Application Amendments and Budget Transfers (Part 2)

Virginia Department of Education Office of Program Administration and Accountability

Title I University, February 12, 2015Chris McLaughlin

Learning Outcomes for Today’s SessionApplication Amendments and Budget Transfers (Part 2)

The participant will be able to:

• State the purpose of application amendments

• Monitor grant spend down of funds

• Adjust program implementation to accommodate critical fiscal deadlines

Review…

Amendments and Budget Transfers, Part 1 (November 13)

Amendments are Required!

§76.702 Fiscal control and fund accounting procedures.A State and a subgrantee shall use fiscal control and fund accounting procedures that insure proper disbursement of and accounting for Federal funds.

§76.770 A State shall have procedures to ensure compliance.Each State shall have procedures for reviewing and approving applications for subgrants and amendments to those applications, for providing technical assistance, for evaluating projects, and for performing other administrative responsibilities the State has determined are necessary to ensure compliance with applicable statutes and regulations.

Education Department General Administrative Regulations (EDGAR), Title 34

Life-Cycle of Grant = 27 MonthsTitle I, Part A

Grant Life Cycle

July 1 Application Due

85% Obligated Prior to

September 30(15 months)

100%(27 months)

Grant Award Timeline

Year of Grant Award

Total Grant Award Period

Deadline to Obligate 85% of

Award

Deadline to Obligate 100%

of Award

Deadline to Request

Reimbursement for ALL funds

FFY 2014 (2014-2015)

July 1, 2014 – Sept. 30, 2016

Sept. 30, 2015 Sept. 30, 2016 Nov. 15, 2016

FFY 2013 (2013-2014)

July 1, 2013 – Sept. 30, 2015

Sept. 30, 2014 Sept. 30, 2015 Nov. 15, 2015

Probable Scenario…

July 1 Due Date

Award Figures Released(Amendment 1)

Programmatic Change(Amendment 2)

Federal Award Adjustment

(Amendment 3)85% Spend Down Plan

(Amendment 4)

Budget Adjustment(Amendment 5)

Carryover FundsZero Balance

(Amendment 6)

27 Month Process

Clear & Concise

Communication

Missed Opportunity to Communicate (Omega Comment Area)

What statements could have been made to document and

summarize the grant activity?

Summary Provided(OMEGA Comment Area)

Amendment Process

Application: Amendments

Summary Provided(Application Cover Page)

Application: Amendments

You may want to note changes within the detailed budget description. This process is optional, but the grantee and VDOE reviewer may find it beneficial.

Original

Amendment

Application: Amendments

Please do not do the following:

1. List a string of codes indicating several line items without providing a description of changes. This typically takes the writer a great deal of effort and is often difficult for the reviewer to understand.

Application: Amendments

Please do not do the following:

2. Reference prior communication, either verbal or written, with the Title I specialist without providing a description of changes. The information within the grant amendment needs to be clear and stand alone. Based on the example below, the reviewer(s) cannot identify the modifications to the grant that are being made.

Title I, Part A Grant Amendments

Amendments are necessary when:

• Allocations are announced via VDOE Superintendent’s Memos

• The division needs to make programmatic changes

• The division needs to change the projected budget; including moving

funds between object codes

Amendments should include:

• Amendment number and description of changes on cover page of

application

• Modifications to application such as:

• Program narrative

• Detailed budget description

• Object code budget

• Budget summary

Life-Cycle of Grant = 27 MonthsTitle I, Part A

Grant Life Cycle

July 1 Application Due

85% Obligated Prior to

September 30(15 months)

100%(27 months)

The “Obligation Clock” is Ticking!

What does “Obligate” mean?

IF AN OBLIGATION IS FOR -- THE OBLIGATION IS MADE --

(a) Acquisition of real or personal property.

On the date on which the state or subgrantee makes a binding written commitment to acquire the property.

(b) Personal services by an employee of the State or subgrantee.

When the services are performed.

(c) Personal services by a contractor who is not an employee of the State or subgrantee.

On the date on which the state or subgrantee makes a binding written commitment to obtain the services.

(d) Performance of work other than personal services.

On the date on which the state or subgrantee makes a binding written commitment to obtain the work.

What does “Obligate” mean?IF AN OBLIGATION IS FOR -- THE OBLIGATION IS MADE --

(e) Public utility services. When the state or subgrantee receives the services.

(f) Travel. When the travel is taken.

(g) Rental of real or personal property. When the state or subgrantee uses the property.

(h) A pre-agreement cost that was properly approved by the State under the applicable cost principles.

On the first day of the subgrant period.

http://www.doe.virginia.gov/federal_programs/esea/title1/part_a/guidelines_procedures/definition_of_obligation.pdf

Will you beat the clock?

Obligate 85% prior to September 30

• Review expenditures• Review obligations• OMEGA balance verification

Obligate 85% prior to September 30

Reminder… Staff salaries may not be considered obligated beyond September 30 each fiscal year when determining percent obligated

SEC. 1127. CARRYOVER AND WAIVER.

• (a) LIMITATION ON CARRYOVER- Notwithstanding section 421(b) of the General Education Provisions Act or any other provision of law, not more than 15 percent of the funds allocated to a local educational agency for any fiscal year under this subpart (but not including funds received through any reallocation under this subpart) may remain available for obligation by such agency for one additional fiscal year.

• (b) WAIVER- A State educational agency may, once every 3 years, waive the percentage limitation in subsection (a) if —

• (1) the agency determines that the request of a local educational agency is reasonable and necessary; or

• (2) supplemental appropriations for this subpart become available.• (c) EXCLUSION- The percentage limitation under subsection (a) shall not

apply to any local educational agency that receives less than $50,000 under this subpart for any fiscal year.

Reallocation Process

• School divisions that do not obligate 85% are subject to reallocation

• Reallocation procedures are provided in Superintendent’s Memo #100-14

Amendments and Budget Transfers

• To meet obligation requirements, grant managers are expected to:– submit amendments and correlating budget transfers.– communicate with key stakeholders in the school division

to plan adjustments.– monitor OMEGA balances on a monthly basis.

• Critical deadlines may require frequent monitoring of the spend down balance

VDOE Contact Information: Title I, Part A

Lynn Sodat, Ph.D., Title I CoordinatorLynn. Sodat@doe.virginia.gov

Phone: (804) 371-2934

Gabie Frazier, Title I SpecialistGabie.Frazier@doe.virginia.gov

Phone: (804) 225-2907

Chris McLaughlin, Title I SpecialistChris.McLaughlin@doe.virginia.gov

Phone: (804) 225-2901

Questions?