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Discretionary Grant Administration

Discretionary Grant Administration. Agenda. Overview of ED financial policies Managing budget Avoiding audit problems Identifying key resources such as Grantmaking at ED. www.ed.gov/fund/grant/about/grantmaking/index.html. Tools of the Trade. Legislation Regulations EDGAR

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Discretionary Grant Administration

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  1. Discretionary Grant Administration

  2. Agenda • Overview of ED financial policies • Managing budget • Avoiding audit problems • Identifying key resources such as • Grantmaking at ED www.ed.gov/fund/grant/about/grantmaking/index.html

  3. Tools of the Trade Legislation Regulations EDGAR Cost Principles (2 CFR/OMB Circulars) Grant Award Notification (GAN) Your approved Application *G5

  4. Cost Principles • 2 CFR Part 220 for Educational Institutions • (see OMB Circular A-21) • 2 CFR Part 225—for State, Local and Indian • Tribal Governments • (see OMB Circular A-87) http://www.gpoaccess.gov/cfr/index.htmld

  5. Grantee Responsibilities • Project’s success and financial accountability • Submit annual & final performance reports EDGAR §§74.51 & 80.40 • Valid & reliable data • Report on GPRA standards & indicators

  6. Monetary Road Map • Clear, concise, and detailed • Consistent with institutional policy • Meets federal requirements • Aligned with GPRA • Revised within scope of project • Achieve project goals

  7. Financial Management Systems • must do the following… • Provide for accurate, current, and complete • disclosure of results regarding the use of • project funds • Document both the federal and non-federal • funds used to carry out the project and track • partners

  8. Financial Management Systems • Provide for accurate current, and complete disclosure of results regarding the use of project funds • Document both the federal and non-federal funds used to carry out the project and track partners • Maintain effective internal controls

  9. Budget Items Allowable – permitted or not specifically prohibited Allocable – necessary for project’s success Reasonable – costs incurred by a “prudent” person

  10. Cost Sharing/Matching

  11. Cost Sharing/ Matching • Definition: The portion of project/program costs not borne by the Federal government • Terms are used interchangeably and refer to either: • Statutorily-specified percentage of project/program costs that must be • Voluntary contribution • Grantee must honor the commitment • Fully documented

  12. Cost Sharing/ Matching • Examples include: equipment, facilities, cash • staff time • Must be treated like Federal dollars • See EDGAR 74.23 and 80.24

  13. Cost-ShareCalculation Applicant’s cost-share requirement is 25% of the total cost of the project. Total project: Fed share X applicant share = Match Federal share % of total cost Amount Total project costs = Federal share + Match Amount

  14. Audits

  15. Common Audit Exceptions • Missing time and effort reports • Poor record-keeping • Failure to obtain prior approval • Incorrect indirect cost rates • Unallowable costs • Lack of internal controls

  16. Audit Requirements • Non-Federal audit if expending $500,000 or more annually in Federal awards • Mail to Federal Audit Clearinghouse • Review Attachment C OMB Circular A-133

  17. Grant Monitoring

  18. Drawdown Policy • Request funds for immediate needs • Minimize time between requests & expenditures • Draws commensurate with approved scope

  19. ED’s Drawdown Policy • Draw down only enough cash to meet • grant’s immediate need • Minimize time between drawdown • and payout of funds Rate of drawdown must be commensurate with approved scope of work and milestones

  20. High-risk Designation • Documented unsatisfactory performance • Financially unstable • Non-standard management • Non-conformance to terms/conditions • Otherwise not responsible Necessary to ensure compliance with grant requirements

  21. Grantee Flexibility

  22. Grantee Flexibility • Goals: • Increase flexibility • Increase accountability • Reduce paperwork burden • Develop relationships Promote successful project outcomes

  23. Prior Approval Changes in project scope or objectives Changes in key personnel IHE & non-profit project directors > absent for more than 3 months > 25% reduction in time Need for additional Federal funds

  24. Time Extension • No-cost extensions require RSA Project Officer approval and will be reviewed on a case-by-case basis (Note: Discretionary Grants operated by the Training Programs Unit in RSA are restricted by the terms and conditions of their award under Attachment “Z” in the GAN. • Attachment “Z” does not permit the grantee to extend the grant without RSA approval. • Requests for no-cost extensions must be submitted at least 45 days in advance of the end of the grant period of performance.

  25. Time Extension • No later than 10 days before project ends • State reasons for extension • Include revised expiration date Written notice to Program Officer

  26. Time Extension Restrictions Not just for using unexpended funds No additional Federal funds No change to scope or objectives

  27. ED Concerns • Large amounts of unobligated funds at end of budget period • Excessive or infrequent drawdown of funds • Project goals not met

  28. What Agencies Look For • Annual substantial progress met • GPRA indicators met • Recordkeeping & fiscal accountability

  29. Questions?

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