To Buy or Not To Buy- That is the Question

1. To Buy or Not To Buy-That is the Question!

2. 21st CCLC Leadership Team Presenters Sandra Ricardo, M.S. Coordinator of Compliance UF 21st CCLC Leadership Team sricardo@hhp.ufl.edu Ive B. Vintimilla, MPA Coordinator of Audits & Budgets UF 21st CCLC Leadership Team ivintimilla@hhp.ufl.edu Policy, Monitoring, and Compliance Unit

3. Topics Basic Cost Principles Questions to Ask Prior to Purchasing Statutes and Regulations Examples Case Studies

5. Guiding Questions Does the purchase support a goal/objective in your grant? Does it support an activity specified in your grant? Is it consistent with special conditions imposed on the grant by FDOE (such as no purchases of food, furniture, incentives, etc.) Is it consistent with Title IV, Part B and other statutes and regulations governing 21st CCLC? Is it consistent with the cost principles in the OMB Circular applicable to your organization?

6. Title IV, Part B of The Elementary & Secondary Education Act, As Amended (formerly NCLB) http://www2.ed.gov/programs/21stcclc/index.html Title IX Part E, Uniform Provisions-Private Schools http://www2.ed.gov/about/offices/list/oii/resources/info/guidance.html Statutes

7. Regulations Education Department General Administrative Regulations (EDGAR) Part 80-for State and Local Governments (LEAs) Part 74-for Colleges, Universities, Hospitals, & Non-Profit Organizations http://www2.ed.gov/policy/fund/reg/edgarReg/edgar.html

8. Guidance U.S. Education Department�s 21st CCLC Non-Regulatory Guidance: provides clarification for statutes does not carry the weight of laws or regulations 21st CCLC Non-Regulatory Guidance (Feb. 2003) http://www2.ed.gov/programs/21stcclc/legislation.html Equitable Services for Eligible Private School Students, Teachers, and Other Educational Personnel http://www2.ed.gov/about/offices/list/oii/resources/info/guidance.html

9. Office of Management and Budget (OMB) Cost Principles for Federal Education Programs OMB Circulars (in each) Appendix A- General Cost Principles General Principles for Determining Allowability of Costs Appendix B-Selected Items of Cost List of 40-50 Specific Allowable/Unallowable Items http://www.whitehouse.gov/omb/circulars/

10. OMB Circulars & Your Organization

11. Basic Guidelines All Costs Must Be: 1. Necessary 2. Reasonable 3. Allocable 4. Legal under state and local law 5. Conform with federal law & grant terms 6. Consistently treated 7. In accordance with GAAP 8. Not included as match 9. Net of applicable credits 10. Adequately documented

12. Necessary and Reasonable Before submitting that P.O. ask yourself the following: Do we really need this? Is this the minimum amount I need to spend to meet the program�s needs? Can I justify the need with the terms of my grant? Do I have the capacity to make the best use of this purchase? Will I pay a fair price and can I prove that it was a fair price? You must be able to answer �yes� to all.

13. Will program participants benefit from this purchase? Example: Purchasing materials & supplies or equipment at the end of the project year is not allocable. Did you charge 21st CCLC in proportion to the value received by the program? Example: Sub-grantee purchases computers to use 50% in the 21st CCLC program and 50% in another federal program � can only charge half the cost to 21st CCLC Allocable

14. Basic Guidelines Continued Legal under State and Local Law If you can�t do it under state law, you can�t pay for it with federal funds i.e., purchasing food Conform with applicable laws, regulations, & the terms of the grant READ YOUR GRANT!! Consistently treated Must follow uniform policies that apply equally to federal and non-federal activities Cannot assign cost as direct cost if indirect under state programs

15. Conform with Generally Accepted Accounting Principles (GAAP)? Not Included as a Match Net of Applicable Credits (rebates, discounts, refunds) Basic Guidelines Continued

16. Adequately Documented No documentation=didn�t happen Some Examples: General Ledger indicating all expenditures Paid Invoices Purchase Orders Bank statements or cancelled checks Receipts (complete with totals) Payroll records (timesheets, PARs, periodic certifications, payroll registers) Travel reimbursement forms and supporting documentation Other records to facilitate an effective audit Basic Guidelines Continued

17. Cannot use federal funds to supplant federal, state, and local resources. Examples of supplanting: Using federal funds to pay for a service required by federal, state, or local laws Using federal funds to pay for a service paid with other funds the previous year Some examples: Purchasing textbooks required for regular school day curricula Paying for teacher training program with 21st CCLC funds. This program was paid with state funds the previous year. Supplement Not Supplant

18. Burden of Proof Monitors presume wrong doing until proven otherwise Burden of proof is on sub-grantee No documentation=it didn�t happen

19. No, No's, Unless� Food (unless have approved cooking classes & purchase �raw� food items) Field Trips to Amusement Parks (unless following park�s educational component) Attending Movies (unless attending educational film tied to unit of study & cost is reasonable) Furniture (unless purchasing locking cabinets to safeguard equipment and supplies) All of the above require excellent documentation to support allowability.

20. No, No's No, No's (some examples) Costs associated with attending sporting events Purchasing video systems and video games Purchasing MP3 players or portable media players Incentives (plaques, trophies, bumper stickers) Capital improvements & permanent renovations Purchases of appliances such as refrigerators & freezers Purchases of vehicles When in doubt, contact our office or your TAT consultant.

21. Approved Plan and Budget Purchases without approval in the budget or amendment may result in questioned costs. Some Examples: Contracting for services The purchase of equipment (capital outlay) Purchases outside of the approved budget period (refer to DOE 200, section 6, Project Period) Paying salaries/wages for type of personnel without authorization (i.e., hiring a paraprofessional not in approved budget)

22. Case Studies Read the case study given to your group. Discuss each scenario and the questions that follow each. Come to a consensus about the answers to the questions. Choose someone from the group to lead a discussion on your scenario.