21st Century Community
Learning Centers Program
Reimbursements 101
Andre’ Hill
Budget Analyst 2
August 8, 2012
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
Why reimbursement?
• Subgrantees are paid for program expenses on a reimbursement basis only
• Georgia is the grantee, and program providers are considered subgrantees
(similar to a sub-contractor)
• Evidence of expenditure, purchase, or payment must be presented to receive
reimbursement
• 21st CCLC program funds must be used to supplement and not supplant
(take the place) of other Federal, State, local, or non-Federal funds
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
2
Cost Principles: Basic Guidelines
All Costs Must Be:
Necessary
Reasonable
Allocable
Legal under State and Local Law
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
3
Basic Guidelines (CONT.)
•
Necessary and Reasonable
 Must be necessary for the performance or administration of the grant
 Must follow sound business practices:
 Arms length bargaining (hint: competitive procurement processes)
 Follow federal, state and local laws
 Follow terms of the grant award
 Fair market prices
 Act with prudence under the circumstances
 No significant deviation from established prices
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
4
Basic Guidelines (CONT.)
•
Allocable
 Can only charge in proportion to the value received by the program
 Example: Organization purchases a computer to use 50% in the Title IV program
and 50% in a state program – can only charge half the cost to Title IV
•
Legal Under State and Local Law
 If an expense cannot be paid under state and local laws, it cannot paid with Federal
funds
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
5
OMB Circular A-87
Attachment B–
Selected Items of Costs
43 specific costs detailed
Listed in alphabetical order
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
6
General Allowable Expenses
•
Salaries for 21st CCLC Project Director, Program Manager, and Site Coordinators
(reasonable and in line with industry standard)
•
Tutors and paraprofessionals
•
Contractors
•
Independent evaluation
•
Supplies and materials required for the 21st CCLC program
•
Computer hardware and software required for the 21st CCLC program
•
Travel to required 21st CCLC trainings, conferences and workshops
•
Transporting students home following 21st CCLC activities
•
Cell phones
Justification must be provided. Must be in accordance with organization policies
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
7
General Allowable Expenses (CONT.)
•
Criminal Background Checks
 Checks must be completed against a reputable criminal background check database on
all 21st CCLC staff, teachers, contractors, sub-contractors, evaluators, etc. involved in the
program, whether or not they are in direct contact with students, prior to start date
 Annual (365 days) criminal background checks are required
 Annual national background checks conducted by school systems are acceptable, and
made available in resource folders
 Fitness Determination Letter – official letter issued by school system stating the fitness of
employee
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
8
General Allowable Expenses (CONT.)
•
Criminal Background Check (cont.)
 Prudent judgment must be used when hiring individuals; policies must be in place, and
followed
 It is the sub-grantee’s responsibility to ensure that all potential business partners are
qualified to work in the program by also checking the company and individuals against
EPLS (https://www.epls.gov/) and the debarment guidelines listed in EDGAR 34 CFR part
74 subpart C and part 85 subparts C and H
Failure to comply may result in immediate forfeiture of funding
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
9
General Allowable Expenses (CONT.)
• Rent and Utilities
 Allocable portion only (ensure supplanting does not take place)
 For rent: agreement needed and must be reasonable and within industry standards
• Light Snack (nutritional)
 For parent involvement activities only
 Cost must be reasonable (current GaDOE cap is $3.50 per person)
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
10
General Allowable Expenses (CONT.)
• T-Shirts
Once a year, for field trip security/safety reasons only. 21st CCLC logo must be affixed.
• Travel
 Meetings and conferences - the primary purpose of which is the dissemination of technical
information (agendas are required). Includes lodging, travel, meals associated with the
meeting or conference. Must consult with GaDOE for approval and generally maximum
of three program personnel per conference.
 Regular travel costs (ex.: mileage costs for Program Director)
• Tablet-type Computer Tools (e.g., iPad, iPod Touch with educational
software) or Video Systems (e.g., Xbox, PS2, Wii)
 May be allowable based on proper planning/implementation. Prior consultation and
approval required from GaDOE
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
11
General Allowable Expenses (CONT.)
• Educational Field Trips
Must have the ability to impact/improve students’ grades, CRCT scores, and/or bring
awareness to college and careers. Lesson plans, sample student surveys, and sample student
essays are required. Consult with your ERES/Budget Analyst prior to expense. Examples:
Georgia Aquarium – Science; GSU – college awareness; CNN – career awareness
• Advertising
Only for the recruitment of personnel required for the performance of a Federal award and the
procurement of goods and services
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
12
Unallowable Expenses
OMB Circular A-87, Attachment B, #14
• Entertainment - Costs of entertainment, including amusement, diversion,
and social activities and any costs directly associated with such costs (such
as tickets to shows or sports events, meals, lodging, rentals, transportation,
and gratuities) are unallowable
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
13
Unallowable Expenses (CONT.)
• Non-educational field trips
Examples: skating, bowling, sporting events, amusement parks, etc.
• Field trips during regular school day hours
• Field trips out-of-state
Exceptions may be given if 21st CCLC site is just outside destination state line
• Payments of stipends to students or family members to participate
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
14
Unallowable Expenses (CONT.)
•
The construction of new buildings or the renovation/remodeling of existing structures
•
Fundraising activities of any kind
•
Payment to students for receiving tutoring or mentoring services
•
Purchase of buildings
•
Purchase of vehicles
•
Personal Digital Assistants (PDAs), Data Plans
•
Incentives or anything that can be perceived as gifts
Gifts in kind, gift cards, iPods, field trips, games, etc.
•
Funds to invest in the stock market, savings or bank accounts
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
15
Unallowable Expenses (CONT.)
•
Food/Snacks
Partnership with feeder schools is encouraged. USDA approved snacks can be supplied through your feeder
schools. Schools will be reimbursed by the USDA for snacks served to your program. Partnerships with
corporate food providers may also help you provide nutritious snacks.
•
Tips
•
Alcohol
•
Parties
Including “blow-up” games and rides
•
Taxes (LEA)
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
16
Unallowable Expenses (CONT.)
• Advertising
Advertisement of the program in advertising media: magazines, newspapers, radio and
television, direct mail, exhibits, electronic or computer transmittals, and the like
• Expenses incurred prior to grant approval
Approval must be received from US ED
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
17
Verification Process
Entered Data
Monitoring Findings
Approval
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
18
Verification Process (CONT.)
• Data
All data must be entered into CAYEN Afteschool21 Data Management System
Objectives, Registration, Attendance (12 hours minimum weekly contact time),
Grades, State Assessment, and Certification
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
19
Data Verification
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
20
Verification Process (CONT.)
• Monitoring
 Must be in compliance with all stat and federal statutory requirements and guidance
 All findings received during the monitoring process must be corrected prior to
continuing reimbursements
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
21
Monitoring Verification
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
22
The Package
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
23
The Reimbursement Process
The AAA Effect
Accurate
Acceptable
Approvable
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
24
Documentation for reimbursement requests
Important:
The difference between documentation for your records vs.
documentation for reimbursement requests (in GAORS)
Track expenses (and balances) by sub-grant in GAORS and also
through your accounting system
Three months’ working capital is needed to operate this program
Link to GAORS login:
•
https://portal.doe.k12.ga.us/login.aspx
Explanation of ‘Check Requests’
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
25
21st CCLC FY13 Required Supporting Documents for Reimbursement Request
Processing
a) Salary and benefits
LEAs
1.Payroll system generated report (one or more of: earnings register detail, benefits distribution report,
payroll summary)
Non-LEAs
1. Payroll system generated report or spreadsheet (if payroll system generated report is unavailable); ADP
register; cancelled checks
LEAs and Non-LEAs (Optional - if required by GaDOE)
1. Time and effort documentation (e.g. semi-annual certificates, Personnel Activity Reports (PARs),
time-sheets, salary distribution records)
2. Proof of salary transfer/payment
b)
1.
2.
3.
Contractors
Detailed invoice with deliverables
Program Director’s signed approval to pay on the invoice
Proof of payment
c)
1.
2.
3.
4.
Field Trips
Flyer (or copy of webpage) from location visited that indicates purpose of visit
Invoice
Program Director’s signed approval to pay on the invoice
Proof of payment
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
26
21st CCLC FY13 Required Supporting Documents for Reimbursement Request Processing
d) Transportation
1.
2.
3.
4.
Invoice from Transportation Department/Transportation service provider
Program Director’s signed approval to pay on the invoice
Proof of payment
Mileage log (Optional – if required by GaDOE)
e) Professional Development
1.
2.
3.
4.
5.
6.
Workshop/conference Agenda
Travel Expense Statement (and receipts of travel expenses, if applicable)
Purchase order
Detailed invoice with deliverables
Program Director’s signed approval to pay on the invoice
Proof of payment
f) National Criminal Background Check (NCBC)
1.
2.
3.
4.
5.
Purchase Order (PO)
Invoice
List of persons covered by the NCBC (preferably on both PO and Invoice)
Program Director’s signed approval to pay on the invoice
Proof of payment
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
27
21st CCLC FY13 Required Supporting Documents for Reimbursement Request
Processing
g) Fidelity Bond and General Liability Insurance (Non-LEAs only)
1. Invoice
2. Program Director’s signed approval to pay on the invoice
3. Proof of payment
h) Telephone
1. Phone bill reflecting 21st CCLC charges (and basis of proration, if applicable)
2. Program Director’s signed approval to pay on the invoice/bill
3. Proof of payment
j) Utilities
1. Utility bill
2. Program Director’s signed approval to pay on the invoice/bill
3. Proof of payment
i) Indirect Cost
1. General ledger/expense statement that serves as the basis of the indirect cost
2. Journal Entry/General Ledger that demonstrates that the indirect cost has been charged to
the 21st CCLC subledger
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
28
21st CCLC FY13 Required Supporting Documents for Reimbursement Request
Processing
j) General Expenses (such as purchase of goods, and other expense categories not mentioned above)
1.
2.
3.
4.
Purchase order
Invoice
Program Director’s signed approval to pay on the invoice
Proof of payment
Notes:
Acceptable proof of payment (subgrantee’s choice of any one of the following. GaDOE may require
more than one and/or additional documents from within this list)
1.
2.
3.
4.
Detailed general ledger/(21st CCLC sub ledger) reports (that includes date and check numbers)
Cancelled checks, if required by GaDOE
Bank statements
Receipts with credit/debit card verification
To facilitate reimbursement request processing, GaDOE may require additional documents
not listed in this document
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
29
Components of the Request (CONT.)
Notes:
 NO social security numbers
 On time sheets: clear and accurate calculation of date-wise (and total) hours worked
 Calculations should be easily traced (adding machine tape, for example)
 All contractors should be verified through the Secretary of State’s office
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
30
Preparing Invoice/reimbursement request
•
Portal Log-in
•
Select “Prepare Invoices” (whether a new request or resubmission)
•
Select Fiscal Year, Grant
•
Select month in “Request Funds for Period:”
•
Click “Add” button to create the new request
•
Fill in Invoice Entry information; click “Add” button
•
The entry is added to the Invoice List
•
Input the original (sub) grant award year in the ‘Year’ column
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
31
Preparing Invoice - Attachments
•
From the list of Invoice Entries, click on the Attachment Icon (piece of paper with red border)
•
EVERY Invoice entry MUST have at least one attachment
•
Click “Browse” button to locate the document to be attached
•
Select the document to be attached from your folders, click “Open”
•
Click on “Upload” button
•
Repeat process until all Invoice Entries have an attachment and full documentation to ensure
timely processing of the Invoice
•
When complete and ready to submit, click “Send to Submitter”
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
32
Submitting an Invoice for Review
•
Subgrantee approver searches GAORS for invoice in status of “Ready for Submission
by Submitter”
•
Select the Invoice Period to be submitted by clicking on the attachment icon (piece of
paper icon)
•
After reviewing documentation and invoice, select the “Revise” button to send back to
Preparer.
•
If documentation is approved to submit to GaDOE for reimbursement, select the
“Submit” button.
•
Invoice reimbursement goes into status “Ready for Review by Program Manager.”
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
33
Invoice Status
• “New Payment Request” – newly created invoice OR an invoice which was previously
submitted but rejected by either the submitter or the Program Manager at GaDOE.
•
“Ready for Submission by Submitter” – Preparer is finished, awaiting approval by local
submitter.
•
“Ready for Review by Program Manager” – Preparer is finished, submitter approved, awaiting
review by GaDOE Budget Analyst (30-days to review).
•
“Ready for Grants Accounting Review” – Invoice was approved by the Budget Analyst, and is
awaiting processing by Grants Accounting.
•
“Approved” – Invoice has been processed for payment by Grants Accounting; monies will
arrive typically in 7 days
•
Note: There are 15 reimbursement request ‘slots’ in each FY in GAORS
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
34
Reimbursement Checklist
•
Were services rendered/goods received in FY13?
•
Exclude pre-award expenses (expense incurred prior to July 1, 2012)
•
Expense – budgeted? Aligned with program objectives? (If unbudgeted, but material – consult with
GaDOE, even if budget amendment is not required)
•
Invoice - sufficiently detailed?
– Service completed? In accordance with contract?
– Describes service/goods in detail? Rate per hour?
– Date-wise number of hours by site?
– Is attendance data in Cayen up-to-date? Facilitate easy cross check with GAORS (activity/session
name)?
– If invoice contains both 21st CCLC and non-21st CCLC items, label/circle 21st CCLC items
– Program Director’s signature of approval (check request)?
– Description on Purchase Order indicates purpose of the purchase?
•
21st CCLC/non-21st CCLC expenses have been prorated accurately and supported by
documentation/calculations?
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
35
Reimbursement Checklist – Cont’d
•
Remember to update inventory list when purchasing inventory items and affix inventory tag on the item
(see Resources folder for sample inventory list, tag)
•
Upload only Adobe Acrobat (PDF) files
•
Maintain documents of record (e.g. POs, contracts, lessons plans, hiring agreements, competitive quotes)
even if not required for GAORS
•
Expenses that should not be charged if you are already charging Indirect Cost
•
Seek reimbursement for mileage (not fuel)
•
Do not implement multi-year contracts (that span multiple FYs)
•
Remember to disburse checks to vendors/suppliers right away. Follow-up with bank statement
reconciliations
•
Field trip timing should not be in conflict with regular school hours
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
36
Reimbursement Checklist – Cont’d
• GAORS:
– Use unique invoice numbers
– Use ‘Year’, ‘School Name’ and ‘Invoice No.’ suffix coding scheme to delineate
multiple grants (Note: use your accounting system/Excel worksheet to track
expenses and balances by grant)
– Using the FY13 Chart of Accounts? (Copy of Chart of Accounts is Located on
the CD)
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
37
Reimbursement Checklist – Cont’d
• If using ‘standard’/projected/budgeted rates – remember to carry out
analysis and adjustments on a quarterly basis
• Refreshments:
•
•
•
•
•
•
Light and nutritional
For parent involvement activities only
Not allowed for professional development events
Current GaDOE cap: $3.50 per person/event
Prior approval required from GaDOE for program to charge fees
When nearing end of FY, check for ‘missing’ invoices from vendors
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
38
Reimbursement Checklist – Cont’d
• Time and Effort
– Time sheet hour calculations – accurate? Rounding up – as per your policy?
– Employee and supervisor signatures on all time sheets?
– Corrections on time sheets (and any document for that matter) being counter
signed?
– Payment to Program Director – authorized by someone of higher/appropriate
authority?
– Personnel Activity Reports (PARs) or Semi-Annual Certifications?
• If someone has multiple cost objectives: PARs
• If someone has single cost objectives: Semi-Annual Certification (Exception: time sheet already
includes all essential elements of a Semi-Annual Certification. If in doubt, use Semi-Annual
Certification)
• Semi-Annual Certification must be signed after-the-fact
– Use clear terms such as hours/minutes instead of non-standard terms such as
‘sessions’
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
3/28/2011
39
FREQUENT REASONS FOR REJECTIONS IN
GAORS
•
Essential supporting documents missing (e.g., invoice, proof of payment)
•
Tips/gratuities, gift cards, door prizes
•
Trip to amusement park/field trip not aligned with program objectives
•
Refreshment expense that does not meet criteria
•
Un-allocable expense (e.g., maintenance expense for an automobile used for 21st and non-21st
CCLC, but expense proration basis is not clear/undocumented)
•
Installation of PABX telephone system/new landline telephone line, permanent fixtures (e.g.
whiteboards), improvement-type ‘repairs’
•
Program Director’s signature of approval (check request) missing
•
•
Prepaid expenses –advances and deposits (e.g., hotel , registration fees)
Background check carried out without Purchase Order (or equivalent authorization from
Program Director)
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
40
Communication
• GAORS Helpdesk
 Automated notification email with brief description
1958 Twin Towers East
205 Jesse Hill Jr. Drive SE
Atlanta, GA 30334
(404) 651-9503
(800) 869-1011 (GA)
(404) 651-5006
dticket@doe.k12.ga.us
• Budget Analysts
 Email with concerns listed
 Telephone call for clarification
 Technical assistance
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
41
Timeline
•
Reimbursements must be submitted on a monthly basis
 Must be submitted by the 15th calendar day of each month
• If multiple requests are submitted, only the current month’s will be processed. The other
request(s) will be considered late and processed only after reimbursement requests from all
subgrantees for the current month have been processed
•
Assurances ensure consequences for continued late submissions; potential to be placed in HighRisk status
•
21st CCLC has 30 days to review each submission
•
Credit to bank account via direct deposit on Thursdays
•
End of State fiscal year processing downtime (June 30th to mid-July)
•
Unforeseen circumstances – TBD
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
42
Sample Packets
Grantee Participation
Review of Form, Resources,
& Sample Folders
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
43
Resources
Cost Principles
• OMB Circular A-21
Educational Institutions
http://www.whitehouse.gov/omb/assets/omb/circulars/a021/a21_2004.pdf
• OMB Circular A-87
State, Local, and Indian Tribal Governments
http://www.whitehouse.gov/omb/circulars_a087_2004/
• OMB Circular A-122
Non-Profit Organizations
http://www.whitehouse.gov/omb/assets/omb/circulars/a122/a122_2004.pdf
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
44
Questions?
Dr. John D. Barge, State School Superintendent
“Making Education Work for All Georgians”
www.gadoe.org
45