Effective Title III Program Administration

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Effective Title III Program Administration

• Dr. Haywood L. Strickland, President and CEO
• Wiley College Marshall, Texas
• June 3-5, 2008

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Its All About Stewardship Excellence

• Fiscal Accountability
• Program Administration
• Monitoring
• Demonstrating Results

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Did you do what you said you were going to do?
At what cost?
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Can you prove It?
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PART I FISCAL ACCOUNTABILITY
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ORDER OF PRECEDENCE WHEN DECIDING ALLOWABILITY OF
COST

• Legislation
• Program Regulations
• EDGAR (Incorporates OMB A-21 Cost Principles for
  Educational Institutions)
• Approved Application

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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

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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.

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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.

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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.

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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

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EDGAR REQUIREMENTS

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

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ALLOWABLE UNALLOWABLE COSTS

• OMB Circular A-21
• Objective
• Provides clear cut guidance on all expenditures
  allowable, allocable, reasonable, and prudent.

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OMB A-21 COST PRINCIPLES

• Purpose
• Establishing principles for determining costs
  applicable to grants, contracts, and other
  agreements with educational institutions.

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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.

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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

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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

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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

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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)

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UNALLOWABLE COSTS (Continued)

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

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INDIRECT COSTS

• INDIRECT COSTS
• ARE NOT ALLOWABLE
• IN THE TITLE III PROGRAM

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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

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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

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DRAWDOWN POLICY

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

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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, HBCUs DONT NEED THE MONEY

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GAPS MONITORINGOF AVAILABLE BALANCES

• Within 90 days, flags grants with 70 or more
  of funds remaining
• Verifies financial data reported on annual
  performance report

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PART II TITLE III PROGRAM ADMINISTRATION AND
MANAGEMENT
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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

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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

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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).

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Roles and Responsibilities of Title III Activity
Directors
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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

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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.

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MAJOR COMPLIANCE PROVISIONS

• EDGAR
• Property Controls
• Prior Approval Requirements
• Notification of Change in Key Personnel
• Annual Evaluations of Performance

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OMB Circular A-110

• Available over the Internet at http//www.whitehou
  se.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.

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OMB CIRCULAR A-21The Cost Principles

• As a reminder, follow four guidelines
• ALLOWABLE
• ALLOCABLE
• REASONABLE
• PRUDENT

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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

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OMB CIRCULAR A-133/The Single Audit Requirements

• A system of checks and balances
• Proof of written policies and procedures
• Property Control Management

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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)

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OMB CIRCULAR A-133/The Single Audit Requirements
(cont.)

• Proof of compliance with the Davis-Bacon Act.
• Proof that all Expenditures Constitute
• Allowable Costs.

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PART III MONITORING BEGINS WITH MEASURABLE
OBJECTIVES
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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.

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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

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A well written objective should also include.

• Time
• Specify the date that the objective will be
  completed.

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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.

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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

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MONITORING

• The Ongoing Review of Activities
• to Manage Performance

• Title III Activity Timetable
• Internal Monitoring of Progress
• Monthly Time and Effort Reports
• Updated Equipment Inventory Records

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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

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GRANTEES RESPONSIBILITIES

• Project success financial accountability
• Submit annual final performance reports
• Valid reliable data
• Report of GPRA standards indicators

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GRANTEES 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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COMMON AUDIT EXCEPTIONS

• Things that should NEVER happen
• Poor recordkeeping
• Unallowable costs or activities
• Missing time effort reports
• Failure to follow procurement standards
• Lack of internal controls
• Failure to obtain prior approval if required
• Poor cash management (excessive draws)

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AUDIT REQUIREMENTS

• Non-Federal audit IF expending 500,000 or more
  annually in Federal awards
• Mail to Federal Audit Clearinghouse

OMB CIRCULAR A-133
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EXPANDED AUTHORITIES

• GOALS (Promote Successful Project Outcomes)
• Increase flexibility
• Increase accountability
• Reduce paperwork burden
• Develop partnerships

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EXPANDED AUTHORITIES (Cont.)

• PRE-AWARD COSTS
• May be incurred up to 90 days before budget
  period begins
• NO PRIOR APPROVAL REQUIRED

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EXPANDED AUTHORITIES (Cont.)

• PRE-AWARD COSTS OVERVIEW
• Reasonable expectation of receiving a grant
• Incurred at own risk
• ED funds are not available for draw down until
  the budget period begins
• NOT for cost over-runs

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EXPANDED AUTHORITIES

• CARRYOVER
• Unexpended funds carried over without prior
  approval
• May be used for allowable costs within the
  approved scope
• Complete unfinished objectives
• Other activities within scope

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EXPANDED AUTHORITIES (Cont.)

• CARRYOVER (continued)
• Program Officer may require
• Written statement to include
• How will unexpended funds be used?
• When will unexpended funds be used?
• In rare cases, new funds may be reduced

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PERFORMANCE MONITORING

• The Routine Tracking of

• Activity Inputs and Outputs
• Adequacy of Project Management
• Extent of Compliance
• Level of Effort
• Adequacy of Property Controls

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MONITORING
Continuous Internal Review of Data to Manage the
Implementation Process
EVALUATION
Periodic External Review of Information to
Describe Short and Long Term Outcomes and Benefits
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PART IV DEMONSTRATING RESULTS
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EXTERNAL EVALUATION ENCOMPASSES BOTH
FORMATIVE SUMMATIVEMETHODOLOGIES
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KINDS OF EVALUATIONS

• FORMATIVE
• for improvement purposes
• SUMMATIVE
• to describe program impacts

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TYPICAL FORMATIVE EVALUATION ACTIVITIES
Include Review of

• Time and Effort Reports
• Property Control Procedures
• Monthly and Quarterly Progress Reports
• Fund Accounting Procedures
• Internal Monitoring Strategies
• General Grant Management Procedures (Checks and
  Balances)

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TYPICAL SUMMATIVE EVALUATION ACTIVITIES
Include Review of

• Annual E-Performance Reports
• A-133 Audit Report Findings Follow-Up
• Assessment Instruments and Results, and
• Level of Institutional Commitment

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PURPOSES OF EVALUATION

• Document Accomplishments
• Provide Data on Cost-Effectiveness
• Describe Program Effectiveness

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PURPOSES (Cont.)

• Document Compliances with Program Regulations
• Ensure Agency (Donor) that Funds were used as
  Approved

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THE EVALUATION PROCESS ENTAILS

• Verification of Relevant Documentation

• Monthly Progress Report
• Annual E-Performance Report
• Minutes of Meetings

• Assessment Surveys and Results
• Equipment Inventory Records

Title III Policies and Procedures Manual
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EVALUATION PROCESS FOCUS

• What are the Actual Outcomes?
• What were the Intended Outcomes?
• Relationship of Actual Outcomes to CDP
  Priorities.
• Relationship of Resources Used to Actual
  Outcomes.
• Were there Unexpected Outcomes?

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THE EXTERNAL EVALUATION PROCESS ULTIMATELY
DOCUMENTS

• INSTITUTIONAL
• Accountability
• AND
• Performance
• AND
• Achievement

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Or Stewardship Excellence
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THE END...
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Thank you for your participation in this
workshop
Haywood L. Strickland hstrickland_at_wileyc.edu June
3-5, 2008