Updates and Fixed Awards
2014 AmeriCorps
State and National Symposium
Agenda
– Omni Circular
– IPERA
– NGA
– Common Audit Findings
– Fixed Price Awards
2014 AmeriCorps
State and National Symposium
OmniCircular
Key areas for Changes that Affect
AmeriCorps Grants:
–Pre-award Assessments
–Single Audits (A-133 audits)
–Indirect Costs
–Time and Activity
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Pre-Award Financial Review
What’s Current:
Grantees should conduct a financial review to determine if
sub-grantees have the capacity to manage federal funds.
What’s Coming:
Grantees must conduct a financial capacity assessment on
subgrantees and are encouraged to also confirm subgrantees financial stability.
2014 AmeriCorps
State and National Symposium
Single Audit Act Requirements (A-133)
What’s Current:
Grantees who expend $500,000 of Federal funds in a year must
conduct an A-133 audit.
What’s Coming:
The threshold for A-133 audits goes up to $750,000. It applies to the
grantee’s fiscal year that begins after December 26, 2014.
Example:
Fiscal year is July 1 – June 30. Threshold begins for fiscal year July 1, 2015 –
June 30, 2016.
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Indirect Costs
What’s Current:
– Grantees must have an established Negotiated Indirect Cost Rate (NIDCR)
from their cognizant agency or elect to use the CNCS 5%/10% option for
AmeriCorps.
– NIDCR must be renewed annually.
What’s Coming:
– All Federal agencies must allow grantees to claim indirect cost rates.
– Grantees without an NIDCR can choose to accept a 10% de minimis rate.
For AmeriCorps grantees this becomes a 5%/5% option.
– Grantees with a current indirect cost rate may elect to apply for a one-time
extension for a period of up to 4 years.
– AmeriCorps grantees continue to be capped at 5% of CNCS share.
– AmeriCorps grantees that use the CNCS 5%/10% option and do not have an
NIDCR will see a decrease in the amount they can claim as match.
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Time and Activity
What’s Current: Nonprofit organizations must have a time-keeping system in
place that – Tracks time and activity on an after-the-fact basis that accounts for total time.
– Is signed by employee or supervisor.
– Is prepared at least monthly and coincides with one or more pay periods.
What’s coming: Time and activity can be supported by – A system of internal control which provides reasonable assurance that the
charges are accurate, allowable, and properly allocated.
– A system that is incorporated into the official records of the grantee.
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Rules around member time keeping remain the same.
IPERA
IPERA is the Improper Payment Elimination and Recovery Act. Under IPERA,
CNCS must determine if programs are susceptible to significant levels of
improper payments. CNCS is assessing the level of improper payments by
testing a randomly selected sample of individual payments charged to CNCS
funding by grantees (or sub-recipients, where applicable)
Challenges in submissions
Submissions are late and incomplete
General ledger does not match FFR amount
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State and National Symposium
IPERA
Discussion:
How do you determine what is recorded on your
FFR?
When would it be OK for the general ledger not to
match the FFR?
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State and National Symposium
What’s on Your Notice of Grant Award?
Review your NGA in eGrants as soon as you get it and make sure all these
elements are correct.
Legal Applicant
Program and Budget start and end dates
Award Description
Funding amounts:
New
Previous
Current
Unexpended
Total to date
Aggregate member data by type
Link to Provisions/Terms and Conditions
Special Conditions
Program and Grants Officer name and phone number
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Lessons Learned from Common Findings
• Procedures must be in place to verify that all costs are adequately
documented before entering any costs into the accounting system
• Grantees must have timesheets to support employees charging time
against the grant
• The amount reported on the FFR must match the amount recorded in
the general ledger. If it doesn’t for some rational reason, grantees
should be able to demonstrate why with a Reconciliation Report
• Required background checks must be conducted on grantee staff and
members
• Grantees should review their policies and procedures for monitoring their
sub-grantees to ensure they cover both programmatic and financial
requirements
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• Timesheets are signed by the employee and/or a supervisor
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• Payments must be well documented and have appropriate approval
Fixed Amount Grants
What is a Fixed Amount Grant?
• Grantees receive a specific amount per MSY and can
only access all of the funds if they recruit and retain 100%
of the members.
• There is no approved budget in the grant award.
• There are no specific restrictions on the use of the grant
funds because the amount of the grants will be
significantly less than the cost of conducting the program.
• The amount awarded is significantly less than the cost of
operating the program.
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State and National Symposium
Fixed Amount Grants
What are the advantages?
•
•
•
•
Cost Principles do not apply
No tracking or documentation of cost sharing is required
Budgets are not required during application process
Limited, if any, financial reporting to the Corporation is
required; the FFR (SF 425) is not required
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State and National Symposium
Fixed Amount Grants
What are the disadvantages?
The full amount of the grant can only be accessed if all
members complete their terms of service
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Fixed Amount Grants
What still applies?
• Administrative Requirements for Federal grants
• Single Audit Regulations
• All AmeriCorps member requirements
– Living allowance
– Citizenship
– Age
– Criminal history checks
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How Does CNCS Monitoring Fixed Grants?
Drawdown Analysis
• Grants officers cross-check enrollments against
drawdowns every six months.
• If grantees have drawn down more funds that they should
based on enrollments the grants officer will contact the
grantee to determine why and work with the grantee to
get back on track.
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State and National Symposium
Closing out your Fixed Amount Grant
Grants officers will compute the amount the grantee was allowed to
access based on data in the My AmeriCorps Portal and the HHS Payment
system. Example:
Program A is approved for 20 members at $13,000 per member, total $260,000.
17 members complete the term of service. The remaining five members served
lesser amounts as follows:
Member 18 completed 1125 hours: 1125 ÷ 1700 = 66% x $13,000 =
$ 8,580
Member 19 completed 458 hours:
458 ÷ 1700 = 27% x $13,000 = $ 3,502
Member 20 completed 920 hours:
920 ÷ 1700 = 54% x $13,000 = $ 7,020
Total Pro-rated Amounts:
Plus Completed Terms:
Final Grant Amount:
$ 19,102
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17 members x $13,000 =
$221,000
$240,102
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The grantee drew down $245,000 from the HHS system and owes CNCS
$4,898 at closeout.
How do Commissions Monitor Fixed Grants?
• Reimbursement based on members on board
• Other?
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State and National Symposium
Questions?
2014 AmeriCorps
State and National Symposium