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Effective Title III Program Administration

Effective Title III Program Administration. Dr. Haywood L. Strickland, President and CEO Wiley College * Marshall, Texas June 3-5, 2008. It’s All About Stewardship Excellence. Fiscal Accountability Program Administration Monitoring Demonstrating Results.

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Effective Title III Program Administration

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  1. Effective Title III Program Administration Dr. Haywood L. Strickland, President and CEO Wiley College * Marshall, Texas June 3-5, 2008

  2. It’s All About Stewardship Excellence • Fiscal Accountability • Program Administration • Monitoring • Demonstrating Results

  3. Did you do what you said you were going to do? At what cost?

  4. Can you prove It?

  5. PART I: FISCAL ACCOUNTABILITY

  6. ORDER OF PRECEDENCE WHEN DECIDING ALLOWABILITY OF COST • Legislation • Program Regulations • EDGAR (Incorporates OMB A-21 Cost Principles for Educational Institutions) • Approved Application

  7. ALLOWABLE COSTS(USE OF FUNDS) • Legislation – Section 323 of Higher Education Act of 1965 as amended U.S. Code 1060 • Part B, Historically Black Colleges & Universities

  8. ALLOWABLE COSTS • Section 323 (a) General Authorization: Use of funds • Purchase, rental, or lease of scientific or laboratory equipment for educational purposes, including instruction and research purposes. • Construction, maintenance, renovation, and improvement in classroom, library, laboratory, and other instructional facilities including purchase or rental of telecommunications technology equipment or services.

  9. Allowable Costs (Sec. 323 continued) • Support faculty exchanges, and faculty development and faculty fellowships to assist in attaining advanced degrees in their field of instruction. • Academic instruction in disciplines in which African Americans are underrepresented. • Purchase of library books, periodicals, microfilm, and other educational materials, including telecommunications program materials. • Tutoring, counseling, and student service programs designed to improve academic success.

  10. Allowable Costs (Sec. 323 continued) • Funds and administrative management, and acquisition of equipment for use in strengthening funds management. • Joint use of facilities, such as laboratories and libraries. • Establishing or improving a development office to strengthen or improve contributions from alumni and the private sector. • Establishing or enhancing a program of teacher education designed to qualify students to teach in a public elementary or secondary school that shall include, as part of such program, preparation for teacher certification.

  11. Allowable Costs (Sec. 323 continued) • Establishing community outreach programs which will encourage elementary and secondary students to develop the academic skills and the interest to pursue postsecondary education. • Establishing or improving an endowment fund. • OTHER ACTIVITIES submitted pursuant to section 323 that: • contribute to carrying out the purpose of this part; and • are approved by the Secretary as part of the review and acceptance of such application

  12. EDGAR REQUIREMENTS • EDUCATION GENERAL ADMINISTRATIVE REGULATIONS (EDGAR) • SECTION 72.27 ALLOWABLE COST • Incorporates OMB Circular A-21, Major Cost Principles for Educational Institutions

  13. ALLOWABLE & UNALLOWABLE COSTS • OMB Circular A-21 Objective Provides clear cut guidance on all expenditures: allowable, allocable, reasonable, and prudent.

  14. OMB A-21 COST PRINCIPLES • Purpose • Establishing principles for determining costs applicable to grants, contracts, and other agreements with educational institutions.

  15. OMB A-21 COST PRINCIPLES • Applicability • All federal agencies that sponsor research and development and other work at educational institutions shall apply the provisions of this Circular in determining costs incurred for such work.

  16. OMB A-21 COST PRINCIPLES • TABLE OF CONTENTS • Purpose and Scope • Definition of Terms • Basic Considerations • Direct Costs • Indirect Costs • Identification and assignment of indirect costs

  17. OMB A-21 COST PRINCIPLES • TABLE OF CONTENTS (Continued) • Determination & Application of Indirect Cost Rate or Rates • Simplified Method for Small Institutions • Reserved • General Provisions for Selected Items of Costs • Certification of Changes

  18. FIRST LEVEL DETERMINATION OF ALLOWABLE COST IN OMB A-21 • ALLOCABLE TO THE GRANT • Benefits received • REASONABLE • Necessary for the operation • ALLOWABLE • Circular, law, local regulation • PRUDENT • Comparability with use of institutional funds

  19. UNALLOWABLE COSTS • OMB Circular A-21, Section J • Alcoholic Beverages • Communications (i.e. line charges, unit charges) • Donations & Contributions • Entertainment (i.e. anything remotely related) • Executive Lobbying (i.e. attempting to improperly influence the decisions of officers or employees of the Federal Government)

  20. UNALLOWABLE COSTS (Continued) • Exclusive Memberships, Subscriptions & Professional Activity (i.e. Country Clubs) • Pre-agreement Costs (Unallowable unless pre-approved) • Scholarships & Student Aid

  21. INDIRECT COSTS INDIRECT COSTS ARE NOT ALLOWABLE IN THE TITLE III PROGRAM

  22. THINGS TO REMEMBER • TO DETERMINE IF A COST IS ALLOWABLE OR UNALLOWABLE, CHECK THE FOLLOWING SOURCES: • The Law • Program Regulations • EDGAR, 34 CFR 74.27 Allowable Costs • OMB Circular 21 • Approved Application

  23. ACCOUNTABILITY • GPRA – 1993 • Government Performance and Results Act • Ties federal funding to results • Greater accountability • GPRA indicators reflected in objectives and activities • Include milestones in objectives to determine success accurately

  24. DRAWDOWN POLICY • Request funds for immediate needs • Minimize time between requests & expenditures (72 HOURS) • Rate of draw downs commensurate with approved scope & milestones

  25. DOE CONCERNS • Large amounts of unobligated funds • Excessive or infrequent requests • Project goals/objectives not met – DOE monitors • Student population is not being served as proposal objectives indicates • Maybe, HBCU’s DON’T NEED THE MONEY

  26. GAPS MONITORINGOF AVAILABLE BALANCES • Within 90 days, “flags” grants with 70% or more of funds remaining • Verifies financial data reported on annual performance report

  27. PART II: TITLE III PROGRAM ADMINISTRATION AND MANAGEMENT

  28. ELEMENTS OF AN EXEMPLARY TITLE IIIPROJECT ADMINISTRATION PROGRAM • RESPONSIBILITIES OF A TITLE III PROJECT DIRECTOR • Provide leadership and coordination • Facilitate integration of Title III activities

  29. RESPONSIBILITIES (Cont.) • Support an ongoing process of institutional effectiveness • Develop and update a project handbook to include policies and procedures • Monitor expenditures and reconcile monthly • Ensure conduct of an annual external evaluation

  30. RESPONSIBILITIES (Cont.) • Ensure that Title III funds are disbursed in keeping with: • Education Departments General and Administrative Regulations (EDGAR) (Revised June 23, 2005); • A-110 (Revised April 25, 2007); • OMB Circular A-21 (revised May 10, 2004); and • A-133 (revised June 27, 2003).

  31. Roles and Responsibilities of Title III Activity Directors

  32. The Title III Activity Director is responsible for…. • Activity management and oversight • Implementation of objectives • Supervision and monitoring of activity staff • Reporting activity status/progress • Approval and processing of requisition • Keeping abreast of grant regs & information • Maintaining up-to-date activity files • Maintaining up-to-date equipment inventory

  33. Roles and Responsibilities of Title III Activity Director (Cont.) • Budget Monitoring and Oversight • Staff meeting attendance • Approval of travel requests • Preparation and submission of annual plan of operation • Documentation of objective implementation • Preparation for and participation in internal and external Title III activity evaluation, site review, etc.

  34. MAJOR COMPLIANCE PROVISIONS • EDGAR • Property Controls • Prior Approval Requirements • Notification of Change in Key Personnel • Annual Evaluations of Performance

  35. OMB Circular A-110 • Available over the Internet at http://www.whitehouse.gov/omb/circulars/a110_compliance/06/pt3.pdf • An institution cannot hold excess cash on hand. (Funds to be spent in 72 HOURS) • A-110 also describes “Davis-Bacon” compliance requirements.

  36. OMB CIRCULAR A-21The Cost Principles • As a reminder, follow four guidelines ALLOWABLE ALLOCABLE REASONABLE PRUDENT

  37. OMB CIRCULAR A-133/THE SINGLE AUDIT REQUIREMENT A-133 single audit requirement pertains to all federal grants which exceed $500,000. A-133 auditing defines institutions as: Low-Risk or High Risk

  38. OMB CIRCULAR A-133/The Single Audit Requirements • A system of checks and balances • Proof of written policies and procedures • Property Control Management

  39. OMB CIRCULAR A-133/The Single Audit Requirements (cont.) • A review of all reports filed • The Financial Transactions (the 269s; 272s); • Performance Reports; • Annual Audit must be filed with the Federal Audit Clearinghouse (which must include any corrective action plans prepared by the institution)

  40. OMB CIRCULAR A-133/The Single Audit Requirements (cont.) • Proof of compliance with the Davis-Bacon Act. • Proof that all Expenditures Constitute Allowable Costs.

  41. PART III MONITORING BEGINS WITH MEASURABLE OBJECTIVES

  42. Writing Measurable Objectives • There are many formats for writing objectives. During this workshop we will use the National Laboratory for Higher Education (NLHE) format and content.

  43. A well written objective should take the form of a single statement that contains the following: • QUANTIFIED OUTCOME • State the projected end result in measurable terms

  44. A well written objective should also include…. • Time • Specify the date that the objective will be completed.

  45. The following are optional parts of an objective: • Responsibility: State what person(s) or unit is/are responsible for implementing the objective. • Conditions: Specify special conditions (if any) that will or may impact that outcome of the objective.

  46. Many grants, such as the Title III Grant, require each objective to have an anticipated result. The anticipated result statement should include… • Performance Level and Baseline Data • Evaluation Method(s) Date(s) • Type and Location of Documentation

  47. MONITORING • Title III Activity Timetable • Internal Monitoring of Progress • Monthly Time and Effort Reports • Updated Equipment Inventory Records The Ongoing Review of Activities to Manage Performance

  48. FISCAL MONITORING • Monthly Expenditure Reports by Activity • Reconciled Monthly to Capture Discounts, Cost-Savings, and Consistency with Drawdown Reports • Required for A- 133 Audit & Timely Submission to the Audit Clearinghouse • Facilitate Title III E-Reporting

  49. GRANTEE’S RESPONSIBILITIES • Project success & financial accountability • Submit annual & final performance reports • Valid & reliable data • Report of GPRA standards & indicators

  50. GRANTEE’S RESPONSIBILITIES • ON SITE: • Funded application & grant award • Previous audits & site visit reports • Annual Performance Reports • Project revision(s) documentation • Current budget & personnel list

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