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FISCAL RESPONSIBILITY IN TITLE III AND OTHER SPONSORED PROGRAMS AND GRANTS ADMINISTRATION. Presented by Sharon S. Crews, M.Ac., CPA Vice President for Administrative & Student Services June 23, 2011. Overview. Administration & Accounting for Title III and Federal Programs
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FISCAL RESPONSIBILITY IN TITLE IIIAND OTHER SPONSORED PROGRAMS AND GRANTS ADMINISTRATION Presented by Sharon S. Crews, M.Ac., CPA Vice President for Administrative & Student Services June 23, 2011
Overview • Administration & Accounting for Title III and Federal Programs • Organizational Structure • Budget Management • Federal Drawdown (G-5) • Accounting Controls • Questions & Answers
Administrative Controls • 34 CFR Part 74 Edgar provides guidance for the Administration of Title III as well as other Grants and Agreements with Institutions of Higher Education, Hospitals and Other Non-profit Organizations. • OMB Circular A-21 Cost Principles for Educational Institutions • OMB Circular A-133 Audits of State, Local Governments, and Non-Profit Organizations
Administrative Controls • Title III is called the President’s grant and the President sets most parameters as to how the funds will be expended. • Title III Directors should be instrumental in helping the President adhere to the requirements of Edgar.
Administrative Controls • Administrative Control includes a plan of organization and the procedures and records that are concerned with the decision processes leading to management’s authorization of transactions. • As part of the Administrative control of the College, authorization is secured and verified before creating accounting transactions that commits the assets of the College.
Administrative Controls • The President is the ultimate decision maker at the College Level. The President initiates approved policies to ensure compliance with State Board Policy and the Laws of the State. • Each institution should operate based on an approved organizational structure designed to ensure consistent workflow and facilitate the decision making process.
Standards for Financial Management Systems • Edgar requires the maintenance of records that provides effective control over and accountability for all funds, property, and other assets. • Allocation and documentation cost principles states that the recipient institution is responsible for ensuring the costs charged to a sponsored agreement are allowable, allocable, and reasonable.
Standards for Financial Management Systems • Institution’s internal controls shall ensure that no one person has complete control over all aspects of a financial transaction. • When procuring property and services under a grant, State will follow the same policies and procedures it uses for procurements from its non-Federal funds.
ORGANIZATION/OVERSIGHT • AWARD NOTIFICATION Approved award-signed by the President. Signed off by Office of Sponsored Programs/Title III Director. Copy of approved award notification, approved budget and detail budgets should be forwarded to the Business Office.
ORGANIZATION/OVERSIGHT • APPROVAL PROCESSES • Activity Director/Budget Manager • Activity Director’s Supervisor • Dean of the Department • Vice President for the Area • President’s Office • Title III Director • The same process is required by all budget managers (restricted and unrestricted funds).
BUDGET MANAGEMENT • Approved Budget forwarded to Business Office. • Accountant enters the budget into the Accounting System • Title III activity budgets are established and separated using accounting codes. • The total of all activity budgets must balance to the total approved funding allocation for the year. • If the budget does not balance it is returned to the Title III Office.
BUDGET MANAGEMENT • When the budget has been entered in the Accounting System, the operating budget line items are set for online budget inquiry and requisition processing. • The salary and benefits line items are not available for online inquiry by the activity directors. • The President authorizes the hiring or termination of personnel and payment of salaries.
BUDGET MANAGEMENT • Once the budgets have been established on the accounting system, the Title III Directors are notified of the budget account codes to be usee for each activity. • The Payroll Accountant is provided a detail of employees paid from these budgets and the effective dates of the payroll. • The cashier receives a receipt code for Title III funds drawdown.
BUDGET MANAGEMENT • Each Title III funding year is set up as a separate set of self-balance accounts. • Title III funds are never combined in the accounting records. • Carryover funds are balanced each year during financial statement preparation.
ACCOUNTING CONTROLS • When requisitions are received in the Business Affairs Office, they are logged in a requisition ledger. • Requisitions are then forwarded to the Grants and Contract accountant for review for budgetary controls. • The accountant will review the requisition for the correct chart of account coding of budget line items.
ACCOUNTING CONTROLS • If the requisition has no discrepancy, it is forwarded to the person responsible for keying requisitions to create purchase orders. • If there is a discrepancy, the Title III Office will be notified that a budget revision is needed and/or the requisition will be returned to the budget manager for revisions.
ACCOUNTING CONTROLS • Purchases are made using established state guidelines. (See state purchasing policy and bid law requireents). • Federal Guidance on contracts over $2,000. ATTACHMENT A • Funds for this project have been provided through the Department of Education, Title III program. The following Federal Regulations must be adhered to: • Davis Bacon Act • Wage Hour Act • Copeland Anti-Kick Back Act • EPA Standards
ACCOUNTING CONTROLS • The successful vendor must furnish the college a Vendor Disclosure Form prior to the awarding of the contract. • Lawson State pays by invoice. All purchases must be made with LSCC purchase order. Terms will become a part of the bid. Bid price must be guaranteed for a period of at least ninety (90) days. • Lawson State Community College is a non-profit state supported institution and as such is tax exempt. Our tax number is 37-17684. Vendors will comply with ACT No. 2006-557 Subsection 41-4-116 which requires that each vendor, contractor, or their affiliate must certify that it is registered to collect and remit Alabama State and local sales, use and/or lease taxes on all taxable sales and leases in Alabama. By submitting this, the bidder is hereby certifying that they are in full compliance with ACT No. 2006-557.
ACCOUNTING CONTROLS • When the purchasing cycle has been completed: • Materials and supplies have been received. • Approved travel request processed. • Accounts payable checks have been issued to the vendor.
ACCOUNTING CONTROLS • MONTHLY DRAWDOWNS • Once expenditures are made on Title III funds, the college is eligible for reimbursement. Calculate drawdown • Total Revenues/Draw downs $650,000.00 • Total Expenditures $785,000.00 • ___________ Difference/Drawdown $135,000.00 Require disbursement of funds within 3 days after drawing it down.
ACCOUNTING CONTROLS • MONTHLY DRAWDOWNS • Once expenditures are made on Title III funds, the college is eligible for reimbursement. • Lawson State requests Title III funds on a monthly reimbursement basis through the G-5 system. • G-5 provides the 5 year authorization under 1 award number. All years expenditures are requested from 1 authorization.
ACCOUNTING CONTROLS • Payroll salaries and benefits are verified monthly to ensure proper posting to authorized budget codes. • Expenditures for equipment costing $1,000 to $4,999 are inventoried and assigned an asset number as inactive inventory. • Expenditures for equipment costing $5,000 or more are inventoried and assigned an asset number as active inventory. • All grants and contracts are reconciled and balanced monthly. (Cash, Revenues and Expenditures are balanced monthly with bank reconciliations).
ACCOUNTING CONTROLS • VP, Director of Accounting and Cashier receive copies of each G-5 draw down. • Federal cash drawn down is direct deposited to the institution’s general funds bank account. • Grants accountant does not have access to the bank accounts.
FISCAL RESPONSIBILITY IN TITLE IIIAND OTHER SPONSORED PROGRAMS AND GRANTS ADMINISTRATION QUESTIONS & ANSWERS