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SS/HS Grantee Meeting December 1, 2005. Grants Administration Bryan Williams & Richard Lucey Office of Safe and Drug-Free Schools U.S. Department of Education. Monitoring and Reporting Requirements. Notify Monitor of Changes Post-Award Call Grant Performance Reports
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SS/HS Grantee MeetingDecember 1, 2005 Grants Administration Bryan Williams & Richard Lucey Office of Safe and Drug-Free Schools U.S. Department of Education
Monitoring and Reporting Requirements • Notify Monitor of Changes • Post-Award Call • Grant Performance Reports • Semiannual, Annual and Final Reports
Grant Performance Report (ED 524B) • ED’s generic performance report for discretionary grants • Used by ED’s program offices as a semiannual,annual and final performance report
Purpose of ED 524B • ED collects performance measures data from grantees to demonstrate program success to Congress (Government Performance and Results Act) • Performance information: • Guides ED’s budget request for programs • Ensures program implementation is focused on results • Ensures success is measured by results achieved
Purpose of ED 524B • Financial and performance monitoring tool for ED program offices for individual grants • Semiannual and Annual Reports: Grantees provide data to demonstrate that they are making substantial progress toward meeting approved goals, objectives, and performance measures to receive continuation funding. • Final Reports: Grantees provide data to demonstrate overall project success and impact.
Site Visits • Site visits are a grant monitoring tool as provided for in EDGAR Part 74.51(g), “The Secretary may make site visits, as needed.” • Also called an on-site review • A site visit may last multiple days
Site Visits Reasons to conduct a site visit • Program performance - Excellent • Goals and objectives achieved in unique or innovative ways • Development of effective strategies that may be replicable at other sites
Site Visits Reasons to conduct a site visit • Program performance - Problem • Difficulty achieving goals and objectives • Compliance issues • Fiscal improprieties • Technical assistance
Site Visits What goes into site visit decision • Review of materials • Performance reports • Financial reports • Performance calls
Site Visits What goes into site visit decision • Review of materials • Correspondence • Communication with grant personnel • Request for technical assistance
Fiscal Management • Excessive Drawdown Memo to discretionary grantees • Draw down funds only as necessary • Project director should continually monitor fiscal activity • Excessive Drawdowns • First Quarter: 50 percent or more • Second Quarter: 80 percent or more • Third Quarter: 100 percent
Audit Requirements • Two types of audits • Grantee-Initiated Audit • Independent Auditor • Compliance with OMB Circular A-133 • Expend more than $500,000 or more in collective Federal funds annually must have a single audit or program-specific audit performed for that year
Audit Requirements • Two types of audits • OIG Audit • Office of Inspector General • Not every grantee is audited • Office of Chief Financial Officer reviews A-133 audit reports • OIG audit triggered by serious audit findings identified by OCFO • Questions? Contact grant monitor
Expanded Authorities • Pre-Award Costs • Budget Transfers • Carryover • No-Cost Time Extensions
Expanded AuthoritiesPre-Award Costs • Parts 74.25(e)(1) and 75.263 • No prior approval up to 90 days prior • New and continuation awards • Reasonable expectation • Expenditures incurred at own risk • Funds unavailable pre-budget period
Expanded AuthoritiesBudget Transfers • Attachment Z limits budget transfers • Must have FPO approval to transfer more than 10% of funds in a single budget (1,2,5,6 or 3,4) • No funds transferred between budgets 1,2,5,6 and 3,4. • Questions about transfer approval? Ask your FPO.
Expanded AuthoritiesBudget Transfers • Under 10%, no prior approval required unless: • Change in project scope, objectives, or activities • Change in key personnel • Notify grant monitor of transfer • Amount of money • Identify budget and categories • Purpose
Expanded AuthoritiesCarryover • Parts 74.25(e)(3) and 75.253(c)(1) • Unexpended funds automatically carry over from one budget period to the next without prior approval • Written justification needed prior to continuation award • Carryover budget must be approved
Expanded AuthoritiesNo-Cost Time Extensions • Parts 74.25(e)(2) and 75.261 • One-time extension for up to 12 months without prior approval • Written justification needed at least 10 days prior to extension • Cannot be for the purpose of exhausting unexpended funds • Cannot require additional funds nor change the project’s scope or objectives
Freedom of Information Act (FOIA) • Any person has the right to request access to federal agency records or information • All records must be made available (application, performance reports, correspondence), except: • Privileged or confidential information • Personal information
Freedom of Information Act (FOIA) • FOIA Process • Project Director contacted • 10 days to respond to ED • Memo to FOIA Officer from ED • Information sent to requestor • Fee involved: research and personnel
Human Subjects Research • Research – “systematic investigation” • Human Subject – “an individual about whom an investigator obtains data or identifiable private information” • Activities include surveys, focus groups • Clearance from ED’s Human Subjects Research group is required • Questions? Contact FPO and/or Helene Deramond (Helene.Deramond@ed.gov)
Useful Resources • EDGAR (Education Department General Administrative Regulations) • Book (not a person) • Reference Tool • Part 75 Direct Grant Programs, but all applicable
Useful Resources • Education Department General Administrative Regulations (EDGAR) http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html • OMB Circulars http://www.whitehouse.gov/omb/circulars/ OMB Circular A-87 • Grant Policy Bulletins http://www.ed.gov/policy/fund/guid/gposbul/gposbul.html
Useful Resources • Monitoring for Excessive Drawdowns www.ed.gov/policy/fund/guid/gposbul/gpos27.html • So You Want to Know About Indirect Costs www.ed.gov/about/offices/list/ocfo/fipao/abouticg.html • Human Subjects www.ed.gov/about/offices/list/ocfo/humansub.html
Useful Resources SS/HS Website www.sshs.samhsa.gov SS/HS Federal Partners websites – may contain other useful resources www.ed.gov www.samhsa.gov www.ojjdp.ncjrs.org/