Financial Form SF-425 Independent Living Unit Rehabilitation Services Administration Office of Special Education and Rehabilitative Services (OSERS) 1 The purpose of this presentation is to: 1. 2. Introduce the SF-425 fiscal reporting requirements for the IL Part C program. Provide helpful guidance. 2 ?? What is it? • The SF-425 is a financial reporting form required by the Office of Management and Budget (OMB) to track actual expenditures related to federal grant awards. • RSA will use the SF-425 to monitor grantees’ financial status and compliance under Title VII, Chapter 1, Part C, of the Rehabilitation Act of 1973, as amended (the Act) and applicable federal regulations. 3 ?? Who must submit it? • Part C-funded centers for independent living (CILs) • Designated state units that receive IL Part C funds under section 723 of the Act (currently Minnesota and Massachusetts) 4 ? ? How will I submit it? • The SF-425 is submitted on-line through the RSA Management Information System (MIS). • Enter data at http://rsa.ed.gov. 5 ?? When is it due? • Final report is due 90 days after the end of each Part C grant period. • For 10/1/2011 – 9/30/12, the due date is December 31, 2012. • The final report serves as the annual report. 6 ?? When is it due? (continued) • Note: Funds must be liquidated within 90 days from the end of the budget period, unless your CIL has submitted, and RSA approved, a late liquidation extension request. • If a late liquidation request is approved, the 425 is due within 90 days after the Part C funds have been liquidated or 90 days after the approved deadline for liquidation has expired. 7 ARRA Part C Reporting • Grantees must complete a separate SF-425 for their IL Part C ARRA grants, in addition to each of their regular continuation Part C grants. • Instructions on ARRA grants will be provided separately. 8 SF 425 in Detail 1. Federal Agency and Organizational Element to Which Report is Submitted 2. Federal Grant or Other Identifying Number Assigned by Federal Agency (To report multiple grants, use FFR Attachment) Page of 1 pages 3. Recipient Organization (Name and complete address including Zip code) 4a. DUNS Number 4b. EIN 5. Recipient Account Number or Identifying Number (To report multiple grants, use FFR Attachment) 8. Project/Grant Period (Month, Day, Year) Report Type 7. Basis of Accounting 9. Reporting Period End Date (Month, Day, Year) Federal Cash From: 10. Transactions To: Cumulative (Use lines a-c for single or multiple grant reporting) Federal Cash (To report multiple grants, also use FFR Attachment): Federal Expenditures and Unobligated Balance a. Cash Receipts b. Cash Disbursements c. Cash on Hand (line a minus b) (Use lines d-o for single grant reporting) Federal Expenditures and Unobligated Balance: d. Total Federal funds authorized e. Federal share of expenditures Recipient Share f. Federal share of unliquidated obligations g. Total Federal share (sum of lines e and f) h. Unobligated balance of Federal funds (line d minus g) Recipient Share: Program Income i. Total recipient share required j. Recipient share of expenditures k. Remaining recipient share to be provided (line i minus j) Program Income: l. Total Federal program income earned m. Program income expended in accordance with the deduction alternative Indirect Cost Rate n. Program income expended in accordance with the addition alternative o. Unexpended program income (line l minus line m or line n) 11. Indirect Expense a. Type b. Rate c. Period From Period To d. Base e. Amount Charged f. Federal Share 9 First: The easy part 10 Much of the data is entered and calculated by the MIS 1. Federal Agency and Organizational Element to Which Report is Submitted 2. Federal Grant or Other Identifying Number Assigned by Federal Agency (To report multiple grants, use FFR Attachment) RSA default Grant award number comes from Grant Award (GAN) 3. Recipient Organization (Name and complete address including Zip code) Page 1 of pa ge s Comes from Box 1 of GAN 4a. DUNS Number 4b. EIN Comes from Box 8 of GAN From G-5 5. Recipient Account Number or Identifying Number (To report multiple grants, use FFR Attachment) 8. Project/Grant Period (Month, Day, Year) 7. Basis of Accounting 9. Reporting Period End Date Comes from Box 6 of GAN. (Month, Day, Year) From: 10. Transactions (Use lines a-c for single or multiple grant reporting) Federal Cash (To report multiple grants, also use FFR Attachment): a. Cash Receipts b. Cash Disbursements c. Cash on Hand (line a minus b) (Use lines d-o for single grant reporting) Federal Expenditures and Unobligated Balance: d. Total Federal funds authorized e. Federal share of expenditures f. Federal share of unliquidated obligations g. Total Federal share (sum of lines e and f) h. Unobligated balance of Federal funds (line d minus g) Recipient Share: i. Total recipient share required j. Recipient share of expenditures k. Remaining recipient share to be provided (line i minus j) Program Income: l. Total Federal program income earned m. Program income expended in accordance with the deduction alternative n. Program income expended in accordance with the addition alternative o. Unexpended program income (line l minus line m or line n) 11. Indirect Expense Report Type 9/30/xx To: Cumulative MIS Calculates MIS Calculates MIS Calculates MIS Calculates MIS Calculates a. Type b. Rate c. Period From Period To d. Base MIS Calculates e. Amount Charged f. Feder al Share MIS Calculates g. Totals: 12. Remarks: Attach any explanations deemed necessary or information required by Federal sponsoring agency in compliance with governing legislation: MIS Cal. 0 0 11 Lines 1-9: Most information (in red) is already entered 1. Federal Agency and Organizational Element to Which Report is Submitted RSA 2. Federal Grant or Other Identifying Number Assigned by Federal Agency (To report multiple grants, use FFR Attachment) Grant award number comes from Grant Award (GAN box 5) default 3. Recipient Organization (Name and complete address including Zip code) 4a. DUNS Number 4b. EIN Comes from Box 8 of GAN Tax I.D. from G-5 One Year 5. Recipient Account Number or Identifying Number (To report multiple grants, use FFR Attachment) 8. Project/Grant Period (Month, Day, Year) From: 10/1/11 Page 1 of pa ges Comes from Box 1 of GAN 6. Report Type Already set as “Final.” 7. Basis of Accounting Choose Cash or Accrual Select Cash or Accrual 9. Reporting Period End Date (Month, Day, Year) To: 9/30/12 9/30/12 12 The tricky part m 13 Section 10 A - C: Federal cash is used to enter grant data for: 1. Cash Receipts (amounts drawn down) 2. Cash disbursements (amounts disbursed). Enter total amount of grant funds drawn down Federal Cash a. Cash Receipts b. Cash Disbursements Enter total amount of grant funds expended c. Cash on Hand (line a minus b) MIS calculates – if more than three business days are on hand, provide reason in section 12. 14 Line 10A: Cash Receipts • Cash receipts represent the cumulative amount drawn down from G5 by your CIL during the grant period. • This amount can be found in the G5 Reports function, under Payments -> External Award Activity. Be sure to select 10/2011 for the Start Date and 09/2012 for the End Date. 15 Line 10B: Cash Disbursements Cash disbursements represent the cumulative amount actually expended by your CIL during the grant period. 16 Section 10D - H: Federal Expenditures and Unobligated Balances: Federal Expenditures and Unobligated Balance: (e.g., $500,000) d. Total Federal funds authorized MIS enters e. Federal share of expenditures Enter total of cash Total grant award. disbursements made (do not include program income) f. Federal share of unliquidated obligations Enter total federal expenses not yet paid for. g. Total Federal share ( line e plus f) MIS calculates! h. Unobligated balance of Federal funds (line d minus g) MIS calculates! Unobligated Balance Line E plus F. Amount awarded but not drawn down. 17 Line 10F: Federal Share of Unliquidated Obligations: • Unliquidated obligations are the direct and indirect expenses for goods and services incurred by the grantee, but not yet paid or charged to the grant award. • Enter “0”in 10f, except in very rare circumstances (for example, if a CIL submitted an approved late liquidation extension request but was unable to liquidate the funds by the extended deadline). • CILs must submit a written request for late liquidation if they expect to be unable to liquidate the Part C funds for the grant period by 12/31/12. 18 10F: Unliquidated obligations (continued) • • • • Written late liquidation requests should be submitted within 30 days after the end of the grant period. The request must justify the reasons for the delay and include documentation that the expenses are allowable and were obligated during the grant period. The remaining balance on the grant cannot be liquidated after the end of the liquidation period unless RSA approves the late liquidation request. The CIL must file a final SF-425 within 90 days after the end of the award period or 90 days after the end of the approved late liquidation period. 19 Lines 10I, J, K: Recipient Share • Enter ‘’0’’ for 10i, 10j, and 10k. • CILs do not report recipient share amounts in 10ik, because the there is no matching requirement in the IL Part C program. 20 Lines 10L - O: Program Income • “Program income means gross income received by a grantee under title VII of the Act that is directly generated by an activity supported under 34 CFR part 365, 366, or 367.” (34 CFR 364.5) • Examples include direct Social Security Administration or Workers’ Compensation payments; fees for services to defray part or all costs of services provided to particular individuals; insurance company payments or reimbursements for consumer services, etc. 21 Program Income Specify Deductive or Addition Method, Enter total in Line m or Line 2 Program Income: l. Total Federal program income earned m. Program income expended in accordance with the deductive alternative (If no program income was expended enter zero) n. Program income expended in accordance with the addition alternative (If no program income was expended enter zero) o. Unexpended program income (line l minus line m or line n) program income earned Enter total program income earned Deduction = Program income used to reduce the amount of the grant. (Means these grant funds will need to be returned to RSA). Addition = Program Enter income used to actual supplement the disburse Federal Share. MIS calculates! -ments 22 Lines 11A - F: Indirect Costs • Indirect costs are those that have been incurred for common, or organization-wide, objectives and cannot be readily identified with a particular grant award. • Examples may include portions of facility rent and maintenance costs, executive officer salaries, general administration and accounting costs, etc. 23 CAP, IDCR Indirect Costs (continued) • Grantees cannot charge indirect costs to their Part C grant unless they have a cost allocation plan (CAP) or indirect cost rate (IDCR) approved by the U.S. Department of Education. • CAP or IDCR proposals are submitted to the Department's Indirect Cost Group for approval. • OMB Circular A-122, Attachment A, Paragraph D, governs indirect cost rates for non-profit organizations. • Part C CILs are addressed in Commissioner’s Memorandum CM 04 (May, 2004). 24 Indirect Costs Rate (Continued) 11. Indirect Expense a. Type b. Rate If IDCR, enter “Final,” “Predetermined,” “Provisional” or “Fixed.” If CAP, enter “CAP.” If none, leave blank. c. Period From If IDCR, enter the approved indirect cost rate . If CAP, enter “100” (for 100 percent). Period To g. Totals: MIS Calculates! d. Base 0 e. Amount Charged f. Federal Share MIS calculates! MIS calculates! If ICDR, enter approved base amount. If CAP, enter 0 0 total indirect costs amount. 25 CAP or IDCR Cost Allocation Plans or Indirect Cost Rates If a grantee does not have a approved Cost Allocation Plan or Indirect Cost Rate, it must contact ED’s Indirect Cost Group. A list of Indirect Cost Group contacts by state is available at: http://www2.ed.gov/about/offices/list/ocfo/fipao/icgre ps.html 26 Lines 13A - E: Certification • Certify that the SF-425 is true, complete and accurate and that the CIL will maintain a signed hard copy. • Include the certifying official’s name, title, telephone and email. • Select “Yes” for “Signed” in 13b. • Indicate the report submittal date. 27 Final Steps • Click “Validate” to identify any omissions or errors before submitting. • Print and sign the completed SF-425. • Click “Mark as Complete and Submit to RSA.” 28 Reminders and Tips • Numbers entered must be a positive or a neutral integer except for percentages (e.g. 0.1). • If there is nothing to report in a required field, you must enter a zero. • The SF-425 for regular Part C and ARRA Part C must be filed separately. 29 To enter the 425 on-line: • Visit http://RSA.ed.gov • If you have a user ID: Log in, click Help and select Technical Support. Then open the “I Need to Enter Data on a Form that Isn’t Listed on my Data Entry Screen” option, and follow the prompts. • If you don’t have a user ID: Open Help, select Info for New Users. • If you have forgotten your ID or password: Click on Log On, click on the New User? link, and select “Click Here if you Have any Problems Logging In.” 30 Requirements Regarding Part C Expenditures Federal regulations at 34 CFR 74.21(b) require CILs to have written procedures to: • minimize the time between the drawdown of federal funds and the expenditure of those; and • ensure the reasonableness, allocability, and allowability of expenditures in accordance the federal cost principles and the terms and conditions of the award. 31 Requirements Regarding Expenditures (continued) According to 34 CFR 75.731 and OMB Circular A-122, RSA may disallow expenditures that lack adequate supporting documentation. 32 Additional Resources • RSA MIS Help link: http://rsa.ed.gov or RSAMIS.Technical.Support@ed.gov • CIL Program SF-425 Policy Directive: http://www2.ed.gov/policy/speced/guid/rsa/pd/2 011/index,html • Model cost allocation plan for CILs: http://www2.ed.gov/programs/cil/costplan.pdf • OMB Circular A-122: http://www.whitehouse.gov/omb/circulars_a122_ 2004 • For additional questions, contact your assigned IL unit representative at RSA. 33