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Grants Management Requirements and Updates

Stay informed on the latest updates and requirements for grants management, including topics such as financial management standards, allowable costs, cash management controls, and audits.

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Grants Management Requirements and Updates

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  1. Grants Management Requirements and UpdatesTiffany Winters, Esq.twinters@bruman.comBonnie Little Graham, Esq.bgraham@bruman.comBrustein & Manasevit, PLLCwww.bruman.com February 2014

  2. EDGAR Roadmap Time and Effort Requirements Omni Circular Updates Topics

  3. Standards for Financial Management How to Determine if a Cost is Allowable Cash Management Controls and Obligations Asset Controls Procurement Controls Selected Cost Items Audits and Enforcement EDGAR Roadmap

  4. What is the significance of EDGAR? Which OMB Circulars apply? What is the relationship to program regulations? What legal authorities do you rely on? Key Questions

  5. Administrative Rules • Postsecondary – Part 74 • Nonprofits – Part 74 • SEAs/LEAs – Part 80 • Direct Grants – Part 75 • State-Administered Programs – Part 76 • Enforcement – Part 81 • FERPA – Part 99 Anatomy of EDGAR Now Be Combined Into One Section?

  6. SEAs/LEAs – A-87 Postsecondary Institutions – A-21 Nonprofits – A-122 Cost Principles

  7. SEAs/LEAs – A-133 Postsecondary Institutions – A-133 Nonprofits – A-133 Audit Principles

  8. Standards for Financial Management Systems • 80.20(b) • Allowable Costs • 80.22 • Basic Guidelines • A-87 Roadmap of EDGAR and OMB Circulars

  9. Period of Availability of Funds • 80.23 • When Obligations are Made • 76.707 • When Certain Subgrantees May Begin to Obligate Funds • 76.708 • Obligations Made During Carryover Period • 76.710 Roadmap of EDGAR and OMB Circulars

  10. Equipment • 80.32 • Procurement • 80.36 • Retention and Access Requirements for Records • 80.42 Roadmap of EDGAR and OMB Circulars

  11. Records Related to Grant Funds • 76.730 • Monitoring and Reporting Program Performance • 80.40 • Enforcement • 80.43 Roadmap of EDGAR and OMB Circulars

  12. Selected Items of Cost • Appendix B to A-87 • Travel (p. 28) • Advertising • Personnel Costs • Meetings Roadmap of EDGAR and OMB Circulars

  13. Time and Effort Documentation

  14. If federal funds are used for salaries, then time distribution records are required. • How staff demonstrate allocability • If employee paid with federal funds, then must show that the employee worked on that specific federal program cost objective. OMB Circulars Time and Effort Rule

  15. All employees paid with federal funds!! • Some employees paid with non-federal funds • When salaries are used for match purposes • NOT contractors Who must participate?

  16. Does X employee have to keep time and effort records?

  17. Semi-Annual Certification • Completed at least every 6 months • After-the-fact record (dated) • Signed by employee or supervisor with first hand knowledge of the activity performed • Accounts for the total activity for which employee compensated A-87: If employee works 100% on single cost objective

  18. Personnel Activity Reports (PARs) • After-the-fact record • Accounts for the total activity for which employee compensated • Completed at least monthly • Signed by the employee • Must coincide with one or more pay periods A-87: If employee works on multiple cost objectives

  19. Time and Effort Guidance by OCFO!!! http://www2.ed.gov/policy/fund/guid/gposbul/time-and-effort-reporting.html

  20. It is possible to work on a single cost objective even if an employee works on more than one Federal award or on a Federal award and a non-Federal award. • The key to determining whether it is a single cost objective is whether the employee’s salary and wages can be supported in full from each of the Federal awards on which the employee is working or from the Federal award alone if the employee’s salary is also paid with non-Federal funds. OCFO Guidance

  21. Title I, Part A funds and State compensatory education funds An LEA supports a supplemental math teacher to serve low-achieving students with 50 percent Title I, Part A funds and 50 percent State compensatory education funds. OCFO Guidance Examples of Single Cost Objectives:

  22. Title I, Part A funds and CEIS (comprehensive early intervening services) funds under IDEA A teacher works with low-achieving students and is supported with 60 percent Title I, Part A funds and 40 percent CEIS funds. Teaching low-achieving students is a single cost objective because it can be fully supported under both Title I, Part A and CEIS. OCFO Guidance Examples of Single Cost Objectives:

  23. Title I, Part A funds and local funds An LEA supports an elementary school teacher with local funds but pays her with Title I, Part A funds to provide after-school tutoring for low-achieving students. Although the teacher could not be paid with Title I, Part A funds to provide elementary education, the portion of her time spent on after-school tutoring is easily separated from her teaching position by her schedule. OCFO Guidance Examples of Single Cost Objectives:

  24. Substitute Systems

  25. Substitute systems may be used in place of these reports if approved by the cognizant agency. • These systems are subject to approval if required by the cognizant or oversight agency. • May include random moment sampling, “rolling” time studies, case counts, or other quantifiable measures of employee effort. Substitute Systems Generally

  26. Q & A

  27. If a State-funded employee is paid a stipend with federal funds for attending professional development, does time and effort documentation have to be kept? A. Yes B. No Federal Stipends

  28. Federal funds can generally be used to pay for stipends for professional development or other extra-curricular activities. • Time and Effort documentation must be kept. • Maryland January 2013 ARRA Audit - • Documentation not kept for employees partially funded with federal funds. Federal Stipends

  29. If a federally paid teacher works on a single cost objective but also has limited other responsibilities, such as cafeteria or bus duties. This teacher must keep: A. Monthly PARs B. Semi-annual certifications

  30. Limited work on another cost objective does not need to be captured in time and effort records. Employees may work 5% or less on another cost objective. The worked performed on these limited duties cannot deprive a benefit from the intended beneficiaries. The Montana Compact on Time Distribution, at p. 8, Q11. De Minimus Benefit

  31. Are substitute teachers paid with federal funds required to track their time? A. Yes B. No Substitute Teachers

  32. Are federal paid part-time employees required to track their time? A. Yes B. No Part-Time Employees

  33. Multiple federally paid employees working on the same single cost objective can be identified on a single semi-annual certification. A. True B. False

  34. Provides flexibility. Identifies multiple employees working on the same single cost objective. Must be prepared at least semi-annually. Signed and dated by supervisor with firsthand knowledge of the employees’ work. The Montana Compact on Time Distribution, at p. 3. Blanket Certification

  35. The district has a Title I, Part A funded contract with a vendor for afterschool tutoring of Title I students. Do the contractor’s employees need to keep time and effort records? • Yes • No Contractors v. Employees

  36. Provides goods or services within normal business operations. • Provides similar goods or services to others. • Operates in a competitive environment. • Provides goods or services that support the Federal program. • Subject to terms of a contract but not compliance requirements of program. OMB Circular A-133(B) §__.210(c) Characteristics of a Contractor

  37. Examples - Right or Wrong?

  38. I certify that for the month of August 2013 I, Michelle Obama, spent my time working on the following programs: Title I, Admin 20% State programs 30%____ Total 50% Signed: ___/s/____ September 10, 2013 PAR Example

  39. I, Britney Spears, certify that I worked 100% of my time on IDEA, Part B from February 1, 2013 to July 31, 2013. Signature of Employee ____/s/______________ Date: August 1, 2013 Semi-Annual Certification Example

  40. I, Taylor Swift, certify that I worked 100% of my time on Title I, Part A Administration from January 1, 2013 to June 30, 2013. Signature of Employee ____/s/______________ Date: June 20, 2013 Semi-Annual Certification Example

  41. I certify that for the month of October 2013 I, Justin Beiber, spent my time working on the following programs: 21st CCLC, Admin 20% State programs 30% Annual Leave 50% Total 100% Signed: ___/s/____ November 10, 2013 PAR Example

  42. I certify that for the month of October 2013 I, Barack Obama, spent my time working on the following programs: 21st CCLC, Admin 85% State programs 15%____ Total 100% Signed: ___/s/____ November 15, 2013 PAR Example

  43. I certify that for the month of October 2013 I, Orlando Bloom, spent 60% of my time working on Title I, Admin. I certify 100% that the above information is accurate. Signed: ___/s/____ November 5, 2013 Semi-Annual Certification

  44. The Omni Circular

  45. A-102: Administrative Rules State and Local Govts • Part 80 – EDGAR • A-110: Administrative Rules IHEs and Nonprofits • Part 74 – EDGAR • A-87: Cost Principals – State and Local Govts • A-21: Cost Principals – IHEs • A-122: Cost Principals – Nonprofit Orgs • A-133: Audit Rules The OMNI Circular: What is covered?

  46. Simplicity • Consistency • Obama Executive Order on Regulatory Review • Increase Efficiency • Strengthen Oversight Reasons for the Change?

  47. All “nonfederal entities” expending federal awards Who is covered?

  48. Feb 1, 2013 Notice of Proposed Rulemaking • Dec 19, 2013 Final Rule Released • Dec 26, 2013 Federal Register Published Rule • April 2014 New OMB ComplianceSupplement • June 26, 2014 ED Draft EDGAR Changes • Dec 26, 2014 Final EDGAR Published Key Dates:

  49. If federal program statute or regulation differs from Omni Circular, then statute / regulation governs. Inconsistency Between Program Statute and Circular

  50. Shift from focus on Compliance to focus on PERFORMANCE!!! • Auditors (A-133 + Federal OIG) and Monitors (Federal and State Pass Through) must look more to “outcomes” than to “process” • The Omni Circular adds significant flexibility to way grantees / subgrantees can adopt their own processes Most Significant Changes

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