Financial Compliance Issues
More Than You Ever Wanted to
Know
About
Administrative Costs
Leveraged Resources
Accrued Expenditures &
Unliquidated Obligations
MoHealthWINs TAACCCT Grant
Prepared by the OTC Finance Office
October 26, 2012
www.mohealthwins.org
Grant Detail and Contact Info
Total Award: $19,982,296.00 CFDA #17.282
Period of Performance: 10/1/11 to 9/30/14
Fiscal Lead: Ozarks Technical Community College Finance Office
Vice Chancellor of Finance – Marla Moody
Senior Staff Accountant – Chasity Daniels
Grants Accountant – Betty Denson: 417-447-4831, densonb@otc.edu
Program Director – Dawn Busick
housed at MCCA Office: 573-634-8787
Information Resources on MCCA Website: www.mccatoday.org
New Reimbursement Report
• MHW Reimbursement Report updated:
• Lines for Accrued Expenditures and Unliquidated
Obligations
• Funds expended to date (actual requests) and
committed to date (includes accrued expenditures
and unliquidated obligations)
• Additional field to show percentage of administrative
funds spent to date
www.mohealthwins.org
Administrative Costs
• 8% administrative cap applied across total budget
• Consortium members with ICR may want to claim all
administrative costs as indirect
• Consortium members without indirect costs may
claim administrative costs in direct line items
• Must report total administrative costs claimed on
each reimbursement report
Administrative Costs
• Not related to direct provision of workforce
investment services, including services to
participants and employers
• Can be personnel or non-personnel
• Can be direct or indirect
Administrative Costs - Examples
• Accounting, budgeting, auditing
• General legal services functions
• Information system development (unless related
to program delivery)
• Support personnel, travel costs, other goods and
services related to administrative functions
Program Costs
• Directly related to provision of workforce
investment services, including services to
participants and employers
• Can be personnel or non-personnel
• Can be direct or indirect
Program Costs - Examples
• Vendor contracts (unless solely for administrative
functions)
• Case management
• Information system development for tracking
participant and performance information
• Support personnel, travel costs and other goods
and services related to program functions
Administrative vs. Program Costs
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Not to be confused with direct or indirect costs
Reasonable and based on benefit received
Some costs may need to be prorated
Allocate based on actual costs involved or duties
performed - not job titles or general categories be prepared to defend
• Program guidance found at 20 CFR 667.220
The MHW Grant & Leveraged Resources
• MHW Grant does not require match – requires
leveraged resources reporting
• Leveraged resources not defined in federal
regulations or related administrative requirements
• 29 CFR 95.23 provides limited guidance
• Leveraged resources could be described as:
•“all resources used by the grantee to support grant
activity and outcomes, whether or not those resources
meet the standards required for match”*
•DOL Training Handout: Background for Match and Leveraged Resources
What are Leveraged Resources?
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May be paid for with federal or non-federal funds.
Includes both cash and in-kind contributions.
Must be allowable under the OMB cost principles.
No administrative cost limitation on LR.
Consortium committed to report over $11 million in
leveraged resources over the life of the grant.
• Federal Project Officer will decide what actions to
take if consortium not able to meet commitment.
Reporting Leveraged Resources
• Reported each quarter - 9130 Report (OTC Finance
Office) and Program Narrative (Program Director)
• Colleges report at least quarterly
• Totals listed on Reimbursement Report Form
• Summary sheet attached - for reporting and
verification
• Keep backup documentation for
on-site monitoring
Leveraged Resources - Examples
• Unclaimed indirect costs
• Direct costs that could have been charged to the
grant, but were not: donated space, staff salaries,
supplies, outreach, web costs, travel costs in support
of the grant, etc.
• Equipment used for grant – purchased with
institutional funds, other federal funds, or donated
• Curriculum costs not charged to grant
• Documented third party donations of space,
personnel, or other resources
Leveraged Resources Valuation
• Guidance available at 29 CFR part 95.23
• Not used for contributions on other federal
projects
• Necessary, reasonable, verifiable
• Allocate to show amount of benefit to grant
• Document and be prepared
to defend valuation
Accruals and Obligations
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DOL requires accrual reporting
Better reflection of true program costs
Colleges report totals on Reimbursement Report
Retain documentation for on-site monitoring
OTC Finance Office reports on Form 9130
Failure to report on accrual basis could lead to
loss of funds
Accrued Expenditure or
Unliquidated Obligation?
• An obligation is a commitment of funds
• All accrued expenditures are obligations, but not
all obligations are accrued expenditures
Questions to Ask:
• Has performance been completed?
• What is our obligation to pay if the program
ends?
Details of the Obligation
• Unpaid delivered goods - accrued expenditure
• Contracted goods - unpaid, but not yet delivered –
unliquidated obligation
• Payroll - accrual if work performed, not yet paid
• Travel expenses or utilities - may be accrual
• Contracts - may be accrual or obligation
• Contract - work performed, not paid - accrual
• Contract with legal commitment - may be obligation
• Review contract terms
Questions?
This PowerPoint and Other Informational Resources are
Available on the MCCA Website at www.mccatoday.org
This workforce solution was funded by a grant awarded by the U.S.
Department of Labor's Employment and Training Administration. The solution
was created by the grantee and does not necessarily reflect the official position
of the U.S. Department of Labor. The Department of Labor makes no
guarantees, warranties, or assurances of any kind, express or implied, with
respect to such information, including any information on linked sites and
including, but not limited to, accuracy of the information or its completeness,
timeliness, usefulness, adequacy, continued availability, or ownership.