Federal Grant Management

1. Federal Programs Directors’ Meeting March 12, 2014 WVDE Office of Federal Programs Melanie Purkey Robert Crawford Laura Pauley Federal Grant Management

2. Overview • Legal Structure/Resources • Fiscal Potpourri • Procurement • Inventory Management • Time and Effort • Tracking Budget Expenditures • Carryover/Period of Availability • Maximizing Federal Funds

3. Legal Structures for Federal Programs • Statutes/Legislation • Program Statutes (NCLB, IDEA, Perkins) • General Education Provisions Act (GEPA) • Regulations • Program Regulations • Education Department General Administrative Regulations (EDGAR) • Office of Management and Budget Circulars • Guidance • Non-Regulatory Guidance

4. Grants Management Resources • Program Guidance:www.ed.gov • Statutes • Regulations • Guidance • General Education Provisions Act (GEPA): http://www.law.cornell.edu/uscode/20/usc_sup_01_20_10_31.html • Education Department General Administrative Regulations (EDGAR): http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html

5. Grants Management Resources • Office of Management & Budget (OMB) Circulars: http://www.whitehouse.gov/omb/circulars • Circular A-87 principles for allowable costs • Circular A-122-cost principles for non-profit organizations • Circular A-133 Compliance Supplement-audit

6. What Rules Apply to Utilizing Federal Funds? State and local agencies must demonstrate fiscal control and accounting procedures to ensure the proper disbursement of and accounting for federal funds. • Section 76 of EDGAR – State Administered Programs • Section 80 of EDGAR – Uniform Admin. Requirements…State & Local Gov.

7. Fiscal Potpourri

8. Procurement Polices and Procedures Specific regulations governing procurement: • LEAs receiving federal education funds must follow procurement rules contained in EDGAR. • Section 80.36(a), allows states and local educational agencies (LEAs) to use the same procurement policies and procedures they use for procurements made with state funds.

9. Procurement Polices and Procedures • WVDE Purchasing Policies and Procedures Manual for Local Educational Agencies--WVBE Policy 8200: http://wvde.state.wv.us/policies

10. Inventory Management Inventory items purchased with federal funds are divided into three categories: • Real Property (if an allowable program cost) • Equipment • Supplies

11. Inventory Management Equipment Inventory vs. Internal Control • EDGAR requires an inventory for equipment • Inventory not required for supplies; however,ED determined that an adequate internal control system must include a process for labeling and locating property purchased with federal funds

12. Inventory Management • Equipment • Federal Definition of Equipment • Tangible property • Useful life of more than one year • Acquisition cost of $5,000 or more • State may use another definition as long as it includes all property described above • Supplies • Small cost items • Consumed quickly • ED expects sub-grantees to track all property purchased with federal funds, in order to prove there has been a benefit to the federal program

13. Inventory Management Practical help for tracking non-equipment items • Small and attractive item list • Conduct risk assessment to identify items susceptible to loss • Implement specific measures to control such items • Certain pre-defined assets (technology equipment)

14. Inventory Management • Equipment inventory updated annually • a description of the property • a serial number or other identification number • the acquisition date and cost of the property • the percentage of federal participation in the cost of the property • the location, use and condition of the property, and • any ultimate disposition data including the date of disposal and sale price of the property • Physical inventory • Must be performed at least every 2 years (recommend annually) • Indicate date and signature of individual(s)

15. Inventory Management • Must protect against unauthorized use • When property is no longer needed, must follow disposition rules: • Transfer to another federal program • Over $5,000 – Keep or sell, but must pay a share based on the percentage of federal ED participation at initial acquisition • Under $5,000 – May keep, sell, or dispose of it with no obligation to ED

16. Inventory Management • Must have adequate controls in place to account for: • Location of equipment - assure that it is used solely for authorized purposes • Custody of equipment - maintain effective control and accountability • Security of equipment - adequately safeguard all property

17. Time and Effort • If federal funds are used for salaries time and effort records must be kept • Must demonstrate that employees paid with federal funds actually worked on the specific federal programs

18. Time and Effort • Type of documentation depends on how many “cost objectives” the employee worked on • These cost objectives must be connected to the employee’s salary source • What is a cost objective? • A specific grant award, or other category of costs, that requires the grantee to track specific cost information

19. Time and Effort • If an employee works on a single cost objective: • Semi-Annual Certification • Signed by employee and supervisor every six months • Example: “I hereby certify that for the period January 1, 2014 through June 30, 2013 one-hundred percent (100%) of my time and effort was spent on Title I Administration.” • Consolidated Admin is considered a single cost objective

20. Time and Effort If an employee works on multiple cost objectives: • Personnel Activity Report (PAR) • After the fact • Account for total activity • Prepared monthly or semi-annually if certain conditions are met • Signed and dated by the employee

21. Time and Effort • “Flexible Certification” can be filed semi-annually if the following conditions are met: • Employee’s schedule includes multiple cost objectives • The work is “predetermined” (e.g. a lesson plan) • The employee is not permitted to work on different cost objectives at the same time

22. Time and Effort • Determine estimates for budgeting • Estimates must produce reasonable approximations of the activity actually performed • Quarterly comparison of estimates to actual costs • If difference is less than 10% - annual adjustment • If difference is more than 10% - quarterly adjustment

23. Time and Effort • Flexible Certifications must contain: • The specific activity or cost objective • Total hours for which the employee was compensated during the time period • Signed by the employee and a supervisory official with first-hand knowledge of the work performed • Include support for any revisions to the employee’s established schedule

24. Time and Effort • PARs must still be completed for any time period for which significant deviations occur from the established schedule that require work on multiple activities or cost objectives at the same time

25. Tracking Budget Expenditures • Total composite budget • Administrative budget • Individual school budgets http://wveis.k12.wv.us/schoolFinance/sf000002.cfm

26. Carry Over Title I and Title II are subject to a cap on amount that be carried forward into the “Tydings Period” which provides another 12 months for the use of funds. • 15% of the grant can be carried forward into the Tydings period • LEAs wishing to carry over a greater percentage may request a waiver once every three years.

27. Carry Over • An LEA has significant discretion in handling its Title I carryover funds. • Funds may be added to the LEA’s subsequent year’s allocation and redistributed to participating schools in accordance with normal allocation procedures – decreasing amount of allocation based on highest to lowest poverty. * • Funds may be added to the LEA’s subsequent year’s allocation and redistributed to participating schools equitably based on a per pupil amount times the number of low income students in each school. * • Funds may be designated for district wide activities that could best benefit from additional funding (e.g. parent involvement activities, professional development, pre-K, services for extended day/year programs). * The requirement for equitable services to private schools also applies to carryover funds. The LEA is not permitted to use Title I carryover funds in a school that is not eligible for Title I funding.

28. Period of Availability • Tydings Amendment • Does not apply to all grants • Funds are available to SEAs for 27 months: • 15 months under the grant award (July 1, 2014 – September 30, 2015) • Plus 12 months (October 1, 2014 – September 30, 2015) • SEA may limit period of availability! • Always double check grant award notice

29. Definition of Obligation Under Federal Law

30. Liquidations • SEA gives LEAs 30 days to liquidate funds after the end of the period of availability • Period of availability: July 1, 2014 – Sept 30, 2016 • Funds must be obligated by Sept 30, 2016 and liquidated by Oct 31, 2016

31. Maximizing Federal Funds • Obligate oldest funds first • Maintain clear accounting records • Continually monitor budget vs. actual • Know your carryover and liquidation rules

32. Maximizing Federal Resources in a Changing Education Environment

33. Maximizing Federal Funds #1 Exercising Program Scope (10-12) #2 Maximizing the Use of Title I Funds Directions: • Read the assigned section ( #1 or #2) • Conduct table discussions and identify key points • Think about the following questions:

34. Realizing the Potential: Future What activities are on your wish list? -What factors are currently preventing you from moving forward with these activities? - How could you connect the activities to promising practices and present proposals within the appropriate context?

35. - Fear of non-compliance fosters an environment that prioritizes what is safe in terms of audit risks over what is effective in terms of outcomes for students. Pg. 7

36. Operationalizing - Application Process • Revision of Monitoring • Title I Plan • Resources: Toolkit & The Changing Landscape

38. - In many states, a technical violation of a paperwork requirement is more likely to trigger state enforcement action than long-term spending on ineffective activities that fail to improve student achievement. Pg. 16