FEDERAL GRANT MANAGEMENT
Federal Programs Directors’ Meeting
March 12, 2014
WVDE Office of Federal Programs
Melanie Purkey
Robert Crawford
Laura Pauley
Overview
• Legal Structure/Resources
• Fiscal Potpourri
– Procurement
– Inventory Management
– Time and Effort
– Tracking Budget Expenditures
– Carryover/Period of Availability
– Maximizing Federal Funds
2
Legal 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
3
Grants 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_20_10_31.
html
• Education Department General Administrative Regulations
(EDGAR):
http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html
4
Grants 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
5
What 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.
Requirements…State & Local Gov.
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Fiscal Potpourri
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Procurement 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.
8
Procurement Polices and
Procedures
• WVDE Purchasing Policies and Procedures
Manual for Local Educational Agencies--WVBE
Policy 8200: http://wvde.state.wv.us/policies
9
Inventory Management
Inventory items purchased with federal funds
are divided into three categories:
• Real Property (if an allowable program cost)
• Equipment
• Supplies
10
Inventory 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
11
Inventory 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
12
Inventory Management
Practical help for tracking non-equipment items
• Small and attractive item list
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•
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Conduct risk assessment to identify items susceptible
to loss
Implement specific measures to control such items
Certain pre-defined assets (technology equipment)
13
Inventory Management
• Equipment inventory updated annually
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–
–
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–
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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)
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Inventory 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
15
Inventory 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
16
Time 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
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Time and Effort
• Type of documentation depends on how many
“cost objectives” the employee worked on
• These cost objectives must be connected to
the employee’s 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
Time 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
Time 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
Time and Effort
• “Flexible Certification” can be filed semiannually if the following conditions are met:
– Employee’s 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
21
Time 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
Time 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
employee’s established schedule
23
Time 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
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Tracking Budget Expenditures
• Total composite budget
• Administrative budget
• Individual school budgets
http://wveis.k12.wv.us/schoolFinance/sf000002.cf
m
Carry 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.
Carry Over
• An LEA has significant discretion in handling its Title I
carryover funds.
1. Funds may be added to the LEA’s subsequent year’s allocation and
redistributed to participating schools in accordance with normal allocation
procedures – decreasing amount of allocation based on highest to lowest
poverty. *
2. Funds may be added to the LEA’s subsequent year’s allocation and
redistributed to participating schools equitably based on a per pupil amount
times the number of low income students in each school. *
3. 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.
Period 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
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Definition 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
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Liquidations
• 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
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Maximizing Federal Funds
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Obligate oldest funds first
Maintain clear accounting records
Continually monitor budget vs. actual
Know your carryover and liquidation rules
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Maximizing Federal Resources in a
Changing Education Environment
Maximizing 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:
Realizing 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?
- 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
Operationalizing
-
Application Process
Revision of Monitoring
Title I Plan
Resources: Toolkit & The Changing Landscape
- 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