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SIF Sub-Grantees Subaward Agreement/ MOU Webinar. Prepared by Steve Adams, Deputy Director, NFWS. February 11, 2011 . Agenda. Introduction Why The Language is There Reviewing Subaward Agreement Reviewing MOU Other Discussion. Introductions. Steve Adams (NFWS) Shannon Mason (NFWS)
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SIF Sub-GranteesSubaward Agreement/ MOU Webinar Prepared by Steve Adams, Deputy Director, NFWS February 11, 2011
Agenda • Introduction • Why The Language is There • Reviewing Subaward Agreement • Reviewing MOU • Other Discussion
Introductions • Steve Adams (NFWS) • Shannon Mason (NFWS) • Jill Moriello (JFF Grants Management Analyst) • Ruth French – auditor at JFF (fed funds experience)
We’re new at federal subgranting • Re-granting federal funds is fairly new to us. So we haven’t tested our subaward agreements much. • Subaward could have been clearer and with fewer requirements. • We should have provided additional guidance along with fiscal webinar.
Why the language is there • Our federal grant from CNCS/SIF requires that we notify subgrantees that the same rules apply to them • We have to show we’re in compliance • Again, could have been clearer with you
The Subaward agreement • Go to Subaward agreement • Go to MOU
Cost Principals • Allowable/Unallowable • Allocable • Reasonable • Consistent
Allowable Costs • Be included in the Approved Budget • Be reasonable and allocable for the performance of the award • Be given consistent treatment within the entire organization • Be in accordance with GAAP • Not included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program
Unallowable Costs • Examples • Lobbying • Fines and Penalties • Expenses not necessary to meet program objectives • Costs that would constitute waste, fraud and abuse • Unreasonable costs from a “prudent person” perspective
Allocable Costs • A cost is allocable to the grant if: • It is treated consistently with other costs incurred for the same purpose in like circumstances and if: • It is incurred specifically for the award • Benefits both the award and other work and can be distributed in reasonable proportion to the benefits received or • Is necessary to the overall operation of the organization
Reasonable • A cost is reasonable if, in its nature or amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the costs
Consistent • Grantees must be consistent in assigning costs • Regardless of the source of funding, i.e. federally or non-federally sponsored activities, and • Following written cost allocation plan, as applicable • Charges must be consistent with those normally allowed in like circumstances in the organization’s non-federally sponsored activities
Proper Documentation is a Must Allowable Allocable Reasonable Consistently Applied Document, Document, Document
Tracking Federal Intermediary and Sub-Grantee Revenues and Expenditures
Efficient Accounting System • Accounting system must be capable of: • Distinguishing between grant vs. non grant related expenditures • Identifying costs by Program Year • Identifying costs by Budget Category • Accounting for each award/grant separately • Properly segregates fund sources • Easily provide management with financial reports at both the detail and summary levels
Fiscal Responsibility Highlights • Effective Financial Management • Written and followed policies and procedures • Qualified and trained financial staff • Effective communications • Succession planning and cross-training • Self-assessment and continuous improvement • Active, knowledgeable and informed Board and finance committee
Fiscal Responsibility Highlights (continued) • Overall compliance with State and Federal regulations • Accurate, timely and complete financial reporting • Tracking of budget to actual expenses • Ensure key staff understand roles, responsibility, understand each other’s priorities and work together
Criminal History Check • Statewide Criminal History Search • www.NationalSexOffenderRegistry.gov • Differs by State • FBI can be substituted for a statewide search • Murder is the only disqualifier • Required personnel: • Anyone receiving a salary • Prime or Sub-grantee level—all are required • Refer to CNCS FAQ on website for further assistance
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