National Association
of HBCU Title IIII
Administrators 2015
Technical Assistance
Workshop
NATIONAL
ASSOCIATION OF
HBCU/TITLE III
ADMINISTRATORS,
INC.
Samuel T. Rhoades, J.D.
Virginia Union University
Special Assistant to the President/Title III Administrator
June 22-26, 2015
Hyatt Regency River walk
San Antonio, TX
Title III Purpose

Title III funds provides financial assistance to establish or
strengthen the physical plants, financial management,
and academic resources and endowments of
undergraduate HBCUs. Funds may be used for the: (1)
purchase, rental or lease of scientific or laboratory
equipment for educational purposes—instructional and
research; (2) construction, maintenance, and
renovation of instructional facilities; (3) faculty
development and exchanges; (4) purchase of
educational material; and (5) funds and administrative
management and acquisition of equipment for use in
strengthening management.
Activity Directors’ Responsibilities
BUT NOT LIMITED TO THE FOLLOWING:
•
Overall Management of the Activity
•
•
•
•
•
•
Fiscal and Programmatic Management
Activities Equipment Inventory
Requisitions and Compliance of University Policies and
Procedures
Internal/External Evaluation of Project Objectives
Maintain appropriate data
Submit Progress of Objective Attainment for Annual
Performance Report to be submitted to the
Department of Education by the deadline.
HBCU Title III
Phase I Formula Grant
•
Number of Pell Grant recipients attending the applicant
institution during the school year immediately preceding the
beginning of the fiscal year in which the applicant applies for a
grant.
•
Number of graduates of the applicant institution during the
school year immediately preceding the beginning of the fiscal
year in which the applicant applies for a grant. (34 CFR Section
608.4 defines “graduates” as a student who has attended an
institution for at least three semesters and fulfilled academic
requirements for undergraduate studies in not more than five
consecutive school years.)
•
Enter the total from Column B, Years1-5.
•
Enter the total from Column C. (Do not count a student
attending graduate school for more than one reporting year.)
Allowable Activities
•
•
•
•
Support of faculty exchanges, faculty development and
faculty fellowships to assist these faculty members in
attaining advanced degrees in their fields of instruction
Academic instruction in disciplines in which Black
Americans are underrepresented
Purchase of library books, periodicals, microfilm, and
other educational materials, including
telecommunications program materials
Purchase, rental, or lease of scientific or laboratory
equipment for educational purposes, including
instructional or research purposes
34CFR Section 608.10
Allowable Activities
•
•
•
•
•
Construction, maintenance, renovation, and
improvement in classroom, library, laboratory, and
other instructional facilities, including purchase or
rental of telecommunications, technology,
equipment or services
Tutoring, counseling, and student service programs
designed to improve academic success
Funds and administrative management, and
acquisition of equipment for use in strengthening
funds management
Joint use of facilities, such as laboratories and
libraries
Establishing or improving a development office to
strengthen or improve contributions from alumni
and the private sector
34CFR Section 608.10
Allowable Activities
•
•
•
Establishing or enhancing a program of teacher education
designed to qualify students to teach in a public elementary
or secondary school in the State that shall include, as part of
the program, preparation for teacher certification
Establishing community outreach programs that will
encourage elementary and secondary students to develop
the academic skills and the interest to pursue postsecondary
education
Other activities that it proposes in its application that
contribute to carrying out the purpose of this part and are
approved by the Secretary as part of the review and
acceptance of the application
34CFR Section 608.10
HBCU Specific Title III Funding
Declines Between FY 08-FY 15
Title III Top 20 FY 2014 Grantees HBCU Program
Grantee
Funding
Grantee
Funding
1. North Carolina A&T
$5,983,060
11. Winston-Salem State University
$4,029,365
2. Florida A&M University
$5,722,787
12. Virginia State University
$3,960,325
3. Morgan State University
$5,224,766
13. Alabama State University
$3,960,264
4. South University A & M College
$4,977,153
14. Fayetteville State University
$3,654,205
5. St. Phillip’s College
$4,938,961
15. Norfolk State University
$3,600,375
6. Jackson State University
$4,862,359
16. Elizabeth City State University
$3,560,283
7. North Carolina Central University
$4,327,505
17. Albany State University
$3,353,850
8. Prairie View A&M University
$4,325,851
18. Grambling State University
$3,274,746
9. Texas Southern University
$4,314,257
19.Savannah State University
$3,178,986
10. Tennessee State University
$4,081,010
20. South Carolina State University
$3,089,971
HISTORICALLY BLACK COLLEGES AND UNIVERSITIES (HBCU)
PROGRAM FY 2014 REGULAR AWARDS
#
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
STATE
NC
INSTITUTION NAME
North Carolina A&T State University
FL
FY 2014
AWARD
$5,983,060
#
27
Florida A&M University
$5,722,787
28
MD Morgan State University
$5,224,766
29
LA
Southern University A&M College
$4,977,153
30
TX
St. Philip's College
$4,938,961
31
MS
Jackson State University
$4,862,359
32
NC
North Carolina Central University
$4,327,505
33
TX
Prairie View A&M University
$4,325,851
34
TX
Texas Southern University
$4,314,257
35
TN
Tennessee State University
$4,081,010
36
NC
Winston-Salem State University
$4,029,365
37
VA
Virginia State University
$3,960,325
38
AL
Alabama State University
$3,960,264
39
NC
Fayetteville State University
$3,654,205
40
VA
Norfolk State University
$3,600,375
NC
GA
Elizabeth City State University
Albany State University
$3,560,283
$3,353,850
LA
Grambling State University
$3,274,746
GA
Savannah State University
$3,178,986
SC
South Carolina State University
$3,089,971
AL
Alabama A&M University
$3,077,055
GA
Fort Valley State University
MD Bowie State University
$3,057,936
$3,039,537
LA
Southern University - Shreveport
$2,985,560
AR
University of Arkansas - Pine Bluff
$2,904,248
MS
Alcorn State University
$2,894,512
41
42
43
44
45
46
47
48
49
50
51
52
53
STATE
INSTITUTION NAME
FY 2014
AWARD
DC
University of the District of Columbia
$2,869,410
FL
Bethune Cookman College
$2,705,381
AL
Lawson State Community College
$2,699,915
SC
Benedict College
$2,630,384
MD
Copping State University
$2,574,762
MD
University of Maryland - Eastern Shore
$2,559,290
FL
Florida Memorial University
$2,548,030
KY
Kentucky State University
$2,500,812
GA
Clark Atlanta University
$2,475,192
SC
Denmark Technical College
$2,448,800
LA
Xavier University (LA)
$2,446,046
VA
Hampton University
$2,332,052
LA
Southern University at New Orleans
$2,310,798
TN
Lane College
$2,310,340
MS
Mississippi Valley State University
$2,309,929
MO
Lincoln University (MO)
$2,263,854
NC
Shaw University
$2,232,719
GA
Morehouse College
$2,211,380
DE
Delaware State University
$2,201,959
MS
Tougaloo College
$2,178,881
AL
Tuskegee University
$2,174,513
MS
Coahoma Community College
$2,150,100
GA
Spelman College
$2,081,987
OK
Langston University
$2,080,860
NC
Livingstone College
$2,039,357
DC
University of the District of Columbia
$2,869,410
FL
Bethune Cookman College
$2,705,381
HISTORICALLY BLACK COLLEGES AND UNIVERSITIES (HBCU)
PROGRAM FY 2014 REGULAR AWARDS
FY 2014
AWARD
# STA
INSTITUTION
54
TE
NAME
$1,979,346
55 OH Central State University
NC
Johnson
C.
Smith
University
$1,965,586
56
$1,965,127
57 AL Bishop State Community
College
Main
TX
Huston-Tillotson
University
$1,924,095
58
$1,895,769
59 PA Lincoln University (PA)
AL
Miles
College
$1,812,036
60
WV
West
Virginia
State
$1,786,475
61
University
University
$1,783,625
62 SC Clafin
VA
Virginia
Union
University
$1,669,422
63
$1,666,461
64 AR Philander Smith College
AL
Oakwood
College
$1,660,387
65
GA
Paine
College
$1,649,711
66
$1,621,346
67 PA Cheyney University of
Pennsylvania
MS
Rust
College
$1,611,943
68
$1,609,699
69 LA Dillard University
VI
University
of
the
Virginia
$1,593,256
70
SC
Islands
Morris
College
$1,580,950
71
$1,574,171
72 TX Wiley College
NC
Saint
Augustine's
College
$1,573,112
73
$1,567,978
74 SC Voorhees College
WV
Bluefield
State
College
$1,567,683
75
MO
Harris
Stowe
State
University
$1,493,594
76
$1,485,198
77 NC Bennett College
MS
Hinds
Community
College
$1,466,107
78
Utica University
$1,421,202
79 SC Allen
TN
Fisk
University
$1,414,071
80
OH Central State University
$1,979,346
#
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
STATE
TX
AL
TN
FL
AL
AL
AL
AL
TN
TX
OH
AR
TX
AL
AL
AL
VA
AR
SC
TX
INSTITUTION
NAME
Jarvis Christian College
Talladega College
Lemoyne Owens College
Edward Waters College
Trenholm State Technical
College
J. F. Drake State Technical
College
Stillman College
Shelton State Community
College - Fredd
American
Baptist College
Texas College
Wilberforce University
Arkansas Baptist College
Paul Quinn College
Concordia College
Bishop State Community
College - State
CarverCommunity
Gadsden
College University of
Virginia
Lynchburg
Shorter
College
Clinton Junior College
Southwestern Christian
College
Total Allocation
FY 2014
AWARD
$1,381,048
$1,375,512
$1,274,364
$1,233,708
$1,199,027
$1,178,351
$1,169,221
$1,162,490
$1,137,978
$1,102,163
$1,091,591
$1,084,533
$1,065,295
$1,023,691
$500,000
$500,000
$500,000
$250,000
$250,000
$250,000
$223,783,000
HISTORICALLY BLACK COLLEGES AND UNIVERSITIES (HBCU) PROGRAM
FY 2014 MANDATORY AWARDS
STATE
NC
FL
MD
LA
MS
TX
NC
TX
TX
TN
NC
AL
VA
NC
NC
VA
GA
LA
GA
SC
AL
GA
MD
AR
LA
MS
DC
FL
AL
SC
MD
MD
INSTITUTION NAME
North Carolina A&T State University
Florida A&M University
Morgan State University
Southern University A&M College
Jackson State University
St. Philip's College
North Carolina Central University
Prairie View A&M University
Texas Southern University
Tennessee State University
Winston-Salem State University
Alabama State University
Virginia State University
Elizabeth City State University
Fayetteville State University
Norfolk State University
Albany State University
Grambling State University
Savannah State University
South Carolina State University
Alabama A&M University
Fort Valley State University
Bowie State University
University of Arkansas – Pine Bluff
Southern University – Shreveport
Alcorn State University
University of the District of Columbia
Bethune Cookman College
Lawson State Community College
Benedict College
Copping State University
University of Maryland - Eastern Shore
FY 2014
AWARD
$1,635,348
$1,586,753
$1,493,914
$1,463,043
$1,421,445
$1,411,106
$1,300,828
$1,297,907
$1,295,952
$1,248,807
$1,235,453
$1,229,847
$1,227,485
$1,173,035
$1,159,709
$1,151,596
$1,108,659
$1,081,699
$1,066,336
$1,046,584
$1,040,312
$1,038,751
$1,036,825
$1,018,510
$1,013,785
$1,010,281
$992,171
$962,566
$952,774
$950,659
$941,142
$934,545
STATE
KY
LA
GA
SC
TN
MS
LA
VA
MO
MS
NC
GA
AL
DE
MS
OK
GA
NC
TX
NC
OH
AL
PA
AL
WV
SC
AR
GA
VA
AL
AL
AL
AL
INSTITUTION NAME
Kentucky State University
Xavier University (LA)
Clark Atlanta University
Denmark Technical College
Lane College
Mississippi Valley State University
Southern University – New Orleans
Hampton University
Lincoln University (MO)
Tougaloo College
Shaw University
Morehouse College
Tuskegee University
Delaware State University
Coahoma Community College
Langston University
Spelman College
Livingstone College
Huston-Tillotson University
Johnson C. Smith University
Central State University
Bishop State Community College - Main
Lincoln University (PA)
Miles College
West Virginia State University
Clafin University
Philander Smith College
Paine College
Virginia Union University
Oakwood College
J. F. Drake State Technical College
Shelton State Community College - Fredd
Stillman College
FY 2014
AWARD
$927,252
$922,946
$917,297
$910,812
$892,470
$887,671
$886,668
$882,621
$877,037
$874,612
$870,951
$867,450
$857,612
$854,207
$844,145
$839,076
$837,509
$828,464
$818,899
$816,427
$814,028
$802,291
$800,337
$782,497
$771,368
$769,646
$761,174
$755,240
$754,181
$744,151
$500,000
$500,000
$500,000
HISTORICALLY BLACK COLLEGES AND UNIVERSITIES (HBCU) PROGRAM
FY 2014 MANDATORY AWARDS
STATE
AR
FL
LA
MO
MS
MS
NC
NC
OH
PA
SC
SC
SC
TN
TN
TN
TX
TX
TX
TX
VI
WV
AL
AL
AL
AR
SC
TX
VA
INSTITUTION NAME
Arkansas Baptist College
Edward Waters College
Dillard University
Harris Stowe State University
Hinds Community College - Utica
Rust College
Bennett College
Saint Augustine's College
Wilberforce University
Cheyney University of Pennsylvania
Allen University
Morris College
Voorhees College
American Baptist College
Fisk University
Lemoyne Owens College
Jarvis Christian College
Paul Quinn College
Texas College
Wiley College
University of Virgin Islands
Bluefield State College
Bishop State Community College Carver
Concordia College
Gadsden State Community College
Shorter College
Clinton Junior College
Southwestern Christian College
Virginia University of Lynchbury
Total Allocation
FY 2014
AWARD
$500,000
$500,000
$500,000
$500,000
$500,000
$500,000
$500,000
$500,000
$500,000
$500,000
$500,000
$500,000
$500,000
$500,000
$500,000
$500,000
$500,000
$500,000
$500,000
$500,000
$500,000
$500,000
$250,000
$250,000
$250,000
$250,000
$250,000
$250,000
$250,000
$78,880,000
Title III Part B, Strengthening Historically Black
Colleges And Universities Program
Conclusion
•
Strong financial systems are critical to properly administer
grants
•
Internal controls are needed to assess the University’s strengths
and weaknesses
•
Ongoing training/technical assistance should be provided for
Staff
•
Policies and Procedures are updated as needed
•
Develop and/or strengthen a continuation and sustainability
strategy that leads to new revenue streams to support
program activity viability.
CRAB MENTALITY


Crabs in a bucket can easily escape from the bucket one at a time, but
instead of doing that they pull each other down whenever one rises to the
top - thus insuring their collective demise.
This is analogous to the behavior of a person who diminishes or pulls down
anyone else who achieves or is about to achieve success greater than their
own.
Crab mentality: We all like to see our friends get ahead, but not too far
ahead.
If I can't have it, no one can have it.
When All Else Fails!
Contact
Government Accountability Office
441 G. Street, NW
Mail Stop 4T21
Washington, D.C. 20548
(202) 512-3000
Office of Inspector General
Department of Health and Human Services
Attn: Hotline
P.O. Box 23489
Washington, D.C. 20026
NATIONAL
ASSOCIATION OF
HBCU/ TITLE III
ADMISTRATORS,
INC.
Uniform
Guidance
Federal Register
Uniform Guidance
Federal Register



To deliver on the promise of a 21st-Century government that is
more efficient, effective and transparent, the Office of
Management and Budget (OMB) is streamlining the Federal
government's guidance on Administrative Requirements, Cost
Principles, and Audit Requirements for Federal awards. The
modifications are a key component of a larger Federal effort to
more effectively focus Federal resources on improving
performance and outcomes while ensuring the financial
integrity of taxpayer dollars in partnership with non-Federal
stakeholders.
The guidance provides a government-wide framework for
grants management, which will be complemented by
additional efforts to strengthen program outcomes through
innovative and effective use of grant-making models,
performance metrics, and evaluation. The reform of OMB
guidance will reduce administrative burden for non-Federal
entities receiving Federal awards.
The final guidance supersedes and streamlines requirements
from OMB Circulars A-21, A-87, A-110, and A-122 (which have
been placed in OMB guidance); Circulars A-89, A-102, and A133; and the guidance in Circular A-50 on Single Audit Act
follow-up.
Uniform Guidance
Federal Register
 The
goal of this reform is to deliver on the
President's directives to (1) streamline our
guidance for Federal awards to ease
administrative burden and (2) strengthen
oversight over Federal funds to reduce
risks of waste, fraud, and abuse.
 Streamlining existing OMB guidance will
increase the efficiency and effectiveness
of Federal awards to ensure best use of
the more than $500 billion expended
annually.
Uniform Guidance
Key Issues for Universities
The single biggest regulatory change in the last 50-years of
research administration. Final rule December 26, 2014.
 Outline of Uniform Guidance
Subpart A – Acronyms and Definitions
Subpart B - General Provisions
Subpart C – Pre-Federal Award Requirements and Contents of
Federal Awards
Subpart D – Post- Federal Award Requirements
Subpart E – Cost Principles
Subpart F – Audit Requirements
Appendices I-XI

Uniform Guidance
200.430 Compensation
Personal Services
 Section
(h) is specific to Higher Education –
Identifies special conditions for: Allowable
Activities, Incidental Activities, Extra Service
Pay, Periods outside the academic year, etc.
 Section (i) is Standards for Documentation of
Personnel Expenses. Charges must reflect
actual work performed and records must be
supported by internal controls and officially
recorded.
Uniform Guidance
200.430 Next Steps
Effort Issues
 Where
do we go from here?
1. Evaluate your current process/system and
potential new systems – (i) Standards for
Documentation
2. Review current system in light of Internal
Control standards. How strong are your
written policies?
3. Evaluate options for change.
Uniform Guidance
What Should I (We) be Doing?
1.
2.
3.
4.
5.
6.
Council on Financial Assistance Reform:
https://cfo.gov/cofar/
Follow the Federal Register and Agency
implementation plans
Pay close attention to advice from your
professional associations
By now, institutions should have a “Point of
Contact” and Plan
Leverage many in the Institution Plan: Project
Directors, all levels of Administration, IT, and your
experts from Purchasing, Payroll, etc.
Start/Continue to develop your Institution via training.
NATIONAL
ASSOCIATION OF
HBCU/ TITLE III
ADMISTRATORS,
INC.
Audit Readiness
& Preparedness
Audit Readiness & Preparedness



When an organization receives Federal education funds,
it assumes certain responsibilities along with those funds.
“Audit Readiness” is a natural by product of the proper
execution of these responsibilities.
A recipient of Federal education funds can expect to
reduce instances of audits that result in findings of
material noncompliance if the overall management
assumed with the funds are carried out properly.
Thus audit readiness occurs when the recipient of
Federal education funds is prepared to undergo an
audit which will disclose that funds are used properly.
Audit Readiness & Preparedness

The Audit or Site Visit is an independent evaluation of:
•
•
•
•
•
Internal Controls (Fiscal, Program)
Management Systems
Policies and Procedures (established by law, regulations,
and/or grantee)
Accountability
Compliance (law, regulations, approved application)
Audit Readiness & Preparedness

What is the purpose of an Audit or Site Visit?
•
To assure that federal funds are being expended within
the provisions of all applicable laws and regulations
•
To assess the progress that is being made in achieving
stated project goals and objectives
•
To provide technical assistance
•
To identify exemplary practices (may not be considered
during an audit)
NATIONAL
ASSOCIATION OF
HBCU/ TITLE III
ADMISTRATORS,
INC.
Writing
Measurable
Objectives
Writing Measurable Objectives

Objectives describe the major ways the project is expected to
impact your goals and the university’s needs. Objectives
should be stated in measurable terms; note the SMART
concept for writing objectives:
 Specific



Measurable
Attainable
Realistic/Reasonable

Time-Bound
Writing Measurable Objectives
When establishing objectives, note the following:

•
How are you going to accomplish the objectives of the program?
•
What quantitative and qualitative methods will you have in place to
monitor the success of your program?
•
On-going monitoring of the program is required to determine that
objectives are being achieved.
•
Frequent self-evaluations enable timely corrections and adjustments if
parts of the program are proving to be ineffective. Title III Directors’
should consider Activity Directors to submit quarterly progress reports as a
method to help monitor activities and alleviate potential fiscal and
programmatic problems.
Writing Measurable Objectives

Sample Objectives:
1)
To ensure that a minimum of twenty (20)
undergraduate students in the College of Arts and
Sciences (Departments of Sociology, Social Work,
Criminal Justice and Psychology) will develop
research skills by collaborating with faculty mentors
to engage in community-based research, each
academic year (Baseline: 10).
Writing Measurable Objectives

Sample Objectives:
2)
To strengthen the University’s one-year retention rate by 1%
annually, yielding at least an 80% retention rate by
September 2012, through the implementation of academic
intervention services that reduce DFWs (Baseline: 69%).
3)
To increase sponsored programs productivity for the entire
University by increasing submissions by 5% annually (Baseline:
25).
NATIONAL
ASSOCIATION OF
HBCU/ TITLE III
ADMISTRATORS,
INC.
Record Keeping
&
Documentation
Record Keeping & Documentation
 The
U.S. Department of Education requires the
University to keep records that show the
amount of funds under the grant, how the
grant funds were used, the total cost of the
project, share of cost provided from other
sources, and other records to facilitate an
effective audit.
34CFR Part 74 Section 74.50 Purpose of Reports
and Records
Record Keeping & Documentation
Records to Retain for Audit Purposes and Internal/External
Evaluations (Financial and Program)









Budget reporting forms
Budget Revisions
Worksheets (including
Departmental Transfers)
Quarterly reports of
progress
Telephone conversation
records
Emails
Equipment inventory forms
Contracts
Registration forms and
other documents from
faculty development and
training activities
Time & Effort Reports
Personnel Action Forms and other
employment information (including
vita, application forms, and
affirmative action forms)
Consultant’s reports
Purchasing requisitions
Travel reports
Released time reports
Evaluation reports
Workshops/Workshop evaluations
Documents showing progress toward
achieving objectives
NATIONAL
ASSOCIATION OF
HBCU/TITLE III
ADMINISTRATORS,
INC.
Travel Policies
& Procedures
Travel Policies & Procedures
Meals and Incidentals

Meals and incidental travel expenses are reimbursable only for
overnight official business travel outside the traveler's official
station. Reimbursement for expenses will be reimbursed on a per
diem system. Per Diem rates are adjusted to accommodate for
travel days and meals that are included in the conference
registration cost.
Lodging

The University will reimburse actual expenses up to a daily maximum
rate plus taxes and surcharges. If approved, rates can be no higher
than the standard rate for your particular location.
Travel Policies & Procedures
Registration Fees

Travelers can cover registration costs by one of the
following options: I) Pay in advance and seek
reimbursement upon return with a paid receipt; or 2)
Request a University check. When choosing the latter
option, attach a copy of the original registration form to the
travel request.
Other Business Expenses

Anticipated charges for business-related Internet charges,
must be itemized on the travel request under “Other".
Travel Policies & Procedures
Mileage

Personal vehicle usage must be approved, in advance, by Facilities
Management and the approval must be attached to the
reimbursement voucher.
Car Rental

Title III will only approve rental care expenses. Title III will only
approve rental car expenses when the traveler can demonstrate in
writing that this mode of travel is more economical than utilizing
other transportation. Car rental must be secured through an
authorized vendor and the original receipt must be attached to the
reimbursement voucher.
Travel Policies & Procedures
Foreign Travel

Title III restricts all out-of-the-country travel. All exceptions must be
justified and approved by the U.S. Department of Education
Program Officer.
Reimbursements for Approved Travel

After the travel has taken place prepare a Travel Reimbursement
Voucher. To the voucher, attach receipts for taxi fares, hotel
accommodations, fees, and other reimbursable expenses. Receipts
are not required for meals. Submit package for approval. A copy
of the conference itinerary and registration form must accompany
the voucher as well.
Travel Policies & Procedures
Report on Travel with Title III Funds
 Person(s)
whose travel expenses are paid
by the Title III grant are required to
complete a "Report on Professional
Meetings” form. This document should be
maintained with the Activity’s office files.
Travel Policies & Procedures


Travel with Title III funds is allowable only for travel
expenses identified in the approved grant application.
Changes in approved travel must be justified. Travel
that is not identified in the approved application
requires approval by the Title III Office.
Approval for Travel
Title III personnel who travel with grant funds must submit
a travel request to the Title III Office no less than thirty
days prior to the actual travel date. Travel expenses
must be limited to only those expenses that are
necessary for providing essential services to the
University.
E-CFR Section 200.474 Travel Costs
NATIONAL
ASSOCIATION OF
HBCU/TITLE III
ADMINISTRATORS,
INC.
Spending Plan
Using Federal
Funds &
Personal
Overhead
Personnel Overhead

All regular University hiring procedures will be followed in the hiring of
personnel for the Title III grant. The following procedures should be used to fill
Title III positions:
 Activity completes the appropriate personnel recruitment forms, as
required by Human Resources, and forwards the completed form to
the proper offices for approval. (Note: Federal regulations require
that the Title III Office signs all documents.)
 Human Resources should advertise position via requested media.
 Human Resources review all applications and refers to the
supervisor only those that meet the qualifications for the position
advertised.
 Activity Director interviews the prospective employees. (Note: No
applicant should be interviewed before the first three steps have
been taken.)
 After a potential employee has been selected, Human Resources
completes a
Personnel Action form and forwards it to the
proper offices for approval.
Personnel Overhead

The Title III Office must have all the credentials of all persons
hired with Title III funds. A copy of the employee's
employment vita or resume will serve this purpose. When
employees leave or are replaced for any reason, the Title III
Office must be informed immediately. Copies of
correspondence, resignation letters and appropriate
Human Resources forms will serve this purpose.
Time and Effort Reports

The U.S. Department of Education requires documentation
of time spent working on Title III activities by all persons
wholly or partially paid with Title III funds. Employees should,
therefore, complete the monthly Time & Effort Report and
submit it to the Title III Administrator. The Time & Effort
Report must be signed by the Department Head/Dean,
Activity Director, and the Title III Coordinator.
Personnel Overhead

For all Title III positions, there must be a search
procedure to ensure that the hiring of persons
supported by Federal funds is in compliance with all
applicable Federal regulations and is within the
framework of the Title III Plan of Operation and
budget. Documentation for personnel management
is essential and should be kept according to the
guidelines that follow.
Hiring of Personnel

Personnel are to be hired in a nondiscriminatory
manner according to the provisions of The Faculty
and Staff Handbook. Also, maintain on-file a job
description and copy of resumes of persons selected
for Title III vacancies.
Personnel Overhead
Time and Effort Reporting

The standards for documentation of personnel costs
charged to the grant are set forth in the Education Division
General Administrative Regulations (EDGAR) Part 74
Administration of Grants Subpart Q Cost Principles Section
74.174 Part IIB which provides that:

“The costs of such remuneration are allowable
to the extent that the total compensation to individual
employees is reasonable for the services rendered and
conform to the established policy of the institution
consistently applies and provided that the charges for work
performed directly on Government Research
Agreements….are determined and supported as herein
provided.” 45CFR 100, Appendix C. Section J.7d.
Spending Plan Using Federal Funds




Title III funds may be spent only on activities that are
included in the approved application.
The application must give a description of the activities to
be carried out; and it must show how grant funds will be
used to supplement, and to the extent possible, increase
the funds that would otherwise be made available for the
activities to be carried out in the grant.
In no case may Title III funds take the place of funds that
would otherwise be available.
For each proposed activity, applicants must prepare a
separate, detailed itemized budget (in dollars) and a
budget narrative for each year you are requesting grant
funds. Demonstrate and justify that all costs are reasonable
in today’s market and necessary to accomplish your
activity objectives.