FEDERAL PROGRAMS WORKSHOP JULY 21, 2010 JAN STANLEY, STATE TITLE I DIRECTOR Federal Grant...
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Transcript of FEDERAL PROGRAMS WORKSHOP JULY 21, 2010 JAN STANLEY, STATE TITLE I DIRECTOR Federal Grant...
FEDERAL PROGRAMS WORKSHOP
JULY 21, 2010
JAN STANLEY, STATE TITLE I DIRECTOR
Federal Grant Federal Grant Management Management
Legal Structures for Federal Legal Structures for Federal ProgramsPrograms
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Statutes/Legislation Program Statutes (NCLB, IDEA, Perkins) General Education Provisions Act (GEPA)
Regulations Program Regulations Education Department General Administrative
Regulations (EDGAR)
Office of Management and Budget CircularsGuidance
Non-Regulatory Guidance
Federal Grants Management Federal Grants Management ResourcesResources
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Program Guidance: www.ed.gov Statutes Regulations Guidance
General Education Provisions Act (GEPA):
http://www.law.cornell.edu/uscode/20/usc_sup_01_20_10_31.html
Education Department General Administrative Regulations (EDGAR): http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html
Federal Grants Management Federal Grants Management ResourcesResources
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Office of Management & Budget (OMB) Circulars: http://www.whitehouse.gov/omb/circulars
Circular A-87 principles for allowable costs
Circular A-122-cost principles for non-profit organizations
Circular A-133 Compliance Supplement-audit
What Rules Apply to Utilizing Federal What Rules Apply to Utilizing Federal Funds?Funds?
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State and local agencies must demonstrate fiscal control and accounting procedures to ensure the proper disbursement of and accounting for federal funds.
Section 76 of EDGARSection 80 of EDGAR
Who or What is EDGAR?
Education Department
General Administrative Regulations (EDGAR)
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Financial Management Requirements
All grantees and sub grantees must implement the requirements and maintain systems that meet specific requirements of EDGAR.
Financial Management Requirements
EDGAR Section 76o Eligibility to receive subgrantso Distribution of funds by formula or
competitive o Private faith-based organizations eligible to
receive fundso State consolidated grant application to EDo Assurance statementso Ability for the SEA to reallocate funds based
on specific federal program
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Financial Management Requirements
EDGAR Section 76 (continued)o LEA grant application and budget approved by the
SEA prior to the issuance of a grant and the expenditure of funds
o Approval processo SEA must provide a grant award that indicates the
amount of the subgrant, obligation period and any requirements that apply to the specific federal program (scope and conditions)
o Consultation with and services for private school students
o Application guidelines for private schools
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Financial Management Requirements
EDGAR Section 76 (continued)o Calculation and approval of indirect cost
rates (restricted)o Coordination of the federal funds with other
programs that serve the same populations (Braiding of funds Title I, Title II and Title III)
o Program evaluations and fiscal auditso SEA and LEA reporting requirements
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Financial Management Requirements
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Section 80 of EDGAR
Specific regulations governing three threshold systems:
Financial Management
Procurement
Inventory
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General Principles
In general, the SEA and the LEA must implement controls over federal funds.
ED looks to “systems,” not individuals, to ensure funds are spent appropriately.
Financial Management
Definition-controlling and accounting for federal funds and assets Used to make informed programmatic decisions Used to substantiate and document expenditures
Seven standards described in Section 80.20(b)of EDGAR
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Financial Management
Seven Requirements: Financial Reporting Accounting Records Internal Control Budget Control Allowable Cost Source Documentation Cash Management
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Budget Controls
Pre-award planning process and technical assistance - developing and approving budgets
Communication between fiscal and program staff at the SEA and LEA levels
Routine reconciliation to actual expenditures at the SEA and LEA levels
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Allowable Cost Controls
Program Regulations Formal procedures or statue relating to costs Guidelines for determining allowable costs
(OMB Circular A-87, EDGAR) Access to helpful resources and program guidance
Financial Management
ObligationObligation-transaction that requires paymentValid obligation–transaction giving rise to an
obligation within the period of grant availability
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Financial Management
Acquisition of property Date of binding or written commitment – PO or contract
Personal services by employee
After services are performed
Personal services by contractor
Date of binding written commitment
Travel After travel is taken
Obligation=transaction that requires payment18
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Financial Management
In some programs, unobligated funds can be “carried over” from first year
Tydings Amendment Does not apply to all grants Allows extra year to obligate funds
Under Tydings, funds are available for 24-27 months 15 months under the grant award Plus 12 months
• Restricted to a 15% carryover for Title I Part A and Title II
Financial Management
Liquidation
Liquidation–settle an obligation by paying funds
All obligations must be liquidated within 90 days after the end of the obligation period.
SEA may impose a shorter deadline on sub grantee.
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Procurement Procedures
General procurement procedures are found in EDGAR and some are found in the individual federal program statute
Follow State’s procurement procedures State Board Policy 8200 Purchasing Policies and Procedures Manual
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Procurement Procedures
Consider purchases based on the following considerations: Allowable by the specific program Reasonable Necessary for the administration and/or implementation of the grant
Review all proposed purchases to avoid unnecessary or duplicative items Surplus property Structure procurement to obtain most economical purchase Intergovernmental agreement for common goods or
services Lease vs. purchase
Conduct all transactions with full and open competition – be cognizant of conflict of interest
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Procurement Procedures
Contracted Services Contract should include clearly defined deliverables and
terms Description of services to be performed or goods to be delivered Description of dates when services will be performed or goods
delivered Description of locations where services will be performed or goods
delivered Description of number of students/teachers/etc. to be served (if
applicable) Remedies for breach of contract-sanctions and penalties Termination procedures Compliance with federal statues – see §80.36(i)(3-6) of
EDGAR Reporting procedures (if applicable) Requirements pertaining to copyrights
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Procurement Procedures
Contracted Services
Must have written invoice from the individual or company contracted Description of services performed or goods delivered Description of dates services were performed or goods
delivered Description of location services were performed or goods
delivered Description of students/teachers/etc. served (if applicable
Invoice should be reviewed & approved before payment Segregation of duties/expenditures Documented approvals
Inventory Management
Inventory items purchased with federal funds are divided into three categories:
Real Property (if an allowable program cost)EquipmentSupplies
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Inventory Management
Equipment Inventory vs. Internal Control
EDGAR requires an inventory for equipment
Inventory not required for supplies; however, ED determined that an adequate internal control system must include a process for labeling and locating property purchased with federal funds
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Inventory Management
Equipment Federal Definition of Equipment
Tangible property Useful life of more than one year Acquisition cost of $5,000 or more
State may use another definition as long as it includes all property described above
Supplies Small cost items Consumed quickly
ED expects subgrantees to track all property purchased with federal funds, in order to prove there has been a benefit to the federal program
Inventory Management28
Practical help Practical help for tracking non-equipment items
Small and attractive item list Conduct risk assessment to identify items
susceptible to loss Implement specific measures to control such
items Certain pre-defined assets (technology
equipment)
Inventory Management29
Equipment inventory-updated annually a description of the property a serial number or other identification number the acquisition date and cost of the property the percentage of federal participation in the cost of the
property the location, use and condition of the property, and any ultimate disposition data including the date of disposal
and sale price of the property
Physical inventory Must be performed at least every 2 years Indicate signature of individual(s)
Inventory Management30
Must protect against unauthorized use
When property is no longer needed, must follow disposition rules:
Transfer to another federal program Over $5,000 – Keep or sell, but must pay a share
based on the percentage of federal ED participation at initial acquisition
Under $5,000 – May keep, sell, or dispose of it with no obligation to ED
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Inventory Management
Must have adequate controls in place to account for: Location of equipment - assure that it is used solely
for authorized purposes Custody of equipment - maintain effective control
and accountability Security of equipment - adequately safeguard all
property
EFFICIENCY IS DOING THE THING RIGHT. EFFECTIVENESS IS DOING THE RIGHT THING.
– PETER F. DRUCKER
Closing Thoughts…...32