21st Century Community Learning Centers Program Reimbursements 101

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21st Century Community Learning Centers
ProgramReimbursements 101

• Andre Hill
• Budget Analyst 2
• August 8, 2012

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Why reimbursement?

• Subgrantees are paid for program expenses on a
  reimbursement basis only
• Georgia is the grantee, and program providers are
  considered subgrantees (similar to a
  sub-contractor)
• Evidence of expenditure, purchase, or payment
  must be presented to receive reimbursement
• 21st CCLC program funds must be used to
  supplement and not supplant (take the place) of
  other Federal, State, local, or non-Federal funds

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Cost Principles Basic Guidelines

• All Costs Must Be
• Necessary
• Reasonable
• Allocable
• Legal under State and Local Law

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Basic Guidelines (cont.)

• Necessary and Reasonable
• Must be necessary for the performance or
  administration of the grant
• Must follow sound business practices
• Arms length bargaining (hint competitive
  procurement processes)
• Follow federal, state and local laws
• Follow terms of the grant award
• Fair market prices
• Act with prudence under the circumstances
• No significant deviation from established prices

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Basic Guidelines (cont.)

• Allocable
• Can only charge in proportion to the value
  received by the program
• Example Organization purchases a computer to
  use 50 in the Title IV program and 50 in a
  state program can only charge half the cost to
  Title IV
• Legal Under State and Local Law
• If an expense cannot be paid under state and
  local laws, it cannot paid with Federal funds

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OMB Circular A-87 Attachment B Selected Items
of Costs

• 43 specific costs detailed
• Listed in alphabetical order

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General Allowable Expenses

• Salaries for 21st CCLC Project Director, Program
  Manager, and Site Coordinators
• (reasonable and in line with industry standard)
• Tutors and paraprofessionals
• Contractors
• Independent evaluation
• Supplies and materials required for the 21st CCLC
  program
• Computer hardware and software required for the
  21st CCLC program
• Travel to required 21st CCLC trainings,
  conferences and workshops
• Transporting students home following 21st CCLC
  activities
• Cell phones

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General Allowable Expenses (cont.)

• Criminal Background Checks
• Checks must be completed against a reputable
  criminal background check database on all 21st
  CCLC staff, teachers, contractors,
  sub-contractors, evaluators, etc. involved in the
  program, whether or not they are in direct
  contact with students, prior to start date
• Annual (365 days) criminal background checks are
  required
• Annual national background checks conducted by
  school systems are acceptable, and made available
  in resource folders
• Fitness Determination Letter official letter
  issued by school system stating the fitness of
  employee

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General Allowable Expenses (cont.)

• Criminal Background Check (cont.)
• Prudent judgment must be used when hiring
  individuals policies must be in place, and
  followed
• It is the sub-grantees responsibility to ensure
  that all potential business partners are
  qualified to work in the program by also checking
  the company and individuals against EPLS
  (https//www.epls.gov/) and the debarment
  guidelines listed in EDGAR 34 CFR part 74 subpart
  C and part 85 subparts C and H
• Failure to comply may result in immediate
  forfeiture of funding

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General Allowable Expenses (cont.)

• Rent and Utilities
• Allocable portion only (ensure supplanting does
  not take place)
• For rent agreement needed and must be reasonable
  and within industry standards
• Light Snack (nutritional)
• For parent involvement activities only
• Cost must be reasonable (current GaDOE cap is
  3.50 per person)

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General Allowable Expenses (cont.)

• T-ShirtsOnce a year, for field trip
  security/safety reasons only. 21st CCLC logo must
  be affixed.
• Travel
• Meetings and conferences - the primary purpose of
  which is the dissemination of technical
  information (agendas are required). Includes
  lodging, travel, meals associated with the
  meeting or conference. Must consult with GaDOE
  for approval and generally maximum of three
  program personnel per conference.
• Regular travel costs (ex. mileage costs for
  Program Director)
• Tablet-type Computer Tools (e.g., iPad, iPod
  Touch with educational software) or Video Systems
  (e.g., Xbox, PS2, Wii)
• May be allowable based on proper
  planning/implementation. Prior consultation and
  approval required from GaDOE

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General Allowable Expenses (cont.)

• Educational Field Trips
• Must have the ability to impact/improve
  students grades, CRCT scores, and/or bring
  awareness to college and careers. Lesson plans,
  sample student surveys, and sample student essays
  are required. Consult with your ERES/Budget
  Analyst prior to expense. Examples Georgia
  Aquarium Science GSU college awareness CNN
  career awareness
• Advertising
• Only for the recruitment of personnel
  required for the performance of a Federal award
  and the procurement of goods and services

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Unallowable Expenses

• OMB Circular A-87, Attachment B, 14
• Entertainment - Costs of entertainment, including
  amusement, diversion, and social activities and
  any costs directly associated with such costs
  (such as tickets to shows or sports events,
  meals, lodging, rentals, transportation, and
  gratuities) are unallowable

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Unallowable Expenses (cont.)

• Non-educational field trips
• Examples skating, bowling, sporting events,
  amusement parks, etc.
• Field trips during regular school day hours
• Field trips out-of-state
• Exceptions may be given if 21st CCLC site is
  just outside destination state line
• Payments of stipends to students or family
  members to participate

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Unallowable Expenses (cont.)

• The construction of new buildings or the
  renovation/remodeling of existing structures
• Fundraising activities of any kind
• Payment to students for receiving tutoring or
  mentoring services
• Purchase of buildings
• Purchase of vehicles
• Personal Digital Assistants (PDAs), Data Plans
• Incentives or anything that can be perceived as
  gifts
• Gifts in kind, gift cards, iPods, field
  trips, games, etc.
• Funds to invest in the stock market, savings or
  bank accounts

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Unallowable Expenses (cont.)

• Food/Snacks
• Partnership with feeder schools is encouraged.
  USDA approved snacks can be supplied through your
  feeder schools. Schools will be reimbursed by the
  USDA for snacks served to your program.
  Partnerships with corporate food providers may
  also help you provide nutritious snacks.
• Tips
• Alcohol
• Parties
• Including blow-up games and rides
• Taxes (LEA)

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Unallowable Expenses (cont.)

• Advertising
• Advertisement of the program in advertising
  media magazines, newspapers, radio and
  television, direct mail, exhibits, electronic or
  computer transmittals, and the like
• Expenses incurred prior to grant approval
• Approval must be received from US ED

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Verification Process

• Entered Data
• Monitoring Findings
• Approval

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Verification Process (cont.)

• Data
• All data must be entered into CAYEN Afteschool21
  Data Management System
• Objectives, Registration, Attendance (12 hours
  minimum weekly contact time), Grades, State
  Assessment, and Certification

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Data Verification
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Verification Process (cont.)

• Monitoring
• Must be in compliance with all stat and federal
  statutory requirements and guidance
• All findings received during the monitoring
  process must be corrected prior to continuing
  reimbursements

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Monitoring Verification
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The Package
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The Reimbursement Process

• The AAA Effect
• Accurate
• Acceptable
• Approvable

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Documentation for reimbursement requests

• Important The difference between documentation
  for your records vs. documentation for
  reimbursement requests (in GAORS)
• Track expenses (and balances) by sub-grant in
  GAORS and also through your accounting system
• Three months working capital is needed to
  operate this program
• Link to GAORS login https//portal.doe.k12.ga.us/
  login.aspx
• Explanation of Check Requests

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21st CCLC FY13 Required Supporting Documents for
Reimbursement Request Processing
a) Salary and benefits LEAs 1.Payroll system
generated report (one or more of earnings
register detail, benefits distribution report,
payroll summary)   Non-LEAs 1. Payroll system
generated report or spreadsheet (if payroll
system generated report is unavailable) ADP
register cancelled checks   LEAs and Non-LEAs
(Optional - if required by GaDOE) 1. Time and
effort documentation (e.g. semi-annual
certificates, Personnel Activity Reports (PARs),
time-sheets, salary distribution records) 2.
Proof of salary transfer/payment   b)
Contractors 1. Detailed invoice with
deliverables 2. Program Directors signed
approval to pay on the invoice 3. Proof of
payment   c) Field Trips 1. Flyer (or copy of
webpage) from location visited that indicates
purpose of visit 2. Invoice 3. Program
Directors signed approval to pay on the
invoice 4. Proof of payment
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21st CCLC FY13 Required Supporting Documents for
Reimbursement Request Processing
d) Transportation   1. Invoice from
Transportation Department/Transportation service
provider 2. Program Directors signed approval
to pay on the invoice 3. Proof of payment 4.
Mileage log (Optional if required by GaDOE) e)
Professional Development   1.
Workshop/conference Agenda 2. Travel Expense
Statement (and receipts of travel expenses, if
applicable) 3. Purchase order 4. Detailed
invoice with deliverables 5. Program
Directors signed approval to pay on the
invoice 6. Proof of payment   f) National
Criminal Background Check (NCBC)   1. Purchase
Order (PO) 2. Invoice 3. List of persons
covered by the NCBC (preferably on both PO and
Invoice) 4. Program Directors signed approval
to pay on the invoice 5. Proof of payment
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21st CCLC FY13 Required Supporting Documents for
Reimbursement Request Processing

• g) Fidelity Bond and General Liability Insurance
  (Non-LEAs only)
•  
• 1. Invoice
• 2. Program Directors signed approval to pay on
  the invoice
• 3. Proof of payment
• h) Telephone 
• 1. Phone bill reflecting 21st CCLC charges (and
  basis of proration, if applicable)
• 2. Program Directors signed approval to pay on
  the invoice/bill
• 3. Proof of payment
• j) Utilities
• 1. Utility bill
• 2. Program Directors signed approval to pay on
  the invoice/bill
• 3. Proof of payment
•  
• i) Indirect Cost
• 1. General ledger/expense statement that serves
  as the basis of the indirect cost
• Journal Entry/General Ledger that demonstrates
  that the indirect cost has been charged to

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21st CCLC FY13 Required Supporting Documents for
Reimbursement Request Processing
j) General Expenses (such as purchase of goods,
and other expense categories not mentioned
above)   1. Purchase order 2. Invoice 3.
Program Directors signed approval to pay on the
invoice 4. Proof of payment   Notes
  Acceptable proof of payment (subgrantees
choice of any one of the following. GaDOE may
require more than one and/or additional
documents from within this list)   1. Detailed
general ledger/(21st CCLC sub ledger) reports
(that includes date and check numbers) 2.
Cancelled checks, if required by GaDOE 3. Bank
statements 4. Receipts with credit/debit card
verification       To facilitate reimbursement
request processing, GaDOE may require additional
documents not listed in this document
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Components of the Request (cont.)

• Notes
• NO social security numbers
• On time sheets clear and accurate calculation of
  date-wise (and total) hours worked
• Calculations should be easily traced (adding
  machine tape, for example)
• All contractors should be verified through the
  Secretary of States office

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Preparing Invoice/reimbursement request

• Portal Log-in
• Select Prepare Invoices (whether a new request
  or resubmission)
• Select Fiscal Year, Grant
• Select month in Request Funds for Period
• Click Add button to create the new request
• Fill in Invoice Entry information click Add
  button
• The entry is added to the Invoice List
• Input the original (sub) grant award year in the
  Year column

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Preparing Invoice - Attachments

• From the list of Invoice Entries, click on the
  Attachment Icon (piece of paper with red border)
• EVERY Invoice entry MUST have at least one
  attachment
• Click Browse button to locate the document to
  be attached
• Select the document to be attached from your
  folders, click Open
• Click on Upload button
• Repeat process until all Invoice Entries have an
  attachment and full documentation to ensure
  timely processing of the Invoice
• When complete and ready to submit, click Send to
  Submitter

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Submitting an Invoice for Review

• Subgrantee approver searches GAORS for invoice in
  status of Ready for Submission by Submitter
• Select the Invoice Period to be submitted by
  clicking on the attachment icon (piece of paper
  icon)
• After reviewing documentation and invoice, select
  the Revise button to send back to Preparer.
• If documentation is approved to submit to GaDOE
  for reimbursement, select the Submit button.
• Invoice reimbursement goes into status Ready for
  Review by Program Manager.

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Invoice Status

• New Payment Request newly created invoice OR
  an invoice which was previously submitted but
  rejected by either the submitter or the Program
  Manager at GaDOE.
• Ready for Submission by Submitter Preparer is
  finished, awaiting approval by local submitter.
• Ready for Review by Program Manager Preparer
  is finished, submitter approved, awaiting review
  by GaDOE Budget Analyst (30-days to review).
• Ready for Grants Accounting Review Invoice
  was approved by the Budget Analyst, and is
  awaiting processing by Grants Accounting.
• Approved Invoice has been processed for
  payment by Grants Accounting monies will arrive
  typically in 7 days
• Note There are 15 reimbursement request slots
  in each FY in GAORS

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Reimbursement Checklist

• Were services rendered/goods received in FY13?
• Exclude pre-award expenses (expense incurred
  prior to July 1, 2012)
• Expense budgeted? Aligned with program
  objectives? (If unbudgeted, but material
  consult with GaDOE, even if budget amendment is
  not required)
• Invoice - sufficiently detailed?
• Service completed? In accordance with contract?
• Describes service/goods in detail? Rate per hour?
• Date-wise number of hours by site?
• Is attendance data in Cayen up-to-date?
  Facilitate easy cross check with GAORS
  (activity/session name)?
• If invoice contains both 21st CCLC and non-21st
  CCLC items, label/circle 21st CCLC items
• Program Directors signature of approval (check
  request)?
• Description on Purchase Order indicates purpose
  of the purchase?
• 21st CCLC/non-21st CCLC expenses have been
  prorated accurately and supported by
  documentation/calculations?

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Reimbursement Checklist Contd

• Remember to update inventory list when purchasing
  inventory items and affix inventory tag on the
  item (see Resources folder for sample inventory
  list, tag)
• Upload only Adobe Acrobat (PDF) files
• Maintain documents of record (e.g. POs,
  contracts, lessons plans, hiring agreements,
  competitive quotes) even if not required for
  GAORS
• Expenses that should not be charged if you are
  already charging Indirect Cost
• Seek reimbursement for mileage (not fuel)
• Do not implement multi-year contracts (that span
  multiple FYs)
• Remember to disburse checks to vendors/suppliers
  right away. Follow-up with bank statement
  reconciliations
• Field trip timing should not be in conflict with
  regular school hours

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Reimbursement Checklist Contd

• GAORS
• Use unique invoice numbers
• Use Year, School Name and Invoice No.
  suffix coding scheme to delineate multiple grants
  (Note use your accounting system/Excel worksheet
  to track expenses and balances by grant)
• Using the FY13 Chart of Accounts? (Copy of Chart
  of Accounts is Located on the CD)

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Reimbursement Checklist Contd

• If using standard/projected/budgeted rates
  remember to carry out analysis and adjustments on
  a quarterly basis
• Refreshments
• Light and nutritional
• For parent involvement activities only
• Not allowed for professional development events
• Current GaDOE cap 3.50 per person/event
• Prior approval required from GaDOE for program to
  charge fees
• When nearing end of FY, check for missing
  invoices from vendors

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Reimbursement Checklist Contd

• Time and Effort
• Time sheet hour calculations accurate? Rounding
  up as per your policy?
• Employee and supervisor signatures on all time
  sheets?
• Corrections on time sheets (and any document for
  that matter) being counter signed?
• Payment to Program Director authorized by
  someone of higher/appropriate authority?
• Personnel Activity Reports (PARs) or Semi-Annual
  Certifications?
• If someone has multiple cost objectives PARs
• If someone has single cost objectives
  Semi-Annual Certification (Exception time sheet
  already includes all essential elements of a
  Semi-Annual Certification. If in doubt, use
  Semi-Annual Certification)
• Semi-Annual Certification must be signed
  after-the-fact
• Use clear terms such as hours/minutes instead of
  non-standard terms such as sessions

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FREQUENT REASONS FOR REJECTIONS IN GAORS

• Essential supporting documents missing (e.g.,
  invoice, proof of payment)
• Tips/gratuities, gift cards, door prizes
• Trip to amusement park/field trip not aligned
  with program objectives
• Refreshment expense that does not meet criteria
• Un-allocable expense (e.g., maintenance expense
  for an automobile used for 21st and non-21st
  CCLC, but expense proration basis is not
  clear/undocumented)
• Installation of PABX telephone system/new
  landline telephone line, permanent fixtures (e.g.
  whiteboards), improvement-type repairs
• Program Directors signature of approval (check
  request) missing
• Prepaid expenses advances and deposits (e.g.,
  hotel , registration fees)
• Background check carried out without Purchase
  Order (or equivalent authorization from Program
  Director)

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Communication

• GAORS Helpdesk
• Automated notification email with brief
  description
• 1958 Twin Towers East205 Jesse Hill Jr. Drive
  SEAtlanta, GA 30334 [phone] (800)
  869-1011 (GA) [phone] 
  dticket_at_doe.k12.ga.us
• Budget Analysts
• Email with concerns listed
• Telephone call for clarification
• Technical assistance

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Timeline

• Reimbursements must be submitted on a monthly
  basis
• Must be submitted by the 15th calendar day of
  each month
• If multiple requests are submitted, only the
  current months will be processed. The other
  request(s) will be considered late and processed
  only after reimbursement requests from all
  subgrantees for the current month have been
  processed
• Assurances ensure consequences for continued late
  submissions potential to be placed in High-Risk
  status
• 21st CCLC has 30 days to review each submission
• Credit to bank account via direct deposit on
  Thursdays
• End of State fiscal year processing downtime
  (June 30th to mid-July)
• Unforeseen circumstances TBD

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Sample Packets

• Grantee Participation
• Review of Form, Resources,
• Sample Folders

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Resources Cost Principles

• OMB Circular A-21
• Educational Institutions
• http//www.whitehouse.gov/omb/assets/omb/circulars
  /a021/a21_2004.pdf
• OMB Circular A-87
• State, Local, and Indian Tribal Governments
• http//www.whitehouse.gov/omb/circulars_a087_2004/
  
• OMB Circular A-122
• Non-Profit Organizations
• http//www.whitehouse.gov/omb/assets/omb/circulars
  /a122/a122_2004.pdf

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Questions?