federal grant management basics perkins grant management webex june 21, 2011 donna brant oregon...

Federal Grant Federal Grant Management BasicsManagement Basics

Perkins Grant Management WebExJune 21, 2011Donna BrantOregon Department of Education

Oregon Department of Education | June 2011

Overview:Overview:

1. The Basics Application and Revision Allowable and Reasonable Allocable and Supplemental

2. Property Control

3. Time Distribution


Disclaimer…Disclaimer…

This webinar is intended for program staff and is presented from a program perspective….

Discuss any questions or procedures with your accounting staff or auditors!


EDGAR…EDGAR…

Who is he and what does he have to do

with my grant??

http://www2.ed.gov/about/offices/list/osdfs/edgar2008.pdf

Google: EDGAR

Education Department General Administrative RegulationsOregon Department of Education | June 2011

EDGAR describes…EDGAR describes…

Financial Reporting Accounting Records Internal Control Budget Control Allowable Costs Source Documentation Cash Management


The Perkins Grant ProcessThe Perkins Grant Process

Grant Application and Budget

Narrative

RevisionsEDGAR 80.30(d) Grantees or subgrantees must obtain prior

approval of the awarding agency whenever any of the following actions is anticipated: Any revision of the scope or objectives of the project

(regardless of whether there is an associated budget revision requiring prior approval).

EDGAR 80.30(f) a request by a subgrantee for prior approval will be addressed in writing to the grantee.


Allowable CostsAllowable CostsOMB Circular A-87OMB Circular A-87

Costs must meet the following criteria:

Be reasonable and necessary

Be allocableBe authorized or not prohibited under state or local laws or federal grant regulations


Reasonable CostsReasonable Costs Do not exceed that which would

be incurred by a prudent person

Are ordinary and necessary for the operation of the program

Represent sound business practices and arms length bargaining


Allocable CostAllocable Cost Must provide a benefit to the

program in proportion to the amount of expenditure

Costs are allocated over the period of the grant

Goods may be charged to the program in accordance with the relative benefit received


Supplement Not SupplantSupplement Not SupplantFederal funds must be used to

augment the regular education program

Supplanting is using federal dollars to provide:◦A required program or service◦A program that was provided by non-

federal funds in the prior year◦Services to some students while

using local sources to provide the same services to others.Oregon Department of Education | June 2011

Records and Source Records and Source DocumentsDocuments Lack of documentation is a primary

reason for audit findings

Documentation must be available to support every expenditure From initial requisition to final

disbursement You must follow your own rules

3 year Federal ~ 7 year OregonOregon Department of Education | June 2011

Property ControlProperty Control

All assets purchased with federal funds

◦Life expectancy of more than one

year

◦Initial cost of more than $200

◦Label with year purchased and

funding sourceOregon Department of Education | June 2011

InventoryInventory

Purchase cost and date

Specific location of asset

Funding used for purchase

Disposition


OMB A-87 RulesOMB A-87 RulesIf federal funds are used for

salaries then Time Distribution records are required.

Must demonstrate◦If employee is paid from federal

funds, then employee worked on that specific federal program or cost objective.


Time Distribution – Why Time Distribution – Why worry?worry?Salary costs are material to many grants.

The absence of adequate documentation is basis for repayment of funds.

Considered explicitly as a “risk factor” by OMB.

Numerous grantees have had to repay millions because of time distribution issues.


TerminologyTerminology

Time and Attendance Records

Time and Effort Records

Payroll records Time distribution records

Timesheet Time distribution record•Semi-annual certification•Personnel activity report (PAR)•Time and effort report

Monday worked 8:00-4:00 Monday worked 60% Perkins Leadership; 5% Perkins Administration; 35% General Fund

ScheduleContract

Work productCalendarTime log


Cost ObjectiveCost ObjectiveA function, organizational

subdivision, contract, grant or other cost activity for which cost data are needed and for which costs are incurred.

◦What federal program cost objective did the employee work on?

◦These cost objectives must be connected to the salary source.


Adequate ReportingAdequate Reporting

Retained by the fiscal agent

Prepared After-the-FactAfter-the-Fact

Full disclosure – Report of full time

worked

Credible endorsement

Reliance from the “bottom up”Oregon Department of Education | June 2011

If work 100% on single cost If work 100% on single cost objective…objective…

Semi-Annual Certification◦Signed every six months by

supervisor or employee

“From August 15, 2010 until December 31, 2010, Donna Brant spent 100% of her time on Perkins Leadership activities at the Oregon Department of Education.”


REMEMBER…Adequate REMEMBER…Adequate ReportingReportingRetained by the fiscal agent

Prepared After-the-FactAfter-the-Fact

Full disclosure – Report of full time

worked

Credible endorsement

Reliance from the “bottom up”Oregon Department of Education | June 2011

If multiple cost If multiple cost objectives…objectives…Personnel Activity Report (aka…PAR, Time and Effort Report)

Signed and dated every month by employee

Actual accounting of time spent After the fact Showing the total effort Should have report and backup

documentation to verify - e.g. calendar, work product, time log


Comparison and Comparison and AdjustmentAdjustmentQuarterlyQuarterly comparison of actual

cost to budgeted distribution.

If difference between actual and budgeted cost is 10% or greater make adjustments quarterlyquarterly.

If difference is less than 10% make adjustment annuallyannually.


MonitoringMonitoringBeginning 2011-2012Expenditure Report

◦Current and Prior Year◦Compare to approved grant/budget◦Looking for allowable

Inventory and LabelingTime Distribution Records


Now that you know…Now that you know…Schedule and appointment with your

business manager to clarify your policy and procedures

Schedule at least quarterly meetings to review budget, expenditures and needed adjustments

If in doubt… contact Donna or Reynold!


For more information:For more information:EDGAR http://www2.ed.gov/about/offices/list/osdfs/edgar

2008.pdf

OMB A-87 http://www.whitehouse.gov/omb/circulars_a087_2004

OMB A-133 http://www.whitehouse.gov/omb/circulars_a133_compliance_09toc/

PCRN http://cte.ed.gov/

Donna Brant, ODE

[email protected]

Reynold Gardner, ODE

[email protected]


federal grant management basics perkins grant management webex june 21, 2011 donna brant oregon...

Documents

program staff

prior approval

required program

servicea program

program perspective

federal dollars

prior yearservices

rules3 year federal