Andrew S. Johnson Grants Management Specialist

1. Andrew S. JohnsonGrants Management Specialist Montana Postsecondary Perkins Winter Training Perkins Fiscal Management February 26, 2014

2. Perkins and Fiscal Management • Perkins IV Law • Perkin IV Questions and Answers (non-regulatory guidance) • Education Department General Administrative Regulations (EDGAR) • Office of Management and Budget “Omni Circular”

3. Perkins and Fiscal Management • Perkins IV Law-Relevant fiscal sections • Section 111-Reservations and State Allotments • Determines State by State allocation after Perkins appropriation finalized • Section 112 Within State Setasides • Line item floors and ceilings within a State Perkins grant • State administration-Section 112 (a)(3) • Not more than 5% of the grant or $250,000 whichever is greater • State administration match Section 112 (b) • State leadership-Section 112 (a) (2) • Not more than 10% of the grant • State Institutions-Not more than 1% of the grant • Non traditional-not less than $60,000 and not more than $150,000 • No funds may be expended on administrative activities

4. Perkins and Fiscal Management • Section 112 Within State Setasides (continued) • Local Uses of Funds-Section 112 (a)(1) • Not less than 85% of the grant • State determines secondary/postsecondary split with these funds • 5% administrative cap (includes indirect costs) • 10% Reserve-Section 112 (c) • Not more than 10% of local uses of funds • Eligible Institutions must meet 1 of 3 criteria in section 112 (c) to be eligible for funding

5. Perkins and Fiscal Management • Section 311 Fiscal Requirements • Section 311 (a) Supplement not supplant • OMB Circular A-133 Compliance Supplement (June 2013) • Part 4 (US Department of Education • Cross Cutting Section and Perkins program specific section • Section 311 (b) Maintenance of Effort • State Expenditures for Career and Technical Education • Aggregate or Per-Student Basis • Section 323 State Administrative Costs • Administrative Hold Harmless • State expenditures cannot be lower than preceding year even if these expenditures exceed State match

6. Perkins and Fiscal Management • Perkins IV Grant Non-Regulatory Guidance (Questions and Answers) • Located on Perkins Peer Collaborative Networks (PCRN) • Website Address • http://cte.ed.gov/perkinsimplementation/nrg.cfm • Addresses all aspects of the Perkins IV law to include Fiscal issues • Examples of Fiscal issues • Small State minimum (States that receive $4,214,921) • CTSO allowable expenditures • Direct assistance to students • Remedial Education

7. Perkins and Fiscal Management • Education Department General Administrative Regulations (EDGAR) • Part 76 State Administered Programs • State Plan submissions • Applying to the State for a sub-grant • Allowable Costs • Indirect Cost rates • Part 80 Uniform Administrative requirements • Financial management systems standards • Equipment and supplies • Financial reporting • Closeout of grants

8. Perkins and Fiscal Management Office of Management and Budget (OMB) “Omni Circular” • Will supersede requirements of OMB Circulars A-21,A-87,A-110,A-122, A-89,A-102, A-133, and the guidance in Circular A-50 on Single Audit follow-up • Final guidance released in December 2013 (Federal Register) • Consolidation of the circulars aims to provide one source location/citation for guidance related to the administrative, cost principles, and audit requirements of Federal awards • Implementation Date • Still not finalized • Most likely this will apply to the Perkins grants that become available to States on July 1, 2015 • Information on the web • https://cfo.gov/cofar/