OSEP Part C Fiscal Management Verification: What Is It And How Do I Prepare For It?

1. OSEP Part C Fiscal Management Verification: What Is It And How Do I Prepare For It? Presented by: Anne Taylor, NECTACDavid Steele, OSEP

2. Agenda • Definition • Framework for Accountability • Fiscal Verification Process • Document Review

3. Definition Fiscal Management Verification is the process used to assess how effectively the lead agency implements the Part C fiscal requirements identified in the IDEA, GEPA, Federal regulations, and applicable OMB guidance

4. Framework for Accountability • Legal authorities provide a framework for understanding accountability. These authorities address the following three aspects of grantee operations: • Administrative requirements refer to matters that are common to grants in general, such as financial management, kinds and frequency or reports, and record retention.

5. Framework for Accountability - Continued • Fiscal requirements pertain to different aspects of Federal revenues and expenditures (e.g., cash management, budgeting, procurement, etc.) • Program performance relates to criteria that pertain to a grantee achieving its grant objectives.

6. Framework for Accountability: Legal Authorities • In their order of precedence, legal authorities include: • Statutes • Regulations and OMB Circulars • Non-regulatory guidance • Departmental letters

7. Framework for Accountability: Statutes • Administrative • General Education Provisions Act (GEPA) • Sets forth general administrative framework for education grant funds. • Single Audit Act • Sets forth audit requirements for grant funds. • Programmatic • Statutory requirements for each Federal education program.

8. Framework for Accountability:Regulations • Regulations • Education Department General Administrative Regulations (EDGAR) • Sets forth administrative requirements that pertain to Federal education funds. • Is presently composed of three volumes (part 1-299, part 300-399, and part 400 to end). • Programmatic • Regulatory requirements for each Federal program.

9. Framework for Accountability:OMB Circulars • A series of Office of Management and Budget (OMB) Circulars provide detailed guidance about administrative and cost principles related to grant awards. • A-133, Audits of States, Local Governments, and Non-Profit Organizations • Sets forth standards for obtaining consistency and uniformity among Federal agencies for audits of States, local governments and non-profit organizations.

10. Framework for Accountability: A-133 Compliance Requirements • Activities Allowed or Disallowed • Are program funds being used for program purposes? • Allowable Costs/Cost Principles • Are charges in accordance with applicable principles (A-21, A-97, A-122, etc.)? • Cash Management • Are funds drawn within allowable timeframes? • Eligibility • Are participants (including sub-recipients) eligible to participate in Federal programs?

11. A-133 Compliance Requirements- Continued • Equipment & Real Property Management • Is the grantee managing and disposing of equipment and real property purchased with Federal funds in accordance with applicable requirements? • Matching, Level of Effort, Earmarking • Is the grantee complying with general requirements for each program? • Period of Availability • Are Federal funds used within their allowed period of availability?

12. A-133 Compliance Requirements - Continued • Procurement & Suspension/Debarment • Is the grantee ensuring that sub-recipients and contractors are not suspended or debarred from receiving Federal funds? • Program Income • Is the grantee property accounting for income generated from Federal funds, and is the income used for allowable purposes? • Reporting • Did the grantee comply with applicable requirements for monitoring sub-recipients of Federal funds?

13. Framework for Accountability:OMB Circulars • A-87 Cost Principles for State, Local, and Indian Tribal Governments • Sets forth principles and standards for determining costs for Federal awards carried out through grants, cost reimbursement contracts, and other agreements with State and local governments and Federally recognized Indian tribal governments.

14. Fiscal Management Verification (FMV) Process • Identify the components of the lead agency’s fiscal management system. • Determine if the lead agency’s fiscal management system contains the components necessary to ensure compliance with Part C fiscal requirements. • Identify barriers that may impede the lead agency’s ability to implement fiscal controls.

15. Fiscal Management does not stand alone. It is a critical component of the State’s overall General Supervision System.

16. FMV Process - Continued • FMV assesses the components of a State’s General Supervision System. An audit is an examination of records or financial accounts to check for accuracy • FMV focuses on the State’s financial policies, procedures and fiscal controls -NOT accounting codes, software programs, tracking receipts, etc.

17. Document Review Part C: Fiscal Management Verification

18. FMV: Desk Audit Functions: • Identify components of the lead agency’s fiscal management system; • Provide information about how the lead agency meets Federal fiscal requirements; • Identify issues to address during the verification visit.

19. Major Sections (Page 5) • Interagency Financial Responsibility - How does the lead agency ensure the assignment and maintenance of interagency financial responsibility? • Fiscal Controls - How does the lead agency ensure Part C funds are used in accordance with State and Federal requirements? • Service Provision Arrangements - How does the lead agency ensure the provision of Part C services?

20. Document Format (page 7)