SIF Sub-Grantees Subaward Agreement/ MOU Webinar

1. SIF Sub-GranteesSubaward Agreement/ MOU Webinar Prepared by Steve Adams, Deputy Director, NFWS February 11, 2011

2. Agenda • Introduction • Why The Language is There • Reviewing Subaward Agreement • Reviewing MOU • Other Discussion

3. Introductions • Steve Adams (NFWS) • Shannon Mason (NFWS) • Jill Moriello (JFF Grants Management Analyst) • Ruth French – auditor at JFF (fed funds experience)

4. We’re new at federal subgranting • Re-granting federal funds is fairly new to us. So we haven’t tested our subaward agreements much. • Subaward could have been clearer and with fewer requirements. • We should have provided additional guidance along with fiscal webinar.

5. Why the language is there • Our federal grant from CNCS/SIF requires that we notify subgrantees that the same rules apply to them • We have to show we’re in compliance • Again, could have been clearer with you

6. The Subaward agreement • Go to Subaward agreement • Go to MOU

7. Cost Principals • Allowable/Unallowable • Allocable • Reasonable • Consistent

8. Allowable Costs • Be included in the Approved Budget • Be reasonable and allocable for the performance of the award • Be given consistent treatment within the entire organization • Be in accordance with GAAP • Not included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program

9. Unallowable Costs • Examples • Lobbying • Fines and Penalties • Expenses not necessary to meet program objectives • Costs that would constitute waste, fraud and abuse • Unreasonable costs from a “prudent person” perspective

10. Allocable Costs • A cost is allocable to the grant if: • It is treated consistently with other costs incurred for the same purpose in like circumstances and if: • It is incurred specifically for the award • Benefits both the award and other work and can be distributed in reasonable proportion to the benefits received or • Is necessary to the overall operation of the organization

11. Reasonable • A cost is reasonable if, in its nature or amount, 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

12. Consistent • Grantees must be consistent in assigning costs • Regardless of the source of funding, i.e. federally or non-federally sponsored activities, and • Following written cost allocation plan, as applicable • Charges must be consistent with those normally allowed in like circumstances in the organization’s non-federally sponsored activities

13. Proper Documentation is a Must Allowable Allocable Reasonable Consistently Applied Document, Document, Document

14. Tracking Federal Intermediary and Sub-Grantee Revenues and Expenditures

15. Efficient Accounting System • Accounting system must be capable of: • Distinguishing between grant vs. non grant related expenditures • Identifying costs by Program Year • Identifying costs by Budget Category • Accounting for each award/grant separately • Properly segregates fund sources • Easily provide management with financial reports at both the detail and summary levels

16. Fiscal Responsibility Highlights • Effective Financial Management • Written and followed policies and procedures • Qualified and trained financial staff • Effective communications • Succession planning and cross-training • Self-assessment and continuous improvement • Active, knowledgeable and informed Board and finance committee

17. Fiscal Responsibility Highlights (continued) • Overall compliance with State and Federal regulations • Accurate, timely and complete financial reporting • Tracking of budget to actual expenses • Ensure key staff understand roles, responsibility, understand each other’s priorities and work together

18. Criminal History Check • Statewide Criminal History Search • www.NationalSexOffenderRegistry.gov • Differs by State • FBI can be substituted for a statewide search • Murder is the only disqualifier • Required personnel: • Anyone receiving a salary • Prime or Sub-grantee level—all are required • Refer to CNCS FAQ on website for further assistance

19. DISCUSSION 19