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Topics of Discussion. Federal Fiscal Management Rules
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1. Emergency Management Performance Grant (EMPG) In-House Training Webinar and Discussion Presenters:
John Isaacson, Chief
Grants Processing Branch
Susan Kantner, Program Analyst
Grants Processing Section
John Thomas, Program Analyst
Emergency Management Grants Section
Huy Tram, Program Analyst
Grants Processing Section
2. Topics of Discussion Federal Fiscal Management Rules & Regulations
Governing Body Resolutions
Reimbursement Requests
Revision Requests
Modifications & Amendments
Quarterly Progress Reports
FY2011 EMPG State Guidance
Proposed Changes
Financial Management Forms Workbook (FMFW)
3. Financial Management Rules and Regulations
John Isaacson, Chief
Grants Processing Branch
California Emergency Management Agency
(916) 324-6529
John.Isaacson@calema.ca.gov
4. The objective of this presentation is to help ESCs understand
What the Federal rules and regulations are, and how to remain in compliance with them;
What you can expect Cal EMA staff to review during a site/monitoring visit; and
How you can assist in that process.
Always remember that we are here to help our subgrantees maintain compliance, and with proper preparation, ESCs can help them avoid problems.
5. Topics of Discussion Procurements
Sole Source Requests
Source Documentation
Records Retention
Federal Transparency Act of 2006
Avoiding Pitfalls (findings)
6. Procurements Subgrantees must have written policies and procedures for the procurement of goods and services to be followed and measured in accordance with applicable Federal Rules and Regulations.
CFR Title 44, Section 13.36
(follow most restrictive policy)
7. Procurement Methods
Small Purchase;
Formal Advertising / Sealed Bid;
Competitive Proposals; and
Noncompetitive Proposals.
8. Small Purchases A simple and informal method for purchasing supplies, services or other goods that cost less than $100,000.
Price or rate quotations must be obtained from an adequate number of qualified sources.
CFR Title 44, Section 13.36 (d)(1)
(document a minimum of two quotes)
9. Formal Ad / Sealed Bids Invitation for Bids (IFBs) are publicly advertised and a firm-fix-priced contract (lump sum or unit price) is awarded to the lowest, responsible bidder.
CFR Title 44, Section 13.36 (d)(2)
(document a minimum of two bids)
10. Competitive Proposals Request for Proposals (RFPs) are publicly advertised and identify all evaluation factors and importance.
Proposals solicited from and adequate number of qualified sources.
Awards made to responsible firm whose proposal is most advantageous.
CFR Title 44, Section 13.36 (d)(3)
11. Noncompetitive Proposals Solicitation from only one source, or competition deemed to be inadequate (Sole Source Procurement).
Only allowed when the award of a contract is infeasible under the Small Purchase, IFB, or RFP process.
Sole Source Procurements over $100,000 require prior approval from Cal EMA.
CFR Title 44, Section 13.36 (d)(4)
12. Sole Source Procurement Subgrantees must request prior approval when:
Procurement is over $100,000; or
Procurement awarded without competition; or
Only one bid or offer is received; or
Procurement specifies a brand name item; or
Procurement awarded to other than the apparent low bidder under a sealed bid procurement; or
Modification changes the scope of contract or increases the contract amount beyond $100,000.
CFR Title 44, Section 13.36 (g)(2)
13. Sole Source Procurement Explain why the item or service is only available from one source.
Describe how a public exigency or emergency will not permit a delay resulting from a competitive solicitation.
Describe the solicitation process that resulted in inadequate competition.
Provide your cost analysis that determined costs are reasonable.
CFR Title 44, Section 13.36 (d)(4)
14. Source Documentation Accounting records must be supported by such source documentation as cancelled checks, paid bills, payroll records, signed time and attendance sheets, purchase orders, invoices, delivery receipts, contract and sub-grant award documents, etc.
CFR Title 44, Section 13.20 (b)(6)
15. Source Documentation (cont.) Subgrantees may be required to provide copies of source documents prior to receiving a reimbursement from Cal EMA.
highlight the total cost.
show your calculations.
attach excel spreadsheet / calculator tape.
16. Records Retention All supporting documentation pertaining to the administrative, programmatic and financial management of the grant must be retained for at least THREE YEARS following Cal EMAs close out of the Federal/State Grant Period and resolution of any monitoring/audit findings.
CFR Title 44, Section 13.42 (c)
17. Records Retention (cont.) Subgrantees must maintain sufficient records to detail the significant history of a procurement. These records must include, but are not limited to:
Procurement method rationale;
Selection of contract type;
Contractor selection or rejection;
Proof of debarment verification; and
Basis for the contract price.
CFR Title 44, Section 13.36 (b)(9)
18. Excluded Parties List System (EPLS) Contractor disbarment verification can be obtained from the
following website: https://www.epls.gov/
The Excluded Parties List System (EPLS) includes
information regarding entities debarred, suspended,
proposed for debarment, excluded or disqualified under the
nonprocurement common rule, or otherwise declared
ineligible from receiving Federal contracts, certain
subcontracts, and certain Federal assistance and benefits.
19. Common Guides, Bulletins, Rules & Regulations
Individual Federal and State Grant Guides and Public Laws http://www.dhs.gov/xfrstresp/standards, http://www.dhs.gov/xopnbiz/grants/ and http://www.calema.ca.gov/
Information Bulletins - http://www.ojp.usdoj.gov/odp/docs/bulletins.htm
Grant Management Memos - http://www.calema.ca.gov/grants.html
California State Strategy - http://www.calema.ca.gov/pdf/2007_state_strategy.pdf
Homeland Security Presidential Directives - http://www.dhs.gov/xabout/laws/editorial_0607.shtm
20. OMB Circulars & Relocation Administrative Requirements:
A-102: Grants & Cooperative Agreements w/State & Local Governments
A-110: Grants & Other Agreements with Institutions of Higher Education, Hospitals, & other Non-Profit Organizations [Relocated to 2 CFR, Part 215]
Costs Principles:
A-21: Educational Institutions [Relocated to 2 CFR, Part 220]
A-87: State, Local and Tribal Governments [Relocated to 2 CFR, Part 225]
A-122: Non-Profit Organizations [Relocated to 2 CFR, Part 230]
and Contracts with Hospitals 45 CFR, Part 74 (Appx E)
21. OMB Circulars & Relocation Cont. Audit Requirements:
A-133: Audits of States, Local Governments and Non-Profit Organizations [Revised June 26, 2007 and Updated Compliance Supplement Part 4: DHS UASI & HS Clusters #97.008 (03/07)
Additions:
A-123: Managements Responsibility for Internal Control (Effective FY 2006)
OMB Guidance for Government wide Debarment & Suspension (Non-procurement)[Revised and issued under 2 CFR, Part 180]
OMB Circulars can be accessed at: http://www.whitehouse.gov/omb/circulars
22. Code of Federal Regulations Title 2: Grants and Agreements [includes Relocated OMB Circulars]
Title 44: FEMA/DHS Rules and Regulations
Title 45: Appendix E Applicable to Research and Development Under Grants and Contracts With Hospitals
CFRs can be accessed at: http://www.gpoaccess.gov/cfr/index.html
23. Which Regulations Apply?
24. Federal Funds Accountability and Transparency Act The primary goal of the Transparency Act is to increase transparency and improve the publics access to information on federal spending.
Awards +$25K after 10/01/2010, must identify the congressional district(s) where the funds will be spent.
25. Clear Audit Trail - Reconciliation Equipment Item
Allowable/Applicable item
Seek Cal EMA authorization
Procure item w/proper coding
Receive item/inventory
Pay off Invoice
Seek Reimbursement from Cal EMA
Record Inventory of Property
26. Subgrantee Monitoring & Oversight Subgrantees are responsible for monitoring all subrecipients, consultants, and contractors that benefit from Cal EMA grant funds. This scope includes, but is not limited to the follow areas of program administration:
M & A
OT/Backfill
Procurement
Equipment & Property Management
Compliance with A-133 monitoring
27. Common Findings Costs may become questionable if:
Unallowable, unnecessary or unreasonable.
Improper debarment and suspension inclusion recording.
They are for improperly procured acquisitions.
Noncompliance with procurement standards.
They are not supported by source documentation.
Did not obtain prior (Sole Source / EHP) approvals.
28. Learning to Navigate Contact EMPG program staff regularly to go over project costs, and to identify and prepare all required documents.
Retention of Records
Amendments (Modifications) to Contracts
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Three years after Cal EMA closeout / audit resolution
Know the specific EMPG program requirements.
Know the Federal, State & Local regulations.
Follow the most restrictive policy.
Read previous SV/Monitoring Reports.
Document, document, and document some more.
29. Questions or Comments?
30. Next Topic of Discussion:
Governing Body Resolutions
&
Reimbursement Requests
31. EMERGENCY MANAGEMENT PERFORMANCE GRANT (EMPG)
Judy Worman, SSMI
Grants Processing Section
California Emergency Management Agency
32. GRANTS PROCESSING SECTION (GPS) STAFF
Judy Worman , Chief (SSMI)
(916) 845-8181; judy.worman@calema.ca.gov
Grants Analysis and Processing Branch(Mather)
Grants Processing Supervisor
Robin Shepard, Program Analyst (Lead)
(916) 845-8175; robin.shepard@calema.ca.gov
Lead Analyst for EMPG reimbursements
Processes reimbursement requests submitted from regions
Grants Processing Contact for:
Coastal Region
Inland Region
Southern Region
Susan Kantner, Program Analyst
(916) 845-8125; susan.kantner@calema.ca.gov
Back-up analyst for EMPG reimbursements
Prepares close-out documents for sub-grantees
33. Topic of Discussion
The objective of this presentation is to provide information
for the following:
Requirements for Governing Body Resolutions (GBR)
Reimbursement Requests
34. Governing Body Resolution
The Governing Body Resolution is to appoint positions or individuals to act on behalf of the governing body and the sub-grantee
The Governing Body Resolution allows for the appointment of individuals or positions
35. Governing Body Resolution For each person or position appointed by the Governing
Body, the following information must be submitted on the
sub-grantees letterhead:
Name
Title
Address
Telephone/Fax Number
Email Address
36. Governing Body Resolution If the resolution identified Authorized Agents by position and/or title, changes need to be made by submitting new Authorized Agent information on sub-grantee letterhead
If the resolution identifies the Authorized Agent by name, a new resolution will be required
37. REIMBURSEMENTS Reimbursement Requests
Payments can only be made if the sub-grantee has submitted an approved application, valid GBR, & Grant Assurances
Sent to applicable region for review who then sends it to Grant Processing Section
No advances
For FY11 EMPG Grant reimbursement requests will be submitted using the Financial Management Forms Workbook (FMFW)
38. Questions?
39. Next Topics of Discussion: Introduction to EMGS Staff
Revision Requests
Performance Reports
Proposed Changes to FY11 EMPG State Guidance
40. Emergency Management Grants Section (EMGS) Staff Kris Whitty, Chief (SSMII)
(916) 323-7734; kris.whitty@calema.ca.gov
Homeland Security, Prop 1B, and Emergency Management Branch
EMGS Supervisor
John Thomas, Program Analyst (Lead)
(916) 322-9235; john.thomas@calema.ca.gov
Cal EMA liaison to FEMA for the EMPG Grant
Applies for EMPG Grant Funding on behalf of the State.
Prepares Quarterly Reports on behalf of Agency and submits them to FEMA.
Overall, oversight of the EMPG Program.
EMGS Contact for:
Inland Region
Southern Region
Michael Bright, Program Analyst
(916) 327-3689; michael.bright@calema.ca.gov
EMGS Contact for:
Coastal Region
Matt Wells, Analyst
(916) 322-2765; matt.wells@calema.ca.gov
Assists EMGS with miscellaneous tasks.
41. The objective of this presentation is to help you understand
The processes, procedures and requirements that relate to the administration of the EMPG grant;
What EMGS staff expect to see when the Operational Areas (OAs) submit EMPG related documents; and
How you (the Emergency Services Coordinators, Senior Emergency Services Coordinators, EMPG Regional Leads and Regional Administrators) can assist in the process.
Always know that we are here to help and are more than willing to assist in anyway possible.
42. Revision Requests(Modifications & Amendments)
All changes to the OAs approved Program Narrative and Budget Worksheet must be submitted to Cal EMA in writing and approved by the Agency Secretary, or his designee, prior to initiating any revised scope of work or incurring the associated expenditures.
The OAs may submit revision requests to Cal EMA at any time during the performance period.
Failure to submit revision requests and receive approval prior to expenditure could result in a reduction or disallowance of that part of the subgrant.
43. Revision Request Packet The Revision Request Packet consists of three documents.
This includes the following:
Program Narrative
Budget Worksheet
Grant Award Amendment
44. Program Narrative
45. Program Narrative Overview
Discuss the following:
proposed change(s) to the project.
reason(s) for project change(s).
Benefits of proposed change(s).
Goal/Objective
List Cal EMA Goal / Objective associated with the proposed change(s).
Activity(ies)
List specific activity(ies) that are being proposed in the revision request.
Task(s) To Be Completed
List task(s) to be completed, as they relate to the proposed revision request activity(ies), as well as to the Cal EMA goals and objectives.
One-Time Special Project Funding Revisions
Complete the lower box section if the revision request is associated with a one-time funded special project (supplemental award).
Please Note: revision requests to one-time funded special project (supplemental award) will require an approval from the Cal EMA Regional Administrator.
46. Budget Worksheet
47. Budget Worksheet Personal Services; Operating Expenses; Equipment;
Management and Administration (M&A); Pass thru to Locals
Breakdown costs in the eligible aforementioned categories.
Complete the Budget Worksheet regardless if category funding amounts are being modified or not.
This section is to include the entirely funded grant award amount.
Be sure TOTAL equates to the OAs total grant funded obligated amount.
One-Time Special Project Funding Revisions
Complete the lower box section if the revision request is associated with a one-time funded special project (supplemental award).
Please Note: revision requests to one-time funded special projects (supplemental award) will require an approval from the Cal EMA Regional Administrator.
48. Grant Award Amendment
49. Grant Award Amendment Have the OA Authorized Agent (AA) sign and date this document and mail it as an original with wet signature directly to the assigned EMPG Program Analyst.
Once the signed amendment is received and combined with the other revision request packet documents, it is submitted to the Agency Secretary, or designee, who approves or denies the revision request.
50. Requesting a Revision Request Packet Revision Request Packets can be obtained upon request by
contacting your regionally assigned Program Analyst.
Please be ready to discuss:
Which OA is requesting a revision;
What grant year is it for;
What changes are being proposed; and
If it is involving a one-time funded special project (supplemental award).
These details help us to better assist you, as well as the
OA to navigate the revision request process.
51. Submission of RevisionRequest Packet Revised Program Narrative and Budget Worksheet are submitted, via e-mail attachment, to the Program Analyst by the EMPG Regional Lead, after they have reviewed it for completeness and errors.
In an effort to expedite processing, Grant Award Amendments are submitted, as originals, directly from the OA to the Program Analyst.
For revision requests requiring Regional Administrator approval, a simple e-mail statement to the Program Analyst approving the revision request is acceptable.
52. Quarterly Progress Reports The OAs must submit performance reports as required. The report must include the progress made on identified activities, as well as other requested information and data.
The last performance is due to Cal EMA by July 31, 2011 (unless extended), and will serve as the final subgrant report.
Failure to submit a performance report could result in subgrant reduction, termination or suspension.
53. Quarterly Progress Report Due Dates OAs must submit their performance report to Cal EMA no later than 30 days after the end of the quarter being reported on.
1st Quarter: July1st through September 30th
Report Due: October 31st
2nd Quarter: October 1st through December 31st
Report Due: January 31st
3rd Quarter: January 1st through March 31st
Report Due: April 30th
Final Report: Cumulative
Report Due: July 31st
54. Quarterly Progress Report Submission Process OA completed performance reports must be signed by the authorized agent of the OA.
An original performance report with wet AA signature is sent to the regional office where it is reviewed by the OA assigned ESC.
After reviewing the ESC will sign and date the performance report to confirm acknowledgement, as well as accuracy of the report.
Completed document will then be submitted to the assigned Program Analyst to be logged and reported on the Cal EMA Transparency Website.
55. Types of OA Performance Reports There are two types of OA Performance Reports documents.
They are the:
Performance Report
Quarterly Reports are completed on this document, such as the 1st, 2nd, and 3rd Quarter Reports.
and
Final Performance Report
This is a cumulative report and thus doesnt just reflect the 4th quarter activities but all activities throughout the grant award period of July 1, 2010 through June 30, 2011.
56. FY2011 EMPG State Guidance-Proposed Changes- The main changes to the FY11 EMPG State Guidance that have been presently identified include the following:
The replacing of the Application of Assistance document with the standardized Cal EMA Grant Award Face Sheet.
Implementation of the Financial Management Forms Workbook (FMFW) for the application, reimbursement request and revision request processes.
Requirement that Reimbursement Requests are submitted by the OAs on a quarterly basis, i.e., every three (3) months, and no later than thirty (30) days after the previous quarter.
57. Questions or Comments?
58. Next Topic of Discussion:
Financial Management
Forms Workbook (FMFW)
60. Topics of Discussion:
61. Financial Management Forms Workbook
62. Financial Management Forms Workbook
63. Financial Management Forms Workbook
64. Financial Management Forms Workbook
65. Financial Management Forms Workbook
66. Financial Management Forms Workbook
67. Financial Management Forms Workbook
68. Financial Management Forms Workbook
69. Financial Management Forms Workbook
70. Financial Management Forms Workbook
71. Financial Management Forms Workbook Instructions Page:
72. Financial Management Forms Workbook Face Sheet:
73. Financial Management Forms Workbook Face Sheet Descriptions:
74. Financial Management Forms Workbook Grant Management Roster:
75. Financial Management Forms Workbook Grant Management Roster Descriptions:
76. Financial Management Forms Workbook Project Ledger:
77. Financial Management Forms Workbook Project Ledger Descriptions:
78. Financial Management Forms Workbook Project Descriptions Page:
79. Financial Management Forms Workbook Project Descriptions:
80. Financial Management Forms Workbook Equipment Inventory:
81. Financial Management Forms Workbook Equipment Inventory Descriptions:
82. Financial Management Forms Workbook Training Roster:
83. Financial Management Forms Workbook Training Roster Descriptions:
84. Financial Management Forms Workbook Planning Roster:
85. Financial Management FormsWorkbook Planning Roster Descriptions:
86. Financial Management Forms Workbook Exercise Roster:
87. Financial Management Forms Workbook Exercise Roster Descriptions:
88. Financial Management Forms Workbook Authorized Agent Page:
89. Financial Management Forms Workbook Authorized Agent Page Descriptions:
90. Cash Reimbursement and Modification Requests
91. Cash Reimbursement Request (without Macros)
92. Cash Reimbursement Request Process
93. Cash Reimbursement Request Process (continue)
94. Modification Request (without Macros)
95. Subgrantee Responsibilities in Modification Requests
96. Questions or Comments?
97. Thank You For Attending!