FEDERAL GRANT MANAGEMENT
Federal Programs Directors’ Workshop
March 13, 2014
WVDE Office of Federal Programs
LOOKING TO THE HORIZON
2
OMB Super Circular
• Combines multiple Federal regulations that
currently govern the way grants are
administered into a single, comprehensive and
streamlined uniform policy guide
3
Objectives
• To strengthen accountability for Federal
dollars by improving policies that protect
against waste, fraud, and abuse.
• To increase the impact and accessibility of
programs by minimizing time spent complying
with unnecessarily burdensome
administrative requirement and focus on
program objectives.
4
How Does This Impact Us?
• The Super Circular consolidates eight OMB
Circulars. Those having a direct impact on
SEAs and LEAs are:
– Circular A-102 Administrative Regulations
– Circular A-87 Cost Principles
– Circular A-133 Audit Requirements
• The Circular did not entirely change the eight
regulations but there are notable differences.
5
Important Changes
•
•
•
•
Cost Principles
Time and Effort
Audit Rules
Pass-Through Entities
6
Cost Principles
• Can extend indirect cost rates for up to four
years
• Allows an flat indirect cost of rate 10%
• Requires pass-through entities to either
negotiate an indirect cost rate or provide the
minimum flat rate
7
Time and Effort
• Now called “Documentation of Personnel
Expenses”
• Documentation is still dependent on the
number of costs objectives worked on
• Eliminates the reference to PARs (now
“Certified Reports”)
• Reports may be electronic
• Certification periods cannot exceed 12 months
8
Audit Rules
• Increases the single audit threshold from
$500,000 in Federal expenditures to $750,000
– This will reduce costs by reducing the number of
single audits
• Changes the determination of which programs
to include in the single audit
– This may impact how many programs are selected
for audit
9
Audit Rules
• The number of compliance areas required to
be audited has been reduced
– Should reduce audit time and cost
– Shifts the burden from auditor to pass-through
entity
10
Pass-through Entities
SEA’s Responsibility:
• Sub-recipient risk assessments/monitoring
• Must give sub-recipients the option of either a
negotiated or flat 10% indirect cost rate
11
Sub-recipient Monitoring
• Risk Based Assessment Focused on:
– Results of previous audits
– Personnel Turnover
– Financial Stability
– History of Program Performance
12
Our Monitoring Requirements:
• Analyze financial and program data
• Ensure timely and appropriate corrective
action is taken regarding any single audit
program findings or prior monitoring findings
13
What Now?
• The Super Circular is effective Dec. 26, 2013 at
the Federal level
• Federal Agencies have one year to implement
their policies and procedures
• Existing Federal awards will continue to be
governed by the old circulars
• Administrative requirements and cost
principles will apply to new awards and
additional funding made after Dec. 26, 2014
14
Resources
• The Super Circular in its entirety can be found
at:
– http://www.gpo.gov/fdsys/pkg/FR-2013-1226/pdf/2013-30465.pdf
• Consolidated Monitoring Information
– http://wvde.state.wv.us/federalprograms/esea/monitoring-procedures.html
15