In accordance with the Office of Management and Budget (OMB) Circular
A-21, the University of Georgia was required to file a Disclosure
Statement (DS-2) with the Department of Health and Human Services’
Division of Cost Allocation (DCA) in July 1996. The DS-2 reflects the
University’s cost accounting practices and conformance to federal
guidelines for sponsored research and is subject to review by the
Federal government’s offices of the DCA, DHHS Inspector General, Defense
Contract Audit Agency, as well as, other external auditors.

To determine the adequacy of the July 1996 submission, the University
contracted with Jim Vitale & Associates, Inc. in March 2004 to provide a
high level assessment of the effectiveness of the written policies and
procedures. A steering committee and several work groups composed of
faculty, staff, and administrators from campus, worked for over one year
to assess and revise existing policies and procedures and create new
ones in areas with deficient standards. On June 28, 2005, a revised DS-2
was submitted to the DCA.

These new policies and procedures outlined in the June 28, 2005
submission are effective January 1, 2006 and as such, a campus wide
training initiative will take place between November 2005 and February
2006. As discussed at the October 27, 2005 Vice Presidents, Associate
Provosts, and Deans meeting, the following training will be coordinated
by the Contracts and Grants department:
• Overview with the Research Communication Group
• Overview with Associate/Assistant Deans and Department Heads
• Training with Faculty during faculty meetings
• Training with college administrators and departmental business
managers
• Regular course offerings at the Training & Development Center

Your support of these training efforts and implementation of the new
policies within your respective areas is critical. The Contracts and
Grants department will be contacting you in the coming days to schedule
training time with your Associate/Assistant Deans and Department Heads
as well as your faculty and certain administrative staff. To provide the
campus community with the information necessary to promote compliance
with these policies and procedures, direct training and communication
with all faculty is necessary.

Experience shows that non-compliance with, or ignorance of, policies and
procedures cited in the DS-2 is an institution’s greatest risk for audit
findings, fines and penalties. Recent examples of fines assessed to
Universities include: New York University -- $5 million, Northwestern
University -- $5 million, Johns Hopkins University -- $2.6 million,
University of Alabama -- $3.4 million, and Florida International
University -- $10 million.

Details on the new and revised policies, procedures, and training
information are available at http://www.busfin.uga.edu/disclosure. This
webpage contains resources for you and your staff such as the disclosure
statement and the cost accounting policies and procedures. If you have
any questions about the upcoming training or general questions about the
DS-2 and related policies and procedures, please contact Tracy Walters,
Director of Contracts and Grants, at 706-227-7223 or email at
twalt01@uga.edu.

Compliance with the University’s cost accounting policies and procedures
can only be attained with your support and that of your faculty and
staff. We appreciate your dedication in providing an environment in
which sponsored program accounts are maintained in compliance with the
established standards. Collectively, our actions demonstrate the
University’s overall commitment and adherence to fiduciary
responsibility and compliance with federal guidelines and expectations.