Blanca Rosa Rodriguez

1
Sociedad de Administradores de Investigacion

• Blanca Rosa Rodriguez
• Senior Policy Analyst
• U.S. Department of Education

2
Todays Agenda

• Administrative requirements
• Managing your budgets
• Working together

3
Project Revisions ( Expanded Authorities )

• Costs
• Carryover
• Budget Transfers
• Time Extensions

4
Carryover

• Unexpended funds are carried over without prior
  approval

• For any allowable cost within the approved
  project scope

• finishing uncompleted activities
• new activities within scope

5
Carryover

• Program Office may require a written statement

• How will unexpended funds be used?
• When At time of funding decision
• In some cases, new funds may be reduced

6
Budget Transfers

• No prior approval required for most budget
  transfers

10rule

• Exceptions in EDGAR
• Transfer training funds to other categories
• Transfer or contracting out any work

• Check OMB Cost Principles for other exceptions

7
EDGAR Prior Approval Requirements

• Changes in project scope or objectives
• Changes in key personnel
• IHE and nonprofit project directors
• Absence for more than 3 months
• 25 reduction in time
• Need for additional federal funds

8
Time Extensions

• Final Year

• One-time extension for up to one year without
  prior approval
• Grantees should carefully consider time extension
  needs

9
Time Extensions

• Send written notice to program officer

• No later than 10 days before project ends
• State reasons for extension
• Include revised expiration date

10
Time Extensions

• Not just for using unexpended funds

• No additional federal funds

• No change to scope or objectives

11
Financial Management
Performance Monitoring
Financial Monitoring
12
Cost Share and Cost Match

• Capability to maintain receipts and expenditures
  for each grant
• Capability to record costs according to
  categories in the budget
• Capability to record source and amounts for cost
  share for each grant
• Record direct cost separately from indirect cost
• Maintain time distribution records for each
  employee

13
Cost Share and Cost Match Requirements

• Contributions that Exceed the Statutory Minimum
• If you stated in your grant application that you
  were going to exceed the statutory minimum, then
  you will be held to that obligation

14
Timing of Match Contribution

• You are required to comply with the annual
  matching percentage stated in your application

15
Types of Matching

• Personnel
• Facilities
• The amount of tuition
• Amount spent on documented services/activities
  provided by volunteers or non-federal paid staff

Anything you could pay for with federal dollars
can be used as a match
16
What documentation should grantees maintain for
matching/cost-sharing contributions?

• Documentation must be maintained for all
  matching/cost-sharing contributions included in
  the grantees approved grant application
  whether statutorily required or volunteered
• Grantees must maintain verifiable records for all
  matching and cost-sharing contributions,
  including cash and 3rd party in-kind
  contributions
• In general, record retention period is 3 years
  from submission of final expenditure report (34
  CFR 74.53 and 80.42, as applicable)
• The fiscal agent in a group or partnership grant
  is responsible for documenting match/cost-share
  for the entire grant and ensuring that verifiable
  records are being maintained by partner
  organizations providing services or other
  contributions

17
What documentation should grantees maintain for
matching/cost-sharing contributions?

• Cash Contributions
• In general, the grantee should maintain the
  following kinds of records regarding cash
  contributions
• Evidence of Cash Received (Documentation of
  sources, including copies of deposited checks,
  deposit slips, receipts provided to donors, etc.)
• Evidence of Cash Expenditures or Outlays
  (Invoices, purchase orders, canceled checks,
  receiving receipts, etc.)
• Services by personnel of the grantee (time and
  effort reports)

18
What documentation should grantees maintain for
matching/cost-sharing contributions?

• In-Kind Contributions
• In general, the grantee should maintain records
  regarding in-kind contributions that indicate
• The description of the item received, including
  the manufacturers serial number and model number
  of the product, if applicable
• The name of the person or entity that donated it
• The date it was donated
• The method the grantee used to determine the
  value of the item or service (See EDGAR, 34 CFR
  74.23 and 80.24 for information on valuing
  volunteer services and donated supplies,
  equipment, buildings and land)

19
When must the grantee notify ED of deviations to
the matching/cost-sharing budget?

• Under EDGAR, 34 CFR 74.25 and the applicable OMB
  cost principles, the grantee must request prior
  approval for certain post-award changes to the
  Federal grant budget
• Same prior approval rules apply if the grantee
  wants to make certain changes to the non-Federal
  (matching/cost-sharing) budget
• Grantee should notify ED if partners contributing
  to the match/cost-share change during the budget
  period or if major sources of planned
  matching/cost-sharing contributions do not
  materialize
• Grantee must also notify ED if it is having
  difficulty meeting required level or amount of
  match/cost-share specified in the Grant Award
  Notification

20
Records

• Source documentation to support claims
• Records available to support 3rd party
  contributions
• Financial and program needs
• Apply equally to grantees of partners

21
Record Retention Period

• In general, 3 years from submission of final
  expenditure report (74.53 and 80.42)
• Period extended until all litigation or audits
  resolved
• Period not extended
• Revisions resulting from closeout
• If litigation audit resolved prior to period end
• Problem if partners dispose of records before
  grantee submits closeout

22
Closeout

• Grants can be closed out if
• The project period has ended
• All of the required reports have been received
  and approved
• GAPS indicates there are zero funds available in
  the grant account

23
Closeout Procedures

• Pre-expiration letter
• 60 days prior to performance end data
• Required reports
• Final performance report (75.590)
• Financial status report if no ED 524B
• Closing a grant with zero balance of funds
  remaining
• Final report reviewed and approved
• All terms of the grant met
• Review financial status in G5

24
Closeout Procedures

• Closing a grant with fund balances
• If balance is greater than 10 ED will contact
  grantee to verify that funds are not needed and
  all obligations are met
• If the funds are needed, submit written request
  and justification and 269 Financial Status
  Report, signed by a certifying official and
  finance office
• Closing a grant in non-compliance may seriously
  affect a grantees ability to receive awards
  under future competitions (75.217)

25
Monitoring Using G5
Track spending patterns for each grant

• Why
• Identify performance problems
• Identify financial problems
• Work in partnership to resolve

26
ED Concerns

• Large amounts of unobligated
• funds at end of budget period
• Excessive or infrequent
• drawdown of funds
• Project goals not met

27
Large Available Balances

• Within 90 days, flags grants with 70 or more
  of funds remaining
• Clarification required before issuing
  continuation award

28
EDs Drawdown Policy

• Draw down only enough cash to meet
• grants immediate need
• Minimize time between drawdown
• and pay out of funds

Rule of thumb
Rate of drawdown must be commensurate with
approved scope of work and milestones
29
G5 Monitoring Report
By end of budget periods 1st quarter More
than 50 drawn 2nd quarter More than 80
drawn 3rd Quarter 100 drawn
Must return excess cash and interest to
government
30
Grantee Responsibilities

• Demonstrates project success and
• financial accountability
• Submits annual and final
• performance reports
• Ensures validity and reliability of data
• Actual and target data for GPRA, Program, and
  Project performance measures.

31
Budget Items
Must be

• Allowable - permitted or not specifically
  prohibited
• Allocable - necessary for projects success
• Reasonable - costs incurred by a prudent person

32
Audit Requirements

• Conducts non-federal audit if expends 500,000 or
  more in federal awards annually
• Mail to Federal Audit Clearinghouse
• Records of partners and lead grantee/fiscal
  agents federal and match
  expenditures

OMB Circular A-133
33
Grantees Responsibilities
On Site

• Funded application Grant Awards
• Previous audits / site visit reports
• Annual performance reports
• Project revision(s) documentation
• Current budget
• Personnel list

34
Managing Your Budgets

• See EDGAR
• 74.28
• 74.23
• 74.53
• 74.62

35
Budget ItemsPersonnel

• Key staff defined
• Specify purpose duties
• Compensation and percentage of time for each
  position
• Fringe benefit rate

• See EDGAR
• 74.27
• 75.511-75.519
• 80.22

36
Personnel Internal Controls
See OMB Circular A-87
Time Attendance Certification

• Maintained for all staff paid by grant
• Reflects staffs total activity
• Signed by staff supervisor
• Prepared monthly (coincide w/ pay period)
• Cost sharing/matching salaries/wages supported

37
Administration ManagementInternal Controls
Lines of Authority

• As stated in approved package
• Key personnel changes need ED approval
• Staff made aware of projects
• purpose, duration, objectives

38
Budget ItemsTravel

• Justify purpose
• Identify travelers
• Destination / travel dates
• Number cost of trips

39
TravelInternal Controls

• Approval required?
• Who approves?
• Advances provided?
• How are costs reconciled?

40
Budget ItemsEquipment Supplies

• Definitions consistently applied with
  institutional policy
• Provide per unit cost
• Maintain control
• Lease or buy?

• See EDGAR
• 74.34
• 80.32

41
Equipment SuppliesInternal Controls
Who

• Initiates?
• Approves?
• Receives?
• Authorizes payment?

42
Contracts

• Written procurement procedures
• Cost and price analysis
• Procurement records
• Contracts administration

• See EDGAR
• 74.44 74.48
• 80.36

43
Procurement Standards Grantees(74.40 80.36)

• Use their own procurement procedures, conforming
  to Federal standards
• Maintain a contract administration system
• Maintain written standards of conduct governing
  the performance of employees in
  award/administration of contracts

44
Which Process to Use?
Ask for institutional policy!

• Simplified procedures not exceeding 100,000
• 3 bids
• Request for quotation
• Commercial Purchase use simplified procedures
  not exceeding 5 million
• Request for quotation
• Contracting by negotiation best value
• Request for quotation

45
Excluded From Competing

• Developed or drafted specifications
• Requirements
• Statement of work
• Invitation for bid are request for proposals

46
Contract Monitoring Plan

• Established prior to the start of a contract
• Recipient relationship to contract
• Monitor aspects of contract performance
• Quality and quantity
• Time
• Cost
• Compare actual performance to contract
  specification

47
Monitoring Plan (continued)

• What performance is to be monitored?
• When will it be monitored?
• How will it be monitored?
• Who will perform the monitoring?
• What standards will performance be compared to?
• What actions are to be taken when actual
  performance does not conform to plans?

48
Budget Categories
Internal Controls - Procedures for expending
funds for

• Personnel
• Travel
• Equipment
• Supplies
• Contracts
• Consultants
• Other

Federal and Non-Federal portion
49
Project Budget Management

• Project ledger
• Current information for each category
• Reconcile ledger with business office
• How often?
• By whom?

50
Audit Exceptions

• Poor record-keeping (e.g., non-federal match)
• Unallowable costs/activities
• Missing time effort reports to support salary
  costs (Personnel)
• Failure to follow procurement standards
• Lack of internal controls
• Failure to obtain prior approval (if req.)
• Failure to meet match (voluntary or req.)
• Poor cash management (e.g., excessive draws)
• Lack of consulting agreements and invoices
• Equipment management

51
On-line Grantee Training
Who new project directors and business
officers refresher for experienced
staff What training materials resources/pubs
ED grant office home page links When
Where wherever you have computer access Why
responsible/effective project management -- avoid
costly mistakes
52
On-line Grantee Training
Who new project directors and business
officers refresher for experienced
staff What training materials resources/pubs
ED grant office home page links When
Where wherever you have computer access Why
responsible/effective project management -- avoid
costly mistakes
53
On-line Grantee Training

• Grantees major responsibilities
• Monitoring activities to evaluate grantees
  performance
• when performance conferences will take place
• performance reports and when to submit them
• Site visits compliance and technical
  assistance
• Fiscal management and recordkeeping
• Four administrative actions permitted via
  expanded authority

http//e-grants.ed.gov/training/index.htm
54
Technical Assistance and Compliance
Go hand in hand