Welcome

1. Fiscal & Grants Management Webinar 2019-20Goal: To provide guidance to new Ohio AmeriCorps subgrantees and new staff of continuing programs on the financial, grants management and compliance requirements of operating a federally-funded AmeriCorps subgrant. Welcome This session will be particularly helpful for new AmeriCorps fiscal staff and newly-funded sub-grantees **************** While waiting to begin, please sign in to the Chat Box, with your name and organization, and any questions you have. Note: this presentation is being recorded. The Webinar Slides are posted on our website under Ohio AmeriCorps Program Director Resources Financial Management Resources and may be found here Strengthening Ohio Communities through Service and Volunteerism.

2. Staff Introductions ServeOhio strengthens communities through AmeriCorps and volunteer engagement.

3. What you need to knowto meet the fiscal/grants management requirements of an Ohio AmeriCorps grant award see CNCS Financial and Grants Management 101 Basics Strengthening Ohio Communities through Service and Volunteerism.

4. Strengthening Ohio Communities through Service and Volunteerism.

5. Regulations and Requirements • Award recipients must read, understand, implement & comply with all Rules, Regulations and Requirements of Federal and AmeriCorps funds, once you accept Federal money. • Compliance is not optional! • Consequences for non-compliance vary depending on the nature and severity of the non-compliance. For example, late reporting may result in suspension or loss of funding, or failure to document costs may result in disallowed costs and having to repay the government or jail time. ServeOhio strengthens communities through AmeriCorps and volunteer engagement.

6. Regulations and Requirements • Award Recipients Must Comply with include, but are not limited to: • National & Community Service Act of 1990 • Serve America Act (2009) • 2 CFR Part 200 aka Uniform Guidance and Part 2205 • State and Local Rules/Regulations • Grant Terms and Conditions (CNCS and ServeOhio) • Notice of Grant Award • Approved Application and Budget • Grant Certifications and Assurances • Notice of Funding Availability • Your Agency Policies and Procedures See page 2 of the CNCS General Terms and Conditions Strengthening Ohio Communities through Service and Volunteerism.

7. Topics Written Policies/Procedures (2 CFR 200.302) Internal Controls (2 CFR 200.303) Accounting System Requirements (2 CFR 200.302) Standards for Documentation (2 CFR 200) Common Audit Findings/Problems – Highlights For full list of recent/common audit findings, click here Ohio AmeriCorps Guidance & Terms and Conditions Strengthening Ohio Communities through Service and Volunteerism.

8. Documentation Standards – Personnel Expenses • See 2 CFR 200.430 (i) • Charges for salaries and wages must be based on records that accurately reflect the work performed. These records must: • Be supported by a system of internal control which provides reasonable assurance the charges are accurate, allowable and properly allocated • Be incorporated into the official records of the organization • Reflect the total activity for which the employee is compensated (grant and matching funds)  • Support the distribution of salaries and wages chargeable between this grant and other programs or functions if the employee is less than 100% on the AmeriCorps grant. • NOTE: state and local government agencies see 2 CFR 200.430 (x)(5) for substitute systems; IHEs see 2 CFR 200.430 (h) for additional information. Strengthening Ohio Communities through Service and Volunteerism.

9. Staff Time and Attendance2 CFR 200.430 Accountability Problem: Time & effort not properly documented Timesheets: Time based on budgeted not actual after-the fact time reported on timesheets Not signed by supervisor and employee Hours added incorrectly Missing timesheets Staff allocating time to more than one grant are not keeping timesheets that show actual time spent on each grant. Remedy: Periodically conduct your own timesheet review or audit Ensure you have a system of internal controls on timekeeping in line with the Uniform Guidance Strengthening Ohio Communities through Service and Volunteerism.

10. Documentation of Staff Time • Based on the Uniform Guidance, ServeOhio expects programs to use timesheets and/or Personnel Activity Reports to track staff time. Any alternate mechanism must receive prior approval by OCSV. Timesheets/PARS must: • Show total hours worked each day; account for total activity of employee, not just time spent on AmeriCorps only (if less than 100% on grant)  • Be signed/dated by employee and supervisor and kept on file (unless agency requires only one signature); and include a certification statement. • Be completed after the fact.  • Be based on actual, not budgeted time. Organizations may estimate time on an interim basis, but ultimately must show they are charging based on the time and activity data, and not charging grants based on budgeted time.   • Be prepared at least monthly, and coincide with one or more pay periods. • (For sample forms and OMB Cost Principles, see CNCS Staff Timesheets: Requirements and Issues) Strengthening Ohio Communities through Service and Volunteerism.

11. Cost Sharing or Match – 2 CFR 200.306 (b) Matching funds and all contributions, including cash and third-party in-kind contributions, must be accepted when they meet all the following criteria: Are verifiable from the non-Federal entity's records; (2) Are not included as contributions for any other Federal award; (3) Are necessary and reasonable for accomplishment of project or program objectives; (4) Are allowable under Subpart E—Cost Principles of this part; (5) Are not paid by the Federal Government under another Federal award, except where the Federal statute authorizing a program specifically provides that Federal funds made available for such program can be applied to matching or cost sharing requirements of other Federal programs; (6) Are provided for in the approved budget when required by the Federal awarding agency; and (7) Conform to other provisions of this part, as applicable. Strengthening Ohio Communities through Service and Volunteerism.

12. Cost Sharing or Match – 2 CFR 200.306 (b) Accountability Problem: Match Not met Undocumented or insufficient, e.g., in-kind time Unallowable – subgrantee claims match for an activity that doesn’t appear in the approved budget Unreasonable – subgrantee claims match that is excessive Not approved in budget – subgrantee substitutes match for activities not in the approved budget Uses unauthorized Federal funds (Note: Other Federal funds may be used with permission of other Federal funder) Remedy: Make sure claimed match is reasonable and included in the Approved Budget, and supports approved activities. Request budget modification if necessary. Record all claimed match in accounting journals. Make sure claimed match is appropriate and supporting documentation is maintained. Make sure match is allowable under 2 CFR 200 Subpart E-Cost Principles. Strengthening Ohio Communities through Service and Volunteerism.

13. Match – 2 CFR 200.306 (b) Accountability Problem: In-kind Contributions – Insufficient documentation Have the same documentation requirements as other expenditures. Documentation must be kept to support the value placed on the contribution. Documentation for staff hours must be explicitly identified. Remedy: Create a form on which 3rd party donors can record in-kind support. For in-kind staff time – maintain a timesheet and/orPAR that differentiates between AmeriCorps and non-AmeriCorps time, and tracks actual hours. see CNCS Match: Documenting Cash and In-kind and ServeOhio AmeriCorps Program Director Financial Management Resources when using OnCorps Reports for Site Supervisory in-kind time documentation requirements Strengthening Ohio Communities through Service and Volunteerism.

14. Organization Accounting Requirements Internal Controls – 2 CFR 200.303 • The non-Federal entity must: • Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). • See the Uniform Guidance for bullets (b) – (e) Strengthening Ohio Communities through Service and Volunteerism.

15. Organization Accounting Requirements Internal Controls – 2 CFR 200.303 • Common Audit Findings: Inadequate internal controls - Costs not allocated properly, financial reporting incomplete, lack of written policies and procedures, separation of duties. • Remedy: • Segregate financial responsibilities of staff. • Review and reconcile budget to actual expenditures for accuracy prior to report submission. • Keep a clear audit trail that properly documents and records expenses. • Follow written policies and procedures. Strengthening Ohio Communities through Service and Volunteerism.

16. Organization Accounting RequirementsInternal Controls (Remedy cont.) • Retain documentation that supports staff time spent on the grant (and other activities if less than 100%); Note: member time keeping is for Education Award. • Prepare all financial reports with information from the accounting system. • Adequate review process for financial reports and budgets. • Adequate cash management procedures. • Monthly bank reconciliations. • A system to follow-upon identified problems to ensure resolution. See U.S. Government Accountability Office Standards for Internal Control in the Federal Government, i.e., Green Book Strengthening Ohio Communities through Service and Volunteerism.

17. Other CNCS Common OIG Audit Findings FFRs (AFR/PERs) do not reconcile to internal accounting records (GL) (2 CFR 200.302) Costs incurred outside of the budget period are charged to the grant (2 CFR 200.309-Period of Performance) Organizations do not separate accounting records for different funding sources (2 CFR 200.302) Strengthening Ohio Communities through Service and Volunteerism.

18. Solid Grant/Fiscal Management All the required financial systems, policies, procedures, and separation of duties are in place and followed. Consistent checks and balances are established, written and followed. Strengthening Ohio Communities through Service and Volunteerism.

19. Accounting System Requirements 2 CFR Part 200.302 Be able to document and verify all costs – grant and match, cash and in-kind. Record in-kind as revenue and expense. Account for each award/grant separately. Record financial transactions by budget line item and program year. Distinguish between federal and non-federal funds. Distinguish between direct and indirect costs. Provide management with financial reports at both the summary or detailed levels that will compare budget to actual amounts. Correlate financial reports submitted to OCSV directlyto accounting information and supporting documents. Strengthening Ohio Communities through Service and Volunteerism.

20. Adequate Documentation Expenditures – documentation should support an expense from Initiation to Payment Staff (employee or in-kind) – Timesheet or PAR (IHE or state agency) In-kind – 3rd party in-kind form ServeOhio strengthens communities through AmeriCorps and volunteer engagement.

21. Requirements of Document Descriptions Descriptions on payment documents must adequately prove that expenses charged to awards are allowable, reasonable and allocable Allowable In accordance with the terms and conditions of the award and as specified in the narrative and budget (see 2 CFR 200.403) Reasonable What a “prudent person” would spend (see 2 CFR 200.404) Allocable Necessary and charged in proportion to the benefit received (see 2 CFR 200.405) ServeOhio strengthens communities through AmeriCorps and volunteer engagement.

22. Good Descriptions Should contain the five W’s Who? Employee X What? ServeOhio Conference Where? Columbus, OH When? 10/22/19 – 10/23/19 Why? (benefit to the award) Enhance Employee X’s knowledge about service and volunteerism as it relates to operating an AmeriCorps program and managing members and volunteers. Sample Description Travel by Employee X from 10/22/2019 through 10/23/2019 to Columbus to attend and participate in ServeOhio’s Conference on Service and Volunteering…(list of daily commute and activities). Information gained from this conference will enhance Employee X’s knowledge about Service and Volunteerism (and attendance is mandatory!). ServeOhio strengthens communities through AmeriCorps and volunteer engagement.

23. Good Descriptions What happens if good descriptions and adequate documentation are not provided? (see 2 CFR 200.53) • “…any payment where insufficient or lack of documentation prevents a reviewer from discerning whether a payment was proper” • Can be deemed an improper payment and disallowed. Remedy: Verification – to ensure compliance and avoid disallowed costs, verify the adequacy of descriptions and supporting documentation, provide clarifications or additional documentation, as needed. ServeOhio strengthens communities through AmeriCorps and volunteer engagement.

24. Now that you understand the fiscal requirements for managing Federal funds, and have ensured your agency policies and procedures, accounting system and internal controls are compliant, let’s discuss the financial management requirements for your Ohio AmeriCorps grant. Strengthening Ohio Communities through Service and Volunteerism.

25. Legislative and Regulatory Authorities National and Community Service Act of 1990, as amended Domestic Volunteer Service Act of 1973, as amended Serve America Act 2009 Federal Grant and Cooperative Agreement Act, 31 USC 6301-6308; and CNCS’ implanting regulations in 45 CFR Chapter XII and/or XXV. Other Applicable Terms and Conditions Uniform Guidance – 2 CFR Part 200 and 2205 AmeriCorps State and National Grants Terms and Conditions Applicable statutes, executive orders, regulations and policies governing the awardplus 6 other requirements outlined in the Terms and Conditions cited above Ohio AmeriCorps Supplementary Terms and Conditions Award recipients must read, understand, implement & comply with all authorities, etc. Governing Authoritiessee CNCS FY2019 General Grant and Cooperative AgreementTerms and Conditions, p.2 Strengthening Ohio Communities through Service and Volunteerism.

26. Terminology/Acronyms Once you are recommended for funding, ServeOhio aka OCSV, the Commission(Ohio Commission on Service and Volunteerism) issues you (our Sub-grantee aka subgrantee, subgrant) NOGA (Notice of Grant Award), and OSTC (Ohio AmeriCorps Supplementary Terms & Conditions) by email. Strengthening Ohio Communities through Service and Volunteerism.

27. Ohio Supplementary Terms & Conditionssee OSTC-5 and OSTC-6 for grants and financial management requirements Strengthening Ohio Communities through Service and Volunteerism.

28. OSTC-5.7 lists three (3) items all subgrantees must submit to fully execute your award and before you can request funds. AND Subgrantees new to receiving funds through the state, must register as a State of Ohio supplier in the Supplier Portal and register for EFT. Note: if you already have a supplier ID, email it tolisa.tope@serveohio.gov Ohio Supplementary Terms & Conditions Strengthening Ohio Communities through Service and Volunteerism.

29. Financial Reporting in OnCorps Cost Reimbursement subgrantees (OSTC 6.2)Use OnCorps online reporting system for all financial reporting, unless otherwise noted. Fixed Amount subgrantees – NA(OSTC 6.4.7) Do not use OnCorps for financial reporting. You are excluded from the reporting discussed on the next slides, including the Periodic Expense Report, Aggregate Financial Report, Unused Funds Estimate and reporting Other Federal Funds. Strengthening Ohio Communities through Service and Volunteerism.

30. OnCorps (OSTC 6.2) Once your APO (AmeriCorps Program Officer) gives you access, set Notifications to receive emails or home page notifications from OCSV when financial reports are approved or returned. 1) Login, then on the menu bar, go to 2) Tools 3) Administrative Tools 4) Email Notifications On/Off Strengthening Ohio Communities through Service and Volunteerism.

31. Once you are set up in OnCorps and have your Notifications set, what’s next? 1) Submit Approved eGrants Budget in OnCorps within 15 days of receiving the NOGA (OSTC-6.3) Ohio Supplementary Terms & ConditionsOSTC-6.3 Strengthening Ohio Communities through Service and Volunteerism.

32. OnCorps(OSTC 6.4) 2) Submit Periodic Expense Reports in OnCorps Basic “rule” for all Reports: Submit in OnCorps (unless otherwise noted), Submit on-time,Submit without errors. *Late reports are recorded for consideration in grant renewal process**Failure to report may result in suspension of funding (OSTC-6.8)* Extension Requests must be submitted two business days in advance of due date (email) (OSTC-6.7) Strengthening Ohio Communities through Service and Volunteerism.

33. Periodic Expense Report (PER) • Required Quarterly (OSTC-6.4) (see AmeriCorps Reporting Periods & Due Dates), but may be submitted once monthly, if requesting funds (OSTC-6.4.2) • Shows federal and match expenditures according to budget category, by line item • Shows match percentage being met on subgrantee spending, including match on OCSV administrative share • It is used to show 100% of grant spending • It’s used as part of grant payment process Notes • Submit one (1) PER at the due date - do not submit prior month PERs on the date the required PER is due. This delays the approval process of the required reports for the entire portfolio. • When selecting the reporting period, select the end date of the reporting period, not the month in which the report is submitted. • Include OCSV admin – (OSTC 6.4.3) Strengthening Ohio Communities through Service and Volunteerism.

34. Financial Reporting Periods & Due DatesPeriodic Expense Report (PER) Grant Year: 2019-2020 Strengthening Ohio Communities through Service and Volunteerism.

35. Budget Changes (OSTC 5.4) Discuss any budget changes with your program officer Submit Budget Modification Request (in OnCorps) for changes exceeding 10% of total budget (federal and match shares) Changes under 10% of total budget may not require budget modification; approved budget lines may be over/under spent as necessary (see T&C and UG) EXCEPTIONS: Expenditures requiring specific prior written approval per 2 CFR 200.407. If adding costs to a budget line or category that had $0 in the Approved Budget, a budget modification is required regardless of the amount. This applies to formula and competitive-funded programs. In addition, for competitive funded programs, changes must be approved by CNCS via grant amendment. Strengthening Ohio Communities through Service and Volunteerism.

36. How do I Request Funds from the Grant? Strengthening Ohio Communities through Service and Volunteerism.

37. Fixed Amount subgrantees (OSTC-5.8.1) Submit the Request for Funds-Fixed Amount (RFF-FA) form; and eGrants Drawdown Calculations and Amounts Report. See User Guide Submit request via email (signed and scanned) to my attention @ lisa.tope@serveohio.gov Cost Reimbursement subgrantees (OSTC-5.8.2) Submit payment requests in OnCorps, using the Request for Funds(RFF) – Payment Calculator box located in the Periodic Expense Report (PER). Advance payment request allowed for initial start up costs only (OSTC 5.8.2) and must be reconciled in accordance with 2 CFR 200.305 A grant payment will be made, with each PER submission Note: PERs and payment requests are required quarterly for all subgrantees, but may be submitted monthly (once every 30 days) Ohio Supplementary Terms & Conditions OSTC-5.8 *The entire process, from receipt of sub-grantee request to issuance of EFT generally takes four weeks or less. Strengthening Ohio Communities through Service and Volunteerism.

38. Other Financial/Grants Management Ohio Supplementary Terms and Conditions – OSTC-5 and OSTC-6 Highlights Strengthening Ohio Communities through Service and Volunteerism.

39. 2019-20 Ohio Supplementary Terms & Conditions

40. 2019-20 Ohio Supplementary Terms & Conditions Strengthening Ohio Communities through Service and Volunteerism.

41. 2017-18 Ohio Supplementary Terms & Conditions Strengthening Ohio Communities through Service and Volunteerism.

42. What other grants/fiscal information do I need to know as I’m starting my program? See ServeOhio website: Financial Management Resources . Strengthening Ohio Communities through Service and Volunteerism.

43. Members only receive a stipend while they are serving. A living allowance is not a wage Not paid on an hourly basis Paid in regular increments, such as weekly, bi-weekly, monthly Payments should not fluctuate based on the member start date or the number of hours served in a particular time period Payments can only be held if member is suspended Payments must cease when a member ends a term of service. Member Stipend Guidance Strengthening Ohio Communities through Service and Volunteerism.

44. Member Living Allowance Distribution(see CNCS AmeriCorps T&C VIII.A.) If a member serves 1700 hours but is permitted to conclude a term of service before the originally agreed upon date, the program may not provide a “lump sum” payment to the member. Similarly, if a member enrolls after the program’s start date, the program must provide regular living allowance payments from the member’s start date and may not increase the member’s living allowance incremental payment or provide a lump sum to “make up” any missed payments. Strengthening Ohio Communities through Service and Volunteerism.

45. Distribution of Member Stipend Example when setting up your distribution, use current year stipend amount Subgrantee: Determine the length of your program (e.g., 12 months) Determine the number of stipend payments to distribute over length of program (e.g., 26) Determine the amount (increment) of each payment (divide the total stipend by the number of payments) Note: Example minimum stipend for FT member is $12,630 Strengthening Ohio Communities through Service and Volunteerism.

46. Member Living Allowance DistributionExample 1) Length of program – 12 months 2) number of stipend payments – 26 pays biweekly 3) Stipend increment – $12,630/26=$485.77 (FT) 1 member x 26 pays@ $485.77/each pay for a total up to $12,630 Strengthening Ohio Communities through Service and Volunteerism.

47. Under no circumstance is the subgrantee allowed to recalculate the member stipend distribution amount for members starting late or ending early Recalculating the distribution amount for members starting late to “catch them up” to the total paid to date is not allowed Recalculating the distribution amount “to payout” the remaining stipend for a member allowed to exit early is not allowed Member Living Allowance Distribution Strengthening Ohio Communities through Service and Volunteerism.

48. Member Living Allowance DistributionOCSV Guidance Establish a written policy that is reasonable and followed consistently: Outlining your practice of distributing the living allowance for FT and less than FT members, including HT members serving in a FT capacity; and For members who come on late or exit early. For example, if members are paid on a monthly basis and a member comes on board within the first two weeks of the month, you might set policy that gives them the entire living allowance. If they start service later than that, you could prorate the amount based on the number of days (not hours) in the month they will serve. The same would hold true for the end of service. If they leave within the first two weeks of the month, their living allowance is based on the number of days in the month they served. If they serve over the 2-week cut-off, they would get the full living allowance. You can establish different cut-off points as long as they are reasonable, documented in policy, and followed consistently. Strengthening Ohio Communities through Service and Volunteerism.

49. FT Member Stipend Payment Distribution – EXAMPLE Program X has a 12-month tutoring program beginning 8/1/19 and ending 7/31/20. The corps consists of all FT members. Member stipend payments are set up and distributed over the length of the program in equal increments across 26 pays. Program X enrolls 15 of its 20 members on 8/1/19. If they end on-time as scheduled, they will receive their entire stipend. FT members may be enrolled up to 45 days after the program start date. Program X enrolls the other 5 members on 9/1/19. Their stipend payments will be set up in the same equal increments as the other full-time members who started 8/1/19. If they are allowed to serve after the program end date (for a full 12 months), they may receive the entire stipend. If they cannot serve after the program end date, they will receive the amount of stipend for the period they serve (i.e., 11/12th of stipend vs. 12/12th as they started 1 month after the program start date). Strengthening Ohio Communities through Service and Volunteerism.

50. HT Member Stipend Payment Distribution – EXAMPLE Half-time members starting at the beginning of the program will have their stipend payments distributed evenly over 12 months. If they start after, see above example for distribution. Half-time members may start up to 6 months after the program start date and serve in a full-time capacity (with prior approval from OCSV). If so, their stipend will be divided evenly over the 6-month period. In all cases the member contract will be written to reflect members actual start/end dates and the distribution amount of the stipend payment set up accordingly in the accounting system. Strengthening Ohio Communities through Service and Volunteerism.