Overview of Carl D. Perkins Grant Program and New …...TACCBO 2015 Annual Conference Overview of...

TACCBO 2015 Annual Conference

Overview of Carl D. Perkins Grant Program and New Federal Grant

Guidance

Donna CarlinAssistant Director, WorkforceAcademic Quality and Workforce

June 18, 2015

Community, State, & Technical College Liaison Meeting

Perkins IV

The Carl D. Perkins Career and Technical Education Improvement Act of 2006 was signed into law in August 2006 for six years.

Funding continued annually since 2013, while awaiting reauthorization.


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Allocation of Perkins Funds


TOTAL CB Funding Texas FY 2015 - $ 27,634,301• Admin - $ 1,381,715 (max)• Leadership - $ 2,763,430 (max)• Basic - $ 23,489,156 (min)

• Basic Reserve up to 10% of Basic 3


Perkins Basic Grants Formula Allocation to Community & Technical Colleges

The formula is determined by:

Full-time Equivalent (FTE) calculated for students enrolled in CTE programs that are Pell grants recipients.


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Reallocation of Funds

All unexpended funds from the prior year are de-obligated and made available for reallocation during the subsequent program year. However, reallocation is never a guarantee!

Question: I f your institution has $50,000 unspent at the end of the grant year, does it go back to your institution the follow ing year?


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Common Uses of Funds Instructional equipment

Upgrading curriculum

Guidance/Counseling, CTE Advisors

Serving Special Populations

• textbooks

• transportation

• childcare

• sign language interpreters

Professional Development


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Perkins Basic Core Indicators of Performance

1P1: Technical Skill Attainment

2P1: Credential, Certificate, or Diploma

3P1: Student Retention or Transfer

4P1: Student Placement

5P1: Nontraditional Participation

5P2: Nontraditional Completion


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1P1 Technical Skill Attainment

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2P1 Credential, Certificate, or Diploma

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3P1 Student Retention or Transfer

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4P1 Student Placement

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5P1 Nontraditional Participation

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5P2 Nontraditional Completion

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Perkins State Leadership Grants

Focus on career and technology education improvement initiatives that have a statewide impact.

Coordinating Board publishes a Request for Applications each spring.

Up to 10 percent of the Title I Perkins funds may be awarded.

9 proposals under review for 2015-2016 grant cycle.


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2014-2015 Perkins State Leadership Grants


Institution Project Title Grant Award

Alamo Community College

San Antonio College ASL/IT Train the Trainer Project $57,478

Del Mar College Skill Standards- Based Curriculum Development and Assessment Project

$65,000

Panola College Team-Based Learning for Health Science Courses $42,322

San Jacinto College Programs of Study: Strategic Alignment $152,564

San Jacinto College Workforce Education Course Manual (WECM) Maintenance

$159,912

TSTC – Harlingen Competency Based Training How-To $36,750

TSTC – System Curriculum Alignment Platform (CAP) $330,456

Victoria College Sustaining TEXASgenuine $96,555

Non-traditional

Alamo Community College

Replicating Women in Non-trad Occupations Student Conference around Texas

$45,000

TOTAL AWARDS $986,037

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Perkins Reserve Funds

During 2012 OCTAE site visit, visitors encouraged use of Reserve funds for “special projects.”

2012-2013: funded two projects:

∙ TSTC Harlingen: Competency Based Project

∙ San Jacinto College: Program of Study: Strategic Alignment

2013-2014: funded one project:

∙ Central Texas College: Achieving Student Success through the College for Credit Heroes Initiative

2013-2014: New Initiative: CTE Early College High School Grant Program

2014-2015: CTE ECHS grants continue


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Perkins Basic Grant 2015-2016

Date posted: June 2, 2015. Changes include:

● reallocation methodology: 50% of reallocation funds will be awarded to grantees meeting 2P1, 3P1, 4P1

● Schedule C Capital equipment: strongly recommend that all capital equipment be approved and ready for submission to the supplier no later than April 30, 2016

● Schedule E: Sub-grants no longer used as part of the Perkins Basic grant, use Schedule D for contracts and consultants

● Purchase of furniture must be instruction-related or for disability accommodation


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Presenter

Presentation Notes

Auditors looking at number of late reports which in turn has increased our enforcement of due dates and follow up for late reports.


Investing in America’s Future: Transforming Career and Technical Education, blueprint for the reauthorization of the Carl D. Perkins Career and Technical Education Act was released on April 19, 2012

http://www.ed.gov/ovae

Reauthorization of Perkins


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http://www.ed.gov/ovae


OCTAE Blueprint for Perkins V

States empowered to identify the in-demand occupations in high-growth industry sectors on which CTE programs should focus

Consortia funding based on programs of study

Private-sector match

Within-state competition to distribute funds to consortia


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Monitoring of Perkins Grants

Risk Assessment run annually in fall. Points awarded and weighted for:

● amount of award

● time since last visit

● number of amendments

● number of late reports

● number of core indicators not met

● fiscal desk review concerns

Grantees with top 15 scores have programmatic desk review

Grantees with top five scores receive site visit


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Sample Site Visit Agenda

Day One

9:00 p.m. – 9:30 a.m. Introductions and Overview of Site Visit (THECB staff)

9:30 a.m. – 12:00 p.m. Meetings re use of Perkins funds, P/P, Core Indicator Performance Please schedule meetings with individuals responsible for:

1)The inventory system and institution’s policies and procedures for inventory control and the disposal of equipment,2) Perkins Contact and others selected individuals to discuss the institution’s performance on the Basic Core Indicators and how the institution uses these data to improve the programs, and3) Working with special populations and students with disabilities.

12:00 p.m. – 1:00 p.m. Lunch


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1:00 p.m. – 5:00 p.m. Program Review Continues (CB Staff, College Representatives, Students, Faculty, Others)

For three selected CTE programs, schedule meetings with Dean/Program Directors/Students (if available) for discussion of advisory committees, technology, program evaluation, and core indicators. CB staff will look at the facilities and equipment purchased for each of the following select CTE programs:

• Largest CTE program• CTE program with largest growth over the past three years• CTE program that is allocated the most Perkins funding for equipment


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Day Two

9:00 a.m. Other business not covered in first day of visit/other programs that the institution would like to highlight

10:00 a.m. Exit Interview

10:30 a.m. Site Visit Concludes


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Sample Desk Review Material Requested


Topic Policies and Procedures Documentation

1. Capital and non-capital equipment

• Purchasing, inventorying, labeling, tracking and disposition

• The last Purchase Order of equipment that was processed in FY2013 with backup documentation (request, receiving, invoice and expenditure)

• Institution’s printed inventory of all Perkins-purchased equipment for the last two completed funding years

1. Travel

• Requests, rates, and reimbursement for in-state and out-of state travel

• Expense report and backup documentation for a recent in-state and out-of-state travel expenditure

3. Child Care / Transportation Vouchers

• Eligibility, dissemination, and accountability

• Application

4. Consultants None needed • Most recent contract5. Sub-

grantees/ Subcontractors

None needed• Most recent sub-

grantee/Subcontractor contract

5. Advisory Committees

None needed

• List of all CTE advisory committees with the date of each committee’s last meeting

• Sample minutes of 3 advisory committees

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Uniform Grant Guidance

Combined 8 Office of Management and Budget (OMB) circulars into one large circular

Went into effect December 26, 2014

Applies to new grants made after that date, so will be in effect for Perkins grants awarded for fall 2015


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Office of Management and Budget (OMB) Revisions

OMB Revised Administrative Rules, Cost Principles, and Audit Rules governing all “nonfederal entities” expending federal awards. (200.69)


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Focus

1. Reduce fraud, waste, and abuse

2. Simplicity and consistency

3. Executive order 13563 (2011) on regulatory review:

• increase efficiency

• strengthen oversight


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New EDGAR Title 2 CFR 200

Old New

Circulars A-89, A-102, A-110 UGG Subparts B, C & D

Circulars A-21, A-87, A-122 UGG Subpart E

Circulars A-133, A-50 UGG Subpart F

EDGAR Parts 75 to 99 EDGAR Parts 75-79 and 81-99

EDGAR Parts 74 and 80 Become part of the uniform guidance


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New EDGAR

CFR Part 200 of EDGAR• Subpart A: Acronyms and Definition

• Subpart B: General Provision

• Subpart C: Pre-Award Requirements

• Subpart D: Post-Award Requirements

• Subpart E: Cost Principles (was A-21)

• Subpart F: Audit Requirements (was A-133)


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Major Changes in Federal Grants Management

1. Focus on Outcomes

2. Performance Metrics

3. Risk Assessments

4. Financial Management Policies

5. Equipment Use


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Major Changes in Federal Grants Management (cont)

6. Micro Purchases

7. Corrective Action

8. Family Friendly Policies

9. False Claims Certifications

10. Audit Thresholds


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Subpart A: Acronyms and Definitions

200.28 Cost Objective NEWProgram function, activity, award, organizational subdivision, contract, or work unit for which cost data are desired and for which provision is made to accumulate and measure the cost of processes, products, jobs and capital projects.


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Uniform Grant GuidanceSubpart A: Acronyms and Definitions

200.33 Equipment: tangible, nonexpendable, personal property having a useful life of more than one year and an acquisition cost of $5,000 or more per unit.

Grantee may also use its own definition of equipment as long as the definition would at least include all equipment defined above.


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200.61 Internal Controls: A process, implemented by a non-Federal entity, designed to provide reasonable assurance regarding the achievement of objectives in the following categories:

• Effectiveness and efficiency of operations;

• Reliability of reporting for internal and external use; and

• Compliance with applicable laws and regulations.


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Presenter

Presentation Notes

Purchases, inventory of equipment



200.94 Supplies: All tangible personal property other than equipment

• NEW Computing devices are supplies if less than $5,000

• NEW Computing devices 200.20

• Machines used to acquire, store, analyze, process, public data and other information electronically

• Includes accessories for printing, transmitting and receiving or storing electronic information


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Subpart B: General Provisions

• Conflict of Interest

• Mandatory Disclosures


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200.113: Mandatory Disclosures

Non-federal entities must disclose in writing, in a timely manner:

• All violations of Federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the federal award

• Failure to make disclosures can result in remedies for noncompliance (200.338)


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Subpart C: Pre-federal Award Requirements and Contents of Federal Awards

• Requirements of Pass-through Entities

• 200.205: risk assessment by federal awarding agency

• 200.331: requirements for pass-through entities (evaluate subrecipient’s risk of noncompliance, monitoring desk review)


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Subpart D: Post-federal Award Requirements

• Financial Management Rules

• Procurement

• Property Management


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Financial Management Rules

• 200.302 NEW: requirement for written procedures to

• implement requirement for payments (200.305), and

• Determining the allowability of costs in accordance with Subpart E, Cost Principles


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Financial Management Rules

• 200.305NEW: written procedures must describe whether non-federal entity uses:

• Advance Payments

• Reimbursement


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Payment

• Advances must be maintained in insured accounts

• Pass through cannot require separate depository accounts

• Accounts must be interest bearing unless:1. Aggregate federal award is under $120,000

2. Account not expected to earn more than $500/year

3. Bank requires minimum balance so high, that account is not feasible

4. A foreign bank system prohibits interest bearing account.


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Payment: 200.305

• Interest amounts up to $500 may be retained by non federal entity for administrative purposes

• Previously: $250 for Institutions of Higher Education

• NEW: Interest earned must be remitted annually to HHS Payment Management System


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Procurement: 200.318

All nonfederal entities must have documented procurement procedures which reflect applicable Federal, State, and local laws and regulations


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Competition: 200.319

All procurement transactions must be conducted with full and open competition.

• Must have protest procedures to handle disputes

• To eliminate unfair advantage, contractors that develop or draft specifications, requirements, statement of work, and invitations for bids or RFPs must be excluded from competing for such procurements


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Competition: 200.319

Situations that restrict competition:• Unreasonable requirements on firms to qualify to do

business

• Requiring unnecessary experience or excessive bonding

• Noncompetitive pricing practices

• Noncompetitive awards to consultants on retainer

• Organizational conflicts of interest

• Specifying a brand name instead of allowing “an equal” if brand name specified must include “or equal” phrase


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Methods of Procurement: 200.320

NEW: Micro-purchase

• Small purchase procedures

• Competitive sealed bid

• Competitive proposals

• Noncompetitive proposals


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Micro-purchases: 200.320 (a)

NEW: acquisition of supplies and services under $3,000

• $2,000 for construction subject to the Davis-Bacon Act

• May be awarded without soliciting competitive quotations if nonfederal entity considers the cost reasonable

• To the extent practicable, must distribute micro-purchases equitably among qualified suppliers


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Small Purchase Procedures: 200.320 (b)

Goods or services that costs $150,000 or less

NEW: Simplified Acquisition Threshold was raised under 200.88

• Institution may set lower threshold

• Must obtain price or rate quotes from an adequate number of qualified sources

Follow State Rules


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Subpart E: Cost Principles

Equipment: 200.313

NEW: When acquiring replacement equipment, may use the equipment to be replaced as a trade-in or sell the property and use the proceeds to offset the cost of the replacement property

Equipment must be used in the program for which it was acquired as long as needed, whether or not the program continues to be supported with federal funds


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Subpart E: Cost Principles

Equipment: 200.313

When equipment is no longer needed, may be used in other activities with the following priority:

• Projects supported by Federal awarding agency

• Project funded by other Federal agencies


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Equipment: 200.313

Procedures for managing equipment must meet the following requirements:

• Property records (serial or ID number, source of funds, location, sale price if sold)

• Physical inventory at least every two years

• Control system to prevent loss, damage, theft

• Adequate maintenance procedures

• If property sold, proper sales procedures


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Conferences: 200.432

What about food?• Is a working lunch necessary?

• Is the portion of the agenda to be carried out during lunch substantive and integral to the overall purpose of the conference or meeting?

• Is there a genuine time constraint that requires a working lunch?

• If a working lunch is necessary, is the cost of the working lunch reasonable?

• Have you carefully documented that a working lunch is both reasonable and necessary?


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Travel Costs: 200.474• Travel cost may be charged on actual, per diem, or

mileage basis?

• Travel charges must be consistent with entity’s written travel reimbursement policies

• NEW: Allows costs for “above and beyond regular dependent care”

• Grantee must retain documentation that participation of individual in conference is necessary for the project

• Travel costs must be reasonable and consistent with written travel policy/or follow GSA 48 CFR 31.205-46(a)


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Time and Effort Documentation: 200.430(i)(1)Time and effort must be maintained for all employees whose salaries are paid in whole or part with federal funds, and are not contractors

Records must:

• Be supported by a system of internal controls which provide reasonable assurance changes are accurate, allowable and properly allocated

• Be incorporated into official records

• Reasonably reflect total activity for which employee is compensated


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Training by Michael Brustein: July 28, 2015

Time: 1:00 -4:00 pm

Location: THECB board room

Cost: free!

Webcast: Yes!

Link: www.thecb.state.tx.us

Click on link on main webpage


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http://www.thecb.state.tx.us/


Link to UGG: http://www.ecfr.gov/cgi-bin/text-idx?SID=704835d27377ef5213a51c149de40cab&node=2:1.1.2.2.1&rgn=div5

Donna CarlinAssistant DirectorDivision of Workforce, Academic Affairs and ResearchTexas Higher Education Coordinating [email protected](512) 427-6241

Questions?

Perkins Orientation

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http://www.ecfr.gov/cgi-bin/text-idx?SID=704835d27377ef5213a51c149de40cab&node=2:1.1.2.2.1&rgn=div5

mailto:[email protected]

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