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Grant Administration FY06 ERCM Initial Grantee Meeting San Antonio, TX December 7, 2006. Rich Lucey Education Program Specialist, U.S. Department of Education, Office of Safe and Drug-Free Schools Bryan Williams Program Analyst, U.S. Department of Education,
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Grant AdministrationFY06 ERCM Initial Grantee MeetingSan Antonio, TX December 7, 2006 Rich Lucey Education Program Specialist, U.S. Department of Education, Office of Safe and Drug-Free Schools Bryan Williams Program Analyst, U.S. Department of Education, Office of Safe and Drug-Free Schools
Agenda • Monitoring and Reporting Requirements • Faith-Based Organizations • Fiscal Management • Audit Requirements • Expanded Authorities • Freedom of Information Act • Useful Resources
Monitoring & Reporting Requirements • Notify Monitor of Changes • Post-Award Performance Call • Semiannual Monitoring Call • Grant Performance Reports • Interim and Final Reports
Grant Performance Report (ED 524B) • ED's generic performance report for discretionary grants • Used by ED's program offices as an interim and final performance report • May be submitted electronically through e-Reports
Purpose of the ED 524B • ED collects performance measures data from grantees to demonstrate program success to Congress (Government Performance and Results Act) • Performance information: • Guides ED's budget request for programs • Ensures program implementation is focused on results • Ensures success is measured by results achieved
Purpose of the ED 524B • Financial and performance monitoring tool for ED program offices for individual grants • Interim Reports: Grantees provide data to demonstrate that they are making substantial progress toward meeting approved goals, objectives, and performance measures to receive continuation funding. • Final Reports: Grantees provide data to demonstrate overall project success and impact.
Highlights of the ED 524B • Project Objectives: State what you hope to achieve with your funded grant project • Performance Measures: Demonstrate whether you have met or are making progress toward meeting your project objectives, including GPRA measures
Highlights of the ED 524B • ED 524B Cover Sheet (Item 7) • Interim Performance Reports: Reporting period is from start of current budget period through 30 days before due date of report. • Interim performance reports are generally due 7 to 10 months after the start of each budget period.
Highlights of the ED 524B • Budget Expenditures Data (Item 8) • All financial questions must be completed by your Business Office • Submit actual budget expenditures for: 1) Entire Previous Budget Period 2) Current Reporting Period • Break down expenditures between federal and non-federal funds
Highlights of the ED 524B • Budget Information (Section B of the Project Status Chart) - must address • Provide an explanation if funds have not been drawn down from GAPS to pay for budget expenditures reported in item 8 on Cover Sheet • Describe significant budget changes resulting from modification of project activities
Site Visits • Site visits are a grant monitoring tool as provided for in EDGAR Part 74.51(g), "The Secretary may make site visits, as needed." • Also called an on-site review • A site visit may last multiple days
Site Visits Reasons to conduct a site visit • Program performance - Excellent • Goals and objectives achieved in unique or innovative ways • Development of effective strategies that may be replicable at other sites
Site Visits Reasons to conduct a site visit • Program performance - Problem • Difficulty achieving goals and objectives • Compliance issues • Fiscal improprieties • Technical assistance
Site Visits What goes into site visit decision • Review of materials • Performance reports • Financial reports • Performance calls • Correspondence • Request for technical assistance
Site Visits What to expect during the site visit • Entrance and exit interviews • Review of grant activities to date • Review recent budget and expenditures with fiscal staff • Review evaluation plan
Site Visits What to expect after site visit • Reviewer's written report • Positive findings • Exemplary practices • Negative findings • Required Actions: Compliance • Recommended Actions: Non-binding suggestions
Site Visits What to expect after site visit • Grantee's response • Required Actions • Detail corrective actions that will bring grant into compliance with programmatic/fiscal guidelines • Dispute findings and present supporting documents • Recommended Actions • Respond to recommended actions
Site Visits What to expect after site visit • Follow-up and closeout • Grant monitor will follow up to ensure that all corrective actions have been accomplished • Grant monitor will inform grantee in writing when review is closed
Faith-Based Organizations • White House Office of Faith-Based and Community Initiatives - January 2001 • Federal Agency Centers - January 2001 • Equal Protection of the Laws for Faith-Based and Community Organizations - December 2002
Faith-Based Organizations • Focus of the Initiative • Identify and eliminate barriers that impede FBCOs in the federal grants process • Increase accessibility to the federal grants process through training and technical assistance
Faith-Based Organizations • Core Principles • Equal treatment for faith-based organizations applying for grants • Preservation of religious liberty/character • Protection of beneficiaries • Federal funds may not be used for inherently religious activities
Faith-Based Organizations • The U.S. Department of Education amended its regulations (EDGAR) to reflect these principles. • 74.44: Procurement procedures • 75.52: Grant eligibility • 75.532: Use of funds for religion prohibited
Faith-Based Organizations • Monitoring • Faith-based organizations are subject to the same accounting and reporting requirements as all other grantees • Federal funds may not be used for inherently religious activities
Faith-Based Organizations • Section 75.532: Use of funds for religion prohibited • (a) No grantee may use its grant to pay for any of the following: • (1) Religious worship, instruction, or proselytization • (2) Equipment or supplies to be used for any of those activities
Faith-Based Organizations • Guidance to Faith-Based and Community Organizations on Partnering with the Federal Government • www.fbci.gov • U.S. Department of Education's Center for Faith-Based and Community Initiatives • www.ed.gov/about/inits/list/fbci/index.html
Fiscal Management • Memo to discretionary grantees • Draw down funds only as necessary • Project director should continually monitor fiscal activity • Excessive Drawdowns • First Quarter: 50 percent or more • Second Quarter: 80 percent or more • Third Quarter: 100 percent
Fiscal Management • Large Available Balances • 70 percent of the project's budget is available 90 days or less before the budget period ends • Grant monitor works with grantee to reconcile situation
Fiscal Management • Indirect Cost Rates (ICR) • Grantee must have a current ICR agreement to charge indirect costs • Applicants without a current negotiated indirect cost rate that are selected for funding are subject to the terms and conditions included in Attachment D: Prohibition against Indirect Cost Recovery
Fiscal Management • Attachment D: Prohibition against Indirect Cost Recovery • Grantee shall submit ICR proposal to cognizant agency (i.e., ED) within 90 days after award of the grant • Grantee may not charge its grant for indirect costs until negotiated ICR agreement is in place • Grantee must provide proof of its negotiated ICR agreement to grant monitor
Audit Requirements • Two types of audits • Grantee-Initiated Audit • Independent Auditor • Compliance with OMB Circular A-133 • Annually expend $500,000 or more in federal funds must have a single audit or program-specific audit performed for that year
Audit Requirements • Two types of audits • OIG Audit • Office of Inspector General • Not every grantee is audited • Office of Chief Financial Officer reviews A-133 audit reports • OIG audit triggered by serious audit findings identified by OCFO • Questions? Contact grant monitor
Expanded Authorities • Budget Transfers • No-Cost Time Extensions
Expanded AuthoritiesBudget Transfers • Parts 74.25 and 75.264 • No prior approval required unless: • Change in project scope or objectives • Change in key personnel • Notify grant monitor of transfer • Amount of money • Identify categories • Purpose
Expanded AuthoritiesNo-Cost Time Extensions • Parts 74.25(e)(2) and 75.261 • One-time extension for up to 12 months without prior approval • Written justification needed at least 10 days prior to extension • Cannot be for the purpose of exhausting unexpended funds • Cannot require additional funds nor change the project's scope or objectives
Freedom of Information Act (FOIA) • Any person has the right to request access to federal agency records or information • All records must be made available, except: • Privileged or confidential information • Personal information
Freedom of Information Act (FOIA) • FOIA Process • Project Director contacted • 10 days to respond to ED • Memo to FOIA Officer from ED • Information sent to requestor • Fee involved: research and personnel
Useful Resources • Web Sites • Publications • Telephone Numbers
Useful Resources • OSDFS Web Site • www.ed.gov/osdfs
Useful Resources • What Works Clearinghouse • Gathers studies on effectiveness of educational interventions • www.w-w-c.org
Useful Resources • The Challenge Newsletter • OSDFS Publication • Provides information and resources to help create safe and healthy learning environments • www.thechallenge.org
Useful Resources • Training and Technical Assistance Centers • Character Education and Civic Engagement • Emergency Response/Crisis Management • Higher Education • Mentoring
Useful Resources • Character Education and Civic Engagement Technical Assistance Center • Provides state program administrators, local educators, and the public with information on character education and civic engagement • www.cetac.org • Contact: Rita Foy Moss • rita.foy@ed.gov
Useful Resources • Emergency Response and Crisis Management Technical Assistance Center • Provides technical assistance and resources to grantees and non-grantee local educational agencies regarding crisis planning • www.ercm.org
Useful Resources • Higher Education Center for Alcohol and Other Drug Abuse and Violence Prevention • Provides training, technical assistance, and publications related to drug abuse and violence prevention on college campuses and in their surrounding communities • www.higheredcenter.org • Contact: Rich Lucey • richard.lucey@ed.gov
Useful Resources • Mentoring Program Training and Technical Assistance Center • Ensure that programs funded under the Mentoring Program receive help in management and implementation of projects • Contact: Bryan Williams • bryan.williams@ed.gov