21st Century 3rd Annual Ohio Summit
January 21, 2014
Office of Grants Management
25 South Front Street Mail Stop G03
Columbus, Ohio 43215-4183
(614) 752-1483
Brian Jones, Director
brian.jones@education.ohio.gov
Yolanda Mitchell, Grants Management Supervisor
yolanda.mitchell@education.ohio.gov
Lois Sunderland, External Audit Supervisor
lois.sunderland@education.ohio.gov
Tiffany Davis, Grants Administrator
tiffany.davis@education.ohio.gov
 Purpose of Grants Management (GM)
• Consultant
 Project Cash Requests (PCR)
 Final Expenditure Reports (FER)
 Federal Requirements (EDGAR)
 (GM) Business Rules
• Subrecipient Monitoring (SRM)
 SRM vs Single Audits (A-133)
 Basics to Prepare for SRM
 Trending Statewide Issues/Findings
• Grants Administration
 Indirect Cost Rate
 Time & Effort
 Combined Federal Circular
Fun Facts
Questions
GM Consultanting
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Substantially Approved Dates
When an obligation is made
Budget Revisions
Period of Availability
Support Documentation
FERs and FER Revisions
Assurances
Important Dates
Subrecipient Monitoring
Sub-recipient Monitoring (SRM) vs Single Audits (A-133)
Subrecipient Monitoring -is the process of providing oversight on subawards
throughout their lifecycle including:
A. Monitoring the activities of its subrecipients (Grantees)
B. Ensuring that Federal awards are used in compliance with laws, regulations
and the provisions of the grant provisions.
C. Ensuring performance goals are achieved.
Single Audit Act (A-133)- A single audit is an organization-wide audit that includes
both the entity's financial statements as well as its federal awards. Effective January
2004, The Office of Management and Budget Circular No. A-133, Audits of States,
Local Governments, and Non-Profit Organizations, requires entities that expend
$500,000 or more a year in federal awards to have a single or program-specific audit
conducted.
Basics to Prepare For SRM:
• Proper Support Documentation (Invoices, Cancelled Checks, Time & Effort,
Semi-Annual Certs, etc…) -34 CFR 80.20-(b) (1) & (2) Standards for
Financial Management Systems. 3-yr record retention
• Inventory Management -34 CFR 80.32.
– Proper tags & Serial #, Physical Inventory every 2 yrs
• Accounting to conform to a data coding structure (i.e. USAS-Uniform
School Accounting System) – OAC 3301-19-03(A).
– AOS mandates that each entity must enter an expenditure with proper
code classification 3-digit object code and 4 digit Function/Purpose
• Proper use of Budget and Budget Revisions– 34 CFR 80.30 C(ii).
– GRANTEE MUST OBTAIN PRIOR APPROVAL IF ACTIVITIES ARE
EXPECTED TO EXCEED 10% OF THE CURR TOT APPR BUDGET
Trending Statewide Issues
1)Lack of or incomplete Time & Effort forms/Semi-Annual Certifications.
• 2 CFR 225 Appendix B 8.g. (1-3) Where an employee work on multiple
activities, A Fed award and a non-Fed award, 2 or more indirect activities
= T&E
• Where are expected to work solely on a single Fed award=Semi Annual
certs
2)Cash Management & Time Lapsed between payments. 34 CFR 80.20 (b)(7) and 80.21
(c )
3)Obligations/Period of Availability (POA) 34 CFR 80.23- Ensure expenses are incurred
within the project period
4)Activities Allowed or Unallowed 34 CFR 80.22 –Allocable Costs and 2 CFR Part 225
Appendix A-Section c(3)(a) and C(1)(a-j) Costs that are:
– Reasonable, allocable, necessary, & compliant
Grants Administration
Indirect Cost Rate (ICR)
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What is an Indirect Cost Rate
What is it used for
Restricted vs Unrestricted Rates
How to apply for an ICR
How to Utilize an Approved ICR in CCIP
Time & Effort
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When an employee works on multiple cost objectives (different federal funds) they must maintain a
distribution of their salaries. This has been done by maintaining time and effort documentation
(personal activity reports), where the employee associates the total hours worked during the pay
period to a specific activity and/or funding source. Failure to complete and retain proper
documentation could result in questioned costs with the potential of loss of funds for the LEA.
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Based on feedback to reduce the burden of this time and effort documentation, USDOE is allowing
ODE to develop substitute systems for tracing required information. An LEA may submit proposed
documentation for personal activity reports that contains the required components. Once the
proposed documentation is reviewed and approved, the LEA will receive notification that their plan
is acceptable and will be able to use their new format.
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Current Requirements
They must reflect an after-the-fact distribution of the actual activity of each employee
They must account for the total activity for which each employee is compensated
They must be prepared at least monthly and must coincide with one or more pay periods
They must be signed by the employee
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New Flexibility
– Allows for a hybrid of semi-annual certifications and employee “calendar”
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Indicate the specific activity or cost objective that the employee worked on for each segment of the employee’s schedule
Account for the total hours for which each employee is compensated during the period reflected on the employee’s
schedule
Be certified at least semiannually and signed by the employee or a supervisory official having firsthand knowledge of the
work performed by the employee
Combined Federal Circular
Combined Federal Circular –
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2 CFR 220 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
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Applicable to FY16
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Designed to strengthen requirements for internal controls while providing administrative flexibility for non-Federal
entities, does not change or modify existing statutes
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Combines similar language from separate guidances for different entity types under one umbrella
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Combines and streamlines OMB Circulars (Federal funding guidance)
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A-87
A-102
A-110
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A-122
A-133
Cost Principals for State, Local and Indian Tribe Governments (relocated to 2CFR 225)
Grants and Cooperative Agreements with State and Local Governments
Uniformed Administrative Requirements for Grants and Other Agreements with Institutions of Higher
Education, Hospitals and Other Non-Profit Organizations (relocated to 2 CFR 215)
Cost Principles for Non-Profit Organizations (relocated to 2 CFR 230)
Audits of State, Local Governments and Non-Profit Organizations
Selected changes/clarifications in the combined circular
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Requirements for Pass through Entities (ODE) - requires pass through entities to consider risks associated with awarding grants
such as financial stability, quality of management systems, history of performance, reports and findings from audits and reviews,
and the entity’s ability to effectively implement statutory, regulatory or other requirements
Conflict of Interest – language added that requires non-Federal entities to disclose in writing any potential conflicts of interest
Supplies – clarifies the threshold for defining personal property as supply vs equipment
Compensation of Personal Services – strengthens requirements to maintain internal controls over salary and wages while
allowing for additional flexibility in the form of alternative time and effort documentation
Conferences – clarifies allowable conference spending
Employee Health and Welfare Costs – eliminates allowance for morale costs
Audit Requirements – raises the Single Audit Threshold from $500,000 to $750.000
Appendix III through VII clarify indirect cost activities and reporting
Questions?