Hi Marcel,

We used to have this issue in the past as well. We addressed it by sending the state agency the language from the UG that states that the amount of federal dollars must be specifically identified in flow-through agreements (2 CFR 200.331(a)(1)(vi)), and we continued to press them on it until they provided the amount. We therefore were able to avoid the SEFA situation you are now unfortunately having to deal with.

Maybe you could reach out to the state agency now with this citation, explain your reporting situation and request that they provide the dollar amount?

Good luck!

Best,

Beth Kingsley, CRA

Grants Contract Manager, Sponsored Programs and Research Office (SPARO)

Office of Research

777 Bannock Street, MC 1952

Denver, CO 80204

(303) 602-7061 (office)

xxxxxx@dhha.org

cid:image003.jpg@01D3587F.884A7BF0

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From: Research Administration List [mailto:xxxxxx@LISTS.HEALTHRESEARCH.ORG] On Behalf Of Villalobos, Marcel A - (marcel)
Sent: Wednesday, September 11, 2019 6:17 PM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: [EXTERNAL] [RESADM-L] SEFA reporting question

Good day research admin colleagues,

For those of you involved in preparing your Schedule of Expenditures of Federal Awards (SEFA), I am wondering what your reporting practice is when you have an agreement where the prime source of funding may be a mixture of federal and non federal funds, but the prime agency refuses or is unable to provide concrete confirmation or any kind of breakdown.

Specifically we have some state agreements where we suspect the state agency receives multiple sources of funds and blends them into programs we receive at our institution, but only makes vague references to the blends, and neither the agreement nor the payments do not provide identifying information.

I am wondering if any of you are unfortunate enough to encounter them like us (my sympathies if so!), and if so, which way you lean to report the expenditures and what the risks may be of either practice.

Thank you!

Marcel

Marcel Villalobos
Assistant Director, Postaward Services
Sponsored Projects & Contracting Services

The University of Arizona
(520) 626-6311

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