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Federal Financial Management Requirements

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Federal Financial Management Requirements An overview Standards Necessary and reasonable Sound business practices Prudent person principle Allocable Only charge costs ... – PowerPoint PPT presentation

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Title: Federal Financial Management Requirements


1
Federal Financial Management Requirements
  • An overview

2
Standards
  • Necessary and reasonable
  • Sound business practices
  • Prudent person principle
  • Allocable
  • Only charge costs that clearly BENEFIT grant
  • Proper allocation methods
  • Authorized or not prohibited
  • Federal, State, or local laws

3
More Standards
  • Consistent treatment
  • Across all programs
  • Year to year
  • Both indirect and direct
  • Not used for matching requirements
  • Unless specifically authorized
  • Conform to ETA grant exclusions limitations
  • Specific unallowable costs
  • Administrative cost limitation

4
And more..
  • Adequately documented
  • Traceable to source documentation
  • Consistent with GAAP
  • Source documentation
  • Evidence of authority to incur cost
  • Demonstrate actual amount
  • Receipts for goods
  • Subcontractor invoices
  • Time sheets for staff costs (payroll records)

5
Internal Controls
  • System to safeguard integrity of funds
  • Accounting system
  • Timely recording of expenditures
  • Qualified personnel
  • Limited access to records
  • Separation of duties
  • Dual signatures for checks
  • Reconciliations by different staff
  • Timesheets and payroll approvals

6
Budget Controls
  • Accounting records need to track to budget
    categories
  • Linking spreadsheets or chart of accounts
  • Spending according to quarterly budget estimates
  • Spending within approved line items
  • Monitor costs and make adjustments
  • Indication of potential modification needs

7
Obligation
  • Amounts of orders placed, contracts and subgrants
    awarded, goods and services received, and similar
    transactions during a given period that will
    require payment by the grantee during the same or
    future period
  • Defined in 29 CFR Parts 97 95

8
Unliquidated Obligation
  • The amount of obligations incurred for which an
    expenditure has not been recorded.
  • goods and services ordered but not received.)

9
Accrued Expenditure
  • Charges incurred by a grantee during a given
    period requiring a provision of funds for
  • (i) goods and tangible property received
  • (ii) services performed by employees,
    subgrantees, subcontractors, etc.
  • (iii) other amounts becoming owed for which no
    current services or performance is due

10
Outlays
  • Same as expenditure
  • Cash payments
  • For reporting purposes
  • Cash payments accruals for goods and services
    received but not yet paid

11
Examples
  • Obligation
  • Subcontract for training services
  • Purchase order for equipment
  • Unliquidated Obligation
  • Purchase order not yet filled
  • Accrued Expenditure
  • Equipment received, but not invoiced or paid

12
Chart of Accounts
  • Numerical Listing or Codes
  • General Ledger/Books of Account
  • Identify Costs in Books of Account
  • Report Financial Results of Operations
  • Accumulate Track Costs
  • Source of Funds
  • Program Activities or Cost Categories
  • Interim Final Cost Objectives

13
Cost Classification
  • Process used to distribute costs
  • Assign allowable costs to cost objectives
  • Costs Assigned
  • Direct Charge
  • Allocation
  • General ledger or books of account

14
Classification System
  • Required by GAAP
  • Trace Costs from Federally required reports
  • To books of account
  • To source documentation

15
Cost Classification Process
16
Cost Categories
  • Only 2 Cost Categories
  • Administration
  • Program Activities
  • Reporting categories
  • Vary by grant
  • Classify within books of account
  • Classify through linking spreadsheets

17
Reporting Categories
  • Program Income
  • Both earnings and expenditures
  • Non-federal costs Sec. 185 (f)(2)
  • AKA Stand-in costs
  • No match required for Earmark grants
  • Both must be traceable to books of account

18
Administrative Limits
  • Contained in Grant Agreement
  • Not to exceed 10 of grant award
  • Unless negotiated to max of 15
  • Documentation Required
  • Subject to Grant Officer Approval
  • Measured at conclusion of grant period

19
WIA Definition
  • 20 CFR 667.220(a)
  • Not related to direct services
  • Either to clients or employers
  • List of specific functions
  • Unlike traditional definitions
  • Applies to all Title I programs
  • Including Earmark grants

20
Administrative Functions
  • Overall general administrative functions
  • Accounting, financial, cash management
  • Procurement
  • Property management
  • Personnel management
  • Payroll
  • Coordinating resolution of findings
  • Audit, monitoring, investigations

21
Administrative Functions
  • General administrative functions
  • Audit functions
  • General legal services
  • Developing systems and procedures
  • Includes information systems
  • Required for administrative functions
  • Monitoring of administrative functions

22
Administrative Costs
  • Goods services
  • Required for administrative functions
  • Travel costs
  • Carry out administrative activities
  • Related to overall management
  • Awards for administrative functions
  • Payroll service for staff

23
Administrative CostsInformation Technology
  • Costs of information systems
  • Related to administrative functions
  • Accounting payroll systems
  • Procurement purchasing systems
  • Costs include
  • Purchase, development operation

24
Program CostsInformation Technology
  • Tracking/monitoring participant performance
    information
  • Employment statistics
  • Performance cost information
  • Eligible providers of training services
  • Youth education activities
  • If both program admin---ALLOCATE

25
Indirect costs
  • Traditionally administrative costs
  • For WIAmay be administrative or program costs
  • Process to determine proportion for reporting
  • Addressed in next workshop
  • Use of linking spreadsheet for reporting

26
Other Guidance
  • Job Title vs. Job Function
  • Costs follow job function, NOT title
  • Multiple functions must be allocated
  • Subrecipient level classification
  • Use of contract proposals or invoicing
  • Function of the award

27
Program Income
  • Additional revenues for the grant
  • Earned as a result of grant activity
  • Earned because of grant
  • 29 CFR 97.25 Governmental Grantees
  • 29 CFR 95.24 Non-governmental Grantees

28
More Program Income
  • Addition method required - WIA
  • 20 CFR 667.200(a)(5)
  • Reported on SF 269
  • Expenditure within a grant period
  • ETA does not reduce grant awards
  • Addition method always applies
  • Both revenues and expenditures identified in
    books of account

29
Uses of Program Income
  • No administrative cost limitation
  • Allowable activities
  • Allowable costs and proper classification
  • Included in the scope of audit
  • Other administrative rules apply
  • Sanctions for misuse

30
Financial Reports
  • SF-269
  • Standard for all Federal grants
  • Quarterly expenditure report
  • Due 30 days after quarter end
  • Electronic reporting system

31
Where do I find the data for reports?
  • Accounting System
  • Cash Basis
  • Accrual Basis
  • Accrual worksheet(s)
  • Subgrantee reports

32
Subrecipient Reporting
  • Direct Grant recipient must establish reporting
    requirements
  • Comply with Federal requirements
  • May impose additional requirements
  • Monitor subrecipient financial activity

33
Common Reporting Elements
  • Identifying information
  • Funding year period covered by report
  • Total Federal Outlays (expenditures)
  • Accrual basis
  • Cumulative by each year of appropriation
  • Refunds, Rebates, etc.
  • Any receipt that reduces Federal Outlays

34
Common Elements
  • Recipient share of net outlays for allowable
    program activities
  • Program income
  • Addition method required
  • Reported in Section 10, lines r-t
  • Indirect costs
  • Reported in Section 11
  • Administrative costs identified in comments
    section (section 12)

35
Status of Funds Section
  • Federal Unliquidated Obligations
  • Total Federal Obligations
  • Net Federal Outlays
  • Total Federal Funds Authorized for this Funding
    Period
  • Unobligated Balance of Federal Funds

36
Web-based Reporting
  • Program-specific software with required data
    elements
  • Grantees provided
  • Passwords (data entry)
  • PINs (data certification)
  • Embedded data entry instructions

37
Password PIN Information
  • Individuals responsible for on-line reporting
    report certification must be identified
  • Instructions contained in grant award transmittal
    letter

38
Steps in electronic reporting
  • Select Report Form
  • Select/Verify Grant Number
  • Select Reporting Quarter
  • Report Header Information

39
Report Status Types
Report Status Description
Not Submitted Indicates that the data has not been submitted for the quarter.
Awaiting Grantee Certification Indicates that data has been entered and passed the edit checks. These edit checks occur from top to bottom on the form. Once the data is saved, the date is applied to the status. This date IS NOT the official submission date for the quarter. It is more of a temporary save.
Grantee Certified Indicates that the Certifying Official has applied the PIN to the report. Once certification is successful, the certification date will be attached to that report. This is the official submission date for the report. At this point, the data becomes available for ETA Regional Office review and acceptance.
Region Accepted Indicates that the ETA Regional Office has reviewed and Accepted the Grantee Certified report. Once the report has been accepted, the date is attached to the report.
40
Finalizing reports
  • 2 Ways to Save the Report
  • Enter PIN and submit
  • Submit
  • Confirmation provided by system
  • Certified
  • Report Status Updated

41
Report Revisions
  • Grantee may revise until data locked
  • Select appropriate FY/PY reporting quarter
  • Explain in comments section
  • Same process for review acceptance by ETA

42
Locking
  • 2 consecutive quarters
  • FPO Accepted
  • LOCKED from revisions
  • Data available
  • Read-only
  • Example
  • Quarter ending 9/30 is FPO Accepted
  • Quarter ending 6/30 is LOCKED

43
Common Problems
  • Compliance with Edit Checks
  • Local internet provider difficulties
  • Difficult to access EIMS at peak times

44
QUESTIONS????
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