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Federal Administrative Requirements:

OMB Circular A-102. UNIFORM ADMINISTRATIVE REQUIREMENTS FOR GRANTS AND COOPERATIVE AGREEMENTS TO STATE AND LOCAL GOVERNMENTS . Purpose. OMB guidance to Federal agencies on the administration of grants to and agreements with institutions of higher education, hospitals, and other non-profit organizations, States and local governments. The guidance sets forth standards for obtaining consistency and uniformity in the agencies' administration of those grants and agreements. .

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Federal Administrative Requirements:

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    1. Federal Administrative Requirements: Frank Roth and Alyssa Clemsen National Policy, Training and Compliance Division Office of Grants and Debarment, USEPA Presented at Maryland Governors Grants Conference 2008 September 8, 2008

    3. OMB Circular A-102 UNIFORM ADMINISTRATIVE REQUIREMENTS FOR GRANTS AND COOPERATIVE AGREEMENTS TO STATE AND LOCAL GOVERNMENTS

    4. Purpose OMB guidance to Federal agencies on the administration of grants to and agreements with institutions of higher education, hospitals, and other non-profit organizations, States and local governments. The guidance sets forth standards for obtaining consistency and uniformity in the agencies' administration of those grants and agreements.

    5. OMB Circulars Basic administrative rules that apply to all Federal grants OMB Circular A-21, Cost Principles for Educational Institutions Relocated to 2 CFR, Part 220 OMB Circular A-87, Cost Principles for State, Local and Indian Tribal Governments Relocated to 2 CFR, Part 225 OMB Circular A-122, Cost Principles for Non-Profit Organizations Relocated to 2 CFR, Part 230

    6. What it All Means The Grantee must have certain systems in place to appropriately manage their Federal assistance dollars. Then grantee must apply these systems consistently across their organization. These are minimum requirements, of course you can have more stringent systems, but we will hold you to them.

    7. What Systems? Standards for Financial Management Systems Does your accounting and financial management system follow Generally Accepted Accounting Principles? OMB Circular A-122, Attachment A, A(2)(e) Cash Requirements

    8. 215.21Standards for financial management systems Is your financial management system able to relate financial data to performance data and develop unit cost information?

    9. 215.21Standards for financial management systems Can your financial management system provide accurate, current and complete disclosure of the financial results of each federally-sponsored project or program in accordance with the requirements of 215.21? These are the Financial Status Report and Report of Federal Cash Transactions.

    10. 215.21Standards for financial management systems Can your financial management system provide records that adequately identify the source and application of funds for federally-sponsored activities? Information to be included is: authorizations, obligations, unliquidated obligations, assets, outlays, income and interest.

    11. 215.21Standards for financial management systems Does your financial management system provide for effective control over and accountability for all funds, property and other assets, including ensuring that all such assets are used solely for authorized purposes?

    12. 215.21Standards for financial management systems Can your financial management system provide for a comparison of outlays with budget amounts for each award, including, where appropriate, information related to performance and unit cost?

    13. 215.21Standards for financial management systems Does your financial management system provide written procedures to minimize the time elapsing between the transfer of funds to the recipient from the U.S. Treasury and the issuance or redemption of checks, warrants or payments by other means for the purposes of the program?

    14. 215.21Standards for financial management systems Does your financial management system provide written procedures for determining the reasonableness, allocability and allowability of costs in accordance with 2 CFR, Part 220, 225 or 230?

    15. Single Audit If applicable, does your financial management system provide procedures for conducting an audit in accordance with OMB Circular A-133? Currently, A-133 audits are required for recipients expending $500,000 or more in federal funds during the fiscal year.

    16. Single Audit (a) Recipients and subrecipients that are institutions of higher education or other non-profit organizations (including hospitals) shall be subject to the audit requirements contained in the Single Audit Act Amendments of 1996 (31 U.S.C. 75017507) and revised OMB Circular A133, Audits of States, Local Governments, and Non-Profit Organizations.

    17. Single Audit (b) State and local governments shall be subject to the audit requirements contained in the Single Audit Act Amendments of 1996 (31 U.S.C. 75017507) and revised OMB Circular A133, Audits of States, Local Governments, and Non-Profit Organizations.

    18. Does your financial management system provide or describe existing or planned indirect cost rates? 2 CFR, Part 220, 225 or 230, Sections C and D

    19. Property and Procurement Standards 215.34 Does your property management system provide for maintaining: (1) a description of the equipment; (2) an identification number; (3) source of the property, including the award number; (4) where title vests;

    20. Property and Procurement Standards 215.34 Does your property management system provide for maintaining: (5) acquisition date; (6) federal share of property cost; (7) location and condition of the property; (8) acquisition cost; (9) ultimate disposition information?

    21. Property and Procurement Standards 215.34 Does your property management system provide for a physical inventory and reconciliation of property at least every two years? Does your property management system provide controls to insure safeguards against loss, damage or theft of the property?

    22. Property and Procurement Standards 215.34 Does your property management system provide for adequate maintenance of the property?

    23. Property and Procurement Standards 215.34 Does your organization maintain written procurement procedures which: (1) avoid unnecessary purchases; (2) provide an analysis of lease and purchase alternatives; and (3) provide a process for soliciting goods and services?

    24. Property and Procurement Standards 215.34 Does your procurement system provide for the conduct and documentation of cost or price analysis for each procurement action?

    25. Personnel and Travel Does your organization maintain written standards of conduct governing the performance of your employees engaged in the award and administration of contract (i.e., conflict of interest) and does it provide for disciplinary actions?

    26. Personnel and Travel Does your organization maintain a personnel system which provides monthly reports on the activities of each employee whose compensation is charged to the assistance agreement? 2 CFR 220, Attachment B, 8(m)

    27. Personnel and Travel Does your organization maintain a standard travel policy? 2 CFR 220, Attachment B, 51(b)

    28. Questions

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