Thanks to those who have responded to my frustration!  Dawn did a much better job than I did at stating exactly what we are doing.  (And, Barbara, this has never been noted as a finding to this point!)
 
Within 3 weeks from the end of each month, we are invoicing for actual expenses incurred (i.e. payroll, supplies, equipment) based on services provided or supplies/equipment actually received during the month.  However, we may not have physically cut a check to the vendors by the time the invoice was submitted to the funding agency.  (Our current policy is to issue payment to vendors at approximately 30 days.)  This is what the auditors apparently have a problem with (for the first time ever).
 
Since I originally issued this listserv question, the auditors did provide me with the following documentation that comes out of the A-133 Compliance Supplement:

C.  CASH MANAGEMENT

Compliance Requirements

When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government.  When funds are advanced, recipients must follow procedures to minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement.  When advance payment procedures are used, recipients must establish similar procedures for subrecipients.
Even though I didn't want to believe it, I guess this states their position pretty clearly.

Deb
***************************************************
Debra K. Hansen

Director of Sponsored Programs and Fiscal Affairs
Marshfield Clinic Research Foundation
1000 N Oak Avenue - 1R3
Marshfield, WI   54449
715-387-9130
xxxxxx@mcrf.mfldclin.edu
***************************************************

From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Dawn Wall
Sent: Thursday, November 02, 2006 11:20 AM
To: xxxxxx@hrinet.org
Subject: Re: [RESADM-L] Invoicing for Cost Reimbursement Type Grants & Contracts

It has been many years since I was involved in a award billings. At that time (I don't think that has changed) the billing method was based on the dictates of the award document.

Cost reimbursable means you request reimbursement for cost incurred, if the expense is booked as a expense on your accounting system (i.e., accrued), regardless of whether payment has been issued, you bill the agency. Now if your payables take a long time issuing payment that's a different problem, that needs to be address by the big wigs at your campus.

Advance means you bill in advance & if you've request more $ than what was needed during a 30 day period you owed the feds interest.

I found many private & foreign sponsors wanted to know the amount of the outstanding obligations. When requested the amount was included on the monthly invoice labled "Outstanding Obligations" and a disclaimer was included to indicate that appropriate F&A costs were not included as the goods and/or services had not been received and University policy did not permit advance calculation of this cost.

There were a few federal agencies who wanted the same info, so when written requests were received the info was sent to them.

Dawn
-- 
Dawn Wall, Accountant
University of Alaska
Statewide Office of Cost Analysis
211B Butrovich Building
PO Box 756540
Fairbanks, AK   99775-6540
Phone - 907.450.8076  fax - 907.450.8071
email - xxxxxx@alaska.edu
http://www.alaska.edu/controller/cost-analysis/

The strength of the United States is not the gold at Fort 
Knox or the weapons of mass destruction that we have, but 
the sum total of the education and the character of our people. 
 -- Claiborne Pell


Hansen, Debra K. wrote:

I need help from some Grant Accountants!

For the past 16 years, and probably more, excluding grants paid via the Payment Management System, we have invoiced our funding agencies based on expenses charged on an accrual basis against our federally funded grant and contract accounts.  Our auditors, who will remain unnamed, are telling us for the first time that we should be invoicing for expenses based on a cash basis (i.e. as expenses are paid).

Does this sound right?  Can anyone direct me to the regulatory documentation that would be provide guidance on this?  Also, if this is correct, how do institutions manage this when their financial reporting is on an overall accrual basis?

Thank you!

Deb

***************************************************
Debra K. Hansen

Director of Sponsored Programs and Fiscal Affairs
Marshfield Clinic Research Foundation
1000 N Oak Avenue - 1R3
Marshfield, WI   54449
715-387-9130
xxxxxx@mcrf.mfldclin.edu
***************************************************

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