Grants Management Training

Andy Zirkle

Grants Management Section Chief

Topics for the Day Where the money comes from . . .

– Funding– Types of Grants

Pre-award– Guidance Documents– Understanding Matching Funds– Understanding Supplanting– Proposal Submission– Budget Submission– How Proposals are Evaluated

Active grant award – Receiving the Award– Types of Agreements– Staying Organized– Reimbursement– Quarterly Reporting– Monitoring– Changing Agreements– Fraud Awareness

Additional Information

Where the Money Comes From . . .

Flow of FundsI. Appropriation – Money set aside by formal action for specific

use

– Congress appropriates the funds for the grant. DHS guidance to be release within 45 days

II. Apportionment – apportioning of funds among the states according to United States law

– Office of Budget Management & budget creates formula for apportionment of the appropriated funds

III. Allotment – allocation of funds to the designated SAA

– DHS, FEMA, etc., notifies Indiana of grant fund availability

IV.Application – submission of formal request for grant funds

– IDHS notified of exact award amount and conditions within 90 days of application

V. Award – notification of accepted application

– IDHS notified of exact award amount and conditions within 90 days of application

Flow of Funds (cont.)

VI.Allocation – grant funds distributed at state and local levels

– IDHS has 45 days to assign funds to projects and sub-grantees

VII. Obligation – legal liability to pay under a grant

– Sub-grantees submit proposals/budgets and have sub-grant agreements and/or MOUs fully executed

VIII. Expenditure – spending of grant funds

– To be done during the performance period of the sub-grant, MOU or agency approved budget

IX.Disbursement – paying funds to reimburse for expenditures

– Upon receipt of equipment or service and request for reimbursement, the distribution of actual funds to the fiscal agent

Funding Decisions

Funding decisions are made based on a variety of factors. These can include:

– Availability of funds– National and State strategies and priorities– Local needs– Allowability of Request– Risk Analysis– Gap Analysis

Grants

According to the website www.usaspending.gov, a grant is:

– An authorized expenditure to a non-federal entity for a defined public or private purpose in which services are not rendered to the federal government.

Grants are categorized as either formula or project grants.

– Formula grants are awarded based on mathematical calculations. EMPG is an example of a formula grant.

– Project grants are funded for a specific project to be completed within a fixed or known period of time. HSGP is an example of a project grant. IDHS selects projects through a competitive process based on risk and effectiveness.

Pre-Award Administration:Knowing Guidance Documents

Required Oversight

All Federal and State funds are subject to certain regulations, oversight and audit.

Federal regulations require IDHS to oversee grant related activities.

Regulations are listed in the agreement, the Administrative Plan and the Guidance for the grant

Policy indicates oversight process of:

– Federal to State Administrative Agency (SAA)– SAA to Project Managers– Project Managers to Sub-grantees and Partners

Guiding Federal Regulations

State and Local Governments

Public and Private Institutions of Higher Education

Hospitals Affiliated with Institutions of Higher Education

Quasi-Public and Private Nonprofits

Public and Private Hospitals

Grant Administration

44 CFR 13 & OMB Circular A-102

OMB Circular A-110

OMB Circular A-110

OMB Circular A-110

OMB Circular A-110

Cost Principles OMB Circular A-87

OMB Circular A-21

OMB Circular A-21

OMB Circular A-87

OMB Circular A-87

Audits OMB Circular A-133

OMB Circular A-133

OMB Circular A-133

OMB Circular A-133

OMB Circular A-133

OMB Circulars are available online at the following website:www.whitehouse.gov/omb/circulars

The table below references federal rules that may apply to your organization:

OMB Circular A-87

REQUIRES that a cost be:

Allowable

Necessary to the performance of a project

Reasonable

Non-profitable

Claimed against only one award

Permissible under State and Federal laws and regulations

Adequately supported by source documentation such as cancelled checks, payrolls, contracts, etc.

OMB Circular A-87

This Circular DOES NOT

Supersede limitations imposed by law (laws overrule OMB)

Dictate how a government should use funds

Relieve State and Local governments of stewardship responsibilities for Federal funds

OMB Circular A-133

Sets forth standards for obtaining consistency and uniformity among Federal agencies for the audit of non-Federal entities expending Federal Awards.

Requires that Audits be performed annually, with the exception of special provisions.

Identifies a “pass-through entity” as a non-Federal entity that provides a Federal award to a sub-grantee to carry out a Federal program

Top Audit Findings*

Accounting procedures need improvement

Grant reporting requirements not met

Grant management procedures need improvement

Cash management procedures need improvement

* Per Office of Justice Programs

IDHS Administrative Plan for Grants Management

Pre-Award Management– Award posted in iGMS– Proposal/Budget accurately entered and submitted in iGMS– Budget approval (need to allow time for approval process,

approximately 2 weeks)– Correctly identifying the sub-grantee (Section II the tax id that is

provided by a sub-grantee or contractor has to be the tax id for the entity named in the agreement)

Active Award Management

– Quarterly Reports

– GANS

– Monitoring

Post-Award Management

– Close-out

Pre-Award Administration:Understanding Matching Funds

Match

Matching or Cost Sharing means the value of the third party in-kind contributions and the portion of the costs of a Federally assisted project or program not borne by the Federal Government. All cost-sharing or matching funds claimed against a grant by State, local or Tribal governments must meet the requirements of the program guidance and/or program regulations, 44CFR § 13, and 2 CFR § 225.

Types of Match

Cash Match (hard)– Includes cash spent for project-related costs under a grant

agreement. Allowable cash match must include only those costs which are allowable with Federal funds in compliance with the program guidance and/or program regulations, 44 CFR § 13, and 2 CFR § 225.

In-kind Match (soft)– Means contributions of the reasonable value of property or

services in lieu of cash which benefit a federally assisted project or program. This type of match may only be used if not restricted or prohibited by program statue, regulation or guidance and must be supported with source documentation. Only property or services that are in compliance with program guidance and/or program regulations, 44 CFR § 13, and 2 CFR § 225 are allowable.

Pre-Award Administration:Understanding Supplanting

Supplanting

Supplanting is unallowable and is defined as:

Deliberately reducing State or local funds because of the existence of Federal funds.

Example: State funds are appropriated for a stated purpose and Federal funds are awarded for that same purpose. (If a county has $50.00 budgeted for snowplowing and is awarded a $100.00 grant for snowplowing, the total project must expend $150.00 – the original $50.00 cannot be removed and used for something else).

Discovering supplanting will result in the immediate return of federal funds related to the expenditure and project. Supplanting puts all federal funds at risk.

Pre-Award AdministrationProposal Submission

Components of a Proposal

I. Two-Sentence Summary

II. Applicant Information

III. Primary Point of Contact

IV. Management Team

V. Strategy Alignment – State/Federal

VI. Current Status of Project

VII. Project Detail/Capability Enhancement

VIII. Milestones

IX. Project Challenges

X. Evaluation/Impact

XI. Sustainability

I. Two Sentence Summary Instructions:

– This section should include information for those readers who will not read the entire document but who will need a summary of the proposal.

• The purpose and anticipated end result of this proposal

• The type and amount of support requested

• The total anticipated budget

• Other information you deem pertinent

Example:– The proposed project, District 5 and Statewide Hospital based

activities, will be implemented under the auspices of Managed Emergency Surge for Healthcare (MESH), a coalition dedicated to establishing best practices for hospital-based medical surge and preparedness for Indiana and the United States. MESH is in a unique position to close the existing gaps in hospital-based efforts, such as overall preparedness planning, expansion of medical surge (due to lack of supplies, space, and human resources), and lack of collaborative policies and infrastructure between the pre-hospital environment, emergency departments and hospitals, outpatient care resources, and governmental entities.

II. Applicant Info

This information is used to prepare the sub-grant agreement and should be completed on behalf of the entity legally authorized to enter into a contract or agreement with the State of Indiana.

Example:

– Organization Legal Name• School of Medicine

– Federal Tax ID• XX-XXXXXXX (MUST Match Organization Legal Name)

– Principle Executive Officer• John C. Jones

– Title• Assistant Vice President

– If non-government, date of IRS Non-Profit Approval

III. Primary Point of Contact This area is used to designate who the sub-grantee has

determined with serve as Project Manager and who we should contact with day-to-day operational questions.

Example:

– First Name – C.– Last Name - Smith– Organization –School of Medicine– Street 1 – 3930 Indiana Road– Street 2– City – Indianapolis– State - IN– Zip - 34567– Primary Phone Number – 317-630-XXXX– Alternate Phone Number– Fax – 317-656- XXXX– E-mail XXXXXX@medicineschool.edu– County - Marion

IV. Management Team

State all federal, state, local, non-profit, private, and educational organization partners should be listed here.

Describe the management team that is directly responsible for the implementation of this project. Specifically, describe any key project roles and responsibilities, structures, and subject matter expertise required by this project, including at least the project manager and the contract management structure. An organizational chart may be included in the response.

– Note: This should not be a description of an organizational chart. In addition to the project manager and SMEs, consider including admin functions such as accounting and procurement.

Management Team Example

Dr. Smith is a Medical Director of Project MESH and under his leadership five full-time staff are responsible for planning, training, and program management-related activities. Project MESH is in the process of establishing a voting board of directors that will provide overall direction to the coalition. The voting board will be comprised of executive leadership from District 5 hospitals, community health centers, and governmental agencies. Additionally, a working group currently meets on a monthly basis to ensure timely completion of projects and coordination among the District 5 Planning Council, the District 5 Hospital Group, MMRS Steering Committee, and the UASI Health and Medical Group.

V. Strategy Alignment – State/Federal

See the Indiana Strategy for Homeland Security’s matrix for a chart of Strategic Goals and Objectives, and their links to the National Priorities. Identify the specific goals and objectives in the Indiana Strategy for Homeland Security to which this project applies by choosing the appropriate goal and objective:

Example:

– Indiana Strategy• 7. Health and Medical – Establish an effective disaster health and medical

system

• 7.01. Ensure a responsible emergency medical service (EMS) system for mass casualty events

– US DHS National Priorities• Strengthen Medical Surge and Mass Prophylaxis Capabilities

• Strengthen Planning and Citizen Preparedness Capabilities

– US DHS Target Capabilities• Medical Surge

• Planning

• Triage and Pre-Hospital Treatment

VI. Current Status of Project This section will be scored in terms of contribution to setting

context and relationship with other sections

Describe the current status of this project, specifically including any outcomes that have already been achieved (be specific!). Discuss other options that were considered and why this project was selected over other options.

Example:

– Coordination of federally-mandated training exercises at Wishard Memorial Hospital, Westview Hospital, and St. Vincent Hospitals.

– In collaboration with Regenstrief Institute, currently in the process of developing an electronic medical records system for community health centers

– Expanded the resource cache for Marion County Health Department’s Points of Distribution Sites (PODS) to include laptop computers for 25 PODS

– Expanded the Siren ePCR project, allowing ambulances access to patient data in ambulances and establishing a link for Regenstrief Institute to access pre-hospital EMS data

VII. Project Detail/Capability Enhancement

Describe the overall, long-term purpose of this project, including how this project supports the Indiana Strategy for Homeland Security Goals and Objectives, the national Priorities, and the Target Capabilities identified.

Example: Through this initiative the following key objectives will be accomplished:

– Expansion of DMORT/DMAT: Project MESH will use the recently drafted District 5 Fatality Plan, and the upcoming fatality exercise to expand initiatives statewide. MESH staff will work with area coroners and morticians to expand fatality planning throughout the district, conduct appropriate training, and develop a District 5 inventory of DMORT resources. Additionally DMAT training will be offered throughout District 5 by expanding the already-established tactical EMS teams. Finally, statewide resources for DMORT/DMAT will be assessed, and MESH staff will work with IDHS officials for statewide planning and gap analyses.

VIII. Milestones

Provide detailed information on the expected timetable/milestones for the project.

– Base the milestones on the following phases:• Pre-Award• Active Grant Award• Post Award

– Appropriate level of detail includes entries such as: • Obtain support and feedback from first-responder stakeholders;

complete training on newly purchased GPS trackers; integrate communicates systems across fire/police departments and hospitals, etc.

• Inadequate detail includes entries such as: Stakeholder engagement, training, exercises.

Pre-Award Example

Description Start Date End Date Completed?

Mass casualty planning /fatality management will be revised and updated

06/01/08 12/31/08 Yes

Project MESH will establish the voting board of directors, comprised of executive-level leadership from area hospitals and governmental entities

01/01/09 07/31/09 No

Active Grant Award

Description Start Date End Date Completed

Project MESH will facilitate collaborative policy development and planning

09/01/09 08/31/10 No

Dedicated staff will develop and implement standardized trainings and functional and tabletop exercises

09/01/09 08/31/10 No

Post Award

Description Start Date End Date Completed

MESH will work with healthcare to continue to enhance their medical surge-related capabilities and ensure collaboration with appropriate governmental agencies

9/30/10 09/29/11 No

IX. Project Challenges

Identify any challenges to the effective implementation of this project. Include the probability that the challenge will occur, and the level of impact should it occur, as well as a description of how the challenge will be mitigated.

Possible areas of challenges include: – Schedule– Costs– Feasibility– Dependencies – Interoperability between this project and others,

Management– Organizational and change Management– Technology– Strategy– Resources

Example:

Challenge Impact Probability Mitigation Steps

Several technology projects need coordination

High Medium Dedicated staff will provide coordination and management of these projects

IX. Project Challenge

X. Evaluation/Impact

What outcomes will indicate that this project is successful at the end of it? What outcomes will indicate that this project is successful at the end of the performance period? Include:

– Outcomes that will be demonstrated throughout the project

– Outcomes that will be expected at the conclusion of the grant period

– Measurable outputs that will lead to these outcomes– How the outcomes will mitigate the risks in Indiana

Example:

The following outputs and outcomes will be used to measure the impact of the initiatives outlined within the scope of this proposal:

a) Medical supplies and PPE will be inventoried in one database for the entire District 5 area

b) Patient tracking software will be implemented and used by all the hospitals in District 5

c) Collaborative policies will be developed to enhance the pre-hospital surge capacity of hospitals and healthcare entities in District 5

d) Healthcare providers in Central Indiana will be well trained using standardized curricula

e) Pertinent hospitals and healthcare entities will collaboratively participate in functional and table top exercises

X. Evaluation/Impact Example

XI. Sustainability

What is the long-term approach to sustaining the capabilities developed by this project? Describe any additional sources of funding to be used, and future plans or milestones for sustaining the investment. Response should reference the impact (x. above) and how progress in addressing the capability gaps (identified in V. and VI. above) will be sustained.

Example:

– School of Medicine (SM) has dedicated significant resources to ensure successful accomplishment of deliverables outlined within the scope of Project MESH. These resources include dedicated staff for resource development, community outreach, and education, IUSM, through it collaborative partnership with Wishard Health Services, and Health and Hospital Corporation of Marion County has been successful in securing funding for various projects and is currently in the process of developing a comprehensive sustainability plan. Project MESH does not anticipate long-term grant funding, rather grant funds are anticipated for use as seed money, with the hope that private businesses and hospitals will support the initiative permanently.

Pre-Award Administration:Submitting a Budget

Submitting a BudgetDetail, detail, detail! Project – Specify proposal. Fund – If multiple funds are associated to a single proposal, specify to

which fund this item is associated. Solution Area (see specific grant guidance for information on

allowable costs)– Planning– Organization– Equipment (always consult http://rkb.mipt.org for equipment allowability)– Training– Exercise– Management and administration (please check with Grants Management before

adding M&A expenditures) Category – Specific to the solution area, specify the category of

expenditure. Discipline – Which primary discipline will benefit Description – Description of item Narrative – Description (when applicable) of how the budget numbers

were determined. For instance, if there is a $5,000 travel line, the Narrative would be a good place to explain the nature of that line item.

You must purchase what is listed in your budget to please be specific and be certain!

Pre-Award Administration:How Proposals are Evaluated

How Proposals Are Evaluated

State Evaluation – Will the proposal be included in the federal grant application for Indiana?– Primary emphasis on District based benefit. This must

be clearly defined and supported by all members of the District.

– Must show strong linkages to the state and national priorities.

– Milestones/goals must be SMART (Specific, Measurable, Attainable, Realistic, Timely)

How Proposals Are Evaluated (cont.)

Federal – Will Indiana score well on the application?

– In sections where a narrative is required, the general scoring is as follows:

• 0 = No narrative, or does not address how the Investment supports requirements.• 1 = Narrative describes a linkage, but provides no specifics on how the

Investment will support requirements.

• 2 = Narrative describes a linkage and provides some specifics on how the Investment will support requirements.

• 3 = Narrative describes a direct linkage and offers detailed specifics on how the Investment will support requirements.

– This scoring criteria is pulled directly from the federal review training program.

Your proposals are the foundation for Indiana’s federal grant application and the template is tailored to get the needed information so IDHS can make a strong and compelling application.

Active-Award Administration:Receiving the Award

Receiving the Award

Successful proposal submissions result in money to your area!

When you submit a proposal, you will be notified of the outcome: approval or denial.

If your award is approved, you will be provided with a sub-grant agreement (local jurisdictions) or MOU (state agencies).

This document is the legal means through which the funding actually gets to you and it is very important to understand what that document means.

Active-Award Administration:Agreements

Types of Agreements

Sub-grant Agreement– Prepared when money is awarded to local entities (i.e.,

counties, cities, non-profits) Memorandum of Understanding

– Prepared when money is awarded to other State agencies

– Prepared with locals to allow IDHS to expend money on their behalf. (i.e., Ardent Sentry where locals did not want the responsibility of coordinating with other state and Federal partners).

All sub-grant agreements and MOUs must be fully executed (signed by all parties at the state and local level) prior to any funding being obligated.

How an Agreement Gets Written and Fully Executed

SBA approves agreement; sends to Attorney General's

Office (AG)**

Legal Section sends agreement to Indiana

Department of Administration (IDOA)

IDOA approves agreement; sends to State Budget Agency

(SBA)

IDHS signs agreement

and returns to LS

AG approves agreement**; sends

to IDOA

IDOA scans document; sends to

IDHS LS

LS makes copy of agreement; delivers

copy to GMB

GMB scans agreement, notes FEA in iGMS and

Notifies sub-grantee

Fully Executed Agreement

available on iGMS

Sub-grant agreement

received, noted in iGMS and delivered

to Legal Section (LS)

Grants Management Branch (GMB) creates and distributes Sub-grant agreement to Project Manager

Project Manager distributes

agreement to Sub-grantee

Signed Sub-grant agreement returned to

IDHS Grants Management Branch

(GMB)

LS prepares EDS sheet, conducts

clearance checks*, legal review/approval, obtains fiscal approval and submits for IDHS

signature

~ 1 day

~ 12 days~ 4 days~ 1 days~ 3 days~ 3 days

~ 2 weeks –(

45 days)

**NOTE: If form approval has been obtained this step may be skipped.

* NOTE: Failure to clear through either the Department of Revenue (DOR) or Department of Workforce Development (DWD) will result in the sub-grant agreement being held until the sub-grantee has resolved the issue. GMB will notify sub-grantee of any issues related to clearance checks.

~ 3 days~ 3 days

~ 3 days ~ 5 days

Things YOU Can Do to Avoid Bumps in the Road

Make sure all documents are returned to IDHS with original signatures! (copies are not accepted)

Return all pages of the agreement Ensure compliance with Department of Revenue and

Department of Workforce Development requirements– Auditors office has all required payments up to date– No outstanding liabilities to either department– You will be notified by IDHS, but the corrective action must take

place between you and the corresponding agency. IDHS staff cannot facilitate a fix due to legal restrictions.

Verify NIMS compliance– Make sure all NIMS requirements are met– For questions, see http://www.in.gov/dhs/2559.htm

Verify EMS and Fire reporting compliance (if applicable)– Make sure all reporting requirements are up to date– For questions, see http://www.in.gov/dhs/2738.htm

Active-Award Administration:Staying Organized

Organization = Success

Every recipient is different, but staying organized will position you for success!

Recommended file organization:– One binder per grant (2006 EMPG, 2007 HSGP, 2008

EMPG, etc.)– Sections

• Agreements (sub-grant agreements, MOUs, amendments)• Proposals• Budget (original exists in agreement, this would be where the

changes and approvals are recorded)• Reimbursements/disbursements• Quarterly reports• Correspondence (anything that explains the whats and whys of a

project)• Other pertinent information (you will not be penalized for over

documentation)

Active-Award Administration:Reimbursement

Requesting Reimbursement

All IDHS grants are reimbursement based. Advances are not allowed.

Requesting a reimbursement is a two part process:– Enter the request in the iGMS– Send the request proof to IDHS. E-mail or fax is most reliable.

Once the reimbursement request is approved in the iGMS (~2 business days after proof is received), that signals the request has been sent for payment. Payment typically happens 10-14 business days after approval (depending on the Auditor of State).

All reimbursements should be approved in approximately 2 business days from receipt of proof, if you have submitted a reimbursement request and corresponding proof, please feel free to contact Grants Management to address any delays. Our top priority is to get your money to you as fast as possible!

Active-Award Administration:Quarterly Reports

Submitting Quarterly Reports

Quarterly reports are due 15 days after the close of the quarter on:– January 15– April 15– July 15– October 15

Successful submission requires:– Transmission in the iGMS– Signed original sent to IDHS Grants Management

Quarterly reports should:– Detail obligations/expenditures– Provide applicable project data including any perceived

or anticipated areas of concern.

Active-Award Administration:Monitoring

Monitoring

The Indiana Department of Homeland Security (IDHS), as the federal grantee, is responsible for monitoring sub-recipients and ascertaining that all fiscal, compliance and programmatic responsibilities are fulfilled.

Monitoring (cont.)

Comprehensive document review may include:

– Monitoring sub-recipient reporting – Recordkeeping – Internal operation/controls– Accounting control systems

Importance of Monitoring

Monitoring assists IDHS to identify areas of need for sub-grantee support and provides feedback on ways to improve its services.

Federal requirements mandate that as the pass-through Agency, the Indiana Department of Homeland Security, is responsible for maintaining the standards of consistency and uniformity set for the audit of non-Federal entities expending Federal awards.

How Can Monitoring Help You?

Help you get organized!

Ensure reimbursement flow

Serve as a resource for documentation of processes and internal operations

Affirm positive actions and processes

Provides feedback and identify areas of need

Prepares you for a local, state or federal audit!

 

Desk Review Monitoring

Our goal at this point is to conduct office-based monitoring reviews for one third of all sub-grantees per fiscal year per active grant program.

The Grants Compliance Officer reviews the sub grantee’s master grant file to perform fiscal, compliance and programmatic monitoring.

 

Desk Review

At a minimum a desk review will be completed for 1/3 of all Sub-grantees for each grant per fiscal year. Items to be reviewed may include:

– Complete application/proposal– Sub-grant agreement– Amendments and associated documentation– Substantial presentation/promotional/training materials– Applicable correspondence– Inventory, receipt of materials– Quarterly financial and progress reports with supporting

documentation (including narrative status reports)– Requests for reimbursements– Proof of expenditures

On-site Monitoring

On sight monitoring can happen as a result of findings from a single audit, desk review or because a sub-recipient is considered high risk

If the sub-recipient has received sub-grants under several programs, all program grants are reviewed and monitored at the same time and the appropriate IDHS Project Managers participate.

The sub grantee will be provided with information regarding what will be required during the monitoring session.

On-site, the Grants Compliance Officer will review applicable grantee spending plans, accounting systems and controls, records retention systems, 3rd-party contracting, procurement activities, and equipment maintenance and property management systems.

A major portion of the meeting involves discussions about project implementation such as milestones, timeline, rate of funds expenditure, project operations, performance measures and evaluation,

Active-Grant Administration:Requesting Changes in Your Grant

Changing an Agreement:Grant Adjustment Notice

(GAN)A GAN is required when: There is a deviation in the award amount

Change in budget detail

Update contact information

Obligate or deobligate funds

To reconcile budget prior to close out

Request to change project period

Requesting a Performance Period Extension

Extension requests must be made 30-60 days prior to the end of the project period (set in the sub-grant agreeement). Late requests will result in deobligation. Requests must include:

– Justification for delay/setback including any mitigating circumstances

– Detailed current report of encumbrances/expenditures– Updated, detailed, realistic timeline to include future

encumbrances and payment schedules– Other applicable supporting documentation

Active-Grant Administration:Fraud Awareness

Fraud Awareness

Each year, the United States Government awards nearly $450 billion dollars in Federal Assistance Agreements, most commonly in the form of grants that help to:

– Support national infrastructure programs in transportation, homeland security, criminal justice, agriculture, human health, and the environment.

– Fund scientific research, studies, and analyses.– Further the social sciences, art, literature, and promote

cultural enrichment.

Unfortunately, grant dollars are susceptible to fraud, waste and abuse.

Common Grant Fraud Scenarios

Grant fraud occurs in many ways, but some of the most common fraud scenarios include:– Charging personal expenses as business expenses

against the grant.– Charging for costs which have not been incurred or are

not attributable to the grant– Charging for inflated labor costs or hours, or categories

of labor which have not been incurred (for example, fictitious employees, contractors, or consultants).

Fraud indicators:– False or altered supplier invoices– Intentional inaccuracies about performance or

completion– Payments to influence grant awards

Case #1 Background

– Chief Financial Officer for Head Start grantee– Agency received $13 million a year– Co-defendant operated shell realty company

Allegations

– CFO funneled $1.1 million from Head Start facility renovation projects to self

– Paid personal bills– Entertained mistress– Paid college tuitions for relatives

How

– Circumvented internal controls– Sole check writer and only person to reconcile bank account

Result

– 51 months confinement– 3 years supervised release– Restitution

Case #2 Background

– Chief of Family Services

– Diverted money from program designed to benefit foster care and adopted children

Allegations

– $35,000 for travel to Israel

– $18,00 in consulting services provided by herself

– $2,700 in catering expenses

– $15,000 in building renovations – in Israel

Charges

– False claims

– Conspiracy

– Obstruction of Justice – Impeding a federal investigation and attempting to conceal that she paid herself federal funds

Result

– 6 months of home confinement

– 100 hours of community service

– 2 years probation

– $250,000 criminal fine

– $274,000 in restitution

– Debarment

Other Fraud Instances

The Senate permanent Subcommittee on Investigations recently reviewed Medicare claims from 2000-2007 and found significant payments for medical services ordered by over 16,500 dead doctors – between $60 million to $92 million.  Some doctors had been deceased for more than 10 years  

A Brooklyn dentist “performed” as many as 991 procedures in a single day

Grants Management Staff“Who Ya’ Gonna Call”

Andy Zirkle - (317) 234-3321– General Management and Oversight

Niki Theeuwes - (317) 234-2981– Grant Writing and General Customer Service

Sy Walden-James- (317) 234-2583 – Award, Budget and IGMS concerns

Dolly Watkins – (317) 234-6507 – Reimbursement and Disbursement concerns

Cindy Riley – (317) 234-5959– HMEP and Monitoring concerns

Beth Clark- (317) 232-1681 – PSIC, CSEPP and IECGP concerns

Vicki Biddle – (317) 234-5917– Quarterly Reports and General Clerical

Additional Resources

www.grants.gov – clearinghouse for federal grant announcements and application

www.ready.gov – source for preparedness information for the general public

www.cfda.gov - The Catalog of Federal Domestic Assistance

www.rkb.mipt.org – Responder Knowledge Base – source for the Authorized Equipment List

www.in.gov/dhs/2338.htm - IDHS Administrative Plan for Grants Management

Sources:

National Procurement Fraud Task Force Presentation

A Guide to Grant Oversight and Best Practices for Combating Grant Fraud, National Procurement Fraud Task Force, Grant Fraud Committee, February 2009

Audit Tips for Managing Disaster-Related Project Costs, Department of Homeland Security, Office of Inspector General, October 2008

Seminar on Financial Management, Office of the Chief Financial Officer, Office of Justice Programs

FEMA Grant Programs Directorate, Grants Management Division, Match Guidance

State of Indiana Department of Homeland Security and Emergency Management Sub-Recipient Grant Management and Monitoring Policy