500 likes | 668 Views
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. Agenda. Introduction Program Planning & Budget Monitoring Evaluation Reporting Resources Q&A.
E N D
National Resource Centers Project Administration September 2010 Amy Wilson, Jessica Barrett Simpson, and Cheryl Gibbs Access to the World and Its Languageswww.ed.gov/ope/iegps
Agenda • Introduction • Program Planning & Budget • Monitoring • Evaluation • Reporting • Resources • Q&A
2. Program Planning • First stage, already completed • Program plans were submitted in application
2. Budget 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 Tips • 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 • 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 - Carryover • 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 Don’ts • 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. Allowable Costs • 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. Draw Downs • 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
3. 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 Progress 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. Essential Tools • 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. EDGAR • 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. Financial Management 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. Internal Controls 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. Personnel Time and Effort • 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. Cost Share/Match • 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. Causes for ED Site Visits • 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. Common Problems to Avoid • 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. Helpful Reminders • 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
4. 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. 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)
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
5. Reporting • 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.
6. 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