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Training Costs: Meals and Family-Friendly Policies

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Title: Training Costs, Meals and Family-Friendly Policies Author: Steven Spillan Created Date: 11/7/2014 6:05:10 PM Document presentation format – PowerPoint PPT presentation

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Title: Training Costs: Meals and Family-Friendly Policies


1
Training Costs Meals and Family-Friendly
Policies
  • Steven Spillan, Esq.
  • sspillan_at_bruman.com
  • Brustein Manasevit, PLLC
  • Fall Forum 2014

2
Agenda
  • Current Rules
  • Omni-Circular Rules
  • Possible Pushback by Agencies

3
Current Rule
  • OMB A-87 Attachment B, Section 27, 42, and 43
  • OMB A-21 Attachment A, Section J, Items 32, 51,
    and 53

4
Current Law A-87 / A-21
  • Costs of meals and travel are allowable if
    primary purpose of meeting / conference is
    dissemination of technical information
  • The cost of training provided for employee
    development is allowable

5
Uniform Grant Guidance (Omni Circular)
6
Training and Education (200.472)
  • The cost of training and education provided for
    employee development is allowable
  • Expanded definition to include education.
  • OIG concerned the category is too open ended

7
Conferences (200.432)
  • Conference defined as
  • A meeting, retreat, seminar, symposium, workshop
    or event
  • Whose primary purposes is the dissemination of
    technical information beyond the non-federal
    entity and
  • Is necessary and reasonable for successful
    performance under the Federal award

8
Conferences (cont.)
  • Allowable conference costs may include
  • Rental of facilities
  • Speakers fees
  • Costs of meals and refreshments
  • Local transportation
  • Other items incidental to such conferences unless
    restricted by terms of federal award

9
Conferences Dependent Care
  • Costs of identifying, but not providing, locally
    available dependent-care resources are allowable.
  • Part of OMBs new family-friendly policies
  • Meant to better enable employees of non-federal
    entities with dependent care responsibilities to
    progress in their careers
  • Essential for advancing the careers of women in
    STEM fields

10
Conferences (cont.)
  • Conference hosts/sponsors must exercise
    discretion and judgment in ensuring that
    conference costs are appropriate, necessary and
    managed in a manner that minimizes costs to the
    federal award.

11
Travel Costs (200.474)
  • Defined Expenses for transportation, lodging,
    subsistence, and related items incurred by
    employees who are on travel for official
    business.
  • May be charged
  • On a per diem or mileage basis
  • Actual Costs or,
  • A combination of the twoprovided the method used
    is applied to an entire trip and not to selected
    days of the trip.

12
Travel (cont.)
  • To charge to Federal award, must show
  • Participation of the individual is necessary to
    the federal award AND
  • The costs are reasonable and consistent with the
    entitys written travel policy (new requirement).
  • In the absence of established policy, the rates
    established under 5 U.S.C. 5701-11, by GSA, or by
    the President must apply to travel under Federal
    awards

13
Travel (cont.)
  • May only pay for the basic least expensive
    unrestricted accommodations class offered by
    commercial airlines, UNLESS
  • Requires circuitous routing
  • Requires travel during unreasonable hours
  • Excessively prolongs travel
  • Results in additional costs that would offset the
    transportation savings or,
  • Not reasonably adequate for travelers medical
    needs.
  • Must justify and document these conditions on a
    case-by-case basis in order for the use of
    first-class or business-class airfare to be
    allowable.

14
Travel Family Friendly
  • Dependent care costs above and beyond regular
    dependent care that directly result from travel
    to conferences are allowable provided the costs
    are
  • Direct result of the individuals travel for the
    Federal award
  • Consistent with entitys documented travel
    policy
  • Temporary during the travel period.
  • Travel costs for dependents are unallowable,
    except for travel of duration of six months or
    more with prior approval.

15
Federal Agency Reactions
16
OIG Concerns Summer 2014
  • OIGs have found conferences held by recipients
    where per-person cost of daily catering was
    between 189 and 400 of applicable locations
    federal per diem for meals and incidental expenses

17
OIG Concerns (cont.)
  • OMB should limit meal costs to federal per diem
    rates and document a cost comparison of at least
    three sites to determine most cost-advantageous
    location

18
ESEA Title II, Part A FAQ Guidance
  • Issued May 2013 via e-mail
  • Available on-line http//www2.ed.gov/policy/fund
    /guid/gposbul/faqs-grantee-conferences-may-2013.do
    c
  • ED Effort to take greater care in enforcing and
    monitoring these costs
  • Title II, Part A office is responsible for the
    largest amount of grant funds related to
    professional development
  • Very high burden of proof to show that paying for
    food is necessary

19
Title II, Part A Guidance (cont.)
  • QA 3 Consider whether hosting a meeting or
    conference is the most effective or efficient way
    to achieve the desired result.
  • QA 6
  • When hosting a meeting, structure the agenda so
    there is time for participants to purchase their
    own food, beverages, or snacks.
  • Consider a location in which participants have
    easy access to food and beverages.

20
Title II, Part A Guidance (cont.)
  • QA 7 In virtually all cases, using grant
    funds to pay for food and beverages for
    receptions and networking sessions is not
    justified
  • QAs 8, 9 Beware of free food and beverages
    embedded in a contract for meeting space ask
    hotel to back out such costs.
  • QA 13 May offer meeting participants the
    option of paying for food and beverages and
    arrange for items to be available at the meeting.

21
Weight of this Guidance?
  • Does not meet standard of Good Guidance (OMB
    Bulletin No. 07-02)
  • SASA Deputy Director clarified applicability of
    this guidance in June 2013
  • This new guidance is generally intended to apply
    to professional meetings, including those that
    you may have with LEA staff, and not to
    school-based events such as a Title I parent
    meeting. As a result, as long as there is a
    connection to a programmatic purpose and the cost
    is reasonable, an LEA may continue to provide
    food at Title I parent meetings.

22
ED Office of General Counsel
  • National Association of State Title I Directors,
    February 2014
  • Very high burden of proof to show that paying for
    food and beverages with federal funds is
    necessary to meet the goals and objectives of a
    federal grant.
  • Structure agenda to allow participants time to
    purchase their own food
  • Consider a location with easy access to food

23
ED OGC (cont.)
  • Working Lunch may be allowable. Factors to
    consider
  • Is a working lunch necessary?
  • Is the portion of the agenda to be carried out
    during lunch substantive and integral to the
    overall purpose of the meeting?
  • Is there a genuine time constraint that requires
    the working lunch?
  • If a working lunch is necessary, is the cost of
    the working lunch reasonable?
  • Has the SEA or LEA carefully documented that a
    working lunch is both reasonable and necessary?

24
DISCLAIMER
  • This presentation is intended solely to provide
    general information and does not constitute legal
    advice or a legal service.  This presentation
    does not create a client-lawyer relationship with
    Brustein Manasevit, PLLC and, therefore,
    carries none of the protections under the D.C.
    Rules of Professional Conduct.  Attendance at
    this presentation, a later review of any printed
    or electronic materials, or any follow-up
    questions or communications arising out of this
    presentation with any attorney at Brustein
    Manasevit, PLLC does not create an
    attorney-client relationship with Brustein
    Manasevit, PLLC.  You should not take any action
    based upon any information in this presentation
    without first consulting legal counsel familiar
    with your particular circumstances.
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