Floridas Subrecipient Requirements for CommunityBased, FaithBased, and Other Nonprofit Organizations

1
Floridas Subrecipient Requirements for
Community-Based, Faith-Based, and Other Nonprofit
Organizations

• Florida Department of Education
• August, 2007

2
Resources

• Contract Document (with ALL attachments)
• Reference Guide for State Expenditures found at
  http//www.fldfs.com/aadir/
• Florida Statutes found at http//www.leg.state.fl.
  us
• Florida Administrative Code found at
  http//www.flrules.org

3
Budgets and Amendments

• All expenditures must be made consistent with the
  approved budget
• If substantive changes need to be made in budget
  allocations across categories, an amendment may
  be necessary
• Amendments must be approved in advance by the
  Department

4
Fiscal and Program Accountability

• Project Records
• All disbursements must be supported by adequate
  documentation including but not limited to
  invoices, receipts, and timesheets
• Records Retention State requires keeping
  records for five years

5
Fiscal and Program Accountability

• Keep records that document
• Resources used in the project
• Performance
• Proper disbursement and accounting for funds
  including revenues

6
Fiscal and Program Accountability

• Supporting documentation for all expenditures is
  required!
• Examples include
• Invoices with check numbers verifying payment
• Payroll ledgers
• Bank statements

7
Fiscal and Program Accountability

• Remember!
• The Department of Financial Services makes
  payments for the Department of Education
• All payments are subject to pre- and post-audit
  as well as monitoring by DOE staff

8
Questionable Expenditures

• Food and beverages including meals, snacks,
  candy, coffee, alcohol, etc. (note exception for
  instructional purposes)
• Decorations
• Greeting Cards
• Gift Cards
• Personal Cell Phones (and allowances for cell
  phones

9
Questionable Expenditures

• Lobbying
• Fund Raising
• Promotional Items
• Entertainment
• Flowers
• Awards
• Office Parties

10
Questionable Expenditures

• Items for the personal convenience of staff
• Microwave Ovens
• Refrigerators
• Coffee Pots
• Portable Heaters
• Fans

11
Americans with Disabilities Education Act (ADA)
Exemption

• When a payment which would not otherwise be a
  lawfully authorized use of state funds is
  requested pursuant to the ADA, such a payment may
  be made if it is documented that the person is a
  qualified individual with a disability and the
  purchase is necessary to provide a reasonable
  accommodation.

12
Cell Phones

• Cell phones should only be used for conducing
  official business. Recipients must have
  established internal controls over the use of
  state-owned or leased cellular telephones to
  ensure that payments serve a specific authorized
  public purchase.

13
Perquisites

• Definition Those things, or the use thereof, or
  services that confer a benefit that is in the
  nature of additional compensation, or that reduce
  to some extent the normal personal expenses of
  the officer or employee receiving them.
• Examples housing, subsistence, utilities,
  laundry services, medical services, and the use
  of state-owned vehicles for other than business
  purposes

14
Perquisites

• Perquisites may not be furnished unless approved
  by DMS

15
Personal Preference

• State funds cannot be expended to satisfy the
  personal preference of employees (example may
  not purchase more expensive office furniture or
  equipment than is necessary because the employee
  prefers a more expensive item)

16
Food Purchases for Conferences, Conventions, and
Workshops

• Food purchases for a conference or convention or
  in connection with the rental of a meeting room
  for workshops or meetings are prohibited unless
  expressly provided by law.
• The negotiated rate for the rental of a room
  should not include food or beverages.

17
No Food!
18
Payment Verification

• Invoices must clearly reflect a description of
  service type, number of units and the cost per
  unit
• Supporting documentation should be submitted in
  an auditable format

19
Payment Verification

• Managers Responsibilities include verifying
  that
• The payment request (invoice) is consistent with
  the obligation document (contract, purchase
  order, agreement)
• Services were rendered within the terms of the
  agreement (including timelines) and were
  satisfactory.

20
Payment Verification

• Verify that expenditures being reimbursed are
• Allowable in the agreement budget
• Allowable pursuant to other rules and regulations
• Directly related to the scope of work
• Reasonable and allocable
• Adequately documented

21
Payment Verification

• Remember
• A cost reimbursement situation does not exist
  until funds have been expended! Incurring a
  liability (obligation or encumbrance) does not
  constitute a reimbursable situation

22
Audits

• Single Audit Reports
• Threshold is 500,000
• Failure to submit audit reports will jeopardize
  future funding
• No award will be made to any recipient who is
  non-compliant with audit requirements

23
Program Income

• Definition
• Generally includes fees for services, use of
  rental property, sale of commodities or items,
  payments of principal and interest to loans made
  with project funds.
• Generally does not include interest earned on
  project funds, rebates, credits, discounts, or
  refunds

24
Program Income

• Generally deducted from the total allowable costs
  to determine net allowable costs
• When authorized by DOE can be added to the
  program budget
• Cannot be treated as profit!

25
Disposition of Equipment

• When equipment is no longer needed for
• original project or other federal program
• Fair market value of less than 5,000 no
  obligation to awarding agency
• Fair market value in excess of 5,000 awarding
  agency should receive share of the value
  approval from the Department is necessary
• Some projects have specific requirements related
  to equipment upon termination of the project

26
Travel

• Travel must be performed and reimbursed only as
  provided by state law (Section 112.061, F.S.)

27
Travel

• Rates
• Per Diem - 80
• Breakfast - 6
• Lunch - 11
• Dinner - 19
• Mileage - .445 per mile (round down to nearest
  cent)

28
Travel

• Hotel Up to 150 without additional
  justification (use most economical for area and
  season)

29
Travel

• Required documentation
• Travel voucher
• Itemized hotel receipts
• Applicable transportation receipts for common
  carrier travel
• Applicable incidental receipts
• In the case of a conference or convention, the
  benefits to the State must be specified and the
  agenda provided (including itemized registration
  cost)

30
Travel

• Receipts needed for incidental expenditures
  (examples)
• Taxi fares in excess of 25 on a per fare basis
• Communication expenses (business-related only)
• Registration fees

31
Travel

• Receipts not needed
• Tips for taxi drivers that do not exceed 15 of
  the fare
• Tips paid for mandatory valet parking not to
  exceed 1 per incident
• Portage not to exceed 1 per bag or 5 per
  incident
• Photocopy charges that are business related

32
Travel

• Meals included in Registration Fee or Provided by
  Hotel or Airline
• When a meal is included in a registration fee,
  the meal allowance must be deducted from the
  reimbursement claim even if the traveler decides
  for personal reasons not to eat the meal.
• Where a meal is provided by a hotel or airline,
  the traveler will be allowed to claim the meal
  allowance.

33
Dispute Resolution

• Informal discussion with Program Manager
• Notify Chief of the Bureau of Contracts, Grants,
  and Procurement, in writing, of the intent to
  initiate a complaint
• Chief reviews case, and if necessary, set a
  complaint hearing date
• Department notifies recipient of Commissioners
  decision.
• Further appeal available through provisions of
  Chapter 120, Florida Statutes, and other
  applicable rules and regulations

34
Thank You!

• We welcome your feedback and input into our
  systems, processes, and procedures. Please feel
  free to contact me.
• Martha K. Asbury
• Chief, Bureau of Contracts, Grants, and
  Procurement
• Florida Department of Education
• 850/245-0735
• martha.asbury_at_fldoe.org