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Updates and Fixed Awards

Updates and Fixed Awards. Agenda. Omni Circular IPERA NGA Common Audit Findings Fixed Price Awards. OmniCircular. Key areas for Changes that Affect AmeriCorps Grants: Pre-award Assessments Single Audits (A-133 audits) Indirect Costs Time and Activity. Pre-Award Financial Review.

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Updates and Fixed Awards

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  1. Updates and Fixed Awards

  2. Agenda • Omni Circular • IPERA • NGA • Common Audit Findings • Fixed Price Awards

  3. OmniCircular Key areas for Changes that Affect AmeriCorps Grants: • Pre-award Assessments • Single Audits (A-133 audits) • Indirect Costs • Time and Activity

  4. Pre-Award Financial Review What’s Current: Grantees should conduct a financial review to determine if sub-grantees have the capacity to manage federal funds. What’s Coming: Grantees must conduct a financial capacity assessment on subgrantees and are encouraged to also confirm sub-grantees financial stability.

  5. Single Audit Act Requirements (A-133) What’s Current: Grantees who expend $500,000 of Federal funds in a year must conduct an A-133 audit. What’s Coming: The threshold for A-133 audits goes up to $750,000. It applies to the grantee’s fiscal year that begins after December 26, 2014. Example: Fiscal year is July 1 – June 30. Threshold begins for fiscal year July 1, 2015 – June 30, 2016.

  6. Indirect Costs What’s Current: • Grantees must have an established Negotiated Indirect Cost Rate (NIDCR) from their cognizant agency or elect to use the CNCS 5%/10% option for AmeriCorps. • NIDCR must be renewed annually. What’s Coming: • All Federal agencies must allow grantees to claim indirect cost rates. • Grantees without an NIDCR can choose to accept a 10% de minimis rate. For AmeriCorps grantees this becomes a 5%/5% option. • Grantees with a current indirect cost rate may elect to apply for a one-time extension for a period of up to 4 years. • AmeriCorps grantees continue to be capped at 5% of CNCS share. • AmeriCorps grantees that use the CNCS 5%/10% option and do not have an NIDCR will see a decrease in the amount they can claim as match.

  7. Time and Activity What’s Current: Nonprofit organizations must have a time-keeping system in place that - • Tracks time and activity on an after-the-fact basis that accounts for total time. • Is signed by employee or supervisor. • Is prepared at least monthly and coincides with one or more pay periods. What’s coming: Time and activity can be supported by - • A system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. • A system that is incorporated into the official records of the grantee. Rules around member time keeping remain the same.

  8. IPERA IPERA is the Improper Payment Elimination and Recovery Act. Under IPERA, CNCS must determine if programs are susceptible to significant levels of improper payments. CNCS is assessing the level of improper payments by testing a randomly selected sample of individual payments charged to CNCS funding by grantees (or sub-recipients, where applicable) Challenges in submissions Submissions are late and incomplete General ledger does not match FFR amount

  9. IPERA Discussion: How do you determine what is recorded on your FFR? When would it be OK for the general ledger not to match the FFR?

  10. What’s on Your Notice of Grant Award? Review your NGA in eGrantsas soon as you get it and make sure all these elements are correct. Legal Applicant Program and Budget start and end dates Award Description Funding amounts: New Previous Current Unexpended Total to date Aggregate member data by type Link to Provisions/Terms and Conditions Special Conditions Program and Grants Officer name and phone number

  11. Lessons Learned from Common Findings • Procedures must be in place to verify that all costs are adequately documented before entering any costs into the accounting system • Grantees must have timesheets to support employees charging time against the grant • The amount reported on the FFR must match the amount recorded in the general ledger. If it doesn’t for some rational reason, grantees should be able to demonstrate why with a Reconciliation Report • Required background checks must be conducted on grantee staff and members • Grantees should review their policies and procedures for monitoring their sub-grantees to ensure they cover both programmatic and financial requirements • Timesheets are signed by the employee and/or a supervisor • Payments must be well documented and have appropriate approval

  12. Fixed Amount Grants What is a Fixed Amount Grant? • Grantees receive a specific amount per MSY and can only access all of the funds if they recruit and retain 100% of the members. • There is no approved budget in the grant award. • There are no specific restrictions on the use of the grant funds because the amount of the grants will be significantly less than the cost of conducting the program. • The amount awarded is significantly less than the cost of operating the program.

  13. Fixed Amount Grants What are the advantages? • Cost Principles do not apply • No tracking or documentation of cost sharing is required • Budgets are not required during application process • Limited, if any, financial reporting to the Corporation is required; the FFR (SF 425) is not required

  14. Fixed Amount Grants What are the disadvantages? The full amount of the grant can only be accessed if all members complete their terms of service

  15. Fixed Amount Grants What still applies? • Administrative Requirements for Federal grants • Single Audit Regulations • All AmeriCorps member requirements • Living allowance • Citizenship • Age • Criminal history checks

  16. How Does CNCS Monitoring Fixed Grants? Drawdown Analysis • Grants officers cross-check enrollments against drawdowns every six months. • If grantees have drawn down more funds that they should based on enrollments the grants officer will contact the grantee to determine why and work with the grantee to get back on track.

  17. Closing out your Fixed Amount Grant Grants officers will compute the amount the grantee was allowed to access based on data in the My AmeriCorps Portal and the HHS Payment system. Example: Program A is approved for 20 members at $13,000 per member, total $260,000. 17 members complete the term of service. The remaining five members served lesser amounts as follows: Member 18 completed 1125 hours: 1125 ÷ 1700 = 66% x $13,000 = $ 8,580 Member 19 completed 458 hours: 458 ÷ 1700 = 27% x $13,000 = $ 3,502 Member 20 completed 920 hours: 920 ÷ 1700 = 54% x $13,000 = $ 7,020 Total Pro-rated Amounts: $ 19,102 Plus Completed Terms: 17 members x $13,000 = $221,000 Final Grant Amount: $240,102 The grantee drew down $245,000 from the HHS system and owes CNCS $4,898 at closeout.

  18. How do Commissions Monitor Fixed Grants? • Reimbursement based on members on board • Other?

  19. Questions?

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