Frequently Asked Questions about Grants Management

1
Frequently Asked Questions about Grants Management

• May 1, 2008
• Russ Inbody, School Finance Administrator
• Marilyn Peterson, Federal Programs Administrator

2
Years

• What is a fiscal year and why are there different
  ones? Who decides? (p. 14)
• Federal, State, District, ESU
• Federal Grants
• 14 month year (07/01 09/30) Current
• Tydings Amendment (10/01 9/30) Carryover
• State Grants
• Defined in authorizing legislation

3
Grant Award Notification

• Grant Award Notification (GAN) official record
  of being awarded funds (p. 15)
• Project Start Date
• Official date you can start obligating funds
• Continuing activities and pre-award costs
• Approval Date
• Project End Date
• Last date you can obligate or spend funds

4
Obligation of Funds

• When is it an obligation?
• When the person in charge authorizes the
  purchase!
• Are federal and state guidelines on obligations
  the same?
• Federal CFR 76.707 (p. 16)

5
Applications

• What is an approved application? (p. 17-18)
• A legally binding contract
• Assurances are the fine print
• Who can be authorized representative?
• Who authorizes and how often?
• Electronic signatures

6
Nonpublic Participation

• Can nonpublic schools participate in grants?
  (pp. 18-20)
• State
• Federal
• What are the rules for federal grants?
• Section 9501 of NCLB
• Fiscal agents

7
Complaints and Appeals

• How do you officially complain? (pp. 20-22)
• Who can submit an appeal and what is the process?

8
Managing Federal Funds

• What are the basic requirements that apply to all
  federal funds? (pp. 22-25)
• Lobbying, debarment and suspension
• Political Activity
• Civil rights
• Cash management
• Supplement, not supplant
• Matching funds and in-kind contributions

9
Supplement, not Supplant

• NCLB
• District level - Maintenance of Effort (MOE)
• School level
• Program level
• IDEA
• MOE

10
Budgets

• What is a budget? (pp. 25-27)
• District/ESU Budgets
• State Timelines
• Requirements
• Budgets in the grants management system
• Amendments

11
Budgets and Accounting Systems

• Flexibility in NCLB
• REAP-FLEX and Section 6123
• Local accounting systems FIFO
• Payment order in GMS

12
Payments

• Payments in the GMS (pp. 27-28)
• Scheduled
• Reimbursement
• Advance payments
• Cash Management Investment Act (CMIA)

13
Expenditure Reports

• Reimbursement Requests (pp. 28-29)
• Scheduled payments and required reporting dates
• Final Reports
• Supporting documentation

14
Carryover Limitations

• NCLB programs
• Title IV, Safe and Drug Free Schools
• 25 carryover limitation for all
• Must apply for waiver before closeout
• Can apply each year
• Title I, Part A
• 15 carryover limitation if initial allocation
  was 50,000 or more
• Can apply only once every three years

15
Federal Cost Principles

• Circular 87
• Also applicable to State Grants
• Necessary and reasonable
• Program must benefit
• Supplement, not supplant

16
Equipment

• Changes to the definitions (pp. 30-31)
• Inventoried equipment
• Equipment that may need to be depreciated
• Users Manual
• Federal Audits

17
Incentives for Early Retirement

• When can federal funds be used for incentive pay
  for early retirement? (pp. 31-32)
• Proportional to the number of years that the
  employee was paid from the grant program
• Reasonable
• Required by law or agency-employee agreement or
  agency policy
• Must be included in an approved budget
• Unused leave and severance pay

18
Indirect Costs

• What are indirect costs? (pp. 32-34)
• How are indirect cost rates determined?
• Who determines the cost rates?
• What is the difference between restricted and
  unrestricted?
• Can indirect costs be charged to one program and
  not another program?

19
Administrative Cost Limitations

• Special Education Grants 8 (higher rates may
  be approved on a case by case basis)
• Perkins Grants (all) no more than 5
• Adult Education Grants no more than 5
• Early Childhood Education - 7
• Early Childhood Professional Development
  Partnerships 7
• Even Start 0
• NCLB
• Title III Language Acquisition 2
• Title IV Safe and Drug Free Schools 2

20
General Guidelines

• What if a program has no specified limit on
  administrative costs?
• reasonable and necessary

21
Administration and Coordination

• Within the GMS, administration and program
  coordination are separate allowable activities
• An option to ensure sufficient staff time for
  program directors, especially in consortia
• MUST keep time and effort records if the same
  staff person is coded under administration and
  program coordination

22
Time and Effort Records

• Who needs to keep time and effort records or
  personal activity reports? (pp. 34-36)
• NEW guidance for staff in Title I schoolwide
  projects

23
Required Audits

• What audits are required? (pp. 36-38)
• Rule 1 (State)
• A-133 (Federal)
• Who else can conduct audits?
• State auditor
• Federal auditors

24
Multi-district Projects

• What is the difference between a consortium and a
  cooperative project?
• Financial record keeping
• Consortia pool resources
• Cooperative projects track resources by district
• Both must have a fiscal agent who is responsible
  for funds and compliance
• Must be a written agreement to join!

25
Records Retention

• Federal five years
• State 3 years or according to schedule
• Secretary of State website (www.sos.state.ne.us)

26
Interest and Program Income

• Federal funds should not be in interest earning
  accounts (pp. 39-40)
• If interest is earned on federal funds, you must
  remit it to the U. S. Department of Education but
  may keep 100 per year for administrative
  expenses!
• Program income general rule is put any income
  back into the program
• No profits

27
Appendices

• Federal Standards for Financial Management
  Systems
• Procurement