Federal Grant Management
FEDERAL PROGRAMS WORKSHOP
JULY 21, 2010
JAN STANLEY, STATE TITLE I DIRECTOR
Legal Structures for Federal Programs
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 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
Federal Grants Management Resources
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 Program Guidance: www.ed.gov
 Statutes
 Regulations
 Guidance
 General Education Provisions Act (GEPA):
http://www.law.cornell.edu/uscode/20/usc_sup_01_20_1
0_31.html
 Education Department General Administrative
Regulations (EDGAR):
http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html
Federal Grants Management Resources
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 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
What Rules Apply to Utilizing Federal Funds?
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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
 Section 80 of EDGAR
Who or What is EDGAR?
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Education Department
General Administrative Regulations (EDGAR)
Financial Management Requirements
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All grantees and
sub grantees must
implement the
requirements and
maintain systems
that meet specific
requirements of
EDGAR.
Financial Management Requirements
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EDGAR Section 76
o Eligibility to receive subgrants
o Distribution of funds by formula or competitive
o Private faith-based organizations eligible to receive
funds
o State consolidated grant application to ED
o Assurance statements
o Ability for the SEA to reallocate funds based on
specific federal program
Financial Management Requirements
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EDGAR Section 76 (continued)
o LEA grant application and budget approved by the SEA
o
o
o
o
prior to the issuance of a grant and the expenditure of
funds
Approval process
SEA must provide a grant award that indicates the amount
of the subgrant, obligation period and any requirements
that apply to the specific federal program (scope and
conditions)
Consultation with and services for private school students
Application guidelines for private schools
Financial Management Requirements
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EDGAR Section 76 (continued)
o Calculation and approval of indirect cost rates
(restricted)
o Coordination of the federal funds with other
programs that serve the same populations
(Braiding of funds Title I, Title II and Title III)
o Program evaluations and fiscal audits
o SEA and LEA reporting requirements
Financial Management Requirements
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Section 80 of EDGAR
Specific regulations governing three threshold
systems:
Financial Management
Procurement
Inventory
General Principles
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 In general, the SEA and
the LEA must
implement controls
over federal funds.
 ED looks to “systems,”
not individuals, to
ensure funds are spent
appropriately.
Financial Management
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 Definition-controlling and accounting for federal
funds and assets


Used to make informed programmatic decisions
Used to substantiate and document expenditures
 Seven standards described in Section 80.20(b)of
EDGAR
Financial Management
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Seven Requirements:
 Financial Reporting
 Accounting Records
 Internal Control
 Budget Control
 Allowable Cost
 Source Documentation
 Cash Management
Budget Controls
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
Pre-award planning process and technical assistance developing and approving budgets

Communication between fiscal and program staff at the SEA
and LEA levels

Routine reconciliation to actual expenditures at the SEA and
LEA levels
Allowable Cost Controls
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Program Regulations



Formal procedures or statue relating to costs
Guidelines for determining allowable costs
(OMB Circular A-87, EDGAR)
Access to helpful resources and program guidance
Financial Management
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Obligation
 Obligation-transaction that requires payment
 Valid obligation–transaction giving rise to an
obligation within the period of grant availability
Financial Management
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Obligation=transaction that requires payment
Acquisition of property
Date of binding or written
commitment – PO or contract
Personal services by
employee
After services are
performed
Personal services by
contractor
Date of binding written
commitment
Travel
After travel is taken
Financial Management
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In some programs, unobligated funds can be “carried over”
from first year
 Tydings Amendment


Does not apply to all grants
Allows extra year to obligate funds
 Under Tydings, funds are available for 24-27 months


15 months under the grant award
Plus 12 months
• Restricted to a 15% carryover for Title I Part A and Title II
Financial Management
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Liquidation



Liquidation–settle an obligation by paying funds
All obligations must be liquidated within 90 days
after the end of the obligation period.
SEA may impose a shorter deadline on sub
grantee.
Procurement Procedures
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 General procurement procedures are found in
EDGAR and some are found in the individual federal
program statute
 Follow State’s procurement procedures
 State Board Policy 8200
 Purchasing Policies and Procedures Manual
Procurement Procedures
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 Consider purchases based on the following considerations:



Allowable by the specific program
Reasonable
Necessary for the administration and/or implementation of the grant
 Review all proposed purchases to avoid unnecessary or
duplicative items




Surplus property
Structure procurement to obtain most economical purchase
Intergovernmental agreement for common goods or services
Lease vs. purchase
 Conduct all transactions with full and open competition –
be cognizant of conflict of interest
Procurement Procedures
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
Contracted Services
Contract should include clearly defined deliverables and terms









Description of services to be performed or goods to be delivered
Description of dates when services will be performed or goods delivered
Description of locations where services will be performed or goods
delivered
Description of number of students/teachers/etc. to be served (if applicable)
Remedies for breach of contract-sanctions and penalties
Termination procedures
Compliance with federal statues – see §80.36(i)(3-6) of EDGAR
Reporting procedures (if applicable)
Requirements pertaining to copyrights
Procurement Procedures
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Contracted Services

Must have written invoice from the individual or company
contracted
Description of services performed or goods delivered
 Description of dates services were performed or goods delivered
 Description of location services were performed or goods delivered
 Description of students/teachers/etc. served (if applicable


Invoice should be reviewed & approved before payment
Segregation of duties/expenditures
 Documented approvals

Inventory Management
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Inventory items purchased with federal funds are
divided into three categories:
 Real Property (if an allowable program cost)
 Equipment
 Supplies
Inventory Management
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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
Inventory Management
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 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 subgrantees to track all property purchased
with federal funds, in order to prove there has been a
benefit to the federal program

Inventory Management
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Practical help for tracking non-equipment items
 Small and attractive item list



Conduct risk assessment to identify items susceptible to
loss
Implement specific measures to control such items
Certain pre-defined assets (technology equipment)
Inventory Management
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 Equipment inventory-updated annually
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
 Indicate signature of individual(s)
Inventory Management
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 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
Inventory Management
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 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
Closing Thoughts…...
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EFFICIENCY IS DOING THE THING RIGHT.
EFFECTIVENESS IS DOING THE RIGHT THING.
–
PETER F. DRUCKER