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