National state rehabilitation council forum

1
Vocational Rehabilitation Program Financial
Management

• National state rehabilitation council forum
• June 24, 2013

2
Todays Presentation

• Terms for the Informed SRC
• Basic Support Program Formula
• Match
• Maintenance of Effort (MOE)
• Allowable Costs
• IE Expenditures
• Federal Program Income
• Carryover
• Reallotted Funds
• 107 Monitoring

3
Effective Partnership

• How can the SRC be an effective partner
• with the VR agency in improving the VR program?
• Be an INFORMED partner in fiscal matters!

4
The Basics
5
Basic Support Program Formula

• Determining State Allotments
• The allotment of Federal funds for vocational
  rehabilitation services for each State is
  computed in accordance with the requirements of
  Section 110 of the Rehabilitation Act.

6
Basic Support Program Formula

• The formula to allocate funds is based on a
  combination of factors including but not limited
  to
• State per capita income
• State population
• Grant amounts are calculated in accordance with
  the program formula consistent with the
  appropriation level.
• Refer to RSA Website for additional
  information

7
Guidance and Reference Materials
Statute
OMB Circulars
EDGAR
RSA
ISSUANCES
8
Feeling Like a Fiscal analyst Yet?

• Good News!
• You dont have to know ALL these details to be an
  effective SRC partner!
• More Good News!
• If you want to know more, the
• RSA Website Guidance and Technical Assistance
  session will help you get there!!

9
What have we covered so far?

• Terms for the Informed SRC
• Basic Support Program Formula
• Match
• Maintenance of Effort (MOE)
• Allowable Costs
• IE Expenditures
• Federal Program Income
• Carryover
• Reallotted Funds
• 107 Monitoring

10
Match
21.3 STATE SHARE
78.7 FEDERAL SHARE
34 CFR 361.60(a)
11
Match

• Typical Sources
• State appropriations.
• Transfers from other units of State government.
• Third-party cooperative arrangements involving
  funds from other public agencies. (34 CFR
  361.28)

12
Match Calculation

• FOR EXAMPLE
• 27,800,000 (award amount) / .787 (Fed share)
• 35,324,015
• In this example, total program outlays must equal
  or exceed 35,324,015 for the grantee to utilize
  its entire Federal allotment of 27,800,000.
• 35,324,015 - 27,800,000 7,524,015
• (State share of program expenditures)

13
Match
Federal Allotment 27,800,000 Required State
Match 7,524,015 Total Program Outlay 35,324,015
34 CFR 361.60(a)
14
Match

• Expenditures from both agencies - General and
  Blind - are combined to determine compliance with
  the match requirement.

15
Maintenance of Effort

• In any given Federal FY, if State non-Federal
  expenditures fall below total State non-Federal
  expenditures for the fiscal year two years before
  the FY under review, the State has not met its
  MOE requirement.

34 CFR 361.62
16
Maintenance of Effort
FOR EXAMPLE
State Expenditures
FY 2011 14,665,000
2011 2 years
State MUST expend a minimum of 14,665,000 in FY
2013
17
Maintenance of Effort

• FY 2011 14,665,000
• FY 2013 14,000,000
• MOE Shortfall ( 665,000)

18
Maintenance of Effort

• FY 2013 MOE Shortfall (665,000)
• This means

19
Maintenance of Effort

• Expenditures from both agencies - General and
  Blind -are combined to determine compliance with
  the MOE requirement.

20
Maintenance of Effort

• Waivers
• May be granted to permit the State to respond to
  exceptional or uncontrollable circumstances i.e.
  natural disasters

34 CFR 361.62(d)
21
Allowable Costs

• Governmental units are responsible for
• the efficient and effective administration
• of Federal awards.

22
Allowable Costs

• Costs must be
• Necessary and reasonable for the proper and
  efficient performance and administration of
  Federal awards.
• Allocable to Federal awards under the provisions
  of the Circular.
• Authorized or not prohibited under State or local
  laws or regulations.

2 CFR Part 2, 225
23
What have we covered so far?

• Terms for the Informed SRC
• Basic Support Program Formula
• Match
• Maintenance of Effort (MOE)
• Allowable Costs
• IE Expenditures
• Federal Program Income
• Carryover
• Reallotted Funds
• 107 Monitoring

24
IE Expenditures

• IE Innovation Expansion Activities
• States must use a portion of funds allotted for
  the development and implementation of innovative
  approaches to expand and improve the provision of
  vocational rehabilitation services.
• 34 CFR 361.35

25
IE and the SRC

• IE is found in State Plan Attachment 4.11(d)
• The SRC reviews the State Plan
• IE funding support for the SRC
• The SRC needs a Resource Plan for its funding
  support
• (34 CFR 361.17 (h)(8)(i)(1)-(5))

26
Federal Program Income

• income received by the State that is directly
  generated by an activity supported under the
  grant.
• Typical sources

34 CFR 361.63

• Payments from the SSA for rehabilitating Social
  Security beneficiaries
• Payments received from workers compensation
  funds
• Fees for services to defray part or all of the
  costs of services provided
• Income generated by a State-operated community
  rehabilitation program

34 CFR 361.63(b)
27
Federal Program Income

• Must be used for the provision of VR services,
  administration of the State Plan, or carrying out
  innovation and expansion activities
• Must be spent before Federal funds are drawn down
• Can also be transferred to
• Independent Living Parts B and C
• Independent Living OIB
• Client Assistance Program

28
Carryover

• Any Basic Support Program funds which remain
  unobligated at the end of the year of
  appropriationincluding realloted fundsremain
  available for obligation during the succeeding
  fiscal year
• The state may only carry forward the unexpended
  Federal funds it was able to match in the year
  the funds were appropriated.

34 CFR 361.64
29
Reallotted Funds

• No later that 45 days before the end of each
  fiscal year, States report to RSA any amount of
  their full allotment which cannot be used or
  matched.
• As soon as possible, but not later than the end
  of the fiscal year, RSA reallots these funds to
  other States that can use those additional funds
  during the current or subsequent fiscal year...

30
Reallotted Funds

• providing the State can meet the matching
  requirement by obligating the non-Federal share
  of any reallotted funds in the fiscal year for
  which the funds were appropriated.

Funds reallotted to another State are considered
to be an increase in the recipient States
allotment for the fiscal year for which the funds
were appropriated.
34 CFR 361.65(b)
31
107 Monitoring
Were from the Federal Government...
And, were here to HELP you!
32
107 Monitoring

• Section 107 of the Rehabilitation Act of 1973, as
  amended, requires the Commissioner of the
  Rehabilitation Services Administration (RSA) to
  conduct annual reviews and periodic on-site
  monitoring of programs authorized under Title I
  of the Rehabilitation Act to determine whether a
  vocational rehabilitation (VR) agency is
  complying substantially with the provisions of
  its State Plan under Section 101 of the
  Rehabilitation Act and with the Evaluation
  Standards and Performance Indicators established
  under section 106.

33
107 Monitoring

• Monitoring and Technical Assistance Guide
• Can be found on the RSA website
• Focus Areas
• Organizational Structure
• Transition Services
• Fiscal Integrity
• The SRC is a stakeholder in the 107 monitoring
  process

34
Fiscal Integrity Priority Focus Area

• Matching and Earmarking
• Payroll
• Procurement
• Program Income
• Property Management
• Record Retention

35
Be an Informed Partner!

• Terms for the Informed SRC
• Basic Support Program Formula
• Match
• Maintenance of Effort (MOE)
• Allowable Costs
• IE Expenditures
• Federal Program Income
• Carryover
• Reallotted Funds
• 107 Monitoring

36
In Closing.

• Understand how the agencys fiscal status may
  affect services
• Be familiar with emerging issues
• Be an Informed Partner in Fiscal Matters!

37
Resources

• RSA website www.rsa.ed.gov
• State Liaisons www.rsa.ed.gov

38
Presenter Information

• Sean Barrett
• Financial Management Specialist
• Department of Education
• Rehabilitation Services Administration
• Sean.barrett_at_ed.gov
• 202-245-7604
• Corinna Stiles
• Vocational Rehabilitation Program Specialist
• Department of Education
• Rehabilitation Services Administration
• Corinna.stiles_at_ed.gov
• 202-245-7374