Financial Management

1. Financial Management Stacey Jones, Resolution Specialist OGCM- Division of Policy, Review and Resolution Young Offender Grants New Grantee Orientation November 4-5, 2009

2. How Feds View Themselves

3. How Grantees View Feds

4. The NEW DOL Grantee • Our Expectations of You: • A program that is designed to focus on customer needs and to address those needs • A program that meets the requirements of Federal law and regulation • A program in compliance with OMB requirements and Generally Accepted Accounting Principles.

5. The NEW DOL Grantee • What you can expect from us: • Assistance with regulations • On site technical assistance and monitoring • Assistance with fiscal and programmatic issues

6. The Fiscal Program Divide • There is a need for program operators to be aware of financial requirements • There is a need for fiscal people to be aware of program requirements • No one gets to opt out

7. It’s All Very Simple • Written Policies and Sound Business Practices • Followed Consistently Over Time • With Each Funding Stream Treated Equally, • With All Costs Being Necessary and Reasonable • Would be done similarly by a Prudent Person • Ensuring Proportional Share and Benefits Received

8. Rules affecting programs • WIA regulations • Administrative cost • 20 CFR 667.220 • Uniform administrative requirements • 29 CFR Parts 95 and 97 • Grant management rules • Cost principles • Determine allowable costs

9. Uniform Administrative Requirements • OMB Circulars A-102 & A-110 • Codified for DOL grant programs • 29 CFR Part 97 • State, local and Indian tribal governments • 29 CFR Part 95 • Everybody else • Slight differences • Follow DOL rules

10. All Financial SystemsMust adhere to 7 separate standards 1. Financial reporting System must permit preparation of Federal financial reports Must report accruals 2. Accounting records Adequately identify grant funds Awards, obligations, assets, liabilities, income and expenditures Supported by source documentation Must be maintained in accordance with GAAP

11. Financial Standards 3. Internal controls System to protect integrity of funds Accountability for cash, property & other assets 4. Budget controls Comparison of actual expenditures (outlays) to approved budget plan Compliance with line item requirements Prevents overspending

12. More Financial Standards 5. Allowable costs Only allowable costs charged Only allocable costs charged 6. Source documentation Costs must trace to authorizing document Proof that costs are allowable & allocable 7. Cash management System to control cash assets

13. Cost principles • Set of government wide rules • Cost principles • Define conditions for charging costs • Types of Costs • Allowable • Unallowable • Allowable with conditions (Prior Approval) • If Cost not Treated- • Principles of necessary and reasonable apply

14. OMB Circulars (Cost Principles) • A-87 • Governments (State, Local, Indian Tribal) • A-122 • Non-profit organizations • A-21 • Institutions of Higher Education • 48 CFR Part 31 • Commercial organizations Handout

15. Factors Affecting Allowability of Costs Authorized or not prohibited Consistent with the Federal rules & Circulars Consistent treatment Conform to limitations/exclusions contained in the cost principles Documented Consistent with GAAP

16. Allowable Grant Costs Based on grant program and Statement of Work: • Curriculum Development • Participant Support Services • Case Manager • Mentoring Program Provider • GED classes • Employment Specialist

17. Allowable Costs with Approval Conditions • Equipment • Computer Networks • Vehicles • If prior approval requirement exists • BEFORE incurring cost • Must be requested in writing • Must be approved • Approval requests to Grant Officer

18. Unallowable Costs Pre-award costs Participant stipends Monthly pizza parties for participants Interest, fines & penalties Contingency reserves Real property purchase/construction Exception: ADA Compliance

19. Unallowable Alcoholic beverages Lobbying Legal expenses for prosecution of claims, ALJ audit appeals or civil actions Entertainment Be careful with employee morale costs.

20. Prohibited Activities • Employment generating • Specific exceptions • Public service employment • Allowable with conditions under some programs • Business relocation • Sectarian activities • Equal Treatment in DOL programs for Faith-based and Community Organizations

21. PL 109-234 • Applies to • All ETA appropriated funds • All grants, contract and interagency agreements • All funds available on June 15, 2006 • Limits salary and bonus payments to individuals • Implementation guidance in TEGL 5-06 • 2008 limit is $172,200

22. Who is covered? • Individuals paid by ETA appropriated funds • Direct recipients and all subrecipients • Direct costs or through an Indirect Cost Rate • Vendors are not subject to limitation

23. Administrative Costs • 20 CFR 667.220(a) • Not related to direct services • Either to clients or employers • List of specific functions • Unlike traditional definitions • 10% limitation • Based on grant award amount Handout

24. Indirect Costs • Costs through an approved Indirect Cost Rate or Cost Allocation Plan • Included on the SF-424A • Reported on the ETA-9130 • May be both Administrative & Program costs • WIA definition applies

25. Leveraged Resources • Recipient share of costs • Non-Federal funds used for grant purposes • Reported on line 10k on the ETA 9130 • Other Federal Funds • Federal Funds available for the project • Reported on line 11a on the ETA 9130 Handout

26. Financial Reports • ETA 9130 • Electronic reporting system • Use of passwords and pins • Quarterly reports • Cumulative from beginning of project • Accrual basis • Due 45 days after quarter end • Final and Closeout Reports Handout

27. Financial Reports • Keep in mind— • Accrual basis of reporting • Administrative costs • Breakout on line 10.f • Leveraged resources • Non-Federal resources expended • Lines 10.k-m • Federal resources expended • Line 11.a

28. Reporting Contacts Initial Contact – Federal Project Officer On-Line Reporting System - Password and PIN -Shantay Logan – logan.shantay@dol.gov -Avery Malone – malone.avery@dol.gov

29. Additional Resources Financial Management Training Tutorial Workforce3One Website (www.workforce3one.org) Tutorial Titles: Introduction to Grant Application Forms (SF 424 and SF424A) Introduction to Procurement Requirements Financial Management Principles Introduction to Financial Reporting (ETA -9130)

30. Questions?