1 national association of title iiii administrators technical assistance workshop june 24, 2010
TRANSCRIPT
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National Association of Title IIII Administrators Technical
Assistance WorkshopJune 24, 2010
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STRATEGIES FOR EFFECTIVELY BALANCING YOUR TITLE III
BUDGETS AND KEEPING YOURINSTITUTION COMPLIANT IN THE MIDST OF BUDGET CUTS
Presenters:Ms. Mary Anne (Vicki)) Payne, Compliance
Officer
Morgan State University
Mrs. Katrina B. Miller, Title III Director
Norfolk State University
Ms. Deborah Newkirk, Independent Consultant
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Today’s ObjectivesToday’s Objectives
Balancing your Title III Budget
Allowable and Unallowable Costs associated with LAAs
Supplementing vs. Supplanting
Strategies for staying compliant
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LEGISLATIVE ALLOWABLE LEGISLATIVE ALLOWABLE ACTIVITIES (LAA)ACTIVITIES (LAA)
forforHBCU, HBGI and CCRAA HBCU, HBGI and CCRAA
GRANTSGRANTS
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REFERENCE for LEGISLATIVE REFERENCE for LEGISLATIVE ALLOWABLE ACTIVITIES (LAA)ALLOWABLE ACTIVITIES (LAA)
• HBCU – Higher Education Act (HEA) of 1965 revised Sec. 323 (a); HEOA, Public Law 110-315 (Aug. 2008) Sec. 309 (12, 13, 14)
• HBGI – Higher Education Act (HEA) of 1065 – revised Sec. 326 (c); HEOA, Public Law 110-315 (Aug. 2008), Sec. 311 (b)
• CCRAA– HEOA, Sec. 302, Title IV, Part J• MANDATORY FUNDING (SAFRA) -
HEOA
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UNALLOWABLE ACTIVITIESUNALLOWABLE ACTIVITIES
Activities inconsistent with a State plan for desegregation
Activities related to sectarian instruction or religious worship
Activities provided by a school of divinity
Cultural Activities for Students
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UNALLOWABLEUNALLOWABLE and and ALLOWABLE COSTSALLOWABLE COSTS
APPROVED activities DOES NOT mean ALLOWABLE
costs
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PUBLIC RELATION/PUBLIC RELATION/ADVETISEMEN T COSTSADVETISEMEN T COSTS
(Circular A-21 (J 1 a, (Circular A-21 (J 1 a, b,,c,,d,,e,,& f)b,,c,,d,,e,,& f)
Allowable
Recruitment of personnel
Procurement of goods and services
Disposal of surplus materials
Costs required by sponsored agreement
Communication costs
Unallowable
ALL costs related to advertisement and public relations except costs specified underALLOWABLE including promoting the institutions
Costs associated with Convocations Costs of meeting rooms, &
other facilities associated with shows and other special events
Costs of promotional items
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SPECIAL PURPOSE and SPECIAL PURPOSE and GENERAL PURPOSE EQUIPMENTGENERAL PURPOSE EQUIPMENT
(Circular A-21 J 16) (Circular A-21 J 16)ALLOWABLE
Research, medical, scientific , medical, or other technical activities
Laboratory, library, and classroom furniture
Furnishing and equipment for Title III office
UNALLOWABLE
General purpose equipment such as; office equipment and furnishings, air conditioning equipment, if not approved in the sponsored agreement
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DEVELOPMENT OFFICEDEVELOPMENT OFFICE(Circular A21 J 22)(Circular A21 J 22)
Allowable Establishing a
development office Physical custody and
control of monies
Unallowable
Organized fundraising Financial campaigns Endowment drives Solicitation of gifts
and bequests Any expenses incurred
solely to raise capital or obtain contributions
Investment counsel and staff whose responsibility is solely to enhance income from investments
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EXAMPLES of OTHER EXAMPLES of OTHER UNALLOWABLE COSTS UNALLOWABLE COSTS
identified in CIRCULAR A-21identified in CIRCULAR A-21Alcoholic Beverages- J2Alumni/a e activities- J3Bad Debts- J4Civil defense costs- J5 Commencement costs- J6Entertainment costs- J15Fines and penalties- J18Housing and personal living expenses-
J20Lobbying costs- J24
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EXAMPLES OF UNALLOWABLE EXAMPLES OF UNALLOWABLE COSTS (continued)COSTS (continued)
Membership, subscriptions, an d professional activity costs –J28 (d, c)
Student activity costs – J45
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SUPPLEMENT not SUPPLEMENT not SUPPLANTSUPPLANT
What is supplementing? To increase funding of existing
institutional programs.
What is supplanting? To use grant funds to replace the
costs associated with existing
institutional programs.
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EXAMPLES OF……….EXAMPLES OF……….
SUPPLANTING
Replacing salaries paid by other
sourceswith grant funds
Using grant funds for existing programs or
activities
SUPPLEMENTING
Using grant funds to increase personnel
Use grant funds to enhance or develop new programs
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EXAMPLES (continued)
SUPPLANTING Using grant funds to
replace Institution funds currently being used for furnishing a computer lab
Replace institution funds for travel, faculty training etc with grant funds
SUPPLEMENTING Using grants funds to
increase the furnishing for the computer lab
Use grant funds to increase the number of faculty being trained and the amount of travel to professional workshops
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IN SHORT…….IN SHORT…….
ANY COSTS PREVIOUSLY PAID BY THE INSTITUTION OR OTHER FUNDING SOURCES SHOULD NOT BE REPLACED WITH GRANT FUNDS
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Building and Strengthening Building and Strengthening the Title III Community the Title III Community through Engagement through Engagement
PrinciplesPrinciples1. Communicate a
compelling message.
2. Build a guiding coalition.
3. Create principled-based versus compliance-based guidelines for decisions and behaviors.
4. Identify early engagement indicators.
5. Generate continuous opportunities for dialogue at al levels.
6. Plan assimilation strategies for new members and new leaders.Gravenkemper, S. (2007) Building Community in
Organizations. Counseling Psychology Journal: Practice and Research.
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Principle-Based versus Principle-Based versus Compliance Based Guidelines for Compliance Based Guidelines for
Decisions and BehaviorsDecisions and Behaviors
Compliance-Based Guidelines
Enforces Federal Regulations
Enforces State policies and procedures
Increases the “red tape” and decreases effective communication.
Principle-Based Guidelines
Promotes dialogue among campus community
Increases engagement/ collaboration
Promotes a sense of community
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Taking Charge: A Plan for Taking Charge: A Plan for Remaining Compliant Remaining Compliant
Survey Title III Community (Transparency)
Provide expectations and roles/responsibilities for those working with Title III (Accountability)
Build Trust through staff forums, activity directors information session and Start-Up meetings (Accountability).
Provide opportunities for growth through internal workshops (Accountability).
“Show and tell” budget progress/spending levels (Transparency).
Design new activity director support program (Accountability).
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Manage Risk Manage Risk AppropriatelyAppropriately
Establish and enforce Internal Controls
Develop effective budget management practices
Maintain “healthy” working relationships with the fiscal office and internal auditor
Determine how to profit from uncertainty while limiting your risk
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....Know What You’re Really Know What You’re Really Going AfterGoing After
Be Visionary
Reveal the “bottom line” for Title III at your institution.
Determine the ultimate goal for Title III at your institituion.
Leverage Title III ResourcesStrengthen through entreprenureial
iniaitives
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TITLE III, PART B CONTACTS
Dr. James E. Laws, DirectorInstitutional Development and Undergraduate Education
Ms. Karen Johnson, Team LeaderHBCU/HBGI; MSEIP; PBI; CCRA
1990 K St., NW6th Floor
Washington, DC 20006202/502-7777
IDUES WEBSITE: http://www.ed.gov/about/offices/list/ope/idues/index.html