Enhancing Grants Management TA Program

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Enhancing Grants Management TA ProgramEnhancing Grants Management TA Program

Basic Fundamentals of Grants ManagementBasic Fundamentals of Grants Management

Sponsored by FEMA in coordination with the National Criminal Justice Association (NCJA)Sponsored by FEMA in coordination with the National Criminal Justice Association (NCJA)

Central Grantees Chicago, IllinoisCentral Grantees Chicago, IllinoisMay 27-28, 2009May 27-28, 2009

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OverviewOverview

FEMA Basic Grants WorkshopCentral Grantees Chicago, Illinois May 27-28,

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AgendaAgenda

• Legal framework• Pre-award processes• Environmental and Historic Preservation • Post-award processes• Group discussion• Breakouts


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IntroductionsIntroductions

• Participant introductions and expectations• Objectives• Overview of the Enhancing Grants Management

Technical Assistance Program

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ObjectivesObjectives

Participants will be able to• Understand/Integrate the Business Process in

Grants Management• Focus on Critical Events• Identify a Team Approach

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ObjectivesObjectives

Participants will be able to• Problem Solve on Specific Issues• Identify and Share Promising Practices• Develop Networks Among Grant Staff

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Enhancing Grants Management Enhancing Grants Management Technical Assistance (TA) ProgramTechnical Assistance (TA) Program

• Promote promising business practices for grants administration

• Workshops and Direct TA Deliveries

• Collaborative effort between FEMA and the National Criminal Justice Association (NCJA)

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National Criminal Justice Association (NCJA)National Criminal Justice Association (NCJA)

• Facilitate Coordination for Department of Justice (DOJ) and DHS State Administrative Agencies (SAAs)

• Policy Support for Recipients and Subrecipients• Congressional Monitoring/Legislative Analysis• Curriculum Development• High Caliber Conferences on Key Issues

• Website for Workshop Documents and Promising Practices www.ncja.org

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http://www.ncja.org/

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FEMA Organizational StructureFEMA Organizational Structure

Office of the AdministratorAdministrator– W. Craig Fugate

Acting Deputy Administrator – David Garratt

Office of the AdministratorAdministrator– W. Craig Fugate

Acting Deputy Administrator – David Garratt

Disaster Operations

Disaster Operations

Center for Faith-Based Initiatives and

Neighborhood Partnerships

Center for Faith-Based Initiatives and

Neighborhood Partnerships

Office of Chief Counsel

Office of Chief Counsel

Office of External Affairs

Office of External Affairs

Office of Chief Financial Officer

Office of Chief Financial Officer

Executive Secretariat

Executive Secretariat

National ContinuityPrograms

National ContinuityPrograms

MitigationMitigationDisaster Assistance

Disaster Assistance

LogisticsManagement

LogisticsManagement

Disability Coordinator

Disability Coordinator

Dotted Lines are Coordination

Solid Lines Are Command and Control

As of May 18, 2009

Associate Deputy Administrator

Associate Deputy Administrator

Law Enforcement

Advisor to the Administrator

Law Enforcement

Advisor to the Administrator

Grant Programs

Grant Programs

National Preparedness

National Preparedness

United States Fire

Administration

United States Fire

Administration

Regional Administrators

Region I Region II Region III Region IV Region V

Region VI Region VII Region VIIIRegion IX Region X

Regional Administrators

Region I Region II Region III Region IV Region V

Region VI Region VII Region VIIIRegion IX Region X

Office of Equal Rights

Office of Equal Rights

National Capital Region

Coordination

National Capital Region

Coordination

Louisiana Transitional

Recovery Office

Louisiana Transitional

Recovery Office

Office of Policy and Prog. Analysis

Office of Policy and Prog. Analysis

ManagementManagement

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Grant Programs Directorate Organization Chart

Grant Operations Eastern Branch

Grant Operations Eastern Branch

Grant Development & Administration Division

C. Gary Rogers, Division DirectorJudy Hampton, Deputy Division Director

Grant Development & Administration Division

C. Gary Rogers, Division DirectorJudy Hampton, Deputy Division Director

Grants Management DivisionLisa Lewis, Division Director

Grants Management DivisionLisa Lewis, Division Director

Assistance to Firefighters

Grants Branch

Assistance to Firefighters

Grants Branch

Transportation Infrastructure

Security Branch

Transportation Infrastructure

Security Branch

Homeland Security Grant

Programs Eastern Branch


Programs Eastern Branch

Program Development &

Information Management

Branch

Program Development &

Information Management

Branch

Systems and Business Support

Branch

Systems and Business Support

Branch

Accountability, Management, and Oversight Branch

Accountability, Management, and Oversight Branch

Training BranchTraining Branch

Office of the Assistant Administrator

Ross Ashley, Assistant AdministratorTracey Trautman, Deputy Assistant Administrator

Office of the Assistant Administrator

Ross Ashley, Assistant AdministratorTracey Trautman, Deputy Assistant Administrator


Programs Central Branch


Programs Central Branch


Programs Western Branch


Programs Western Branch

Grant Operations Western Branch

Grant Operations Western Branch

Grant Operations Central Branch

Grant Operations Central Branch

Office of Resource Management and

Business Administration

Office of Resource Management and

Business Administration

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Grant Programs DirectorateManage federal assistance to measurably improve capability and reduce the risks the Nation faces in times of man-made

and natural disasters.

Grants Management Division Grants Management Division Mission StatementMission Statement

Grants Management Division

GMD, the driving force for strategic grants management initiatives serving FEMA, its regions, and the grantee community through the delivery of federal financial

assistance, policy, training, systems, and data analysis.

FEMATo lead America to prepare for, prevent, respond to and

recover from disasters with a vision of “A Nation Prepared.”

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Grants Management Division (GMD)Grants Management Division (GMD)

• Five Functional AreasFive Functional Areas– PolicyPolicy– OperationsOperations– SystemsSystems– OversightOversight– TrainingTraining

• Each functional area plays a different role in the organization, but all require extensive knowledge of the Federal requirements for all grants as outlined in legislation, OMB Circulars, Regulations

• Every functional area ensures standardization, internal controls and compliance

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StandardizationStandardization

• Ensure that FEMA applies Federal requirements evenly across all grant programs

• Ensure standardization of processes and procedures wherever possible

• Standardize the implementation, application, review, award/obligation, management and closeout of grants.

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Internal ControlsInternal Controls

• Delegation of authority to obligate FEMA in legally binding non-disaster grant agreements

• Ensure the proper separation of duties between the program office that determines eligibility and the fiduciary agent that determines reasonableness, allowability and allocability of grant dollars

• Provide the review, oversight and documentation required by all FEMA offices to legally bind the Federal government in a grant agreement

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– Appropriations Statute

– Authorizing Statute (e.g., Stafford Act, 9-11 Act)

– Federal Regulations (44 CFR)

– OMB Circulars (Administrative Requirements, Cost Principles, and Audit)

– Terms & Conditions of the grant award

– Program Guidance (incorporated by reference in the Terms & Conditions)

– DHS Policy

– FEMA Policy

ComplianceCompliance

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Legal FrameworkLegal Framework

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Federal Assistance vs. ContractsFederal Assistance vs. Contracts• The Federal Grant and Cooperative

Agreement Act of 1977– Grants

• Carry out Public Purpose in Law• No Substantial Federal Involvement

– Cooperative Agreements• Carry out Public Purpose in Law• Substantial Federal Involvement

– Contracts• Acquire Property or Services

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The Stafford Act of 1988The Stafford Act of 1988

• Robert T. Stafford Disaster Relief and Emergency Assistance Act – Authorizes Federal assistance for disaster

response, recovery, preparedness and hazard mitigation

– Authorizes the president to issue major disaster declaration

– Authorizes the creation of a Disaster Relief Fund


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9/11 Commission Act of 20079/11 Commission Act of 2007

• Primarily affects Preparedness grants

• Administration and monitoring of FEMA preparedness grants– Conduct programmatic and financial

monitoring for each State and high-risk urban area not less than once every two years


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PKEMRA of 2006PKEMRA of 2006• Post-Katrina Emergency Management Reform

Act (PKEMRA) – Adds Preparedness Assistance to FEMA’s

Portfolio

– Implements a National Preparedness System to set national goals, track progress, and report on the state of preparedness

– Integrates Mission at Headquarters and Regions

– Creates the New FEMA VisionFEMA Basic Grants Workshop

Central Grantees Chicago, Illinois May 27-28, 2009

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American Recovery and Reinvestment ActAmerican Recovery and Reinvestment Act• The ARRA provides $787 billion in stimulus funds

including:– $150 million for the Port Security Grant Program

(PSGP)– $150 million for the Transit Security Grant

Program (TSGP)– $210 million for Assistance to Firefighters Grants

(AFG)– $100 million for the Emergency Food and Shelter

Program

• Reporting requirements and milestone dates

• Maximum transparency and accountability in the awarding of stimulus funds under the ARRAFEMA Basic Grants Workshop


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Authorities: CFRAuthorities: CFR• 44 Code of Federal Regulations (CFR) regulates

FEMA Programs– Common Rules that set conditions for grant

authority– Have the force and effect of law– Non-disaster assistance regulations are in

various parts of 44 CFR, particularly Part 13– Federal Register Notices are required when

regulations do not exist

• 44 CFR Website:– http://www.access.gpo.gov/nara/cfr/waisidx_07/44cfrv

1_07.html FEMA Basic Grants WorkshopCentral Grantees Chicago, Illinois May 27-28,

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http://www.access.gpo.gov/nara/cfr/waisidx_07/44cfrv1_07.html

http://www.access.gpo.gov/nara/cfr/waisidx_07/44cfrv1_07.html

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Authorities: CFRAuthorities: CFR

• The regulations in force when the grant was awarded should apply– All grants previously awarded through DHS

Grants & Training:• On or after April 1, 2007, follow 44 CFR• Prior to April 1, 2007, follow Department of

Justice’s codified regulations, 28 CFR


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Authorities: CFR - ACTIVITYAuthorities: CFR - ACTIVITY

Instructions: Determine when 28 CFR or 44 CFR apply in the following situations.

Scenario: A DHS Preparedness Grant is awarded April 1, 2007. What CFR applies?

Answer: 44 CFR, FEMA

Scenario: A DHS Preparedness Grant is awarded March 31, 2007. What CFR applies to a payment request made on April 1, 2007?

Answer: 28 CFR, Department of Justice


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Authorities: CFR vs. OMB CircularsAuthorities: CFR vs. OMB Circulars

• Code of Federal Regulations (CFR)– Permanent Rules– Executive Agencies and Departments– Published in Federal Register

• OMB Circulars– Rules Apply to All Grants


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Authorities: OMB CircularsAuthorities: OMB Circulars

• Administrative Requirements

• Cost Principles

• Audit Requirements


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Administrative Requirements Administrative Requirements vs. Cost Principlesvs. Cost Principles

Administrative Requirements

Cost Principles

Prescribe standards for grant administration to achieve uniformity and consistency for recipients of Federal Assistance

Define allowable costs for different types of recipients; failure to mention a particular item of cost in the Cost Principles is not intended to imply that it is either allowable or unallowable


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OMB CircularsOMB CircularsA-110, A-87, A-21 and A-122 relocated to 2 CFR

Summary of Applicable Regulations

Grantee Type Admin Requirements

Cost Principles Audit Requirements

State & Local Governments 44 CFR Part 13 (A-102 )

2 CFR, Part 225

(A-87)

A-133

Colleges & Universities

2 CFR, Part 215

(A-110)

2 CFR, Part 220

(A-21)

Non-Profits 2 CFR, Part 230

(A-122)

Website:http://www.access.gpo.gov/nara/cfr/waisidx_08/2cfrv1_08.html#215


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http://www.access.gpo.gov/nara/cfr/waisidx_08/2cfrv1_08.html#Slide%20215

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Authorities: Program Guidance

• Program Guidance includes– Funding requirements and eligible applicants– Allowable and unallowable costs– Program application process and evaluation– Application requirements– Award and reporting requirements


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Program GuidanceProgram Guidance

• HQ Produces and Disseminates via Website– http://www.fema.gov/government/grant/index.shtm

– http://www.firegrantsupport.com

• Issued for most FEMA grant programs

• Updated Every Federal Fiscal Year

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http://www.fema.gov/government/grant/index.shtm

http://www.firegrantsupport.com/

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Grants ManagementGrants ManagementPutting the Pieces TogetherPutting the Pieces Together

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Business Process = The Grants CycleBusiness Process = The Grants Cycle

Funding

AcquisitionProgram

Establishment Application Review

AwardMonitoringAmendments

Payment Requests

Reporting AuditsClose-

Out


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Pre-Award Business PracticesPre-Award Business Practices

FundingAcquisition

ProgramEstablishment

Application Review


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Post-Award Business PracticesPost-Award Business Practices

Monitoring Amendments Payment Requests

ReportingAudits and Close-out


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Funding Acquisition


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Appropriations and Funding ProcessAppropriations and Funding Process

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Overview of Federal Budget ProcessOverview of Federal Budget Process

• Phase 1: Budget Formulation

• Phase 2: Budget Presentation and the Congressional Process

• Phase 3: Budget Execution

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Budget FormulationBudget Formulation

• FEMA Budgets for Grant Programs

• FEMA Budget Request

• DHS Total Budget Request

• OMB/President’s Budget to Congress

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AppropriationsAppropriations

• Budget Presentation to Congress

• Congressional Budget Resolution

• Appropriation

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Types of AppropriationsTypes of Appropriations

• Annual: Must be obligated within the fiscal year

• Multiple Year: Available for obligation for a definite period in excess of one fiscal year

• No-year: Available for obligation without financial year limitations

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Budget ExecutionBudget Execution

• Office of Management and Budget (OMB) Apportionment– Budget Authority to distribute funds

• DHS Allotment

• FEMA Allotment

• Allocations to Each Grant Program

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Continuing ResolutionContinuing Resolution

• Applies if new FY and annual appropriation is not passed

• Continues existing programs until annual appropriation passes

• Can Impact Internal Operations and Activities

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ProgramEstablishment


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Establishing Your ProgramEstablishing Your Program

• Establish Homeland Security Office • HS Structures Vary by Jurisdiction

– Executive Order…by Governor• Office of Homeland Security

– Legislative Authority…by Statute• Department of Homeland Security


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• Advisory Board Authority and Responsibilities• Incorporating National Priorities into State Priorities

– Includes Local Priorities• HS Policy, Program and Grant Administration


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• HS Roles and Responsibilities– Policy, Program and Grants

• Setting Goals and Priorities• Funding Sources: Fed/State/Local/Tribal


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• Physical Location• Information Technology Requirements/Needs• Communication…Internal

– Written Policies/Procedures– Regular Staff Meetings– Dialogue with Advisory Board– Clarify Expectations vs. Requirements


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• Communication…External– Public– Media Relations– Attorneys…State, County, Other– SAAs: Subrecipients…Your Customers– Locals: Your Citizens


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• Information Management– Accessible…Shared with All Disciplines– Retrievable…eGMS– Analyze Data to Improve Decision-making– Data Calls– Supportable


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• Strong Financial Management System• Staffing Needs and Structure…Key Positions• Integrating Policy, Program and Financial• Assistance from Other Agencies…MOUs• Regionalization of Functions

– Planners, Regionalize Staff, etc.


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• Hiring Personnel– M&A vs. Planning $– Position Descriptions– Posting Jobs and Interviewing– Background Checks - Time is $– Consultant Contracts… Review Committee


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• Training Personnel– Cross-training– Retention and Career Development– M&A Use for Online Courses– M&A Budget…Travel for Staff Training– Document and Evaluate Annually


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Creating Policies and ProceduresCreating Policies and Procedures

• What?– Integrate Federal, State and Local Policies– Develop Internal and External Forms and

Procedures– Expectations v. Requirements– Publish Formally


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• Why?– Provides Documentation and Authorization– Tracks Modifications– Provides Accountability and Audit Compliance

• Who?– SAA: Advisory Board, Program Analyst, etc.– Locals: Obtain SAA Support Prior to

Implementation


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• All Grant Stages– Application– Award– Administration– Monitoring– Closeout

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Application


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Application and GuidanceApplication and Guidance

• Integrate Priorities– National– State and/or Local

• Require Budget and Program Narratives • Incorporate Reporting Elements

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Prepare Applications and Guidelines

• Include Grant Terms and Conditions • Require Three Signatures • Include Example of Subgrant Application

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Announce Funding and Priorities

• Publish Funding Availability and Deadlines• Consider Conditional Grant Awards • Conduct Grant Application Workshops • Encourage Local Advisory Board Consensus

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Announce Funding and PrioritiesAnnounce Funding and Priorities

• HQ produces and disseminates via website– http://www.fema.gov/government/grant/index.shtm– http://www.firegrantsupport.com

• Information bulletin via ASKGMD (Prep)• Issued for each grant program

– Updated annually (existing programs)– Funding Availability and DeadlinesFunding Availability and Deadlines

• DHS Information Bulletin via CSIDDHS Information Bulletin via CSID


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http://www.fema.gov/government/grant/index.shtm

http://www.firegrantsupport.com/

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Methods of SolicitationMethods of Solicitation

• www.Grants.gov– OMB Mandated Initiative– Find (eFIND)– Apply (eAPPLY)– All Federal Grant-making Agencies


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http://www.grants.gov/

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• http://www.federal.gov/– Traditional Methods of Advertising– FEMA Requires Publication in Federal

Register


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http://www.federal.gov/

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• www.CFDA.gov– Database of all Federal Programs Available– Searchable by Assigned CFDA Number– Includes Contact Information for Program

Office and Application Guidance


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http://www.cfda.gov/

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• Recipient – Implementing Agency

• State Administrative Agency (SAA)• State Emergency Management Agency

– Conduct Annual Pre-Application Workshops– Electronic Notification– Legal Notice Published in Newspaper


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Review

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How are Reviews Conducted?How are Reviews Conducted?

– Use evaluation criteria, rating system– Evaluate technical merit– Objective– No Conflict of Interest– Confidentiality


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Types of ReviewTypes of Review

Eligibility Review

Field/Independent Review

Panel Review

Programmatic Review

Financial Review

* Sequence of the reviews depends on the grant program FEMA Basic Grants WorkshopCentral Grantees Chicago, Illinois May 27-28,

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Eligibility RequirementsEligibility Requirements

• Timely submission• Complete narrative• Necessary contact information• Adequacy of information provided• Signatures by authorized official• Assurances and Certifications complete

Eligibility Review

Field/ Independent Review

Panel Review

Programmatic Review

Financial Review


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Field and Panel ReviewsField and Panel Reviews

• Field/Independent Review– Federal or Non-Federal reviewers that work

independently, not part of a group

• Panel– A group of several people, or a committee,

assembled to review applications • Ad Hoc – temporary and for specific short-term

task

Eligibility Review


Panel Review

Programmatic Review

Financial Review


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Field and Panel Reviews Field and Panel Reviews Program Program Office ReviewOffice Review

• Program Offices review applications after panel or field reviews


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Program Office ReviewProgram Office Review

• Evaluate:– Technical merits– Programmatic merits

Eligibility Review


Panel Review

Programmatic Review

Financial Review


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Program Office Program Office Financial Review Financial Review

• Conduct detailed financial reviews– Based on Program Office recommendations


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Financial ReviewFinancial Review

• Analyze budget and cost– Necessary, reasonable, allocable and

allowable• 44 CFR• OMB Circulars• Program Guidance

– May negotiate grant budget with grantee

Eligibility Review


Panel Review

Programmatic Review

Financial Review


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Financial Review ComponentsFinancial Review Components

• A-133 Compliance

• No Conflict of Interest

• Applicant’s Standing (Good, Debarred, Suspended)

• Budget Review

Eligibility Review


Panel Review

Programmatic Review

Financial Review


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Budget ReviewBudget Review

• Detailed budget and budget narrative• Complete, reasonable and cost effective in

relation to the proposed project• Detailed justification for each cost• All costs in appropriate approved cost categories

Eligibility Review


Panel Review

Programmatic Review

Financial Review


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Budget Review Cost CategoriesBudget Review Cost Categories

• Personnel• Fringe Benefits• Travel• Equipment• Supplies• Contractual• Other• Indirect Costs

Eligibility Review


Panel Review

Programmatic Review

Financial Review


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Indirect Costs vs. M&A CostsIndirect Costs vs. M&A Costs

• Indirect Costs

– Incurred for common or joint objectives

–Cannot be readily allocated to a particular award/project

–Contribute to recipient’s ability to support projects and programs and sustain organization’s daily operations

– Indirect Cost Rate Agreement

• Ratio or percentage of total indirect costs to direct cost base

Eligibility Review


Panel Review

Programmatic Review

Financial Review


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Indirect Costs vs. M&A CostsIndirect Costs vs. M&A Costs

• Management and Administrative Costs (M&A)

–Direct costs that are incurred to administer a particular program/award

–Identifiable and unique to each program/award

–Charged based on the activity performed for that particular project

Eligibility Review


Panel Review

Programmatic Review

Financial Review


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Examples of Indirect Costs and M&A CostsExamples of Indirect Costs and M&A Costs

• Indirect Costs: – Administrative salaries– Supplies– Costs of operating and maintaining facilities,

equipment, grounds, etc.– Depreciation or use allowances

Eligibility Review


Panel Review

Programmatic Review

Financial Review


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Examples of Indirect Costs and M&A CostsExamples of Indirect Costs and M&A Costs

• M&A Costs– Hiring full-time/part-time staff or

contractors/consultants– Developing operating plans

• Responses to DHS data calls– Travel expenses directly related to program

administration– Meeting-related expenses directly related to

administration

Eligibility Review


Panel Review

Programmatic Review

Financial Review


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Application Application Award Award

• If the application has met all review requirements, the grant is awarded


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Award


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Award ProcessAward Process

– Pre-award cost– Award process– Grant award– Award terminology– Award Packages and Release of Funds– Accept Award and Special Conditions


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Award Packages and Release of FundsAward Packages and Release of Funds

• Administrative or Implementing Agency– Project-Specific Conditions

• Special Conditions– Reporting Forms and Instructions– Audit and Close-out Forms and Instructions– Policies and Procedures– Equipment, Training, Exercises Requirements


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Assurances and CertificationsAssurances and Certifications• Written confirmation of compliance

– federal laws policies and regulations

• Also known as: – Certified assurances– Terms and Conditions

– Davis-Bacon Act– Nondiscrimination– FF 20-16A,B,C

– Lobbying– Debarment and

Suspension– Drug-free workplace


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Pre-Award CostPre-Award Cost• Pre-award costs:

– Cost incurred by the applicant prior to the start date of the assistance agreement• Requires prior written approval from FEMA• Cost incurred at grantee’s own risk• Cost are allowable only if they would be

allowable during the life of the award. • Eligible within 90 days preceding the start

date of the award – GPD may approve on a case by case basis for periods greater than 90 days


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Grant AwardGrant Award

• What is an award document?– Official document used for FEMA assistance

• Establishes legally binding arrangement between FEMA and recipient

• Establishes Period of Performance• Contains or references Terms and

Conditions of the grant or cooperative agreement

• Obligates Federal Funds FEMA Basic Grants Workshop


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Terms and ConditionsTerms and Conditions

• Also known as: – Agreement Articles– Special Conditions

• Details award project specific conditions and general terms and conditions– Reporting requirements– Governing provisions


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Award Notification & AcceptanceAward Notification & Acceptance

• Award Notification– Email– Grants Management System

• Award Acceptance– Sign and return award


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Getting Started…Getting Started…Financial Management SystemsFinancial Management Systems

• Organizing for Receipt of Federal Funds• Program v. Financial-Not Mutually Exclusive• Understanding Federal Requirements• Establishing Policies and Procedures


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Financial Management SystemsFinancial Management Systems

• Minimum Requirements for Financial System– Provide Financial/Performance Data– Associate Grant Expenditures to Specific

Funding Source– Provide Clear Audit Trail– Manage Cash Effectively


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• “Adequate” Accounting Systems Require– Internal Controls– Ability to Test Internal Control– Chart of Accounts– Compliance with CMIA– Procedures Minimizing Federal Cash-on-

Hand


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• “Adequate” Accounting Systems Require– Track Expenditures on Accrual Basis

(Budget Control)– Track both Financial and Program Budgets– Ensure Allowability of Costs Charged to

Grants


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• “Adequate” Accounting Systems Require– Documentation for All Grant-related

Expenditures• Broken Down by Award

– Fulfill Government-required Financial Reporting


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• Must Record and Report Grant Funds– Receipt– Obligation– Expenditure


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Fiscal MattersFiscal Matters


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Fiscal Matters…Proceed with CautionFiscal Matters…Proceed with Caution

• Allowable vs. Unallowable Costs

• Prior Approval Costs• Renovations and

Construction• Travel Authorizations


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• Time and Effort• Overtime and Backfill • Direct Costs• Indirect Costs

– (F&A Higher Education)


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• Supplanting• Consultants (HS Staffing)

– Fair Market Value-cautious on sole sourcing contractors

• Interest Earned/Program Income

• Match


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• Cash Advance– Interest Earned (CMIA)

• Outstanding Purchase Orders

• Excessive Spending Near End of Grant Period

• Records Retention


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Fiscal Matters…ProcurementFiscal Matters…Procurement

• Identify Conditions Requiring Prior Approval• State Administrative or Implementing Agency

– Develop Forms for Prior Approval• Understand Differences Between Types

– Competitive– Federal (GSA) or State Contract– Sole Source


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– Sole Source-Use is Discouraged Except• Emergency• Only One Source (Provider)

(Uniqueness/Compatibility)• After Solicitation, Competition Deemed

Inadequate


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Fiscal Matters… ProcurementFiscal Matters… Procurement

– Sole Source for “Inadequate Competition”• Definition from 44 CFR, Part 13

–“After Solicitation from a Number of Sources, Competition is Deemed Inadequate”

– Solicitation Likely through Competitive Bidding Process

– Inadequate…Only One Source/Provider


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• Sole Source – Recommend Project Director and Local

Procurement Official Signatures• Contractual Services…Use Review Checklist • Coordinate with State Procurement Assn.• Include Procurement Officer during

Monitoring


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Monitoring


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GMD Financial Monitoring VisitGMD Financial Monitoring Visit

Mission: Ensure Stewardship over Mission: Ensure Stewardship over Federal Funds Awarded Federal Funds Awarded

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What is Monitoring?What is Monitoring?

• Oversight and Stewardship of Federal funds• Assessment of performance and progress• Quality assurance and control• Compliance to Regulations, Administrative

Requirements, OMB Circulars• Not a one-time event, but an on-going process• Requires Technical Assistance (TA)


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Why Monitor?Why Monitor?

• Assess progress of grantee• Identify problems early• Work with Grantee to correct problems• Prevent waste, fraud and abuse• Ensure good performance and success • Develop relationships


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Who Monitors?Who Monitors?• Programmatic

– Strategic and Objectives-based– Technical– Performance

• Financial– Business and financial administration– Evidence of expenditures– Compliance with Federal financial rules and

program requirements

• Monitoring should be a partnership between program and financial staff


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Types of FEMA MonitoringTypes of FEMA Monitoring

• Cash Analysis– Financial Monitoring

• Desk Reviews– Financial and Programmatic Monitoring

• Site Visits– Financial and Programmatic Monitoring


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Cash AnalysisCash Analysis

• Reconciling grant records on a quarterly basis and comparing them with the Federal Financial Report (FFR)– Reconcile data– Compare reconciled data to financial and

progress reports– Take appropriate follow-up action


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Cash AnalysisCash Analysis

• What the Analysis Indicates – Up-to-date information on the grantee’s

expenditures– Cost share requirements– Grant status


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Desk ReviewsDesk Reviews

• Desk-based

• Verifies grantee compliance– Federal regulations– Terms and conditions

• Identifies exceptions and potential issues


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Desk Reviews – FinancialDesk Reviews – Financial

• Desk-based financial monitoring is a review of all transactions

• Grants reviewed on a regular basis

• Core review of a grantee’s general management practices

• May require further scrutiny through on-site financial monitoring


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• On-site review

• Ideally conducted by a team– Program Office staff (programmatic)– Grants Management Specialist (financial)

• Assess grantee’s capability, performance and compliance against administrative regulations and public policy requirements

Site VisitsSite Visits


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• What are some common findings?– Recipient has no written procedures– Lack of documentation – Inadequate/untimely submission of reports– Inventory Management Deficiencies– Inadequate Subrecipient Monitoring– Period of Performance expired with no prior

approval for an extension– Inadequate time and effort records– Lack of competition during procurement– Conflicts of interest

Examples of Financial Monitoring FindingsExamples of Financial Monitoring Findings


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• What are some common findings?– Failure to manage audit results– Inadequate accounting procedures– Inaccurate Federal Financial Reports (FFR)– FSR Fail To Agree With Accounting Records– Questioned Expenditures– Excess Cash on Hand– Commingling of funds (See handout)– Supplanting (See handout)

Examples of Financial Monitoring Findings


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________________ __________________ __

GMD Financial Monitoring VisitGMD Financial Monitoring Visit

• GMD Does Not Conduct Audits

• GMD Does Conduct– Cash Analysis– Desk Reviews– Site Visits


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Subrecipient Program and Financial Monitoring


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Getting Started…Take the TemperatureGetting Started…Take the Temperature

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Subrecipient MonitoringSubrecipient MonitoringPurposesPurposes

• Periodic Monitoring Required• Information Sharing and Gathering• Status of National and State Goals• Reinforce Priorities and Policies


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Subrecipient MonitoringSubrecipient MonitoringBenefitsBenefits

– SAA Provides TA to Customers– Subrecipients Identify/Showcase Successes– Ensure Projects are on Track– Improve Communications/Process– Correct Shortfalls and Offer Solutions


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Subrecipient Monitoring Subrecipient Monitoring Different Approaches and TypesDifferent Approaches and Types

• Desk– Provides Documentation– Used When SAA Staff Size is Limited– Short-Term Approach– Captures Limited Information


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Subrecipient Monitoring Subrecipient Monitoring Different Approaches and TypesDifferent Approaches and Types

• Site Visits– SAA Staff/Team Approach– Direct Contact with Stakeholders

• Projects and Players– Visual Project Status…Big Picture– Requires Follow-up by SAA and Subrecipient


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Subrecipient MonitoringSubrecipient MonitoringTools and Resources Used by SAATools and Resources Used by SAA

• Federal Guidelines– Program Guidance (by Federal Fiscal Year)

• Monitoring Checklist…for Consistency


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Subrecipient Monitoring Subrecipient Monitoring What to Expect from the SAA?What to Expect from the SAA?

• SAA Determines General “Health”– Project Goals and Project Management

• SAA Staff Make Advance Notes– Areas Needing Special Attention

• All SAA Staff Talk (Policy, Program and Financial)– Most Recent Status


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• Pre-Monitoring Letter/Email– Confirm Location, Date and Time– Name of SAA Staff Conducting Monitoring– Subrecipient Representatives Required

• Project Director and Financial Officer• Authorized Official…SAA Staff Meet• Procurement Official(s)


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• Pre-Monitoring Letter/Email– Monitoring Objectives– Materials/Equipment Necessary for Monitoring

• Inventory Inspection…Location• Grant File(s)• Programmatic and Financial Records• Grant-funded Personnel


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Subrecipient Monitoring Subrecipient Monitoring What to Expect from the SAA? What to Expect from the SAA?

• Compare Grant Files…Yours and Theirs– Signed Grant Award– Final Application (Program/Financial Pages)– Met Special Conditions– Personnel Status…Position Descriptions?,

Interviewing?, Hiring?– Status of Procurement, Revisions, etc.


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• Review Grant File(s) Folder– Previous Monitoring Reports/Correspondence– Compliance with Deadlines– Progress and Financial Reports– Fiscal Information

• Invoices, Payments, Backup, POs


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Subrecipient MonitoringSubrecipient MonitoringSuggested Grant File FormatSuggested Grant File Format

Label each tab1. Correspondence

2. Blank Forms, POC Info.3. Financial-Payments-Special Cond.4. Application, Signed Award, GANs5. Review & Audit Resolution6. Progress & Monitoring Reports

1. Corresp

ond

.


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• Post Monitoring Letter (Desk or On-site)– Agreed-upon Modifications– Remaining Compliance Issues– Recommendations for Improvements


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• Post Monitoring Letter (Desk or On-site)– Recognition of Progress and Successes– Deadline for Response, if Applicable– Copied to Authorized Official


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Monitoring versus AuditingMonitoring versus Auditing

• Monitoring is preventative

• Auditing is corrective /

curative


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Amendments

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Amendments = ChangeAmendments = Change

• Also known as:– Modifications– Revisions– Grant Adjustment Notice (GAN)


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Amendments = ChangeAmendments = Change

• An amendment is a change to the Award and/or Terms & Conditions that requires prior written approval from FEMA in accordance with OMB Circulars, 44 CFR and the Program Guidance


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• Require prior approval from Funding Agency• Must meet original program intent• Comply with Grant Terms and Conditions• Allowable costs from FY Program Guidance• Strong justification for approval• Allowable, Allocable, Reasonable

AmendmentsAmendments


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• Types of amendments:– Extend the Period of Performance– Change the Budget– Change the Scope or Objectives– Change Authorized Representative



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– Change the Budget• Cumulative transfers that exceed 10% of the

current total approved budget whenever FEMA’s share exceeds $100,000

• Transfer of funds from direct to indirect costs



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2009


Payment Requests

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Payment RequestsPayment Requests

• Cash Management Improvement Act (CMIA)– To improve the transfer of Federal funds to

Grantees• Efficiency• Effectiveness • Equity


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• ADVANCE– Up to 120 days– Minimize time between transfer of funds and

expenditure

• REIMBURSEMENT– Grantee should periodically draw down funds

throughout Period of Performance (POP)


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• Not to exceed Federal share of total grant award

• Costs must be allowable, allocable, reasonable and necessary


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• Funds Disbursed as Costs Incurred– Limit Cash on Hand

• Based upon Immediate Disbursement and Reimbursement– Minimize Time between Transfer of Funds from

• U.S. Treasury to Recipients (i.e. SAA)• SAA to Subrecipients


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• Interest earned is due quarterly

• Interest Bearing Account– Grantees and subgrantees shall remit interest

earned at least quarterly – May keep up to $100 per year for

administrative expenses


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Payment SystemsPayment Systems

• SmartLink• Payment and Reporting System (PARS)


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SystemsSystems

• SmartLink– Processes payments through the Department of

Health and Human Services (HHS) computer link with the U.S. Treasury Department

– If Grantee does not have SmartLink account a request can be processed via the SF 270

• Payment and Reporting System (PARS)– Allows Grantees to make online payment requests

and submit quarterly SF 269 report– Interfaces with FEMA accounting system


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2009

Subrecipient ReimbursementSubrecipient Reimbursement

• Subrecipient Requests for Reimbursement– Include Procurement Documentation– Provide Proof of Payment

• Invoices Submitted with the Signed Request

• Copy of Cancelled Check• Computer-Generated Report

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Things to ConsiderThings to Consider

• SAA Provides Written Guidance to Subrecipients• Grant Award Paperwork• Monitoring Visits• Annual Grant Financial Workshop


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• SAA Advises Subrecipients– Invoices– Purchase Orders– Requests for Reimbursement– Unallowable Costs, etc.


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• Withhold Payments: Reimbursement– Subrecipient’s Inability to Submit Reliable

and/or Timely Reports– Improper Engagement of Administering

Subawards


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Reporting

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RequiredReporting

Federal Financial ReportFinancial

Performance ReportProgrammatic

ReportingReporting


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ReportingReporting

• Reports required semi-annually; no more than quarterly– Individual program reporting requirements vary

Performance

Reports

Financial Reports*

Individual project progress

Status of funds


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Financial ReportingFinancial ReportingAccurate DataAccurate Data

• Federal Standards• Recipient: Required to Expend and Account

for Grant Funds– State Laws/Procedures– Internal Accounting System

• The Federal Financial Report (FFR) or SF 425 will replace the Financial Status Report (FSR) October 1, 2009.

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ReportingReporting

• Where do you find reporting requirements for a particluar grant?– Terms & Conditions– Program Guidance


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Programmatic ReportingProgrammatic Reporting

• FEMA Preparedness– Categorical Assistance Progress Report

(CAPR)• Due no later than January 31 and July 31

and at Close-out• Type “See BSIR” in Narrative Section for

SAAs• Complete Narrative Section for Direct

Recipients (including Ports)

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2009

Programmatic ReportingProgrammatic Reporting

• FEMA Preparedness– Grant Reporting Tool (GRT)

• Biennial Strategy Implementation Report (BSIR)

–Due no later than January 31 and July 31 and at Close-out

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Audits


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AuditsAudits

Requirements and TypesRequirements and Types

• State/Local Agency Financial Audit• Compliance with OMB Circular A-133

– Statewide Single Audits• DHS IG Performance Audits


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AuditsAuditsState/Local State/Local Agency Financial AuditAgency Financial Audit

• Must Follow the Requirements in A-133• State Agencies and Local Governments

– Auditor’s Office Will Test Grant Programs but Focus on• Financial Compliance• Financial Statements

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AuditsAuditsState/Local State/Local Agency Financial AuditAgency Financial Audit

• How Do I Prepare for the Financial Audit?

– Follow All Rules and Regulations Set Forth

– State, Local, and Federal Regulations

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2009

AuditsAuditsCompliance with Compliance with OMB Circular A-133OMB Circular A-133

• Review of All Federal Grant Programs and Requirements

• All Non-federal Entities are Required to Comply with OMB Circular A-133

– Government, Education, and Non-profit

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AuditsAuditsWhat is a What is a Statewide Single AuditStatewide Single Audit??

• Exempt vs. Non-exempt– Exempt

• Non-federal Entity that Expends Less Than $500K in Federal Funds in their Fiscal Year

– Non-exempt• Non-federal Entity that Expends $500K or

More in Federal Funds their Fiscal Year

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AuditsAuditsWhat is a What is a Statewide Single AuditStatewide Single Audit??

• Audit Report Is Due 9 Months after the End of the Fiscal Year

• Local Governments– Not Subject to Statewide Single Audit

• Submit the Audit Package to the Federal Audit Clearinghouse (FAC) in Jeffersonville, Indiana


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A-133: Most Common Audit A-133: Most Common Audit FindingsFindings

• Activities allowed or unallowed• Allowable costs/cost principles• Cash management• Equipment and real property management• Period of availability of funds• Procurement• Real property acquisition and relocation

assistance• Reporting• Subrecipient monitoring


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Audit ResolutionAudit Resolution

• Awarding Agency Responsibility– Resolve Audit Finding of Direct Recipients


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Audit ResolutionAudit Resolution• Review and analyze the A-133 Audit Report:

– Audit Resolution staff within GPD’s Office of Resource Management & Business Administration (RMBA)

– Coordinate with Regional Grants Management Specialists and Program Office at Headquarters

• If there are findings:– RMBA, Program Office, and Regional Grants

Management Specialist work collaboratively with grantee to develop Corrective Action Plan


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• Recipient (SAA) Responsibility– Audit Submission to FAC– Monitoring and Resolution of Subrecipient

Audit Findings


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• Review and Analyze the Audit Report

• If Findings, the Audited Recipient– Should be Contacted– Corrective Action Plan Should be Requested


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• Corrective Action Plan (CAP) Should Include:– Description of Each Finding– Specific Steps to be Taken to Implement the

Recommendation– Timetable for Performance of Each Corrective

Action– Description of Monitoring to be Performed to

Ensure Implementation of the CAP


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• Audited Recipient– Generate Response to CAP Request within

30 Calendar Days of Request

• Primary Recipient– Analyze Response– Follow-up on Action Taken


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DHS Office of the Inspector General (OIG) DHS Office of the Inspector General (OIG) Performance AuditsPerformance Audits

• Rotating Schedule of States, Locals, Programs• Conducted by OIG Staff or Contract Support• Compares Expenditures to Program Impact• Evaluates State HS Strategy Goals and

Objectives with Activities• Reports posted on OIG Website at

http://www.dhs.gov/xoig/rpts/


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http://www.dhs.gov/xoig/rpts/

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Examples of IG Audit FindingsExamples of IG Audit Findings

• Financial reporting• Questioned costs• Monitoring and oversight• Procurement practices• Measurable program goals and objectives• Needs assessments• Personal property controls


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FindingsFindings

• Findings in common:– Monitoring– A-133 Audits– Inspector General (IG) Audits


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Close-Out


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Recipient CloseoutRecipient Closeout

• Due within 90 Days after End of Award or any Approved Extension

• Final Progress Report (CAPR/BSIR)• Final Federal Financial Report (SF 425)

• No Unliquidated Obligations• Indicate Exact Balance of Unobligated Funds• Remit Check to FEMA for Excess Funds


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Subrecipient CloseoutSubrecipient Closeout

• Final Request for Reimbursement– Submitted to State Administrative or

Implementing Agency– Due Pre-determined Number of Days after

End of Grant Period

• Final Fiscal Report (Deobligation Report) – Generated by State Administrative or

Implementing Agency


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Subrecipient CloseoutSubrecipient Closeout

• Final Fiscal Report (Deobligation Report) – Includes Total Expenditures

• Federal Amount• Subrecipient Amount (if applicable, for

Match…EMPG)• Investment Type• Strategy Goal/Objective


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Recipient CloseoutRecipient Closeout

• Final Fiscal Report (Deobligation Report) – Mailed after Final Request is Approved and

Processed– Requires Signature of Authorized Official and

Return to State Administrative or Implementing Agency


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Inventory ControlInventory Control

• Requirements for Grants Awarded

– After April 1, 2007 (44 CFR, Part 13)

– Prior to April 1, 2007 (OJP Financial Guide)• http://www.ojp.usdoj.gov/financialguide/part

3/part3chap6.htm


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http://www.ojp.usdoj.gov/financialguide/part3/part3chap6.htm

http://www.ojp.usdoj.gov/financialguide/part3/part3chap6.htm

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• After April 1, 2007 (44 CFR, Part 13)– Part III-Chapter 6: Property and Equipment

• (a) Title• (b) Use• (c) Disposition

–(1) Retention of title–(2) Sale of property–(3) Transfer of title.


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• Prior to April 1, 2007 (OJP Financial Guide)– 13.31 Real property.

• 1. Title• 2. Use• 3. Management• 4. Disposition


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Retention of RecordsRetention of Records

• Retention of Records– 6.3 Years for FEMA– Recipient or Subrecipient for 3 Years after

Submitting Final Federal Financial Report• Records must be retained until resolution of any

action such as litigation, claim, negotiation, or audit

• Obligated to Protect Records • Authorized Access to Records


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2009

ConclusionsConclusions

• You Understand the Business Processes • You Know the Critical Events• You Recognize Need for Team Approach • You Problem Solved on Specific Issues• You Shared Promising Practices• You Developed Networks

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Direct Technical Assistance Delivery

• Identify Areas of Need in Grants Management • Submit DHS TA Request Form

– to the SAA (subrecipient)– to the Program Analyst (direct recipient)

• DHS TA Catalog Form– Email: [email protected]

mailto:[email protected]

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Grants Management TA

• GMD Training Branch– Vanessa Pert, Section Chief

• Email: [email protected]• Office: (202) 786-9564

– Sherry Wilder, Grants Management Specialist• Email: [email protected] • Office: (202) 786-9861



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Grants Management TA

• National Criminal Justice Association (NCJA) www.ncja.org (202) 628-8550

– Lisa Nine Accordini, Senior Staff Associate–Email: [email protected]–Cell: (202) 421-7693

http://www.ncja.org/


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Questions???Questions???


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Enhancing Grants Management TA Program

Documents

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