Grants Management American Indian Vocational Rehabilitation Services

1. Grants Management American Indian Vocational Rehabilitation Services Andy Winnegar, Consulting andy@winnegar.com 505-466-6563 505-660-1839 6 Nido Lane, SF, NM 87508 www.winnegar.com “It is our duty as human beings to proceed as though the limits of our capabilities do not exist.” (Pierre Teilhard de Chardin)

2. Grants ManagementNatural Support for Professional Development • Establishes a good working relationship with tribal finance to ensure proper draw-downs and spending of VR funding • Knowledgeable of grant writing process for tribal VR proposals • Possesses the ability to manage grant funds to meet program goals and objectives • Possesses the ability to conduct a needs assessment for the service area • Willingly applies for other grants or projects to supplement and compliment the program

3. Organization • Grant Award & Assurances • Successful Proposal, Budget & Objectives • Communication with funding agency • Budget Adjustment requests • No cost extensions • Personnel Activity Reports (PARS) • Budget & Program Reviews • Copies of GAP Drawdowns • Indirect Cost Plans • Cost Sharing documentation • Program Income documentation

4. AIVR Grants Management • Understanding of Allowable Costs, acceptable purchasing for goods and services • Acceptable personnel cost allocation methods & Personnel Activity Reports • Maintain an inventory and property management system • Establish and maintain a cooperative agreement with the VR State Agency (RSA-TAC-12-04) • References OMB Circular A-87 (relocated to 2 CFR Part 225—Appendix B, paragraph 8.h) OMB Circular No. A-102, OMB Circular No. A-110 EDGAR 34 CFR Parts 74, 75 and 80.

5. 34 CFR 361.24 - Cooperation and coordination with other entities. Cooperative agreement with recipients of grants for services to American Indians—(1) General. In applicable cases, the State plan must assure that the designated State agency has entered into a formal cooperative agreement with each grant recipient in the State that receives funds under part C of the Act (American Indian Vocational Rehabilitation Services). (2) Contents of formal cooperative agreement.

6. Strategies for Collaboration and Coordination The agreement required under paragraph (a)(1) of this section must describe strategies for collaboration and coordination in providing vocational rehabilitation services to American Indians who are individuals with disabilities, including—(i) Strategies for interagency referral and information sharing that will assist in eligibility determinations and the development of individualized plans for employment; (ii) Procedures for ensuring that American Indians who are individuals with disabilities and are living near a reservation or tribal service area are provided vocational rehabilitation services; and (iii) Provisions for sharing resources in cooperative studies and assessments, joint training activities, and other collaborative activities designed to improve the provision of services to American Indians who are individuals with disabilities.

7. Personnel Activity Reports • They must reflect an after-the-fact distribution of the actual activity of each employee; • They must account for the total activity for which each employee is compensated; • They must be prepared at least monthly and must coincide with one or more pay periods; and • They must be signed by the employee. • Single grant certifications will be prepared at least semi-annually • Multi-grant certifications with payroll or as approved by cognizant federal agency.

8. Personnel Activity Reports A distribution of employee salaries or wages will be supported by personnel activity reports or equivalent documentation unless a statistical sampling system or other substitute system has been approved by the cognizant federal agency. • More than one federal award; • A federal award and a non-federal award; • An indirect cost activity and a direct cost activity; • Two or more indirect activities which are allocated using different allocation bases; or • An unallowable activity and a direct or indirect cost activity

9. To meet the U.S. Department of Education Requirementsemployees prepare a Daily Personnel Activity Report or Approved Time Study by the cognizant federal agency Compliance with OMB Circular A-87 (relocated to 2 CFR Part 225—Appendix B, paragraph 8.h)

10. Funding cannot be shared between funding sources Any cost allocable to a particular award or other cost objective under these principles may not be shifted to other federal awards to overcome funding deficiencies, or to avoid restrictions imposed by law or by the terms of the award.

11. Multiple Funding PAR Example

12. Allowable Costs, Cost Sharing, Program Income, Indirect Cost & Cost Allocation "Cost allocation plan" means central service cost allocation plan, public assistance cost allocation plan, cost sharing or matching and indirect cost rate proposal. “Cost" means an amount as determined on a cash, accrual, or other basis acceptable to the Federal awarding or cognizant agency. Cost does not include transfers to a general or similar fund.

13. Tracking Progress

14. Where are we?

15. Approvals & Requirements EDGAR § 80.30 (applicable to state, local, and tribal governments) requires that a grantee obtain prior approval from ED for changes to key persons identified in the application and for changes in the project director or principal investigator in research projects regardless of whether those individuals were identified in the application. EDGAR §§ 74.25 and 80.30 appear to give ED program officials the authority to review and approve requests to change the scope or objectives of a discretionary grant. However, ED does not permit changes to the scope or objectives of a grant except in rare cases where the competition for the grant was not truly competitive. EDGAR § 75.620 The contents of this (insert type of publication; such as book, report, film) were developed under a grant from the Department of Education. However, those contents do not necessarily represent the policy of the Department of Education, and you should not assume endorsement by the Federal government.

16. Allowable Costs • Be necessary and reasonable for proper and efficient performance and administration of Federal awards. • Be allocable to Federal awards under the provisions of this Circular. • Be authorized or not prohibited under State or local laws or regulations. • Conform to any limitations or exclusions set forth in these principles, Federal laws, terms and conditions of the Federal award, or other governing regulations as to types or amounts of cost items. • Be consistent with policies, regulations, and procedures that apply uniformly to both Federal awards and other activities of the governmental unit.

17. Allowable Costs • Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. • Except as otherwise provided for in this Circular, be determined in accordance with generally accepted accounting principles. • Not be included as a cost or used to meet cost sharing or matching requirements of any other Federal award in either the current or a prior period, except as specifically provided by Federal law or regulation. • Be the net of all applicable credits. • Be adequately documented.

18. Reasonable Costs A cost is reasonable if, in its nature and 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 cost.

19. The question of reasonableness is particularly important when governmental units or components are predominately federally funded. In determining reasonableness of a given cost, consideration shall be given to: • Whether the cost is of a type generally recognized as ordinary and necessary for • the operation of the governmental unit or the performance of the Federal award. • The restraints or requirements imposed by such factors as: sound business practices; arms length bargaining; Federal, State and other laws and regulations; and, terms and conditions of the Federal award. • Market prices for comparable goods or services. • Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the governmental unit, its employees, the public at large, and the Federal Government. • Significant deviations from the established practices of the governmental unit which may unjustifiably increase the Federal award's cost.

20. Allocable Costs • A cost is allocable to a particular cost objective if the goods or services involved are chargeable or assignable to such cost objective in accordance with relative benefits received. • All activities which benefit from the governmental unit's indirect cost, including unallowable activities and services donated to the governmental unit by third parties, will receive an appropriate allocation of indirect costs.

21. Allocable Costs • Any cost allocable to a particular Federal award or cost objective under the principles provided for in this Circular may not be charged to other Federal awards to overcome fund deficiencies, to avoid restrictions imposed by law or terms of the Federal awards, or for other reasons. • Where an accumulation of indirect costs will ultimately result in charges to a Federal award, a cost allocation plan will be required as described in Attachments C. Scope of the Central Service Cost Allocation Plans; D. Submission Requirements and E. Documentation Requirements for Submitted Plans.