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MDE and ISD Partnership: Darkening the Dotted Lines. Monitoring and Compliance Training: Financial Management. Overview. Financial Management Pre-Training Assessment Survey. Financial Management: Allowable Costs. Allowable Costs Overview. Reasonable and necessary Allocable
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MDE and ISD Partnership:Darkening the Dotted Lines Monitoring and Compliance Training: Financial Management
Financial Management Pre-Training Assessment Survey
Financial Management: Allowable Costs
Allowable CostsOverview • Reasonable and necessary • Allocable • Legal under state and local law • Conform with federal law and grant terms
Consistently treated In accordance with GAAP Not included as match Allowable Costs
Allowable Costs: Regulations and Guidance • General Education Provisions Act (GEPA) • Program statute and regulations • EDGAR (Education Department) General Administrative Regulations) Sub Part C, §80.22 Allowable Costs
Allowable Costs: Regulations and Guidance • OMB Circular A 87 State, Local, and Indian Tribal Governments • Section C – Basic Guidelines • Attachment B – Selected Items of Cost
Allowable Costs • Helpful Questions for Analyzing Costs: • Is the proposed cost allowable under the relevant program? • Is the proposed cost consistent with an approved program plan and budget?
Allowable Costs • Is the proposed cost consistent with program specific fiscal rules? • Is the proposed cost consistent with EDGAR?
Allowable Costs:Basis for Allowability • Must follow applicable cost principle to determine reasonableness, allowability, and allocability of all costs • All costs must be: • Necessary • Reasonable • Allocable • Legal under state and local law
Allowable Costs:Necessary • A cost is necessary and reasonable if: • Needed for the performance or administration of the grant • Follows sound business practices; arms length bargaining • Reflects fair market prices for comparable goods or services • Is prudent
Allowable Costs:Necessary • Practical aspects of ‘necessary’ • Do I really need this to administer my program? • Is this the minimum amount I need to spend to meet my need?
Allowable Costs:Reasonable • Practical aspects of ‘reasonable’ • Is this targeted to valid programmatic/administrative considerations? • Do I have capacity to use what I am purchasing for this program?
Allowable Costs:Reasonable • Did I pay a fair rate and can I prove it? • If this expense were in the local newspaper “Headlines”, would I be comfortable?
Allowable Costs:Allocable • Practical aspects of ‘reasonable’ • Can I prove the program benefited? • Time/effort records • Inventory management records • Can I prove other programs are not benefiting? • Ensuring only authorized use • Incidental benefit
Allowable Costs:Adequate • Adequately documented • Amount of funds under grant • How the funds are used • Total cost of the project • Share of costs provided by other sources
Allowable Costs:Adequate • Records that show compliance • Records that show performance • Other records to facilitate an effective audit
Allowable Costs:Compensation for Service • Overview of process • Estimate how employee will work • Pay based on estimate • Reconcile estimates to how actually worked
Allowable Costs:Compensation for Service • Necessary documentation • Payroll records • Time and effort records • Semi-annual certifications (single cost objective) • Personnel Activity Reports (PARs) (multiple cost objectives)
Allowable Costs:Things to Consider • Maintenance of Effort • Supplement vs. Supplant • In-Kind Requirements • LEA Match (soft and hard match) • Timely Amendments • Document, Document, Document
Allowable Costs: FAQs • Is there a list of allowable costs that we can look at to analyze a contemplated cost?No. Although lists are available, they are lists of “allowable, but”, they must meet the other tests spoken to earlier
Allowable Costs: Other Resources • MDE • Office of Audits (Auditing Manual • http://www.michigan.gov/mde/0,1607,7-140-6530_9091---,00.html • MDE – Specific Program Office
Allowable Costs: Other Resources • OMB Circular A-21, Cost Principles for Educational Institutions • Part C: Basic Considerations • Part J: General Provisions for Selected Items of Cost
Allowable Costs: Other Resources • OMB Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments • Appendix A: General Principles for Determining Allowable Costs
Allowable Costs: Other Resources • OMB Circular A-133, Compliance Supplement • OMB Circular A-122, Cost Principles for Non-Profit Organizations • Attachment B, Selected Items of Cost
Allowable Costs: More Information • Contacts • MDE: Specific Program Office • ISD:
LEA Fiscal Review Tool
LEA Fiscal Review Tool • Developed by MDE staff responsible for federal and state fund management • Lists major elements reviewed during an audit performed by MDE state auditors
LEA Fiscal Review Tool • Lists all items contained within the FMS Self-Assessment Survey and reflected in the Professional Development modules • Purpose • To assist an LEA in the development of its own plan for improvement of its FMS
Resources All resources identified in this Professional Development module are available on: Michigan LearnPort www.learnport.org Collaboration Center Community Room LEA Financial Management Resources
Michigan LearnPort • www.learnport.org • A web-based professional development delivery system • Created in partnership with Michigan Virtual University and the Michigan Department of Education
Michigan LearnPort • ISDs and LEAs may use Learnport to assist with easy access to financial documents by uploading files to created community rooms and utilizing discussion forums for centralized, online question and answer banks • LearnPort is free to public schools, ISDs, and employees of the state of Michigan
Michigan LearnPort • Offers full professional development record-keeping capabilities • School employees are provided up-to-date and flexible online professional development to help meet personal and district learning requirements
LearnPort Account Creation • Creating Account • Verification E-Mail • New Account Login • LearnPort Main Page • Accessing LEA Financial Management Resources Room • Online Financial Resources Assistance
Creating Account • Go to learnport.org • Below the login area on the right side of the screen is “New User? CLICK HERE.” Select this link
Creating Account • On this page you will be prompted to enter a username and password • Make sure they are easy to remember • Once you enter all the required sign up information you will be sent a confirmation e-mail to the e-mail that you provided
Verification E-mail • After LearnPort notifies you that you will be sent a confirmation E-mail, check the E-mail address that you used in sign-up after five minutes • You must select the link in the E-mail that LearnPort sends you for your account to be finalized • You won’t be able to log in without doing this
New Account Login • Once you have selected the link to verify your account creation you will be able to access Learnport • Return to learnport.org and enter your account information
LearnPort Main Page • After logging in you will be taken to Learnport’s Main Page • To access the “Community Rooms” where you can create rooms for your own use, or view rooms that are already created you need to select “Collaboration Center” from the left side toolbar • We will be accessing the LEA Financial Management Resources room created by MDE
Accessing LEA Financial Management Resources Room • On the next page there will be 5 buttons to choose from • To access LearnPort’s listing of the available community rooms, select “Community Rooms” • The link to the left of this is where you would create your own room for your ISD/LEA if you would like to
Accessing LEA Financial Management Resources Room • This page will contain a scroll bar in the middle of the screen towards the bottom for scrolling through available rooms • Go down to LEA Financial Management Resources Room and select the link • The “i” in a circle in this section gives a brief informational explanation of the item it is next to, select the words themselves to go to the community room
Online Financial Resources Assistance • The Community Room’s page will appear with several options on the left. • Select “Content” • Within the content area are the reference documents that will assist with Financial Management procedures • Some are links to actual documents • Some are website links to obtain documents
Online Financial Resources Assistance • This room will be kept up to date with any legislation changes and added necessary documents to complete the LEA’s Financial Management Process. • Feel free to use the “Discussion Forums” section of this community room to ask one another questions and provide answers.