EVERYTHING YOU EVER WANTED TO KNOW ABOUT EARMARK GRANT MANAGEMENT

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EVERYTHING YOU EVER WANTED TO KNOW ABOUT EARMARK
GRANT MANAGEMENT

• ...But Were Afraid to Ask

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CONFERENCE AGENDA

• Purpose of a Post-Award Conference
• Grant Award Agreement Requirements Overview
• Grant Agreement Face Sheet
• Award Document
• Additional Provisions
• Other Items of Interest
• Grant Modifications
• Subrecipient Reporting
• Questions and Answers

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EARMARK POST-AWARD GUIDE

• Detailed info about topics highlighted during the
  session
• Additional Guidance
• Structure
• Part I Grant Award Requirements
• Part II Addendum
• Attachments
• Technical Information 411

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GRANT AGREEMENT FACE SHEET

• Grant Agreement Face Sheet
• General Provisions
• Uniform Administrative Requirements
• Cost Principles
• Other Requirements

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GRANT AGREEMENT FACE SHEET
GENERAL PROVISIONS

• Period of Performance
• Total Government Financial Obligation
• Draw down payments

Handout 1 Grant Award Face Sheet
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GRANT AGREEMENT FACE SHEET
UNIFORM ADMINISTRATIVE REQUIREMENTS

• Grant Management Rules
• Apply to all grants awarded by DOL
• 29 CFR Part 95 Institutions of Higher Education,
  Hospitals, Non-Profit/Commercial Organizations,
  Organizations under the Jurisdiction of Foreign
  Governments and International Organizations or
• 29 CFR Part 97 State, Local and Indian Tribal
  Governments
• Require Policies and Procedures

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GRANT AGREEMENT FACE SHEET
UNIFORM ADMINISTRATIVE REQUIREMENTS

• Why have policies and procedures
• Provide a framework for grant operations
• Facilitate consistent service delivery
• Safeguard federal funds
• Fulfill a financial and administrative grant
  requirement

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GRANT AGREEMENT FACE SHEET
UNIFORM ADMINISTRATIVE REQUIREMENTS

• Standards for Financial Management Systems
• Written procedures for determining the
  reasonableness, allocability, and allowability of
  costs in accordance with the provisions of the
  applicable Federal cost principles and the terms
  of the grant award
• 29 CFR Part 95.21 Institutions of Higher
  Education
• 29 CFR Part 97.20 Governmental Grantees

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GRANT ADMINISTRATIVE REQUIREMENTS
ON THE WEB

• Codes of Federal Regulations (CFRs)
• www.gpoaccess.gov/cfr/index.html
• Office of Management and Budget (OMB) Circulars
• www.whitehouse.gov/omb/circulars

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GRANT AGREEMENT FACE SHEET
COST PRINCIPLES Overview

• Set of government wide rules
• Define conditions for charging costs
• OMB Circular A-21 Cost Principles for Educational
  Institutions or
• OMB Circular A-87 Cost Principles for State,
  Local and Indian Tribal Governments
• Necessary, reasonable, allocable

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GRANT AGREEMENT FACE SHEET
SELECTED ITEMS OF COSTS

• Frequently Asked Questions
• Refreshments/Awards/Events
• Unallowable Costs
• Entertainment
• Graduation ceremonies (A-21 only)
• Allowable Costs
• Providing refreshments at partner meetings
• Consistent with Grantee Policies
• Awards
• Refreshments at award ceremonies

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GRANT AGREEMENT FACE SHEET
OTHER REQUIREMENTS Single Audit Act

• Audit requirements
• Procedures for resolution of audit findings
• 500,000 threshold for grant recipient and
  subrecipient
• 29 CFR Part 96 Audit Requirements For Grants,
  Contracts And Other Agreements
• 29 CFR Part 99 Audits of States, Local
  Governments, and Non-Profit Organizations

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GRANT AGREEMENT FACE SHEET
OTHER REQUIREMENTS Lobbying Certification

• 29 CFR Part 93 Lobbying Certification
• Grant recipient/subrecipient requirements
• Disclosure of Lobbying Activities (SF-LLL-A)
• Lobbying Certification and Disclosure of
  Lobbying Activities form

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GRANT AGREEMENT FACE SHEET
OTHER REQUIREMENTS Equal Opportunity

• 29 CFR Part 37 Non-Discrimination and Equal
  Opportunity Requirements
• Discrimination is prohibited on the basis of
• race
• color
• religion
• sex
• national origin
• age
• disability
• political affiliation, and
• Citizenship / status as a lawfully admitted
  immigrant authorized to work in the United
  States.

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GRANT AGREEMENT FACE SHEET
OTHER REQUIREMENTS Equal Opportunity

• EO Notice Communication
• Posted prominently
• Provided to each participant and made part of
  participants file
• EO Notice Content
• Required wording in 29 CFR Part 37.30

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GRANT AGREEMENT FACE SHEET
OTHER REQUIREMENTS Equal Opportunity

• EO Data Collection Requirements
• Required data collection categories
• Information may not be furnished on behalf of the
  individual
• An individual has the right to refuse to provide
  any part or all of the data

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GRANT AGREEMENT FACE SHEET
OTHER REQUIREMENTS Equal Opportunity

• Hispanic or Latino
• ? Yes ? No
• Race
• American Indian or Alaska Native
• Asian
• Black or African American
• Hawaiian Native or other Pacific Islander
• White

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GRANT AGREEMENT FACE SHEET
OTHER REQUIREMENTS Debarment Suspension

• 29 CFR Part 98
• Debarment and Suspension grant recipient/subrecipi
  ent requirements
• Contract termination/default
• Excluded Parties List System
• http//epls.arnet.gov

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GRANT AGREEMENT FACE SHEET
OTHER REQUIREMENTS Drug-Free Workplace

• 29 CFR Part 98
• Drug-Free Workplace Policy
• Published statement
• Drug Awareness Program
• Establishment of Drug Awareness program
• Appendix C of 29 CFR Part 98.

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GRANT AWARD DOCUMENT

• STATEMENT OF WORK
• BUDGET INFORMATION
• ASSURANCES / CERTIFICATIONS
• SPECIAL CLAUSES / CONDITIONS

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PART I STATEMENT OF WORK

• Statement of Work (SOW)
• Project Description
• Timelines
• Outcomes
• Deliverables

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PART II BUDGET INFORMATION

• Budget Information
• Budget Summary Form (SF-424A)
• Line item expenditures description

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DO YOU KNOW YOUR GRANT AGREEMENT?
Lead-Based Paint Poisoning Prevention Act
Earmark Performance Act of 2006
Wide and Scenic Rivers Act of 1968
Flood Disaster Protection Act of 1969
Laboratory Animal Welfare Act of 1966
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PART III ASSURANCES/CERTIFICATIONS
SELECTED ASSURANCES

• (2) Access to Records
• (3) Conflict of Interest/Personal Gain Safeguards
• (4) Statement of Work
• (6) Non-Discrimination Equal Opportunity
• (8) Hatch Act

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QUESTIONS ANSWERS
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PART IV SPECIAL CLAUSES/CONDITIONS
SPECIAL CLAUSES

• Budget Line Item Flexibility
• Prior GO approval required for
• ANY increase/decrease in personnel, fringe
  benefits, and/or indirect costs line items
• More than 20 change for any other line item
• Prior FPO review required for
• Mix/match change within personnel and/or fringe
  benefits
• Prior FPO consultation suggested for
• ANY change to budget

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PART IV SPECIAL CLAUSES/CONDITIONS
SPECIAL CLAUSES

• Indirect Cost Rate Cost Allocation Plan
• Current ICR or CAP on file
• No ICR or CAP
• Temporary Billing Rate Approved
• Forward ICR proposal to cognizant Federal agency
  within 90 days

Handout 2 Indirect Cost Rate Status Sheet
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PART IV SPECIAL CLAUSES/CONDITIONS
ADMINISTRATIVE COSTS

• Definition
• Administrative costs
• Function-based definition
• Program Costs
• Those not associated with Administrative costs
• Indirect costs
• Can be EITHER administrative or program

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PART IV SPECIAL CLAUSES/CONDITIONS
EXAMPLES OF ADMINISTRATIVE COSTS

• Accounting
• Audit
• Budgeting
• Financial Management
• Payroll
• Personnel Management
• Procurement
• Property Management

• Monitoring related to administrative functions
• Travel related to administrative functions
• IT related to administrative functions
• Goods and Services related to administrative
  functions

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PART IV SPECIAL CLAUSES/CONDITIONS
EXAMPLES OF PROGRAM COSTS

• Costs associated with services to participants
• Costs not associated with administrative costs
• Tracking / monitoring participant performance
• Travel related to program functions
• Curriculum development
• Training
• Subrecipient Costs
• Costs associated with the direct provision of
  services to participants and employers

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PART IV SPECIAL CLAUSES/CONDITIONS
ADMINISTRATIVE COSTS

• Limitations
• 10 of total grant award amount
• Include BOTH direct and indirect administrative
  costs

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PART IV SPECIAL CLAUSES/CONDITIONS
TEST YOUR KNOWLEDGE
For each of these costs, please indicate if it is
Admin
Program
Neither
Both
Space and utilities costs for the Accounting
Office
Wine Reception for Graduating Nursing Participants
Data entry costs associated with
tracking/monitoring participant performance
information
Staff Travel Costs
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10-MINUTE BREAK
TIME REMAINING
10 MIN
9 MIN
8 MIN
7 MIN
6 MIN
5 MIN
4 MIN
3 MIN
2 MIN
1 MIN
WELCOME BACK!
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PART IV SPECIAL CLAUSES/CONDITIONS
SPECIAL CONDITIONS

• Federal Project Officer (FPO)
• Primary DOL contact
• Provides oversight, monitoring, and technical
  assistance
• Not authorized to make any changes to terms of
  grant agreement
• Responsible for reports approval

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PART IV SPECIAL CLAUSES/CONDITIONS
SPECIAL CONDITIONS

• Equipment
• Per unit acquisition cost of 5,000 and
• Useful life of more than 1 year
• Purchase or lease
• Prior approval from GO required
• Grantee maintains title after end of grant

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PART IV SPECIAL CLAUSES/CONDITIONS
SPECIAL CONDITIONS

• Program Income
• Addition method used.
• Wholly expended within grant period of
  performance
• Used to further program objectives
• Use before Federal funds
• Remaining program income used to reduce grant
  expenditures at closeout

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PART IV SPECIAL CLAUSES/CONDITIONS
SPECIAL CONDITIONS

• Pre-Award Costs
• Costs incurred prior to start date
• Unallowable by Grant Officer
• Example grant planning activities

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PART IV SPECIAL CLAUSES/CONDITIONS
SPECIAL CONDITIONS

• Quarterly Fiscal/Program Reports
• Due 30 days after end of quarter
• January 30, April 30, July 30, October 30
• Final Report
• 90 days after end of period of performance, or
• 90 days after all funds are expended

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PART IV SPECIAL CLAUSES/CONDITIONS
SPECIAL CONDITIONS Reports

• Quarterly Financial Status Report (SF-269)
• Submitted through Enterprise Business Support
  System (EBSS)
• If EBSS not available send reports to FPO, not GO

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PART IV SPECIAL CLAUSES/CONDITIONS
SPECIAL CONDITIONS Reports

• Quarterly Progress Report
• Suggested format based on uniform administrative
  reporting requirements
• Due to the FPO via email
• Format included in the Attachments section of
  Earmark Post-Award Guide

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PART IV SPECIAL CLAUSES/CONDITIONS
SPECIAL CONDITIONS Reports

• Accrued Expenditures or Federal Share of Outlays
• Reported on SF 269, line 10j
• Value of all goods/services and indirect costs,
  to-date
• Even if costs have not been billed or payments
  made
• Procedures needed to track and report accruals

DEMONSTRATION FSR (SF-269)
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PART IV SPECIAL CLAUSES/CONDITIONS
SPECIAL CONDITIONS Reports

• Unliquidated Obligations
• Reported on SF 269, lines 10k through 10n.
• Program Income
• Reported on SF 269, lines 10q through 10t

DEMONSTRATION FSR (SF-269)
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GRANT AGREEMENT FACE SHEET
SPECIAL CONDITIONS Reports

• Administrative Costs
• Reported on SF 269, Comments (block 12)
• Cumulative amount and percentage reported
  quarterly

SF-269 Example
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PART IV SPECIAL CLAUSES/CONDITIONS
ADDITIONAL INFO Subrecipient Reporting

• Subrecipient Reporting Suggestions
• Accrual reporting method
• Monthly reports
• Preponderance of data
• More accurate financial data
• Reports submitted within 15 days of quarter end
• Written estimate of accrued costs

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PART IV SPECIAL CLAUSES/CONDITIONS
SPECIAL CONDITIONS

• Consultant Fees
• Limited to 500 per day
• Grant Officer (GO) approval needed for higher fees

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QUESTIONS ANSWERS
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PART IV SPECIAL CLAUSES/CONDITIONS
SPECIAL CONDITIONS

• Rebates
• Publicity
• Public Announcements
• Executive Order 12928

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PART IV SPECIAL CLAUSES/CONDITIONS
SPECIAL CONDITIONS Procurement

• Procurement Requirements
• Open and free competition
• Procurement Records
• History of procurement
• Basis for the selection
• Basis for award cost or a price analysis
• Sole source justification (if applicable)

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PART IV SPECIAL CLAUSES/CONDITIONS
SPECIAL CONDITIONS Procurement

• Grantees must follow procurement regulations
• 29 CFR Part 95 or Part 97
• OMB Circular A-21 or A-87
• Procurement standards for obtaining any
  subrecipient
• Partners specified in Grant Agreement
• Service providers

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PART IV SPECIAL CLAUSES/CONDITIONS
SPECIAL CONDITIONS Veterans Priority

• Jobs for Veterans Act, PL 107-288
• Grantees are responsible for
• Giving priority of services to veterans and
  certain spouses when providing services to
  eligible participants
• Developing procedures to determine the priority
  of service.

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QUESTIONS ANSWERS
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ADDENDUM TABLE OF CONTENTS
EARMARK POST-AWARD CONFERENCE GUIDE

• Grant Modification Procedures
• Reporting
• Subrecipient Reporting
• Cost Principles
• Administrative and Program Costs
• Procurement
• DOLs Demand-Driven Vision
• Labor Market Information
• Websites Guide
• Cross Reference of Administrative Requirements
• Records Retention
• Forms and Other Documents

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RECORDS RETENTION

• Financial Records
• 3 years from submission date of final expenditure
  reports
• Equipment Property
• 3 years from date of final disposition
• Litigation, claims, or audits
• 29 CFR Part 95.53

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GRANT MODIFICATION PROCEDURES

• Modification requests required for
• Any change in the scope or objective of the
  project/program
• Any change in a key person specified in the
  application or award document
• A need to extend the grant period of performance

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GRANT MODIFICATION PROCEDURES
Continued

• Modification requests required for
• Change in Partners/subrecipients as stated in the
  grant agreement
• Increase or decrease in Personnel, Fringe
  Benefits, or Indirect Costs line items
• Any change exceeding 20 budget flexibility in
  all other line items
• Equipment purchase

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GRANT MODIFICATION PROCEDURES

• Modification request format
• Letterhead with original signature
• Justification
• Revised copy of the Budget Form SF-424A (if
  applicable)
• Revised Narrative (if applicable)
• Send to FPO

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GRANT MODIFICATION PROCEDURES
COMMON MODS AT-A-GLANCE

• Equipment purchase/lease
• Cover letter listing equipment, estimated unit
  cost, justification
• Incorporating ICR
• Cover letter Copy of Approved Indirect Cost
  Rate Agreement

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QUESTIONS ANSWERS