Tracking the money

1
Tracking the money

• A primer for Rural Development Employees

Karen Savoie Murray, OCD Alden Turner, RD/ME
2
The Rules

• OMB Circulars
• http//www.whitehouse.gov/OMB/circulars/index.html
  numerical
• A-21 Cost Principles for Educational Institutions
• A-87 Cost Principles for State, Local and Indian
  Tribal Governments
• A-102 Grants and Cooperative Agreements with
  State and Local Governments
• A-110 Uniform Administrative Requirements for
  Grants and Other Agreements with Institutions of
  Higher Education, Hospitals and Other Non-Profit
  Organizations
• A-122 Cost Principles for Non-Profit
  Organizations
• A-133 Audits of States, Local Governments, and
  Non-Profit Organizations

3
The Rules

• USDA Regulations
• http//www.access.gpo.gov/nara/cfr/waisidx/7cfrv15
  _99.html3010
• 7 CFR Part 3015 Uniform Federal assistance
  regulations
• 7 CFR Part 3016 Uniform administrative
  requirements for grants and cooperative
  agreements to State and local governments
• 7 CFR Part 3017 Governmentwide debarment and
  suspension (nonprocurement) drug-free workplace
  (grants)
• 7 CFR Part 3018 New restrictions on lobbying
• 7 CFR Part 3019 Uniform administrative
  requirements for grants and agreements with
  institutions of higher education, hospitals, and
  other non-profit organizations
• 7 CFR Part 3052 Audits of States, local
  governments, and non-profit organizations

4
7 CFR PART 3016

• UNIFORM ADMINISTRATIVE REQUIREMENTS FOR GRANTS
  AND COOPERATIVE AGREEMENTS TO STATE AND LOCAL
  GOVERNMENTS

5
7 PART 3019

• UNIFORM ADMINISTRATIVE REQUIREMENTS FOR GRANTS
  AND AGREEMENTS WITH INSTITUTIONS OF HIGHER
  EDUCATION, HOSPITALS, AND OTHER NON-PROFIT
  ORGANIZATIONS

6
Sec. 3016.20, 3019.21 Standards for financial
management systems.

• Grantees responsible for
• accurate, current, and complete disclosure of the
  grant financial activities
• records which adequately identify the source and
  application of funds provided for
  financially-assisted activities.
• grant or subgrant awards and authorizations,
  obligations and income.

7
Sec. 3016.20, 3019.21 Standards for financial
management systems

• Source documentation
• cancelled checks,
• paid bills,
• payrolls, time and attendance records,
• contract and subgrant award documents, etc.

8
Sec. 3016.20, 3019.21 Standards for financial
management systems

• Cash management
• minimize the time elapsing between the transfer
  of funds from the U.S. Treasury and disbursement
  by grantees and subgrantees
• must be followed whenever advance payment
  procedures are used.

9
Sec. 3016.21, 3019.22 Payment

• minimize the time elapsing between the transfer
  of funds and disbursement by the grantee or
  subgrantee, in accordance with Treasury
  regulations at 31 CFR part 205.
• Grantees and subgrantees shall disburse
  repayments to and interest earned on a revolving
  fund before requesting additional cash payments
  for the same activity.

10
Sec. 3016.22, 3019.27 Allowable costs.

• Reasonable fees or profit to cost-type
  contractors
• No fee or profit (or other increment above
  allowable costs) to the grantee or subgrantee.
• Applicable cost principles.
• OMB Circular A-87
• OMB Circular A-122

11
Sec. 3016.24, 3019.23 Matching or cost sharing

• Federal grants cannot be used as a match for
  another Federal Grant (statuory exceptions).
• Program income, as defined in Sec. 3016.25 and
  3019.24, may not be used for cost sharing or
  matching.
• Does not apply to income earned by a grantee or
  subgrantee from a contract awarded under another
  Federal grant.
• In-kind contributions have special restrictions.

12
Sec. 3016.26, 3019.26 Non-Federal audit

• Grantees and subgrantees are responsible for
  obtaining audits -- Single Audit Act Amendments
  of 1996 (31 U.S.C. 7501-7507) and revised OMB
  Circular A-133, Audits of States, Local
  Governments, and Non-Profit Organizations.''
• In USDA, revised OMB Circular A-133 is
  implemented in 7 CFR part 3052, Audits of
  States, Local Governments, and Non-Profit
  Organizations.''

13
Sec. 3016.30, 3019.25 Changes and Revisions

• Funds can be moved within the approved budget
  categories
• unanticipated requirements
• limited program changes
• May require the prior written approval of the
  awarding agency.

14
Purchases

• Sec. 3016.31, 3019.32 Real property
• Sec. 3016.32, 3019.34 Equipment
• Sec. 3016.33, 3019.35 Supplies
• Agency must be compensated for residual inventory
  of unused supplies exceeding 5,000

15
Sec. 3016.36, 3019.41-.48 Procurement

• Grantees and subgrantees will use their own
  procurement procedures
• reflect applicable State and local laws and
  regulations,
• conforms to applicable Federal law and standards
  identified in this section.

16
Sec. 3016.40, 3019.51 Monitoring and reporting
program performance.

• Grantees are responsible for
• managing grant and subgrant supported programs,
  functions and activities.
• compliance with applicable Federal reporting
  requirements
• achievement of performance goals
• Performance reports must be submitted on schedule
  required by agency

17
Sec. 3016.41, 3019.51-.52 Financial reporting

• Standard Form 269 or 269A, Financial Status
  Report (some exceptions for construction grants)
• Accounting basis -- cash or accrual basis as
  prescribed by the awarding agency.
• Frequency -- No more than quarterly (30 days), no
  less than annually (90 days if annual).
• Request for advance or reimbursement--Standard
  Form 270, Request for Advance or Reimbursement.
  
• Standard Form 271, Outlay Report and Request for
  reimbursement for Construction Programs.

18
Sec. 3016.42, 3019.53 Retention and access
requirements

• applies to all financial and programmatic
  records, supporting documents, statistical
  records, and other records of grantees or
  subgrantees
• does not apply to records maintained by
  contractors or subcontractors.
• records must be retained for three years after
  (unless litigation pending)

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Sec. 3016.43, 3019.61-.62 Enforcement

• If Grantee fails to comply with statute or
  regulation
• agency may
• Temporarily withhold cash payments
• Suspend or terminate the current award for the
  grantee's or subgrantee's program,
• Withhold further awards for the program (tax
  benefits, earmarks)
• The agency will provide the grantee or subgrantee
  
• an opportunity for hearing, appeal, or
• Other administrative proceeding

20
7 CFR 25

• Regulation changes for employees

Karen Savoie Murray, OCD Alden Turner, ME
21
Highlights of the changes

• Implementation
• Lead entity requirements
• Board composition
• Grants management regulations
• USDA regulations adopted
• Project eligibility criteria established
• Environmental regulations adopted

22
Subpart E --

• Post-Designation Requirements

23
 25.404 Validation of designation

•  25.404(a) Maintaining the principles of the
  program
• Continuous improvement
• Participation

24
 25.404(b) Administration of the strategic plan

• The strategic plan must be administered in a
  manner consistent with the principles of the
  program contained in  25.202(a).

25
Administration of the strategic plan

• Lead entity
• legal status and authority to receive and
  administer Federal funds
• legal capacity to implement the plan
• Board membership
• representative of entire socio-economic spectrum
• 55 elected
• one member from each census tract
• elected and representative of the low income
  residents

26
Administration of the strategic plan

• Partnerships are critical to success !
• local governments/institutions
• regional organization
• community organizations
• Public information
• keep citizens and partners informed
• must have written PR procedures

27
Subpart G --

• Round II and Round IIS Grants

28
 25.620 Eligible grant purposes

• services directed at the goals of --
• economic self-sufficiency
• preventing or remedying neglect, abuse, or
  exploitation of children and adults unable to
  protect their own interests, or preserving,
  rehabilitating or reuniting families
• projects and activities identified in the
  strategic plan for the area and
• activities that benefit residents of the area for
  which the grant is made.

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 25.621 Ineligible grant purposes

• local match required for other federal grants
• duplication or replacement of current services or
  financial support provided from other sources.
  Expanded service OK.
• assisting a private business with less than 51
  percent ownership by US citizens or legal
  permanent residents
• relocation of businesses from other communities

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 25.621 Ineligible grant purposes

• support or promotion of gambling
• political activities
• preparation of EZ/EC program application package
• costs incurred prior to the execution date of the
  MOA
• judgments or debts owed to the United States
• political lobbying.

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 25.604 Disbursement of grant funds

• 7 CFR 3015, 3016 and 3019 of this title govern
  disbursements
• request for advance or reimbursement, in form
  and substance satisfactory to USDA, must be
  completed by the grantee on behalf of itself and
  all applicable subrecipients and submitted to the
  funding official.

32
 25.604 Disbursement of grant funds

• Requests for funds must include for each
  benchmark activity
• amount requested
• cumulative amount received
• total obligated for each
• total approved budget for the project (all
  sources)
• of the benchmark completed
• certification that the lead managing entity are
  in compliance with all applicable laws and
  regulatory requirements and
• other information as the funding official may
  require.

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OTHER USDA REGULATIONS

• 7 CFR part 3015, Uniform Federal Assistance
  Regulations
• 7 CFR part 3016, Uniform Administrative
  Requirements for Grants and Cooperative
  Agreements to State and Local Governments
• 7 CFR part 3017, Governmentwide Debarment and
  Suspension (Nonprocurement) and Governmentwide
  Requirements for Drug-Free Workplace (Grants)
• 7 CFR part 3018, New Restrictions on Lobbying
• 7 CFR part 3019, Uniform Administrative
  Requirements for Grants and Agreements with
  Institutions of Higher Education, Hospitals, and
  other Non-Profit Organizations and
• 7 CFR part 3052, Audits of States, Local
  Governments, and Non-Profit Organizations.

• www.access.gpo.gov/nara/cfr/waisidx_02/7cfrv15_02.
  html3000

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What Next?

• For more information
• OCD Website Grants Management site
• Slideshows will be posted on conference web site
• Call your desk officer, or
• Email ocd_at_ocdx.usda.gov with questions