ON TARGET WITH GRANTS COMPLIANCE Traci Gatewood, Colleen Fitzgerald, Grants Director Accounting Director Gena Tran, Joan Stack, Grants Coordinator Grants Accountant Presented By: Traci V. Gatewood
ON TARGET Learning Objectives Objective One – Explain compliance and discuss its importance Objective Two – Review order of precedence of laws, regulations, policies, and agency guidance Objective Three – Review “governing documents” and their importance in grants management Objective Four – Review roles and responsibilities of grant managers as well as grants, accounting services and research and accountability departments Objective Five – Identify district resources that assist with grants management 2
ON TARGET All Grants Are Not the Same Types of Grants • Federal Discretionary Grants • Smaller Learning Communities Federal Formula Grants (State Pass-Thru or Direct Federal) • • NCLB Title VI-B & 619 Preschool • • Carl Perkins • Indian Education Formula Hybrids (Grant Contracts) • Alaska Youth First • Construction Academy • 3
ON TARGET Compliance Applies to all Grants What is compliance? Why is it important? Following statutory and regulatory Grants are NOT gifts. There are lots of requirements, the rules of the funding “strings” attached! agency, and FNSBSD policies. Non-compliance with a single grant can Avoiding fraud, mismanagement and waste jeopardize the district’s ability to compete for grants in the future. Implementing and monitoring grant activities and budget American Recovery and Reinvestment Act (ARRA)…new age of transparency Meeting reporting requirements Meeting deadlines set by funding agencies • Federal Financial Accountability and Transparency Act • Improper Payments Elimination and Recovery Remember: It is not enough to comply! It Act of 2010 is essential to maintain records to show Federal Awardee • compliance. Performance and Integrity Information System 4
ON TARGET Stay on Target COMPLIANCE BASICS 5
ON TARGET Three Steps for Compliance Step 1 Step 2 Step 3 Know, understand, and Maintain excellent Use the district’s follow all governing record keeping and Guide to Grants documents file management Management as a tool to help you properly manage your grant 6
ON TARGET Stay on Target ORDER OF PRECEDENCE 7
ON TARGET Statutes Order of Precedence Regulations Executive Orders OMB Circulars FNSBSD Policies & Regulations Individual Grant Documents Stay on Target by Understanding All Source Documents That Impose Conditions on Grants 8
ON TARGET Stay on Target STATUTES 9
ON TARGET Statutes: Programmatic and Administrative Program Statutes Administrative Statutes Authorizing Statutes that outline formal legal Do not address programmatic issues requirements and address requirements such as: How funds are generated Outline the base threshold requirements or processes that apply to federal funds How funds must be allocated and Administrative statutes examples: permissible use of funds Who is eligible to be served Single Audit Act How programs must be designed General Education Provision Act What types of reports or evaluations are Improper Payments Information Act required Other specific fiscal requirements such as Federal Civil False Claims Act supplement not supplant, set asides, match, carryover limits, maintenance of effort Examples: NCLB, Perkins Act, IDEA Program Fraud Civil Remedies Act 10
ON TARGET Single Audit Act Establishes threshold amount (currently $500,000) of federal expenditure in a given year that triggers the requirement for a single audit Requires “pass - through entities” to conduct subrecipient monitoring Establishes audit reporting, submission, and corrective action requirements 11
ON TARGET General Education Provisions Act Basic administrative requirements that pertain to most ED programs Some portions do not apply to certain programs Essential to check program statutes to determine whether rules in program statutes or rules in GEPA apply. Certain programmatic statues such as NCLB state that some portions of GEPA do not apply to certain programs. General provisions of GEPA address the following: Forward funding and the period of availability of federal funds State reporting requirements State agency monitoring and enforcement responsibilities Single state and local application requirements Family Educational Rights and Privacy Act (FERPA) requirements Requirements relating to protection of pupil rights Enforcement provisions for noncompliance 12
ON TARGET Stay on Target REGULATIONS 13
ON TARGET EDGAR: Education Department General Administrative Regulations 14
ON TARGET EDGAR: What is it? Contains regulations for administering discretionary and formula grants awarded by the Department of Education Many of the concepts laid out in the GEPA statute are further articulated and explained in EDGAR Addresses pre-award requirements, post-award requirements, property standards, procurement standards, reports and records, termination and enforcement The particular portions of EDGAR that apply to a specific grant depends on who is receiving the grant (SEA vs. LEA) and what type of grant is being received (direct federal grant vs. “State” pass thru). Often the EDGAR sections that apply to specific grants are detailed in the Grant Award Notice Establishes audit reporting, submission, and corrective action requirements 15
ON TARGET EDGAR: Commonly Used Parts Part 75-Direct Grant Part 76-State- Programs Administered Programs Part 80-Uniform Administrative Part 77-Definitions That Requirements for Apply to Department Grants and Cooperative Regulations Agreements to State and Local Governments Part 81-General Education Provisions Act-Enforcement 16
ON TARGET Stay on Target OFFICE OF MANAGEMENT & BUDGET (OMB) CIRCULARS 17
ON TARGET OMB Circulars OMB Circular A-87, Cost OMB Circular A-133, OMB Circular A-133: Principles for State, Audits of State, Local Compliance Supplement Local Governments & Governments, & Non Local Tribes Profit Organizations • A placeholder for text for more • A placeholder for text for more Establishes the basic Provides a source of information information threshold standards that Governs audit rules and information for auditors to must be present for a cost standards and establishes understand the Federal to be permissible with the general audit program’s objectives, federal funds requirements for grantees procedures, and compliance requirements Must comply with cost principles because EDGAR makes them applicable by reference 18
ON TARGET The 10 OMB Circular A-87 Cost Principles (2CRF, Part 225) Necessary & Reasonable Adequately Allocable to Federal Documented Award(s) Authorized or Not Net of All Applicable Prohibited Under Credits State or Local Laws or Regulations Conforming to Not Included as a Limitations or Match or Cost Share Exclusions Determined in Consistent with Accordance with Policies, Regulations GAAP & Procedures Accorded Consistent Treatment 19
ON TARGET OMB Circular A-87 Attachment B to Circular A-87 Lists in alphabetical order specific allowable and unallowable cost allocable to grants Paragraph h Semi-annual certifications Personnel activity reports 20
ON TARGET OMB Circular A-133, Audits of States, Local Governments & Nonprofit Organizations A-133 describes the audit requirements that apply to recipients of federal funds. Each year the school district must have a single audit performed by an independent auditor. Auditors must study and evaluate our internal controls system. Auditors determine if we are in compliance with the provisions of laws and regulations governing grant. Results of school district’s annual audit, including all instances of reportable non- compliance, are reported to the federal government through the Federal Audit Clearinghouse. 21
ON TARGET A-133 Compliance Supplement Assists auditors in performing single audits Provides a source of information for auditors to understand the Federal program’s objectives, procedures, and compliance requirements Important for grantees because it is the “roadmap” that auditors will use when conducting the single audit Can be useful because it can serve as a self “spot - check” to determine if we are complying with federal requirements Additional guidance for ARRA funded programs is included in the Compliance Supplement 22
ON TARGET Stay on Target YOUR GRANT DOCUMENTS 23
Your Grant Documents ON TARGET 1. Request for Applications (RFA) 2. Grant application/budget/evaluation 3. Grant Award Notification 24
ON TARGET Request for Application (RFA) Official document that invites entities to submit grant applications to accomplish a specific program purpose Guide to completing the grant application, including budget and evaluation Federal program purpose Funding selection criteria and priorities Mandatory project components Budget and match requirements Requirements such as conference attendance, training, etc. Government Performance and Result Act Measures-GPRA Reporting requirements 25
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