Site Visits

The U.S. National Science Foundation performs site visits as a component of its advanced monitoring of NSF awardee organizations.

NSF performs approximately 30 site visits each year.

The goals of site visits and NSF's other advanced monitoring activities are to:

  • Promote stewardship of federal funds.
  • Identify potential areas of awardee noncompliance.
  • Identify areas where NSF may provide business assistance to better organizations' award administration capacities.

What is a site visit?

The goals of a site visit are to assess:

  • An awardee organization's capacity for award administration.
  • An awardee organization's compliance with administrative regulations, public policy requirements and award terms and conditions, including those contained in the NSF program announcement/solicitation and the NSF grant or cooperative agreement.
  • The extent to which an organization maintains a controlled environment where awards are likely to be administered in compliance with federal financial and administrative regulations and NSF agreement provisions.

NSF also extends business assistance during site visits by offering award administration best practices and answering questions related to NSF expectations and federal award administration requirements.

 

Core review areas

Site visits include three core review areas:

Assesses the extent to which an organization has a sound organizational structure that will:

  • Protect assets.
  • Ensure against the incurrence of improper liabilities.
  • Ensure the accuracy and reliability of financial and operating information.

Assesses the sufficiency of an organization's financial management policies, procedures and controls to:

  • Accurately and completely disclose and document the financial results of federal awards.
  • Provide effective control and accountability of funds, property and other assets.
  • Determine the reasonableness, allocability and allowability of costs.

Verifies that organization reimbursements do not exceed cumulative expenses recorded in the accounting system as of the time reviewed and have not resulted in excess cash on hand. If funds are drawn in advance of expenditures incurred, verifies that funds are timely used.

Targeted review areas

Based on a pre-visit risk assessment, NSF also selects three to five of the following targeted review areas well in advance of the site visit:

Verifies that the claimed costs are reasonable, allocable and allowable per 2 CFR 200.459 and the Proposal and Award Policy and Procedures Guide (PAPPG), and that appropriate written agreements are in place.

Assesses an awardee organization's system for documenting and accounting for claimed cost-sharing amounts.

Verifies that the awardee organization has established procedures to ensure that final project reports are submitted promptly.

Verifies that the benefits claimed are reasonable, allocable and allowable to the awards to which they are charged.

Ascertains whether the awardee organization:

  • Has a negotiated indirect cost rate agreement (NICRA) or facilities and administrative (F&A) rate agreement established with NSF or another federal agency.
  • Is accounting for indirect costs per the applicable established agreement.
  • Is claiming indirect costs per the terms and conditions contained in the award agreement.

Ascertains whether the awardee organization has:

  • Appropriately and separately accounted for participant support costs.
  • Existing written policies and procedures to ensure compliance with all terms and conditions applicable to participant support costs.

Reviews and assesses practices and controls related to the procurement of supplies and other expendable property, equipment and other services procured with federal funds.

Assesses whether the awardee organization has policies and procedures to ensure compliance with accounting for proper use of program-related (award-generated) income per the award terms and conditions.

Assesses whether equipment purchased with federal funds is administered per federal and NSF requirements.

Determines if the awardee organization is aware of and in compliance with an award's special terms and conditions.

Verifies the awardee organization has documented a system of controls to assess risk for and monitor subawards issued under NSF-sponsored projects and that written subaward agreements are in place.

Verifies the awardee organization maintains a system to track and report effort and documented controls that support labor charges to NSF awards that comply with federal requirements.

Verifies that travel costs charged to NSF grants are documented, allocable and reasonable per the award terms and conditions and the applicable federal requirements.

Who receives site visits?

NSF prioritizes awardee organizations to participate in advanced monitoring (including desk reviews and site visits) based on:

  • The results of its annual award portfolio risk assessment.
  • Monitoring requests from NSF divisions.
  • Professional judgment.

NSF's annual risk assessment assigns each awardee organization to a review category. The assessment includes award factors such as institutional factors, prior NSF monitoring activities and results, and award administration and program staff feedback.

Site visit process

Site visits may be conducted in person or virtually.

The site visit process begins when NSF sends a letter notifying the awardee organization that they have been selected to participate in a site visit and options for the timing of the review. In many cases, a desk review will be scheduled before a site visit to gather preliminary information from the organization.

A month to six weeks before the site visit, the awardee organization receives a request for documentation from NSF. Reviewers typically look at three core review areas and a selection of three to four targeted review areas. 

 

Information frequently requested during a site review

In accordance with 2 CFR 200.303 "Internal controls," awardee organizations "must establish and maintain effective internal control" over federal awards, including written policies and procedures that promote consistency and clarity.

The following information and documentation are frequently requested during an NSF site visit review:

Core review areas

  1. Most recent single audit (formerly A-133 audit) report or recently audited financial statements.
  2. Current NICRA or F&A agreement.
  3. List of current board of directors members and bylaws.
  4. Overall organizational chart and other applicable organizational charts.
  5. Written policies and procedures regarding delegation of authority to legally commit the organization (i.e., approval for proposals, acceptance of awards and amendments).
  6. Written policies and procedures that describe the sponsored projects budget revision/amendment process.
  7. Completed sample budget revision.
  8. Written policies and procedures regarding sponsored projects budget and expenditure monitoring.
  9. Written policies and procedures that describe cost transfers/expenditure reclassifications between projects or awards.
  10. Written policies and procedures related to expenditure approval and competitive bidding.

  1. Accounting manual and date of last update. In lieu of an accounting manual, a set of common accounting policies (e.g., year-end closing, bank reconciliations, disbursements/payments).
  2. General ledger chart of accounts/expense code list, date of last update, and explanation of account hierarchy to understand how NSF funding is segregated in the accounting system.
  3. Written standards and procedures for determining the reasonableness, allocability and allowability of costs charged to federally funded projects.
  4. Written policies and procedures regarding the accounting treatment of unallowable direct and indirect costs.
  5. Written policies and procedures that describe standards for supporting documentation for transactions recorded in the organization's accounting system.
  6. Written policies and procedures on record retention standards for award agreements, financial reports, supporting documentation and other award-related records.
  7. Information regarding the system of personnel compensation used (e.g., hours worked, percent of time) for each category of employee (e.g., exempt and non-exempt/hourly staff).

  1. Recently prepared project cost ledger for the selected NSF award(s), printed directly from the accounting system within 10 days of the request, from the inception of the award to a date stipulated by the NSF analyst performing the desk review.
  2. Written policies and procedures regarding ACM$ preparation, approval and submission.

Target review areas

Each site visit typically just reviews a selection of three or four of these target areas.

  1. List of consultants being charged to the selected NSF award(s).
  2. Copies of consultant agreements selected by the reviewers.
  3. Written policies and procedures for the selection and management of consultants to include verification that consultants are not presently debarred, suspended, proposed for debarment, declared ineligible or voluntarily excluded from covered transactions by any federal department or agency.
  4. Copies of invoices paid to consultants under the selected NSF award(s).

  1. Written policies and procedures regarding identification of and accounting for cost-sharing activities.
  2. Documentation showing how the cost-sharing requirement is being met for the selected award(s).
  3. Copies of accounting records related to cost-sharing activities for the selected award(s).
  4. Copies of annual cost-sharing certifications.

  1. Written policies and procedures regarding the submission of final project reports and close-out of awards.

  1. Copy of a federally negotiated fringe benefits rate (if applicable).
  2. Written policies and procedures regarding identification of and accounting for fringe benefits.
  3. Written policies and procedures that address over-recovery and under-recovery, if a different rate is being used by the institution than what is federally negotiated.

  1. Copy of a NICRA or F&A agreement (if applicable).
  2. Written policies and procedures regarding identification of and accounting for indirect costs.

  1. Written policies and procedures regarding the identification of and accounting for participant support activities.
  2. Copy of any subsidiary ledger(s) used to record participant support activities.
  3. Documentation supporting participant support charges (e.g., participant lists).

  1. Organizational chart or other documentation showing all departments involved in the procurement process and their responsibilities.
  2. Written policies and procedures regarding the execution of all types of procurement.
  3. Documentation of delegations of authority authorizing individuals to approve procurement actions.

  1. Written policies and procedures related to accounting for program- or award-related income.
  2. Copy of general ledger account codes used to record program- or award-related income.
  3. Copies of recipient records to verify that program income was used to achieve program objectives.

  1. Written policies and procedures regarding the administration/tracking of equipment and supplies.
  2. Copies of records related to the most recently completed physical inventory.

  1. Copies of any records related to special terms and conditions. (Note: many special terms and conditions are covered in their own target review area, such as participant support and cost-sharing.)

  1. List of subawards charged to the selected NSF award(s).
  2. Copies of subaward agreements selected by NSF's reviewers.
  3. Written policies and procedures on subawardee selection and cost/price analysis.
  4. Written policies and procedures regarding how subawards are issued, managed and monitored.
  5. Documentation demonstrating compliance with subawardee monitoring requirements.
  6. Copies of invoices paid for subawards under the selected NSF awards(s).

  1. Copies of personnel compensation records for each category of personnel (e.g., exempt and/or nonexempt/hourly staff) charging time to the selected NSF award(s).
  2. Written policies and procedures related to completion and maintenance of personnel compensation records for each category of personnel (e.g., exempt and/or non-exempt/hourly staff) charging time to the selected NSF award(s).

  1. Written policies and procedures related to incurring and accounting for travel costs and supporting documentation.
  2. Copies of supporting travel documentation.

The on-site review includes discussions with the awardee organization's functional area representatives to collect additional information and/or documentation and to assist awardee representatives with award-specific and general grant management questions/concerns, as needed. The review team may follow up with the awardee after the on-site visit to gather additional information or clarify some aspects of a review area.

The process culminates in the development and issuance of the site review letter which provides feedback to the awardee organization and identifies best business practices, areas of weakness and recommendations for improvement.

Awardees may be required to prepare a corrective action plan to remedy any deficiencies. NSF tracks the status of each awardee's implementation of a mutually agreed-upon remedy until the issues are resolved. Minor concerns may not require a corrective action plan, but awardees are expected to address the issues promptly to ensure compliance and prevent findings under 2 CFR 200 Subpart F audits and/or Office of the Inspector General audits.

 

Who participates in the site visit?

Typically, two to four representatives from the awardee organization (e.g., two sponsored programs office staff and one accounting staff) participate in the site visit process. Since the site review focuses on award administration and not award performance, the principal investigator of the award reviewed is not usually involved in the site visit.

Two to four staff members from the NSF Resolution and Advanced Monitoring Branch will participate in the site visit.

 

How long does the site visit process take?

Site visits typically take four months from the start of the site visit planning through receipt of the awardee organization's response to the site visit letter.

NSF notifies awardee organizations four to six weeks before the scheduled site visit date. The site visit team uses this period to collect information about the organization, consult with NSF program and grants officers, and analyze any results from prior monitoring activities, such as a desk review.

Site visits typically last three to four days (either virtually or in-person), after which the site visit team has 90 days to prepare a site visit report for internal distribution and a site visit letter with recommendations for the awardee organization.

Awardee organizations are expected to respond within 30 days with a corrective action plan.

Contact us

If you have questions about site visits, contact bfadiasmonitoring@nsf.gov.