Language Resource Center Program
FY 2010 – 2013 Grant Cycle
Clarity & communication◦ Please ask questions if/when you have them!
Documentation◦ Provides greater protection against audit inquiries
Meeting deadlines
Budget revisions – clear and concise
“Open Door Policy” – please let me know if/when you will be in town!
Expectations
Authorized/Certifying Representative: authorized person on campus to sign for the grant; this person is established at the time of application on the SF-424
Project Director: person in charge of grant activities; director of the established center
Principal Investigator = We do not use this term
LRC Terminology: On Campus
Additional contacts (IRIS): person(s) who help with the administration of the grant via IRIS; please limit access to a select few
Contract: a procurement contract under an award or subaward, and a procurement subcontract under a recipient's or subrecipient's contract.
Subrecipient: the legal entity to which a subaward is made and which is accountable to the recipient for the use of the funds provided.
LRC Terminology
A subcontract covers a specific service(s) to be rendered, while a subgrant means an award of financial assistance to another entity
A subgrant is UNALLOWABLE, per 75.708 Prohibition of subgrants:◦ (a) A grantee may not make a subgrant under a program
covered by this part unless specifically authorized by statute.
Subcontractors are not allowed to render services that are outside the parameters of the LRC regulations
Subcontract vs. Subgrant
The Language Resource Centers Program provides assistance to establish, strengthen, and operate centers that serve as resources for improving the nation’s capacity for teaching and learning foreign languages effectively
Language Resource Centers
The conduct and dissemination of research on new and improved methods for teaching foreign languages, including the use of advanced educational technology;
The development and dissemination of new materials for teaching foreign languages, to reflect the results of research on effective teaching strategies;
Authorized Activities
The development, application, and dissemination of performance testing that is appropriate for use in an educational setting to be used as a standard and comparable measurement of skill levels in foreign languages;
The training of teachers in the administration and interpretation of foreign language performance tests, the use of effective teaching strategies, and the use of new technologies;
A significant focus on the teaching and learning needs of the less commonly taught languages, including an assessment of the strategic needs of the United States, the determination of ways to meet those needs nationally, and the publication and dissemination of instructional materials in the less commonly taught languages;
The development and dissemination of materials designed to serve as a resource for foreign language teachers at the elementary and secondary school levels; and
The operation of intensive summer language institutes to train advanced foreign language students, to provide professional development, and to improve language instruction through preservice and inservice language training for teachers.
◦ Allowable costs: Honoraria
◦ Unallowable costs: T-shirts, souvenirs, gifts
Budget
Allocable: charged in proportion to value received by project
Allowable: either permitted or not specifically prohibited
Budget Revision = changes made to the budget throughout the grant period
Reasonable: costs that would be incurred by a “prudent” person
Revised Budget: agreed upon, edited budget that was resubmitted after receiving the Grant Award Notification (GAN)
Budget Terminology
Budget amounts: Year 1: Actual amount awarded Years 2-4: Anticipated amounts, based on current funding.
Indirect costs are limited to 8%
Equipment costs cannot exceed 15%
Grantees need to adhere to budget submitted and approved by US/ED. Some changes may require US/ED approval.
Prior approval is not required for most budget transfers unless they are over 10% or $100K, though program officers like to be notified of changes.
Budget Guidelines
Carryover from one fiscal year to the next fiscal year is allowable
The amounts of carry over funds must be reported in IRIS
An explanation will be needed for the large sum, as well as a plan to expend it
Be sure to separate carryover from new fiscal year funds in budget and budget reporting.
Carryover Funds
Draw down only enough cash to meet grant’s immediate need
Minimize the time between draw down and pay out of funds (three-day rule of thumb)
Reimbursement method is the safest
Drawing down too much or too little will cause you to be flagged by the Department of Education
Draw-Downs
Ultimate goal: clear and concise for 4 years
Discuss any changes with the program officer before making permanent amendments on campus
Any programmatic changes and/or reprogramming of funding must be documented in a new budget
Cost shares submitted in the application (ED 524 Section B) must be honored for the duration of the grant
Maintaining Your Budget
If you indicate a non-federal contribution on the SF 524 budget form, you are required to provide that amount and follow the regulations on documenting cost share/match found in EDGAR §74.23
Matching contributions must be verifiable from the recipient’s records, not included as a contribution for any other federal project (no double counting), necessary and reasonable for the accomplishment of the project, allowable under the cost principles, and not paid by the Federal Government under another award
Cost Share/Match
OMB Circular A-21: Cost Principles for Educational Institutions◦ Learn it, live it, love it!
Examples of unallowable costs:◦ Alcohol◦ Fundraising◦ Entertainment
Is that allowable?
Monitoring
Implementing the project
Compliance with statutory & regulatory requirements
Fiscal management and accountability
Recordkeeping and reporting requirements
Project Director Responsibilities
34 CFR 655 and 34 CFR 669
EDGAR Regulations: Parts 74, 75, 77, 79, 80, 81, 82, 85, 86, 97, 98, and 99.
OMB Circular A-21: Cost Principles
OMB Circular A-133: Audit Principles
Department Directives and Bulletins
Individual Grant Terms and Conditions
Approved and Awarded Grant Application
LRC Monitoring Tools
Must be Fly America Act compliant
Security concerns
Per Diem Rates:◦ Domestic: as established by General Service
Administration (GSA)◦ International: as established by the Department
of State (DOS)
Travel
EDGAR 34 CFR § 74.21 (b) Standards for financial management systems
◦ (1) Disclosure of financial results◦ (2) Records that identify the source and application of
funds ◦ (3) Effective control and accountability ◦ (4) Comparison of outlays with budget amounts ◦ (5) Procedures for draw downs◦ (6) Procedures for determining the reasonableness,
allocability, and allowability of costs◦ (7) Accounting records including cost accounting
records that are supported by source documentation
Financial Management
Purpose:◦ Reliability of financial reporting◦ Compliance with laws and regulations◦ Safeguarding of assets
Requirements:◦ Written policies and procedures◦ Segregation of duties◦ Proper authorizations◦ Sufficient documentation◦ Reporting
Internal Controls
Personnel costs must be reasonable and reflect actual work performed
Effort includes the time spent working on a sponsored project in which salary is directly charged or contributed (cost-shared)
Effort is expressed as a percentage distribution that adds up to 100%
Effort reports are different from payroll records. Reports must be certified and signed on a regular basis
Personnel Time and Effort
Exemplary project
Multiple grants
Large grant award amount
Random selection
We just like you.
Need for technical assistance
A-133 single audit findings
Complaint
Late performance report
Frequent turnover of personnel
Site Visits: Why us?
Poor record-keeping/ lack of documentation Weak internal controls Unallowable costs Poor sub-recipient monitoring Contracting out project activities without
approval Missing time and effort reports
Common Problems to Avoid
Set out clear roles and responsibilities Develop and follow written policies and
procedures Document, document, document If in doubt:
◦ Consult the “Monitoring Tools”◦ Contact your Program Officer
Helpful Reminders
Evaluation
Evaluation is the systematic data collection, analysis and information gathering needed to make decisions.
It is a continuous process – start now to determine where you want to be in four years.
Be selective: What elements/components of your program are you evaluating and why? How do these tie to your objectives?
Evaluation: What is it?
Programmatic: AIR study and survey
Institutional: Impact of Title VI on campus
Project: Overall impact of LRC grant activities
Component: Curriculum, Outreach, Language Proficiency
Sub-Component: A specific aspect such as a teaching training workshops or summer institutes
Levels of Evaluation
Evaluation is vital to the overall international education initiatives at your institutions. It informs priorities, resource allocations, and any adjustments needed to improve instruction, outreach, professional development activities, student services, etc.
Why is it important?
Accountability◦ Are we doing what we said we would?
Outcome◦ The immediate or direct effect of the project.
Impact◦ Is the program making a difference. (gets back to the
evidence, i.e., data collection) Sustainability
◦ What elements exist or will be in place to ensure that improvement will be sustained. Institutionalization. Brand recognition. Leveraging appeal.
Lessons learned◦ Factors that supported or inhibited the accomplishment of
stated objectives. Unexpected outcomes.
Core Components
A key to successful evaluation is a set of clear, measurable, and realistic project objectives.
If objectives are not realistic or not appropriate to what you have envisioned, you will not be able to demonstrate or provide evidence that project activities have been successful.
Other Considerations
Grant Maintenance
Bi-annual reports, fall and spring, are captured through IRIS
◦ The LRCs and NRCs have different spring report due dates!
Please make sure budgets are submitted with the spring report
Information collected in these reports contribute to decisions on non-competing continuations (NCC)
Reporting
Reporting is also used for Departmental measures and requirements
Progress on projects should be clearly explained and indicated
Yes, your reports in IRIS matter!
Call or email to let us aware of the situation Questions to consider:
◦ Do funds need to be reprogrammed?◦ How does this affect the grant in the short term?◦ How does this affect the grant in the long-term?◦ What could be possible solutions?
Each “problem” will be approached and resolved individually
Please speak to us directly!
What if something changes?
Must immediately notify us when –◦ Change of key personnel◦ Reduction of 25% of the time devoted to the project◦ Absence of a project director for more than 3 months◦ (See EDGAR 74.25)
If a new project director is hired, the Authorized Representative must send his or her CV immediately
Please keep us abreast of any “significant” staff changes
Staff Changes
Prospective goal: two sites visits for fiscal year 2011
Not attending ACTFL
Please alert me to any LRC-related events within the DC Metro Area
Out & About
The LRCs and NRCs function under different sets of regulations.
If you haven’t heard it from me or via Elaine, then it is likely not true.
Friendly Reminders
DOS Per Diem: http://aoprals.state.gov/web920/per_diem.asp
Electronic Code of Federal Regulations: http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=/index.tpl
Fly America Act (Airline Open Skies Agreement): http://www.gsa.gov/portal/content/103191
GSA Per Diem: http://www.gsa.gov/portal/category/21287
Helpful Websites
IRIS: http://iris.ed.gov Joint LRC Website: http://nflrc.msu.edu/ LRC Website:
http://www2.ed.gov/programs/iegpslrc/index.html
OMB Circular A-21 for Educational Institutions: http://www.whitehouse.gov/omb/circulars_a021_2004
Helpful Websites
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