grants management close out requirements school improvement grant 2014 office of general counsel and...

Grants ManagementClose Out Requirements

School Improvement Grant 2014

Office of General Counsel and the Office of School Transformation

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Regulations: What is EDGAR?


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• Education regulations are in Title 34 of the Code of Federal Regulations (a.k.a. 34 CFR)

• US Department of Education put its general administrative requirements (34 CFR Parts 74-86 and 97-99) together into the “Education Department General Administrative Regulations” or EDGAR

• LEAs follow 34 CFR Part 80.

Get Ready for Closeout


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Prepare to close all activities, contracts with vendors, etc. • Process final payments.• Retain proper documentation.

My Project is ending. Now What?


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§80.42, §80.50-80.52

CloseoutReconcile all activitiesProcess remaining expenditures.Prepare any budget amendments.Ensure proper documentation is retained.



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§80.42, §80.50-80.52

Closeout, cont’dPrepare financial closeout reports.Prepare final Grant Activity Report and any

Grant Activity Reports that have not been previously submitted.

De-obligate funds with the SCDE.Prepare final expenditure claims request.



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§80.42, §80.50-80.52

Closeout, cont’d

Account for all real and personal property.Re-pay any funds as a result of an audit.Complete record retention and ensure availability for

a minimum of 5 years.Prepare disposition of property if program is not

continuing by completing and submitting a disposition letter and a tangible personal property report for property with a value of $5,000 or greater.



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§80.32

Disposition of EquipmentWhen equipment acquired under a grant or

subgrant is no longer needed for the original project/program, it may be used for other activities currently or previously supported by a Federal agency.

If equipment is being transferred to another federally funded program/project, then inventory will need to be tracked across programs/projects.



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§80.32

Disposition of Equipment, cont’dIf there is no other federally funded program/project to

transfer the equipment and the current per unit fair market value is less than $5,000, then the equipment may be retained, sold or otherwise disposed of but if the current per unit fair market value is in excess of $5,000, then the equipment may be retained or sold and the awarding agency shall have a right to an amount calculated by multiplying the current market value or proceeds from sale by the awarding agency’s share of the equipment.



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§80.33

Disposition of Supplies• Title to supplies acquired under a grant or subgrant will

vest, upon acquisition, in the grantee or subgrantee respectively.

• If there is residual inventory of unused supplies exceeding $5,000 in total aggregate fair market value upon termination or completion of the award, and if the supplies are not needed for any other federally sponsored programs or projects, the grantee or subgrantee shall compensate the awarding agency for its share.

Important Dates

• The due date for reimbursement claims to be submitted for expenditures made on or before June 30, 2014 is August 15, 2014.

• The due date for budget amendments pertaining to expenses incurred from July 1, 2014 until September 30, 2014 is September 5, 2014. Amendments must include only costs that are directly related to the grant activities for the 2013-14 program year.

• The due date for reimbursement claims to be submitted for expenditures made between July 1, 2014 and September 30, 2014 is November 15, 2014.

• All deadlines will be strictly enforced. • All funds must be encumbered by September 30, 2014.


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Recommended Grant File

Maintain an official grant file that contains the following:

1. original application and any other comments;

2. required forms;

3. grant award notification(s) (GAN);

4. annual grant performance reports;


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Recommended Grant File5. all financial reports;

6. all budgets and budget modifications;

7. annual audit report including the management letter;

8. Official related correspondence;

9. Official decisions; and

10. any other documentation relevant to the grant throughout its life cycle.


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Recommended Grant FileFile includes documents submitted, processed, and maintained on paper or electronically. Follow the best practices used for filing to allow for easy retrieval of both systems.


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Recommended Grant File

Establish a secure area in the respective office to store the official grant files. Routinely review the official files and reinforce proper controls and procedures with program staff as inconsistencies are noted.


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Recommended Grant File• Make appropriate distinctions between

personal notes and official records. Notes should not be included in the official grant file

• Personal notes by staff and officials that are used for their personal recollection are not shared with other personnel or funding agency personnel.


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Resources• 34 CFR 80 http

://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=4c0e552692e19eabca0c1e104d88a555&tpl=/ecfrbrowse/Title34/34cfr80_main_02.tpl

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

• Guidelines for Retaining Documentation to Support Expenditures Claims – Aug 30, 2012 letter (Melissa A. Austin, Audit Manager) http://ed.sc.gov/agency/as/documents/Guidelines_RetainingDocToSupportExpenditureClaims.pdf


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http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=4c0e552692e19eabca0c1e104d88a555&tpl=/ecfrbrowse/Title34/34cfr80_main_02.tpl




http://www.whitehouse.gov/omb/circulars_a087_2004/



http://ed.sc.gov/agency/as/documents/Guidelines_RetainingDocToSupportExpenditureClaims.pdf



grants management close out requirements school improvement grant 2014 office of general counsel and...

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