FINANCIAL/ADMINISTRATIVE PROCEDURES MANUAL guidance

1. FINANCIAL/ADMINISTRATIVE PROCEDURES MANUALguidance Financial Organizational Review & Compliance (FOR-C) Education Service Center, Region 20 Denise Dusek (210) 370-5378 denise.dusek@esc20.net

2. definitions • Policy: “A set of policies are principles, rules, and guidelines formulated and adopted by an organization to reach its long-term goals and typically published in a booklet or other form that is widely accessible.” Business Dictionary.com http://www.businessdictionary.com/definition/policies-and-procedures.html Accessed 5/28/15 EDUCATION SERVICE CENTER, REGION 20 | FOR-C

3. definitions • Procedure: “Procedures are the specific methods employed to express policies in action in day-to-day operations of the organization.” Business Dictionary.com http://www.businessdictionary.com/definition/policies-and-procedures.html Accessed 5/28/15 EDUCATION SERVICE CENTER, REGION 20 | FOR-C

4. definitions • Policies and Procedures: “Policies and procedures are designed to influence and determine all major decisions and actions, and all activities take place within the boundaries set by them…Together, policies and procedures ensure that a point held by the governing body of an organization is translated into steps that result in an outcome compatible with that view.” Business Dictionary.com http://www.businessdictionary.com/definition/policies-and-procedures.html Accessed 5/28/15 EDUCATION SERVICE CENTER, REGION 20 | FOR-C

5. definitions • Policy = • Law, Requirement, • Goal of the organization • Procedures = • How implemented at local level; • Steps to achieve goals EDUCATION SERVICE CENTER, REGION 20 | FOR-C

6. Why important • Effective Internal Control System • Required by EDGAR • Evidence of compliance • Maintain consistency • Training tool EDUCATION SERVICE CENTER, REGION 20 | FOR-C

7. Getting started • Begin the dialogue • Use the templates to develop a framework to provoke thoughtful, deliberate analysis of: • What you do, • How you do it, and • How to implement Federal and State requirements at the local level • Consider how things connect – business side, program side • Collaborative effort – consider creating workgroups EDUCATION SERVICE CENTER, REGION 20 | FOR-C

8. The journey • Consider the manual a work in progress • Revise as needed, based on: • TEA guidance • USDE guidance • Results of audits • Changes in local policy and processes EDUCATION SERVICE CENTER, REGION 20 | FOR-C

9. Continuous cycle • DEVELOP • Include stakeholders, staff members who perform the tasks • Include both fiscal and programmatic personnel • AGREE • Buy-in from those who will use the policies and procedures • Formally adopt, according to local policy • IMPLEMENT • Train staff • MONITOR & REVIEW • Ensure proper implementation • Review annually or whenever new guidance is released • Determine if revisions needed • UPDATE EDUCATION SERVICE CENTER, REGION 20 | FOR-C

10. LOCAL DECISIONS • What to call the manual? • Financial Procedures? • Administrative Procedures? • Financial/Administrative Procedures? • One manual or several, separate manuals? • Financial/Administrative Procedures • Procurement Procedures • Travel Procedures EDUCATION SERVICE CENTER, REGION 20 | FOR-C

11. LOCAL DECISIONS • Policies and procedures together in one manual? OR • Separate manual for policy and separate manual for procedures? EDUCATION SERVICE CENTER, REGION 20 | FOR-C

12. LOCAL DECISIONS • Federal Program Procedures/Program Operating Guidelines vs Financial/Administrative Procedures • Include fiscal-related program requirements in both? OR • Include fiscal-related program requirements in the Financial/Administrative Procedures manual and make reference to these in your Program Manual? EDUCATION SERVICE CENTER, REGION 20 | FOR-C

13. Important considerations • Compliant with federal and state requirements • Must not conflict with local policy • Local policy must not conflict with federal and state requirements • Follow most restrictive requirement: • EDGAR (cross-cutting, applies to all federal education grants) • Program-Specific Statute/Regulations • State Rules and Regulations • Local Policy EDUCATION SERVICE CENTER, REGION 20 | FOR-C

14. Important considerations • Address all requirements that apply to federal and state grants • Consistently treated • Applicable to all federal programs (cross-cutting) • Include program-specific fiscal requirements and procedures, when applicable • Example: Indicate the fiscal compliance requirements of IDEA-B, such as Excess Cost calculation and MOE analysis EDUCATION SERVICE CENTER, REGION 20 | FOR-C

15. Important considerations • Effective Date • Procedures describe the process adequately, but not overly prescriptive (auditors will look for implementation) • Develop flowchart (optional); Auditors like this! • If a certain element/topic is not applicable, don’t remove the topic from your manual. Instead, state N/A • Example: If you don’t use credit cards, have a section where you state that your LEA does not use credit cards EDUCATION SERVICE CENTER, REGION 20 | FOR-C

16. Important considerations • Training is critical • Employees need to know and understand the policies and procedures • Employees need to understand the reasoning behind the procedure • Example: why time and effort reporting? • Auditors may ask an employee to describe how and why they carry out a certain task • Common audit finding: Procedure is not being implemented EDUCATION SERVICE CENTER, REGION 20 | FOR-C

17. Above all, customize! • Must be localized, customized • Use caution if using a template with standard procedures, or adopting a manual from another LEA • Not a “plan in a can” EDUCATION SERVICE CENTER, REGION 20 | FOR-C