Grant Award and Contract Accounting 1

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1
Grant Award and Contract
Accounting
2
Overview on Grants
• State Agencies are responsible for tracking both
State and Federal Grants for audit and reporting
purposes
• Agencies can utilize a 5 digit grant number to
record revenues and/or expenditures associated
with a grant when posting transactions in FLAIR
3
Overview on Grants
• There are no true “grant management” functions
provided in the accounting system:
1. Development and processing of cost allocations
2. Ability to systematically identify
eligible/ineligible activities, program outputs,
constraints on funding (i.e., match, MOE, etc)
4
Federal Grant Requirements
5
Federal Expenditures By State Agency- FY11/12
($40.6 Bil)
Expenditures by State Entity
AHCA
$10,442,441,990.0
0
30%
All Others
$8,055,954,270.00
23%
DCFS
$6,480,102,074.00
19%
AHCA
DCFS
DOE
DEO
DOT
DOH
All Others
DOH
$1,416,507,815.00
DOT
4%
$2,319,676,928.00
7%
DEO
$2,939,198,717.00
8%
DOE
$3,024,355,305.00
9%
6
Federal Grants
• Federal Grants are identified by a Catalog of Federal
Domestic Assistance (CFDA) number and Federal Grant
Reference number.
• General Federal Regulations are in
▫ OMB Circular A-102
▫ OMB Circular A-110
▫ OMB Circular A-133.
• Specific Grant Requirements can be found in the laws,
Code of Federal Regulation and the provisions of
contract or grant agreements pertaining to the program
7
Federal Grant Compliance Requirements for the
Grant Manager
• Monitoring of Allowed or Unallowed Activities for the grant
▫ Program requirements specify the activities that can or cannot be
funded under a specific program
▫ Example: CFDA 93.053 – Nutrition Services Incentive Program
(NSIP)
 State Agency may use funds for State Plan administration
 No nutrition services may be provided directly by the State
Agency
 The Area Agency on Aging (Area Agency) may use funds for plan
administration
 No nutrition services may be provided directly by an Area
Agency
 Service Providers may use funds to provide home-delivered
meals
8
Federal Grant Compliance Requirements for the
Grant Manager (continued):
• Adhering to Allowable Costs/Cost Principles
▫ OMB Circulars describe selected cost items, allowable and
unallowable costs and standard methodologies for
calculating indirect costs rates
 OMB Circular A-87 and OMB Circular A-21
• Optimizing Cash Management
▫ Minimize time elapsing between the drawdown of federal
funds and disbursement
▫ Comply with Florida’s Cash Management Improvement Act
(CMIA)
9
Federal Grant Compliance Requirements for the
Grant Manager (continued):
• Adhering to Eligibility Requirements
▫ Program requirements specify criteria for determining
eligible participants of the program
▫ Example: CFDA 93.053 – NSIP
 Eligibility for Subrecipients – Service Providers may
include profit-making organizations except that providers
of case management services must be public or non-profit
agencies
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Equipment and Real Property
Management
• The federal agency must provide disposition instructions for
real property that was acquired with federal awards and is no
longer needed for federally supported programs.
• Agencies must ensure that the title to equipment or real
property acquired with federal awards vests with the state
agency.
• Agencies will include the grant number on the applicable
property records for tracking/reporting purposes
11
Common Funding Requirements
• Matching –contribution of a specified amount or
percentage of non-federal funds to match the Federal
Award
• Level of Effort –provide specific level of service or
expenditures for a period of time where Federal funds
supplement and not supplant State funding of services
• Earmarking – specifies the minimum and/or maximum
amount or percentage of the program’s funding that
must be used for a specific activity
12
Period of Availability of Federal Funds
• When the funding period has been specified, only costs
resulting from obligations incurred during the funding period
specified and any authorized pre-award costs can be charged
to the grant.
▫ Example: CFDA 93.053 – NSIP
 Funds are awarded annually to the State and must be
obligated by the end of the Federal fiscal year in which
they were awarded.
 The State has an additional two years to liquidate the
obligations.
• Unless specifically authorized, all unobligated funds must be
refunded to the federal program.
13
Program Income
• Income is revenue received that is directly generated by the
federally funded program during the grant period.
• Unless specified, program income shall be deducted from
program expenditures
• Other specified uses of program income are:
▫ Add to program budget
▫ Meeting Match Requirements
• Example: CFDA 93.053 – NSIP
▫ Service Providers are required to provide an opportunity for
voluntary contributions from individuals being served
▫ These contributions must be used to expand the service from
they are collected
14
Reporting
• Recipients use standard financial reporting
forms as authorized by OMB
• Program outlays and income are reported on a
cash or accrual basis as prescribed by the
Federal awarding agency
15
Reporting (continued)
• The Federal Funding Accountability and Transparency
Act (FFATA) legislation requires information on federal
awards (federal financial assistance and expenditures) be
made available to the public via a single, searchable
website, which is www.USASpending.gov.
• The FFATA Subaward Reporting System (FSRS) is the
reporting tool Federal grants recipients use to capture
and report subaward and executive compensation data
regarding their first-tier subawards to meet the FFATA
reporting requirements.
16
Grant Reporting
• Schedule of Expenditures of Federal Awards (SEFA) –
OMB Circular A-133, Section .310(b)
▫ The schedule shall include:
 A list of the individual Federal programs by Federal
Agency
 The name of the State Agency(aka pass-through
entity) & identifying number assigned by the State
Agency
 The Total Federal awards expended for each Federal
program and the CFDA number
 Notes that describe the significant accounting
policies used in preparing the schedule
 The amounts provided to subrecipients from each
Federal program
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Sub-recipient Monitoring
• Any agreement for the sub-award of federal financial
assistance is subject to the rules applicable to the grant.
• Recipients must monitor sub-recipient activity to provide
reasonable assurance of compliance
▫ Example: CFDA 93.053 – NSIP
 State Agency develops policies to govern all aspects of
programs operated under the State Plan and monitors
their implementation.
 Area Agencies oversee the activities of service providers
with respect to services, reporting, and voluntary
contributions.
• Recipients must classify sub-recipients of a federal award
(Recipient Type Code).
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State Grant Requirements
19
State Expenditures by Agency – FY11/12
($1.3 billion)
AHCA
$110,208,341.51
8%
AHCA
DEO
DEP
DEO
$98,752,091.59
8%
DEP
All Others
$294,074,508.57
22%
$120,395,386.21
9%
DJJ
DOE
DOT
All Others
DOT
$411,454,934.46
31%
DOE
$197,185,231.13
15%
DJJ
$91,924,570.88
7%
20
State Financial Assistance Process
• The Single Audit Act of 1999, Section 215.97,F.S., Required
the Creation of the Catalog of State Financial Assistance
(CSFA) Numbers.
• For new appropriations, State agencies complete the State
Project Determination Check List to determine if the funds
will be classified as “state financial assistance”
• Department of Financial Services (DFS) will . . .
▫ Establish CSFA Numbers for “state financial assistance”
funds
▫ Identify the Type or Class of Financial Assistance for each
CSFA Number
▫ Create a Vendor vs. Recipient/Sub-recipient Checklist form
▫ Maintain the codes for identifying the types of organization
that is receiving state financial assistance (Recipient Type
Code)
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State Financial Assistance Process
• State Agencies record the CSFA number on appropriate
grant or contract in FLAIR. The grant and/or contract is
then recorded on applicable transactions.
• State Agencies are responsible for completing the
Vendor vs. Recipient/Sub-recipient Checklist for each
contract that is expending state financial assistance.
▫ If the Agency determines that the service provider is a subrecipient, then the provider will have to adhere to the singe
audit act reporting requirements and any specific grant
restrictions identified in the state project compliance
supplement, pursuant to Section 215.97
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Recipient and Sub-recipient
Requirements
• Must identify the State Agency that has provided
Financial Assistance and the appropriate CSFA
number.
• Audit Threshold – Must have expended more
than $500,000 in State Financial Assistance for
a fiscal year.
• When a State Agency provides state financial
assistance to a sub-recipient, the State Agency
must inform the sub-recipient of the Florida
Single Audit Act requirements.
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Grant Accounting
in FLAIR
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FLAIR Provides Three Functions for
Grant Management:
• Grant Information File
• Federal Catalog No. – Titles
• State Catalog No. – Titles
• Beginning in April 2014 FLAIR will provide limited
grant accounting information
25
Grant Information File
• Grant Information is established by each Agency and is
recorded at the agency’s operating level (OLO).
▫ Results in duplicate grant numbers across the agencies
and difficult to track grants that may cross agencies.
• Provides a limited number of fields for recording
information related to a grant.
• The Grant Information File is static in nature and can
not be used for grant management or cost accounting
functions.
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Grant Information File
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Recipient Type Code - FLAIR
Used to identify the type of organization that is receiving
state or federal financial assistance
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Other Grant Functionality
• Agencies use various field in FLAIR for tracking grant
expenditures and revenue.
▫
▫
▫
▫
Grant Number
Other Cost Accumulator
Contract Number
Project Number
• FLAIR provides Master Balance Files for Contracts,
Grants and Projects.
• The Master Balance Files provide Month to Date, Year to
Date and Life to Date totals.
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Other Grant Functionality (continued)
• Statewide Cost Allocation Plan (SWCAP)
▫ Authority/Guidance
 Section 215.195, Florida Statutes
 OMB Circular A-87 (now codified 2 CFR Part 225,
Appendix C, Appendix D, Appendix E)
• The SWCAP and the Agency Indirect Cost Rate Proposals are the
Federally approved methods that allow for the recovery of central
service costs related to Federal grants.
▫ Indirect Costs – Costs that are incurred by agencies for implementing
Federal programs. (Administrative functions)
▫ Central Service costs – Costs that can be allocated or billed to
agencies for services provided by an enterprise entity (i.e., State Data
Centers, State Purchasing, DFS Division of Accounting and
Auditing).
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Contracts
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Contracts
• During the 2011 Legislative Session, Section 215.985.
F.S. was amended (Chapter 2011-49 Laws of Florida)
requiring the CFO to implement a contract tracking
transparency website.
• The Department’s transparency system: Florida
Accountability Contract Tracking System (FACTS) was
implemented in June 2012
https://facts.fldfs.com/Search/ContractSearch.aspx
• Agencies are required to input their contract and grant
disbursement agreements into FACTS
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Contracts
• FLAIR provides nightly files for update of the validation
tables in FACTS for the following data elements:
▫ OLO
▫ Contract ID
▫ Vendor ID
▫ Commodity/Service Type
▫ CFDA/CSFA
▫ Recipient Type
• FLAIR also sends payment data associated with a valid
5-digit contract number to FACTS.
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Contracts (continued)
• FACTS sends contract records to FLAIR’s Contract
Information (CI) File. The CI file stores the following
data elements from FACTS:
▫ OLO
▫ Contract ID
▫ Short Title
▫ Long Title
▫ CFDA/CSFA (first occurrence, if multiple)
• FLAIR will add the Contract ID to the title files, allowing
agencies to use the Contract ID on FLAIR transactions.
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Contract Entry in FACTS
• State Agencies enter information for their active
contracts in FACTS via entry webpages:
▫ Add New Contract Agreement
▫ Add New Grant Disbursement Agreement
▫ Add Budgetary Funding of the contract/grant
agreement
▫ Add vendors/recipients/sub-recipients of the
contract/grant disbursement agreement
▫ Add deliverables of the contract/grant disbursement
agreement
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FACTS – Add New Contract Agreement
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FACTS – Add Grant Disbursement Agreement
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FACTS – Add Budget
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FACTS – Add Vendor Information
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FACTS – Add Deliverables
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