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Proper Documentation

Proper Documentation. Kristina Tecce Walker & Company LLP Ktecce@walkerllp.com 877-363-9300. Regulatory Requirements Provide the Guidance & Foundation For Your Financial Management Systems. OMB CIRCULAR REQUIREMENTS. STATE REQUIREMENTS. GRANT PROVISIONS. NOTICE OF GRANT AWARD.

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Proper Documentation

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  1. Proper Documentation Kristina Tecce Walker & Company LLP Ktecce@walkerllp.com 877-363-9300

  2. Regulatory Requirements Provide the Guidance & Foundation For Your Financial Management Systems OMB CIRCULAR REQUIREMENTS STATE REQUIREMENTS GRANT PROVISIONS NOTICE OF GRANT AWARD PROGRAM

  3. Determination of Acceptability of Costs • Conditions in award letter • Provisions • OMB Circulars • Program Applicability • Allocable • Allowable • Reasonable • Necessary

  4. Reasonable Costs • A cost is reasonable if it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the costs. The question of the reasonableness of specific costs must be scrutinized with particular care in connection with organizations or divisions which receive the preponderance of their support from awards made by Federal agencies. Definition from OMB Cost Circular

  5. Efficient Accounting System • The Grantees accounting system must be capable of: • Distinguishing grant versus non-grant related expenditures • Identifying costs by program year • Identifying costs by budget category • Differentiating between direct and indirect costs (administrative costs) • Accounting for each award/grant separately • Ideally recording in-kind contribution as revenue and the related expense

  6. Matching • Match: • Must be verifiable from recipient records • Must not be included as contribution for other federally-assisted program • Must be necessary and reasonable for accomplishing program objectives • Must be allowable according to cost principles (OMB Circulars)

  7. Documentation Documentation should ensure that all costs are: • Reasonable and allocable • Conform to grant/contract limitations • Treated consistently • Recorded in accordance with Generally Accepted Accounting Principles (GAAP) • Not included as cost or match for other federally-assisted program

  8. Documentation Objective • All documentation (federal and grantee shares) should contain information that supports: • Whatis the service or good obtained • Why the transaction is allowable for the grant purposes • The value of the contribution • Accounting records should trace back to source documentation

  9. Time & Activity Documentation

  10. Time & Activity Documentation • All salaries and wages charged to CNCS grants must be supported by signed Time and Attendance records except for: • State, Local and Indian Tribal governments must comply with OMB A-87 • Educational Institutions must comply with OMB A-21 • Time must be based on after-the-fact activity and not based on a predetermined basis

  11. Time & Activity Reporting Nonprofit Organizations According to OMB Circular A-122 • Reports reflecting the distribution of activity of each employee must be maintained for all those whose compensation is charged (in whole or in part) to awards. The reports must reflect an after-the-fact determination of the actual activity of each employee. Budget estimates do not qualify as support. • Activity reports must be signed by the employee and supervisor.

  12. Time & Activity ReportingState or Local Government According to OMB Circular A-87 • If an employee works on a single Federal award – support for salary can be periodic certifications by the employee (at least semi-annually) • If an employee work on multiple cost objectives/activities, support must be 1) after the fact, 2) account for total hours worked 3) be prepared at least monthly and 4) signed by employee and supervisor

  13. OMB A-87 requirements of documentation for Activity reporting: • Must reflect an after-the-fact distribution of each employee’s actual activity • Must account for the total activity of each employee • Must be prepared at least monthly and should coincide with one or more pay periods • Must be signed by the employee

  14. Time & Activity OMB A-87: Budget estimates do not qualify as support for expenditure, except on an interim basis, provided that: • The estimates produce reasonable approximation of the actual activity performed • Quarterly comparison to actual activity is performed • Budget estimates are revised at least quarterly to reflect changed circumstances

  15. Documenting In-Kind Contributions Received Document the basis for determining the value of personal services, material equipment, building, and land. Obtain acknowledgement of the contribution which should include: * Name of donor * Date and Location of donation * Description of item/service * Estimated value Keep a copy of the receipt in your files.

  16. Records Retention • Retain all financial records: • 3 years from date of submission of final Financial Status Report • If there is an on-going audit: 3 years from final audit resolution

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