National Resource Centers Project Administration
September 2010
Amy Wilson, Jessica Barrett Simpson, and Cheryl Gibbs
Access to the World and Its Languages www.ed.gov/ope/iegps
1. Introduction
2. Program Planning & Budget
3. Monitoring
4. Evaluation
5. Reporting
6. Resources
7. Q&A
Agenda
Introduction
Program Planning and Budget
First stage, already completed
Program plans were submitted in application
2. Program Planning
The budget plan is the financial expression
of the project or program as approved during the award process
EDGAR 74.25
2. Budget
FY 10-13 revised NRC budgets approved by US/ED. Grant Award Notifications (GANs) have been mailed
Please review attachments to GAN as they provide parameters
Grantees need to adhere to budget submitted and approved by US/ED. Some changes may require US/ED approval
Budget amounts: Year 1: Actual amount awarded Years 2-4: Anticipated amounts, based on funding
2. Budget
Revised Budget = what was submitted to US/ED for issuance of the award
Vs.
Budget Revision = what will happen throughout the grant cycle
2. Budget
NRC Director salary not on budget
Rule of thumb for other salaries: Up to 50% of the salary for time spent on NRC activities
LCTL instructors: can list at 100%
2. Budget Tips
Budget items should be:◦ Allowable – either permitted or not specifically prohibited◦ Allocable – charged in proportion to value received by project◦ Reasonable – costs incurred that would be considered prudent and
necessary to conduct project activities◦ See OMB Circular A-21: Cost Principles for Educational Institutions
Indirect costs are limited to 8% Conference registration fees may be allowable** Prior approval is not required for most budget
transfers unless they are over 10% or $100K, though program officers like to be notified of changes
2. Budget
Conference registration fees are allowable if the person will be presenting or sharing/distributing information about the NRC or NRC related/supported research or course development activities at the conference
2. Budget
Carryovers from one fiscal year to the next fiscal year are allowed on NRC budget
The amounts of carry over funds will be reported in IRIS
Explain large carryover and plans to spend funds
Separate carryover from new fiscal year funds in budget and budget reporting
2. Budget - Carryover
IRIS Screen Shot – Spring Budget
IRIS Screen Shot – Fall Budget
Do not request money for domestic or ethnic studies
Do not request money for GPA expenses Equipment costs exceeding 10% of the
grant are not allowable Grant funds may not be used to supplant
institutional funds
2. Budget Don’ts
See OMB Circular A-21: Cost Principles for Educational Institutions
Examples of unallowable costs:◦ Fundraising◦ Entertainment◦ Alcohol
Travel costs: See the Fly America Act◦ Travel on U.S. airlines
2. Allowable Costs
Draw down only enough cash to meet grant’s immediate need
Minimize the time between draw down and pay out of funds (three-day rule of thumb)
Reimbursement method is the safest
Drawing down too much or too little will cause you to be flagged by the Department of Education
2. Draw Downs
Monitoring
Project Director Responsibilities:
Implementing the project Monitoring progress towards goals and
objectives Compliance with statutory & regulatory
requirements Financial management and accountability Recordkeeping and reporting requirements
3. Monitoring
Project Monitoring Questions:
Are project activities on track? Are we meeting our goals and objectives? Have there been any unexpected changes? What modifications are needed? What feedback are we getting from faculty
and students? How can we improve?
3. Monitoring Progress
Statutes – Higher Education Opportunity Act NRC Program Regulations – 34 CFR Parts
655 & 656 Department Regulations – EDGAR OMB Circulars – A-21, A-133 Department Directives and Bulletins Individual Grant Terms and Conditions Approved and Awarded Grant Application
3. Essential Tools
Education Department General Administrative Regulations (EDGAR) found in Title 34 Code of Federal Regulations Parts 74-86 and 97-99
Your EDGAR CD is in your packet
It is also online: http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html
3. EDGAR
EDGAR 34 CFR § 74.21 (b)Standards for Financial Management
Systems
(1) Disclosure of financial results(2) Records that identify the source and application of funds (3) Effective control and accountability (4) Comparison of outlays with budget amounts (5) Procedures for draw downs(6) Procedures for determining the reasonableness,
allocability, and allowability of costs(7) Accounting records including cost accounting records that
are supported by source documentation
3. Financial Management
Purpose of Internal Controls:
◦ Reliability of reporting◦ Compliance with laws and regulations◦ Safeguarding of assets
Requirements:
◦ Written policies and procedures◦ Segregation of duties◦ Proper authorizations◦ Sufficient documentation◦ Reporting
3. Internal Controls
Personnel costs must be reasonable and reflect actual work performed
Effort includes the time spent working on a sponsored project in which salary is directly charged or contributed (cost-shared)
Effort is expressed as a percentage distribution that adds up to 100%
Effort reports are different from payroll records. Reports must be certified and signed on a regular basis
3. Personnel Time and Effort
If you indicate a non-federal contribution on the SF 524 budget form, you are required to provide that amount and follow the regulations on documenting cost share/match found in EDGAR §74.23
Matching contributions must be verifiable from the recipient’s records, not included as a contribution for any other federal project (no double counting), necessary and reasonable for the accomplishment of the project, allowable under the cost principles, and not paid by the Federal Government under another award
3. Cost Share/Match
Exemplary project Multiple grants Large grant award amount Need for technical assistance A-133 single audit findings Complaint Late performance report Frequent turnover of personnel Random selection
3. Causes for ED Site Visits
Poor record-keeping/ lack of documentation Weak internal controls Unallowable costs Poor sub-recipient monitoring Contracting out project activities without
approval (if not mentioned in the application) Missing time and effort reports Late performance reports
3. Common Problems to Avoid
Set out clear roles and responsibilities
Select indicators and collect data
Develop and follow written policies and
procedures
Document, document, document
If in doubt:
◦ Consult the “Essential Tools”
◦ Contact your Program Officer
3. Helpful Reminders
Evaluation
What is it ?
◦Evaluation is the systematic data collection, analysis and information gathering needed to make decisions
4. Evaluation
Evaluation is a continuous process—start now to determine where you want to be in four years
Evaluation is vital to the overall international education initiatives at your institution
Evaluation informs priorities, resource allocations, and any adjustments necessary for improving instruction, outreach, professional development, etc.
4. Evaluation
Levels of Evaluation
Program: AIR study and survey Institutional: Impact of Title VI on campus Project: Overall impact of NRC grant
activities Component: Curriculum, Outreach,
Language Proficiency Sub-Component: A specific aspect such as
a Certificate program, conference series
4. Evaluation
FY 2010 NRC/FLAS applications indicated that evaluation plans were institution-wide
Examples: “The outcome-oriented evaluation of our specific NRC
programs are in addition to the regular university evaluation of all South Asia courses”
“In addition to our overall evaluation, we will continue to assess all individual activities related to the grant…so that key programmatic adjustments and improvements take place. An annual self-evaluation report will be submitted to the Vice-Provost for Research and International Affairs”
4. Evaluation
A key to successful evaluation is a set of clear, measurable, and realistic project objectives
If objectives are not realistic or not appropriate to what you have envisioned, you will not be able to demonstrate or provide evidence that project activities have been successful
Be selective: What components are you evaluating and why?
4. Evaluation
Examples of Objectives from FY 2010 Applications:
OBJECTIVE: (LCTL): To develop and sustain a portfolio of least-commonly taught and high-level less-commonly languages
Measurable Indicators: Number of courses available; study abroad opportunities; percentage of graduate students pursuing third year and above in least-commonly taught and fifth year and above in less-commonly taught languages
4. Evaluation
Example of short term outcomes Changes in Knowledge, Attitude, Skills, or Aspirations:
increase awareness of LCTL learning opportunities onsite, via video-delivery, Ph.D. traveling scholar program, study abroad and internship opportunities, and via communications such as brochures and 3-announcements
Example of medium term outcomes Changes in Behavior: Increase enrollments in, usage of,
and applications to LCTL courses and programs
Example of long term outcomes/impact System level changes: Improve institutional capacity to
offer and sustain LCTL learning opportunities
4. Evaluation
ACCOUNTABILITY: Are we doing what we said we would
OUTCOME: The immediate or direct effect of the project
IMPACT: Is the program making a difference. (gets back to the evidence, i.e., data collection)
SUSTAINABILITY: What elements exist or will be in place to ensure that improvement will be sustained. Institutionalization. Brand recognition. Leveraging appeal.
LESSONS LEARNED: Factors that supported or inhibited the accomplishment of stated objectives. Unexpected outcomes.
4. Evaluation
Final Thoughts
Who should conduct the evaluation…internal, external, both?
Share evaluation reports with IFLE
Option to share via IRIS
4. Evaluation
Reporting
All reporting submitted through IRIS
Only the Project Director may submit reports to US/ED
IRIS reporting timeline will be available in the Program Administration Manual (PAM)
4. Reporting
5. Reporting
IRIS Screen Shot
5. Spring Report (4/1)*
IRIS Screen Shot
5.Fall Reporting (10/15)*
IRIS Screen Shot
5.Final Report (11/14)*IRIS Screen Shot
Reporting using reliable information is important to US/ED. We use the information you provide in your report for our reporting requirements to the department and beyond.
5. Reporting
Coming soon…public downloads
Resources
NRC Website http://www2.ed.gov/programs/iegpsnrc/
IRIS http://iris.ed.gov/iris/ieps/irishome.cfm
EDGAR http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html
OMB Circulars http://www.whitehouse.gov/omb/circulars/
Financial Management Requirements http://www.ed.gov/policy/fund/guid/gposbul/FinancialMgmtMemo.pdf
Grants Management Training http://e-grants.ed.gov/training/index.htm
6. Resources
Question and Answer