
• Uniform Guidance 2 CFR §200.335, Requests
for transfer of records
• Uniform Guidance 2 CFR §200.336, Methods
for collection, transmission, and storage of
information
• Uniform Guidance 2 CFR §200.337, Access to
records
• Uniform Guidance 2 CFR §200.338,
Restrictions on public access to records
• Uniform Guidance 2 CFR §200.334,
Retention requirements for records
• Uniform Guidance 2 CFR §200.335, Requests
for transfer of records
• Uniform Guidance 2 CFR §200.336, Methods
for collection, transmission, and storage of
information
• Uniform Guidance 2 CFR §200.337, Access to
records
• Uniform Guidance 2 CFR §200.338,
Restrictions on public access to records
• Uniform Guidance 2 CFR §200.334,
Retention requirements for records
• Uniform Guidance 2 CFR §200.335, Requests
for transfer of records
• Uniform Guidance 2 CFR §200.336, Methods
for collection, transmission, and storage of
information
• Uniform Guidance 2 CFR §200.337, Access to
records
• Uniform Guidance 2 CFR §200.338,
Restrictions on public access to records

Page 46 of 83

APPENDIX A

General Management

A-1. GENERAL MANAGEMENT REFERENCES AND QUESTIONS

Citation/Reference/
Subsequent Update

QUESTIONS/FOCUS AREAS PRINCIPLE 4.
•
•
•
•
•
•
•
•
•
•

•
•
•
•
•
•

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
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.

BSR Guide, NSF 22-102

• COSO Control Activities Principle 11
• COSO Control Activities Principle 11

• NSF Programmatic Terms and Conditions

Page 47 of 83

APPENDIX A

General Management

A-1. GENERAL MANAGEMENT REFERENCES AND QUESTIONS

Citation/Reference/
Subsequent Update

QUESTIONS/FOCUS AREAS PRINCIPLE 5.
•
•
•
•
•
•
•
•
•
•

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
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.

• Uniform Guidance 2 CFR §200.303, Internal
controls

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.

BSR Guide, NSF 22-102

Page 48 of 83

APPENDIX A

A-2. AWARD MANAGEMENT REFERENCES AND QUESTIONS

A-2. Award Management Principles, Practices, References, and Questions
Award Management

Citation/Reference/
Subsequent Update
PRINCIPLE 1. A COMPLIANT STRUCTURE OF AWARD MANAGEMENT FUNCTIONS SUPPORTS
THE MAJOR FACILITY.
Practice 1.1. The Recipient’s and Major Facility’s
organizational structure responsible for award
management is documented and clearly outlined.
Practice 1.2. The collective positions in the award
management organizational structure are
documented, and for each, the role, duties,
authorities and reporting lines are clearly defined.
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, including sharing of lessons learned?
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?

BSR Guide, NSF 22-102

Page 49 of 83

APPENDIX A

Award Management

A-2. AWARD MANAGEMENT REFERENCES AND QUESTIONS

Citation/Reference/
Subsequent Update
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.

BSR Guide, NSF 22-102

• Uniform Guidance 2 CFR §200.213, Reporting
a determination that a non-Federal entity is
not qualified for a Federal award
• Uniform Guidance 2 CFR §200.214,
Suspension and debarment
• Uniform Guidance 2 CFR §200.300, Statutory
and national policy requirements
• Uniform Guidance 2 CFR §200.458, Pre-award
costs
• 2 CFR §25.200, Requirements for notice of
funding opportunities, regulations, and
application instructions
• 2 CFR §25.205, Effect of noncompliance with
a requirement to obtain a unique entity
identifier or register in the SAM
• 2 CFR §25.APPENDIX A to Part 25—Award
Term
• Uniform Guidance 2 CFR §200.300, Statutory
and national policy requirements
• Uniform Guidance 2 CFR §200.302, Financial
management
• Uniform Guidance 2 CFR §200.308, Revision
of budget and program plans
• Uniform Guidance 2 CFR §200.309,
Modifications to Period of Performance
• Uniform Guidance 2 CFR §200.329,
Monitoring and reporting program
performance
• 2 CFR §25.APPENDIX A to Part 25—Award
Term
• Uniform Guidance 2 CFR §200.209,
Certifications and representations
• Uniform Guidance 2 CFR §200.344, Closeout
• Uniform Guidance 2 CFR §200.345, Postcloseout adjustments and continuing
responsibilities
• Uniform Guidance 2 CFR §200.346, Collection
of amounts due

Page 50 of 83

APPENDIX A

Award Management

A-2. AWARD MANAGEMENT REFERENCES AND QUESTIONS

Citation/Reference/
Subsequent Update

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

•
•
•
•
•
•

•
•
•
•
•

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 information about itself to
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 is the process for distributing the information on 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?
How does the Recipient relate financial data and accomplishments to performance goals and
objectives of the Federal award, demonstrating cost effective practices?
What mechanisms does the Recipient have in place to review and negotiate award terms and
conditions?

BSR Guide, NSF 22-102

Page 51 of 83

APPENDIX A

Award Management

A-2. AWARD MANAGEMENT REFERENCES AND QUESTIONS

Citation/Reference/
Subsequent Update
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.

• Uniform Guidance 2 CFR §200.331,
Subrecipient and contractor determinations

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.

• Uniform Guidance 2 CFR §200.332,
Requirements for pass-through entities

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.

BSR Guide, NSF 22-102

• Uniform Guidance 2 CFR §200.206, Federal
awarding agency review of risk posed by
applicants
• Uniform Guidance 2 CFR §200.303, Internal
controls
• Uniform Guidance 2 CFR §200.329,
Monitoring and reporting program
performance
• Uniform Guidance 2 CFR §200.332,
Requirements for pass-through entities
• 2 CFR §25.300, Requirement for recipients to
ensure subrecipients have a unique entity
identifier
• COSO Control Environment Principles 1–5

• 2 CFR §183.25, Responsibilities of recipients
• 2 CFR §183.APPENDIX A to Part 183—Award
Terms for Never Contract With the Enemy
• Uniform Guidance 2 CFR §200.202, Program
planning and design
• Uniform Guidance 2 CFR §200.215, Never
contract with the enemy
• Uniform Guidance 2 CFR §200.216,
Prohibition on certain telecommunications
and video surveillance services or equipment
• Uniform Guidance 2 CFR §200.300, Statutory
and national policy requirements
• Uniform Guidance 2 CFR §200.301,
Performance measurement
• Uniform Guidance 2 CFR §200.329,
Monitoring and reporting program
performance
• Uniform Guidance 2 CFR §200.332,
Requirements for pass-through entities
• Uniform Guidance 2 CFR §200.332,
Requirements for pass-through entities
• Uniform Guidance 2 CFR §200.339, Remedies
for noncompliance
• Uniform Guidance 2 CFR §200.340,
Termination
• Uniform Guidance 2 CFR §200.341,
Notification of termination requirement
• Uniform Guidance 2 CFR §200.342,
Opportunities to object, hearings, and
appeals
• Uniform Guidance 2 CFR §200.343, Effects of
suspension and termination

Page 52 of 83

APPENDIX A

Award Management

A-2. AWARD MANAGEMENT REFERENCES AND QUESTIONS

Practice 3.6. Documented policies and procedures
explain the requirements and process to provide
fixed amount subawards.

Citation/Reference/
Subsequent Update

• Uniform Guidance 2 CFR §200.333, 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?
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?
In its capacity as a pass-through entity, how does the Recipient carry out and document the
various requirements with its subrecipients?

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.

BSR Guide, NSF 22-102

• Uniform Guidance 2 CFR §200.303, Internal
controls

• Uniform Guidance 2 CFR §200.303, Internal
controls
• Uniform Guidance 2 CFR §200.339, Remedies
for noncompliance
• Uniform Guidance 2 CFR §200.340,
Termination
• Uniform Guidance 2 CFR §200.341,
Notification of termination requirement
• Uniform Guidance 2 CFR §200.342,
Opportunities to object, hearings, and
appeals
• Uniform Guidance 2 CFR §200.343, Effects of
suspension and termination

Page 53 of 83

APPENDIX A

Award Management

A-2. AWARD MANAGEMENT REFERENCES AND QUESTIONS

Citation/Reference/
Subsequent Update

QUESTIONS/FOCUS AREAS PRINCIPLE 4.
•
•
•
•
•
•
•
•
•

What mechanisms does the Recipient have in place to monitor the NSF award, websites,
publications, and policy issuances to keep current and to manage the statutory and national
policy requirements included in the Federal award?
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?
How does the Recipient's and Major Facility's policies and procedures address the NSF term and
condition on foreign collaborators?
What reviews are conducted of foreign collaborations listed in the current and pending support
of proposals and other staff disclosures such as conflict of interest and/or commitment?
What records are maintained to document the review and monitoring of the foreign
collaborations?

To return to the module review, click Award Management Review Module

BSR Guide, NSF 22-102

Page 54 of 83

APPENDIX A

A-3. BUDGET PLANNING AND EXECUTION REFERENCES AND QUESTIONS

A-3. Budget Planning and Execution Principles, Practices, References, and Questions
Budget Planning and Execution

Citation/Reference/
Subsequent Update
PRINCIPLE 1. A COMPLIANT STRUCTURE OF BUDGET PLANNING AND EXECUTION FUNCTIONS
SUPPORTS THE MAJOR FACILITY.
Practice 1.1. The Recipient’s and Major Facility’s
organizational structure responsible for budget
planning and execution is documented and clearly
outlined.
Practice 1.2. The collective positions in the budget
planning and execution organizational structure are
documented, and for each, the role, duties,
authorities and reporting lines are clearly defined.
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 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, including sharing of lessons learned?
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 22-102

Page 55 of 83

APPENDIX A

A-3. BUDGET PLANNING AND EXECUTION REFERENCES AND QUESTIONS

Budget Planning and Execution

Citation/Reference/
Subsequent Update
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).

• GAO Cost Estimating Guide
• PAPPG Chapter II C.2g Budget and Budget
Justification
• PAPPG Chapter II E.13 Research Infrastructure
Proposal
• RIG 4.2 Cost Estimating and Analysis

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.

• Uniform Guidance 2 CFR §200.308, Revision
of budget and program plans
• RIG 4.2.1 Overview of Guidance and Process
for Both Construction and Operations Awards

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/subrecipient’s budget to assure
accuracy and compliance with Federal regulations
and requirements and needed refinement.

BSR Guide, NSF 22-102

• GAO Cost Estimating Guide
• RIG 4.2.2.6 Escalation
• RIG 4.2.3 Additional Guidance for
Construction Estimates
• RIG 4.2.4 Additional Guidance for Operations
Estimates
• PAPPG Chapter II C.2g Budget and Budget
Justification
• RIG 4.2.2 Elements of Both Construction and
Operations Estimates
• RIG 4.2.2.1 Cost Estimating Plan
• RIG 4.2.2.2 Estimate Formats
• RIG 4.2.2.4 Supplementary Guidance for NSF
Budget Categories from the PAPPG
• RIG 4.2.2.5 Fee
• RIG 4.2.2.7 Work Breakdown Structure (WBS)
• Uniform Guidance 2 CFR §200.302, Financial
management

Page 56 of 83

APPENDIX A

A-3. BUDGET PLANNING AND EXECUTION REFERENCES AND QUESTIONS

Budget Planning and Execution

Citation/Reference/
Subsequent Update

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

•
•
•
•
•
•
•
•
•
•

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
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.
BSR Guide, NSF 22-102

• Uniform Guidance 2 CFR §200.302, Financial
management

• Uniform Guidance 2 CFR §200.308, Revision
of budget and program plans
• Uniform Guidance 2 CFR §200.301,
Performance measurement

Page 57 of 83

APPENDIX A

A-3. BUDGET PLANNING AND EXECUTION REFERENCES AND QUESTIONS

Budget Planning and Execution

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.

Citation/Reference/
Subsequent Update

• Uniform Guidance 2 CFR §200.302, Financial
management

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

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 22-102

Page 58 of 83

APPENDIX A

A-4. FINANCIAL MANAGEMENT REFERENCES AND QUESTIONS

A-4. Financial Management Principles, Practices, References, and Questions
Financial Management

Citation/Reference/
Subsequent Update
PRINCIPLE 1. A COMPLIANT STRUCTURE OF FINANCIAL MANAGEMENT FUNCTIONS
SUPPORTS THE MAJOR FACILITY.
Practice 1.1. The Recipient’s and Major Facility’s
organizational structure responsible for financial
management is documented and clearly outlined.
Practice 1.2. The collective positions in the financial
management organizational structure are
documented, and for each, the role, duties,
authorities and reporting lines are clearly defined.
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, including sharing of lessons learned?
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 22-102

• Uniform Guidance 2 CFR §200.302, Financial
management

Page 59 of 83

APPENDIX A

Financial Management

A-4. FINANCIAL MANAGEMENT REFERENCES AND QUESTIONS

Citation/Reference/
Subsequent Update

Practice 2.2. Documented policies and procedures
require that records identify the source and
application of funds for Federally-funded activities
through a chart of accounts.

• Uniform Guidance 2 CFR §200.302, Financial
management
• Uniform Guidance 2 CFR §200.414, Indirect
(F&A) costs
• Uniform Guidance 2 CFR §200.418, Costs
incurred by states and local governments
Practice 2.3. Documented policies and procedures
• Uniform Guidance 2 CFR §200.301,
Performance measurement
address the generation of required reports and
•
Uniform
Guidance 2 CFR §200.302, Financial
specify the use of detailed receipt and expenditure of
management
funds related to the award.
• Uniform Guidance 2 CFR §200.403, Factors
affecting allowability of costs
• Uniform Guidance 2 CFR §200.415, Required
certifications
• Uniform Guidance 2 CFR §200.419, Cost
accounting standards and disclosure
statement
•FAR Part 31
Practice 2.4. Documented policies and procedures
• Uniform Guidance 2 CFR §200.302, Financial
management
specify how accurate, current and complete
reporting of the financial results of the Federal award
or Program is assured.
Practice 2.5. Documented policies and procedures
• Uniform Guidance 2 CFR §200.305, Federal
payment
implement the required payment methods.
• Uniform Guidance 2 CFR §200.415, Required
certifications
Practice 2.6. Documented policies and procedures
• Uniform Guidance 2 CFR §200.302, Financial
management
explain how the allowability of cost is determined
•
Uniform
Guidance 2 CFR §200.403, Factors
and reviewed.
affecting allowability of costs
• Uniform Guidance 2 CFR §200 Subpart E—
Cost Principles
Practice 2.7. Documented policies and procedures
• Uniform Guidance 2 CFR §200.APPENDIX III to
Part 200—Indirect (F&A) Costs Identification
address how the Recipient correctly applies current
and Assignment, and Rate Determination for
Federally negotiated indirect cost rates.
Institutions of Higher Education (IHEs)
• Uniform Guidance 2 CFR §200.APPENDIX IV to
Part 200—Indirect (F&A) Costs Identification
and Assignment, and Rate Determination for
Nonprofit Organizations
• Uniform Guidance 2 CFR §200.APPENDIX V to
Part 200—State/Local Governmentwide
Central Service Cost Allocation Plans
• Uniform Guidance 2 CFR §200.APPENDIX VII
to Part 200—States and Local Government
and Indian Tribe Indirect Cost Proposals
• Uniform Guidance 2 CFR §200.APPENDIX VIII
to Part 200—Nonprofit Organizations
Exempted From Subpart E of Part 200

BSR Guide, NSF 22-102

Page 60 of 83

APPENDIX A

Financial Management

A-4. FINANCIAL MANAGEMENT REFERENCES AND QUESTIONS

Citation/Reference/
Subsequent Update

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

Does the Major Facility in construction have a Segregation of Funding 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 and
state requirements?
Where are the relevant data fields outlined and defined for users? (assistance listing program
title and number, Federal award identification number and year, name of the Federal awarding
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 awarding agency 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?
If a Recipient has a Federally negotiated indirect cost rate agreement (NICRA), how is it

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

BSR Guide, NSF 22-102

• Uniform Guidance 2 CFR §200.305, Federal
payment
• PAPPG Chapter VIII Financial Requirements
and Payments
• Uniform Guidance 2 CFR §200.307, Program
income
• PAPPG Chapter VIII Financial Requirements
and Payments
• PAPPG Chapter VIII Financial Requirements
and Payments

Page 61 of 83

APPENDIX A

Financial Management

A-4. FINANCIAL MANAGEMENT REFERENCES AND QUESTIONS

Citation/Reference/
Subsequent Update

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
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.

• 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 Financial Management Review Module.

BSR Guide, NSF 22-102

Page 62 of 83

APPENDIX A

A-5. HUMAN RESOURCES MANAGEMENT REFERENCES AND QUESTIONS

A-5. Human Resources Management Principles, Practices, References, and Questions
Human Resources Management

Citation/Reference/
Subsequent Update
PRINCIPLE 1. A COMPLIANT SYSTEM TO SUPPORT HUMAN RESOURCES MANAGEMENT
FUNCTIONS SUPPORTS THE MAJOR FACILITY.
Practice 1.1. The Recipient’s and Major Facility’s
organizational structure responsible for human
resources management is documented and clearly
outlined.
Practice 1.2. The collective positions in the human
resources management organizational structure are
documented, and for each, the role, duties,
authorities and reporting lines are clearly defined.
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 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, including sharing of lessons learned?
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 22-102

• PAPPG Chapter II C.1d Proposal Certifications
• PAPPG Chapter XI A. Non-Discrimination
Statutes and Regulations

Page 63 of 83

APPENDIX A

A-5. HUMAN RESOURCES MANAGEMENT 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/
Subsequent Update

• PAPPG Chapter II C.1d Proposal Certifications
• PAPPG Chapter IX A. Conflict of Interest Policies

• PAPPG Chapter II C.1d Proposal Certifications
• PAPPG Chapter XI A. Non-Discrimination
Statutes and Regulations

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 non-discrimination
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
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.

• 41 USC 81 Drug-Free Workplace

• 41 USC 81 Drug-Free Workplace
• 41 USC 81 Drug-Free Workplace

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 22-102

Page 64 of 83

APPENDIX A

A-5. HUMAN RESOURCES MANAGEMENT REFERENCES AND QUESTIONS

Human Resources Management

Citation/Reference/
Subsequent Update
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 22-102

• COSO Control Environment Principle 4

Page 65 of 83

APPENDIX A

A-5. HUMAN RESOURCES MANAGEMENT REFERENCES AND QUESTIONS

Human Resources Management

Citation/Reference/
Subsequent Update

QUESTIONS/FOCUS AREAS PRINCIPLE 4.
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•

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?
How does the Recipient assure that its workforce collectively possesses a broad range of essential
professional competencies to manage the Major Facility?

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
address written performance goals, objectives and
metrics/expectations for the established
performance period.

BSR Guide, NSF 22-102

• COSO Control Environment Principle 5

Page 66 of 83

APPENDIX A

A-5. HUMAN RESOURCES MANAGEMENT REFERENCES AND QUESTIONS

Human Resources Management

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.

Citation/Reference/
Subsequent Update

• COSO Control Environment Principle 5

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
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.

• Uniform Guidance 2 CFR §200.303, Internal
controls

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 22-102

Page 67 of 83

APPENDIX A

A-6. PROCUREMENT REFERENCES AND QUESTIONS

A-6. Procurement Principles, Practices, References, and Questions
Procurement

Citation/Reference/
Subsequent Update
PRINCIPLE 1. A COMPLIANT STRUCTURE OF PROCUREMENT FUNCTIONS SUPPORTS THE MAJOR
FACILITY.
Practice 1.1. The Recipient’s and Major Facility’s
organizational structure responsible for procurement
is documented and clearly outlined.
Practice 1.2. The collective positions in the
procurement organizational structure are
documented, and for each, the role, duties,
authorities and reporting lines are clearly defined.
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 3
• COSO Control Environment Principle 3

• 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, including sharing of lessons learned?
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 22-102

Page 68 of 83

APPENDIX A

Procurement

A-6. PROCUREMENT REFERENCES AND QUESTIONS

Citation/Reference/
Subsequent Update
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
address the considerations for determining
responsible contractors.
Practice 2.3. Documented policies and procedures
specify oversight of contractors’ performance.

Practice 2.4. 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 2.5. Documented policies and procedures
address steps to avoid unnecessary purchases or
duplicative items, and appropriate analysis to
determine the most economical approach.
Practice 2.6. 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 2.7. Documented policies and procedures
require the maintenance of records with details
required to show the procurement history.

Practice 2.8. Documented policies and procedures
specify conditions for use of time and materials
contract types.
Practice 2.9. Documented policies and procedures
require settlement of all contractual and
administrative issues arising out of procurements.

BSR Guide, NSF 22-102

• Uniform Guidance 2 CFR §200.317,
Procurements by states
• Uniform Guidance 2 CFR §200.318, General
procurement standards
• Uniform Guidance 2 CFR §200.318, General
procurement standards
• Uniform Guidance 2 CFR §200.318, General
procurement standards
• Uniform Guidance 2 CFR §200.APPENDIX II to
Part 200—Contract Provisions for Non-Federal
Entity Contracts Under Federal Awards
• Uniform Guidance 2 CFR §200.318, General
procurement standards

• Uniform Guidance 2 CFR §200.318, General
procurement standards

• Uniform Guidance 2 CFR §200.318, General
procurement standards
• Uniform Guidance 2 CFR §200.322, Domestic
preferences for procurements
• Infrastructure Investment and Jobs Act, Public
Law 117-58, §§70911-70917, Title IX Build
America, Buy America
• Uniform Guidance 2 CFR §200.318, General
procurement standards
• Uniform Guidance 2 CFR §200.318, General
procurement standards

Page 69 of 83

APPENDIX A

Procurement

A-6. PROCUREMENT REFERENCES AND QUESTIONS

Citation/Reference/
Subsequent Update

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

What steps are taken and how frequently does the Recipient assess the compliance and alignment
of its state or 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 for contracts greater than the simplified acquisition threshold on issues such
as source evaluation, protests, disputes, claims, and other issues, including provisions for
contractual or legal remedies?

PRINCIPLE 3. COMPLIANT PROCUREMENTS PROVIDE FULL AND OPEN COMPETITION TO
SUPPORT THE MAJOR FACILITY.
Practice 3.1. Documented policies and procedures
ensure objective assessment of contractor
performance and elimination of 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.

BSR Guide, NSF 22-102

• Uniform Guidance 2 CFR §200.319, Competition

Page 70 of 83

APPENDIX A

Procurement

A-6. PROCUREMENT REFERENCES AND QUESTIONS

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.

Citation/Reference/
Subsequent Update

• Uniform Guidance 2 CFR §200.319, Competition

QUESTIONS/FOCUS AREAS PRINCIPLE 3.
•

•
•
•
•
•
•
•
•
•
•

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
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
proposals address the conditions for use and
applicable requirements of proposals, technical
evaluations, award selection and application to
architectural/engineering professional services.
BSR Guide, NSF 22-102

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

Page 71 of 83

APPENDIX A

Procurement

A-6. PROCUREMENT REFERENCES AND QUESTIONS

Practice 4.5. Documented policies and procedures for
noncompetitive procurement should address the
required circumstances for use.

Citation/Reference/
Subsequent Update

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

QUESTIONS/FOCUS AREAS PRINCIPLE 4.
•
•
•

•
•
•
•

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 pass-through 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, LABOR SURPLUS AREA FIRMS, AND
DOMESTIC PREFERENCE REQUIREMENTS 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 and that
domestic preference requirements for the purchase,
acquisition, or use of goods, products, or materials
are met.

• Uniform Guidance 2 CFR §200.321, Contracting
with small and minority businesses, women's
business enterprises, and labor surplus area
firms
• Uniform Guidance 2 CFR §200.322, Domestic
preferences for procurements
• Infrastructure Investment and Jobs Act, Public
Law 117-58, §§70911-70917, Title IX Build
America, Buy America

QUESTIONS/FOCUS AREAS PRINCIPLE 5.
•
•
•
•

How does the procurement process assure that minority businesses, women's business
enterprises, and labor surplus area firms are used when possible?
How does the Recipient align with domestic preference procurement requirements. (e.g., domestic
preferences, flow-down requirement, retention of records)?
For Research Infrastructure implementation awards, how does the Recipient document or
substantiate any circumstance where it was not possible to acquire suitable U.S. domestic goods,
products, or materials (i.e., domestic non-availability)?
How does the Recipient document any Build America, Buy America waiver requests, when not
purchasing American made iron, steel, manufactured products, and construction materials to be
used in any form of construction, alteration, maintenance, or repair of infrastructure in the United
States?

BSR Guide, NSF 22-102

• Uniform Guidance 2 CFR §200.323,
Procurement of recovered materials

Page 72 of 83

APPENDIX A

Procurement

A-6. PROCUREMENT REFERENCES AND QUESTIONS

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.

Citation/Reference/
Subsequent Update

• Uniform Guidance 2 CFR §200.216, Prohibition
on certain telecommunications and video
surveillance services or equipment
• Uniform Guidance 2 CFR §200.322, Domestic
preferences for procurements
• Uniform Guidance 2 CFR §200.324, Contract
cost and price
• Uniform Guidance 2 CFR §200.327, Contract
provisions
• Infrastructure Investment and Jobs Act, Public
Law 117-58, §§70911-70917, Title IX Build
America, Buy America
• Uniform Guidance 2 CFR §200.324, Contract
cost and price
• Uniform Guidance 2 CFR §200.326, Bonding
requirements

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

What checklists or tools are used to verify that procured items which meet specified requirements
align with the guidelines of the EPA?
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?
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/subcontracts, and is bonding addressed?
How does the Recipient align with the prohibition on procuring or obtaining covered
telecommunication equipment or services, including transition from covered equipment and
services?

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.

BSR Guide, NSF 22-102

• Uniform Guidance 2 CFR §200.324, Contract
cost and price

• Uniform Guidance 2 CFR §200.325, Federal
awarding agency or pass-through entity review

• Uniform Guidance 2 CFR §200.324, Contract
cost and price
• Uniform Guidance 2 CFR §200.325, Federal
awarding agency or pass-through entity review

Page 73 of 83

APPENDIX A

Procurement

A-6. PROCUREMENT REFERENCES AND QUESTIONS

Citation/Reference/
Subsequent Update

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, subcontracting 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)?

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 awarding
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 awarding agency.

• Uniform Guidance 2 CFR §200.325, Federal
awarding agency or pass-through entity review
• Uniform Guidance 2 CFR §200.325, Federal
awarding agency or pass-through entity review
• Uniform Guidance 2 CFR §200.325, Federal
awarding 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-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.

• 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 22-102

Page 74 of 83

APPENDIX A

A-7. PROPERTY MANAGEMENT REFERENCES AND QUESTIONS

A-7. Property Management Principles, Practices, References, and Questions
Property Management

Citation/Reference/
Subsequent Update
PRINCIPLE 1. A COMPLIANT SYSTEM OF PROPERTY SUPPORTS THE MAJOR FACILITY.
Practice 1.1. The Recipient’s and Major Facility’s
organizational structure responsible for property
management is documented and clearly outlined.
Practice 1.2. The collective positions in the property
management organizational structure are
documented, and for each, the role, duties,
authorities and reporting lines are clearly defined.
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, including sharing of lessons learned?
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 22-102

Page 75 of 83

APPENDIX A

Property Management

A-7. PROPERTY MANAGEMENT REFERENCES AND QUESTIONS

Citation/Reference/
Subsequent Update
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, Federallyowned 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, and Recipient-owned: capital assets having a useful life of
greater than one year, real property, personal property/equipment, 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)?
How does the Recipient perform and document property valuation, including work-in-progress
(WIP) and construction-in-progress (CIP)?

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.

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

BSR Guide, NSF 22-102

• Uniform Guidance 2 CFR §200.311, Real
property
• Uniform Guidance 2 CFR §200.312, Federallyowned and exempt property
• Uniform Guidance 2 CFR §200.313, Equipment
• Uniform Guidance 2 CFR §200.311, Real
property
• Uniform Guidance 2 CFR §200.312, Federallyowned and exempt property
• Uniform Guidance 2 CFR §200.313, Equipment
• Uniform Guidance 2 CFR §200.315, Intangible
property

Page 76 of 83

APPENDIX A

Property Management

A-7. PROPERTY MANAGEMENT REFERENCES AND QUESTIONS

Citation/Reference/
Subsequent Update

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.
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.

BSR Guide, NSF 22-102

• Uniform Guidance 2 CFR §200.311, Real
property
• Uniform Guidance 2 CFR §200.313, Equipment
• Uniform Guidance 2 CFR §200.310, Insurance
coverage
• Uniform Guidance 2 CFR §200.313, Equipment

• Uniform Guidance 2 CFR §200.332,
Requirements for pass-through entities

Page 77 of 83

APPENDIX A

Property Management

A-7. PROPERTY MANAGEMENT REFERENCES AND QUESTIONS

Citation/Reference/
Subsequent Update

QUESTIONS/FOCUS AREAS PRINCIPLE 4.
•
•
•
•
•
•
•
•
•
•
•
•

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?
How does the Recipient make the determination on what to insure and the necessary coverage for
real property and equipment acquired or improved with Federal funds?
How does the Recipient record and report on Federal ownership and NSF's conditional interest in
property?

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 22-102

• Uniform Guidance 2 CFR §200.312, Federallyowned and exempt property
• Uniform Guidance 2 CFR §200.313, Equipment
• 41 CFR §101-39, Interagency Fleet Management
Systems
• Uniform Guidance 2 CFR §200.1, Definitions
• Uniform Guidance 2 CFR §200.313, Equipment
• Uniform Guidance 2 CFR §200.330, Reporting
on real property
• 41 CFR §101-39, Interagency Fleet Management
Systems

Page 78 of 83

APPENDIX A

Property Management

A-7. PROPERTY MANAGEMENT REFERENCES AND QUESTIONS

Citation/Reference/
Subsequent Update

QUESTIONS/FOCUS AREAS PRINCIPLE 5.
•
•
•
•
•

•

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
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.

• Uniform Guidance 2 CFR §200.303, Internal
controls

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 22-102

Page 79 of 83

APPENDIX B

APPENDIX B: LIST OF ACRONYMS
AM
AOR
BFA
BPE
BSR
CA
CA-FATC
CAP
CASB
CFA
CFO
CFR
CIP
COGR
COI
COSO
DACS
DCAA
DIAS
FAR
FASB
FFRDC
FM
GAO
G/AO
GM
HLFO
HRM
IPT
LFO
MREFC
NSF
O&M
OIG
OMB
ONR
PAPPG
PI
PII
PM
POC
PR
R&RA
RAM
RIG
SOG
SOP
USC
WIP

LIST OF ACRONYMS

Award Management
Authorized Organizational Representative
Office of Budget, Finance and Award Management
Budget Planning and Execution
Business Systems Review
Cooperative Agreement
Cooperative Agreement Financial and Administrative Terms and Conditions
Cost Analysis and Pre-Award Branch
Cost Accounting Standard Board
Core Functional Area
Chief Financial Officer
Code of Federal Regulations
Construction-in-Progress
Council on Government Relations
Conflict of Interest
The Committee of Sponsoring Organizations of the Treadway Commission
Division of Acquisition and Cooperative Support
Defense Contract Audit Agency
Division of Institution and Award Support
Federal Acquisition Regulation
Financial Accounting Standards Board
Federally Funded Research and Development Center
Financial Management
Government Accountability Office
Grants and Agreements Officer
General Management
Head, Large Facilities Office
Human Resources Management
Integrated Project Team
Large Facilities Office
Major Research Equipment and Facilities Construction
National Science Foundation
Operations and Maintenance
Office of Inspector General
Office of Management and Budget
Office of Naval Research
Proposal and Award Policies and Procedures Guide
Principal Investigator
Personally Identifiable Information
Property Management
Point of Contact
Procurement
Research and Related Activities
Resolution and Advanced Monitoring
Research Infrastructure Guide
Standard Operating Guidance
Standard Operating Procedure
United States Code
Work-in-Progress

BSR Guide, NSF 22-102

Page 80 of 83

APPENDIX C

APPENDIX C: GLOSSARY
Cooperative Agreement

GLOSSARY

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 Recipient 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 Recipient in carrying out the
activity contemplated by the NSF award. 2
Core functional area (CFA) Part of the administrative business system framework which organizes
the review focus by the business topics of General Management, Award
Management, Financial Management, Budget Planning and Execution,
Human Resource Management, Procurement, and Property
Management.
Equipment
Tangible personal property (including information technology systems)
having a useful life of more than one year and a per-unit acquisition cost
which equals or exceeds the lesser of the capitalization level established
by the non-Federal entity for financial statement purposes, or $5,000. 3
Expenditure
A charge made by a non-Federal entity to a project or program for which
a Federal award was received. 4
Facility Life Cycle
There are five stages in a facility’s life cycle – development, design,
construction, operations, and divestment. 5
Federal awarding agency The Federal agency that provides Federal financial assistance to
recipients. 6
Federal program
All Federal awards which are assigned a single Assistance Listings Number
(formerly, CFDA number); includes clusters of programs such as Research
and Development (R&D). 7
Federally-owned property Property where title to the property remains vested in the Federal
Government. 8
Fixed amount subaward
A type of grant or cooperative agreement under which the Federal
awarding agency or pass-through entity provides a specific level of
support without regard to actual costs incurred under the Federal award.
This type of Federal award reduces some of the administrative burden
and record-keeping requirements for both the non-Federal entity and
Federal awarding agency or pass-through entity. Accountability is based
primarily on performance and results. 9

Uniform Guidance 2 CFR §200.1, Definitions. Cooperative Agreement; Proposal and Award Policies and Procedure Guide, NSF
22-1
3
Uniform Guidance 2 CFR §200.1, Definitions. Equipment
4
Uniform Guidance 2 CFR §200.1, Definitions. Expenditure
5
RIG, NSF 21-107, December 2021
6
Uniform Guidance 2 CFR §200.1, Definitions. Federal awarding agency
7
Uniform Guidance 2 CFR §200.1, Definitions. Federal program
8
Uniform Guidance 2 CFR §200.1, Definitions. Federally-owned property
9
Uniform Guidance 2 CFR §200.1, Definitions. Fixed amount subaward

BSR Guide, NSF 22-102

Page 81 of 83

APPENDIX C

Integrated Project Team

GLOSSARY

The Integrated Project Team (IPT) serves as a formal internal NSF
coordinating body for major facilities oversight, chaired by the Program
Officer. The IPT 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. The core members of the IPT
are the Program Officer, Grants and Agreements Officer, and the LFO
Liaison. 10
Major Facility
Per Section 267 of the National Defense Authorization Act (NDAA) of FY
2021, a major multi-user research facility project (Major Facility) is a
science and engineering facility project that exceeds $100,000,000 in
total construction, acquisition, or upgrade costs to NSF. NSF interprets the
above to mean the Total Project Costs (TPC) as defined by the investment
in construction or acquisition, not the operations or associated science
program costs. If the TPC is above the major facility project threshold, it is
considered a major facility throughout its full life cycle. 11
A state, local government, Indian tribe, institution of higher education
Non-Federal entity
(IHE), or nonprofit organization that carries out a Federal award as a
recipient or subrecipient. 12
Information that can be used to distinguish or trace an individual's
Personally identifiable
identity, either alone or when combined with other personal or
information
identifying information that is linked or linkable to a specific individual.
"Protected" personally identifiable information (PII) is a critical
subcategory of PII that excludes PII required by law to be disclosed.
Protected PII includes an individual's first name or first initial and last
name in combination with any one or more of types of information,
including, but not limited to, social security number, passport number,
credit card numbers, clearances, bank numbers, biometrics, date and
place of birth, mother's maiden name, criminal, medical and financial
records, and educational transcripts. 13
Property trust relationship Real property, equipment, and intangible property that are acquired or
improved with a Federal award must be held in trust by the non-Federal
entity as trustee for the beneficiaries of the project or program under
which the property was acquired or improved. 14
Real property
Recipient

Land, including land improvements, structures and appurtenances
thereto, but excluding moveable machinery and equipment. 15
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 §200.1 Non-Federal entity. 16

Scoping

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.

Subaward

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 passthrough 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. 17

RIG, NSF 21-107, December 2021, Table 2.1.6-1 Summary of Principal Roles and Responsibilities of the core members of the
IPT (PO, G/AO or CO, and LFO Liaison) by Facility Life Cycle Stage
11
RIG, NSF 21-107, December 2021
12
Uniform Guidance 2 CFR §200.1, Definitions. Non-Federal entity
13
Uniform Guidance 2 CFR §200.1, Definitions. Personally Identifiable Information; Protected Personally Identifiable Information
14
Uniform Guidance 2 CFR §200.1, Definitions. Property trust relationship
15
Uniform Guidance 2 CFR §200.1, Definitions. Real property
16
Uniform Guidance 2 CFR §200.1, Definitions. Recipient
17
Uniform Guidance 2 CFR §200.1, Definitions. Subaward

BSR Guide, NSF 22-102

Page 82 of 83

APPENDIX C
Subrecipient

Supplies

18
19

GLOSSARY

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. 18
All tangible personal property other than property described in the
definition of equipment in this section. A computing device is a supply if
the acquisition cost is less than the lesser of the capitalization level
established by the non-Federal entity for financial statement purposes or
$5,000, regardless of the length of its useful life. 19

Uniform Guidance 2 CFR §200.1, Definitions. Subrecipient
Uniform Guidance 2 CFR §200.1, Definitions. Supplies

BSR Guide, NSF 22-102

Page 83 of 83

File Type	application/pdf
File Title	BSR_Guide_June 2022
Author	DHS NSF
File Modified	2022-07-22
File Created	2022-07-07