Title: Federal Grant Management
1Federal Grant Management
- Federal Programs Directors Meeting
- March 12, 2014
- WVDE Office of Federal Programs
- Melanie Purkey
- Robert Crawford
- Laura Pauley
2Overview
- Legal Structure/Resources
- Fiscal Potpourri
- Procurement
- Inventory Management
- Time and Effort
- Tracking Budget Expenditures
- Carryover/Period of Availability
- Maximizing Federal Funds
3Legal Structures for Federal Programs
- Statutes/Legislation
- Program Statutes (NCLB, IDEA, Perkins)
- General Education Provisions Act (GEPA)
- Regulations
- Program Regulations
- Education Department General Administrative
Regulations (EDGAR) - Office of Management and Budget Circulars
- Guidance
- Non-Regulatory Guidance
4Grants Management Resources
- Program Guidance www.ed.gov
- Statutes
- Regulations
- Guidance
- General Education Provisions Act (GEPA)
- http//www.law.cornell.edu/uscode/20/usc_sup_01_2
0_10_31.html - Education Department General Administrative
Regulations (EDGAR) http//www.ed.gov/policy/fund
/reg/edgarReg/edgar.html
5Grants Management Resources
- Office of Management Budget (OMB) Circulars
http//www.whitehouse.gov/omb/circulars - Circular A-87 principles for allowable costs
- Circular A-122-cost principles for non-profit
organizations - Circular A-133 Compliance Supplement-audit
6What Rules Apply to Utilizing Federal Funds?
- State and local agencies must demonstrate fiscal
control and accounting procedures to ensure the
proper disbursement of and accounting for federal
funds. - Section 76 of EDGAR State Administered Programs
- Section 80 of EDGAR Uniform Admin.
RequirementsState Local Gov.
7Fiscal Potpourri
8Procurement Polices and Procedures
- Specific regulations governing procurement
- LEAs receiving federal education funds must
follow procurement rules contained in EDGAR. - Section 80.36(a), allows states and local
educational agencies (LEAs) to use the same
procurement policies and procedures they use for
procurements made with state funds.
9Procurement Polices and Procedures
- WVDE Purchasing Policies and Procedures Manual
for Local Educational Agencies--WVBE Policy 8200
http//wvde.state.wv.us/policies
10Inventory Management
- Inventory items purchased with federal funds are
divided into three categories - Real Property (if an allowable program cost)
- Equipment
- Supplies
11Inventory Management
- Equipment Inventory vs. Internal Control
- EDGAR requires an inventory for equipment
- Inventory not required for supplies however, ED
determined that an adequate internal control
system must include a process for labeling and
locating property purchased with federal funds
12Inventory Management
- Equipment
- Federal Definition of Equipment
- Tangible property
- Useful life of more than one year
- Acquisition cost of 5,000 or more
- State may use another definition as long as it
includes all property described above - Supplies
- Small cost items
- Consumed quickly
- ED expects sub-grantees to track all property
purchased with federal funds, in order to prove
there has been a benefit to the federal program
13Inventory Management
- Practical help for tracking non-equipment items
- Small and attractive item list
- Conduct risk assessment to identify items
susceptible to loss - Implement specific measures to control such items
- Certain pre-defined assets (technology equipment)
14Inventory Management
- Equipment inventory updated annually
- a description of the property
- a serial number or other identification number
- the acquisition date and cost of the property
- the percentage of federal participation in the
cost of the property - the location, use and condition of the property,
and - any ultimate disposition data including the date
of disposal and sale price of the property - Physical inventory
- Must be performed at least every 2 years
(recommend annually) - Indicate date and signature of individual(s)
15Inventory Management
- Must protect against unauthorized use
- When property is no longer needed, must follow
disposition rules - Transfer to another federal program
- Over 5,000 Keep or sell, but must pay a share
based on the percentage of federal ED
participation at initial acquisition - Under 5,000 May keep, sell, or dispose of it
with no obligation to ED
16Inventory Management
- Must have adequate controls in place
- to account for
- Location of equipment - assure that it is used
solely for authorized purposes - Custody of equipment - maintain effective control
and accountability - Security of equipment - adequately safeguard all
property
17Time and Effort
- If federal funds are used for salaries time and
effort records must be kept - Must demonstrate that employees paid with federal
funds actually worked on the specific federal
programs
18Time and Effort
- Type of documentation depends on how many cost
objectives the employee worked on - These cost objectives must be connected to the
employees salary source - What is a cost objective?
- A specific grant award, or other category of
costs, that requires the grantee to track
specific cost information
19Time and Effort
- If an employee works on a single cost objective
- Semi-Annual Certification
- Signed by employee and supervisor every six
months - Example I hereby certify that for the period
January 1, 2014 through June 30, 2013 one-hundred
percent (100) of my time and effort was spent on
Title I Administration. - Consolidated Admin is considered a single cost
objective
20Time and Effort
- If an employee works on multiple cost objectives
- Personnel Activity Report (PAR)
- After the fact
- Account for total activity
- Prepared monthly or semi-annually if certain
conditions are met - Signed and dated by the employee
21Time and Effort
- Flexible Certification can be filed
semi-annually if the following conditions are
met - Employees schedule includes multiple cost
objectives - The work is predetermined (e.g. a lesson plan)
- The employee is not permitted to work on
different cost objectives at the same time
22Time and Effort
- Determine estimates for budgeting
- Estimates must produce reasonable approximations
of the activity actually performed - Quarterly comparison of estimates to actual costs
- If difference is less than 10 - annual
adjustment - If difference is more than 10 - quarterly
adjustment
23Time and Effort
- Flexible Certifications must contain
- The specific activity or cost objective
- Total hours for which the employee was
compensated during the time period - Signed by the employee and a supervisory official
with first-hand knowledge of the work performed - Include support for any revisions to the
employees established schedule
24Time and Effort
- PARs must still be completed for any time period
for which significant deviations occur from the
established schedule that require work on
multiple activities or cost objectives at the
same time
25Tracking Budget Expenditures
- Total composite budget
- Administrative budget
- Individual school budgets
- http//wveis.k12.wv.us/schoolFinance/sf000002.cfm
26Carry Over
- Title I and Title II are subject to a cap on
amount that be carried forward into the Tydings
Period which provides another 12 months for the
use of funds. - 15 of the grant can be carried forward into the
Tydings period - LEAs wishing to carry over a greater percentage
may request a waiver once every three years.
27Carry Over
- An LEA has significant discretion in handling its
Title I carryover funds. - Funds may be added to the LEAs subsequent years
allocation and redistributed to participating
schools in accordance with normal allocation
procedures decreasing amount of allocation
based on highest to lowest poverty. - Funds may be added to the LEAs subsequent years
allocation and redistributed to participating
schools equitably based on a per pupil amount
times the number of low income students in each
school. - Funds may be designated for district wide
activities that could best benefit from
additional funding (e.g. parent involvement
activities, professional development, pre-K,
services for extended day/year programs). - The requirement for equitable services to
private schools also applies to carryover funds. - The LEA is not permitted to use Title I carryover
funds in a school that is not eligible for Title
I funding.
28Period of Availability
- Tydings Amendment
- Does not apply to all grants
- Funds are available to SEAs for 27 months
- 15 months under the grant award (July 1, 2014
September 30, 2015) - Plus 12 months (October 1, 2014 September 30,
2015) - SEA may limit period of availability!
- Always double check grant award notice
29Definition of Obligation Under Federal Law
Acquisition of Property Date of Binding Written Commitment
Personal Services by Employee When Services are Performed
Personal Services by Contractor Date of Binding Written Commitment
Travel When Travel is Taken
30Liquidations
- SEA gives LEAs 30 days to liquidate funds after
the end of the period of availability - Period of availability July 1, 2014 Sept 30,
2016 - Funds must be obligated by Sept 30, 2016 and
liquidated by Oct 31, 2016
31Maximizing Federal Funds
- Obligate oldest funds first
- Maintain clear accounting records
- Continually monitor budget vs. actual
- Know your carryover and liquidation rules
32Maximizing Federal Resources in a Changing
Education Environment
33Maximizing Federal Funds
- 1 Exercising Program Scope (10-12)
- 2 Maximizing the Use of Title I Funds
- Directions
- Read the assigned section ( 1 or 2)
- Conduct table discussions and identify key points
- Think about the following questions
34Realizing the Potential Future
- What activities are on your wish list?
- -What factors are currently preventing you from
moving forward with these activities? - - How could you connect the activities to
promising practices and present proposals within
the appropriate context?
35- - Fear of non-compliance fosters an environment
that prioritizes what is safe in terms of audit
risks over what is effective in terms of outcomes
for students. Pg. 7
36Operationalizing
- - Application Process
- Revision of Monitoring
- Title I Plan
- Resources Toolkit The Changing Landscape
37(No Transcript)
38- - In many states, a technical violation of a
paperwork requirement is more likely to trigger
state enforcement action than long-term spending
on ineffective activities that fail to improve
student achievement. Pg. 16