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Office of Grants Management Grants Management Fundamentals Office of the National Coordinator for Health Information Technology (O N C) Grants 101.

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Presentation on theme: "Office of Grants Management Grants Management Fundamentals Office of the National Coordinator for Health Information Technology (O N C) Grants 101."— Presentation transcript:

1 Office of Grants Management Grants Management Fundamentals Office of the National Coordinator for Health Information Technology (O N C) Grants 101

2 2 Office of Grants Management – Organization and Functions Systems and Data Management Bianca Costa Collect, report, and manage grants management data Analyze grant data to identify trends in implementation of funds ONC administrator for grants management systems GMO: Workforce Training and Technical Assistance Jen Cramer Develop and deliver grants management training for external stakeholders and ONC staff Provide customized, direct technical assistance services Coordinate overall grants management training and technical assistance efforts GMO: Beacon and SHARP Grant Operations Arlene Ramsey Provide procedural and technical business support to award recipients and ONC program offices Conduct on-site monitoring visits and desk reviews Develop grants management standard operating procedures GMO: REC and State HIE Office of Grants Management (OGM) Lisa Lewis Chief Grants Management Officer Office of Grants Management (OGM) Lisa Lewis Chief Grants Management Officer Policy Wendy Kilgore Develop and manage ONC grants management policies Facilitate objective reviews Liaison with other HHS Grants Management Offices

3 O G M - Responsible for the Portfolio of O N C Cooperative Agreements 3 Workforce: Competency Examination Workforce: Competency Examination Workforce: Curriculum Development Centers Workforce: Curriculum Development Centers Workforce: University Based Training Workforce: University Based Training Workforce: Community College Workforce: Community College SHARP Beacon Regional Extension Centers Regional Extension Centers State Health Information Exchange State Health Information Exchange

4 O N Cs Program Offices and Grants Office Partnership AAGAM Chapter Answer grantee questions on complex technical grants business management matters Answer grantee questions on complex technical grants business management matters Perform budget analyses & business mgmt capability assessments & perform budget negotiations Perform budget analyses & business mgmt capability assessments & perform budget negotiations Take action to withhold payment, suspend or terminate award or to lift withholding or suspension Take action to withhold payment, suspend or terminate award or to lift withholding or suspension Provide input on satisfaction of business mgmt special conditions; lift restrictions via NGA Provide input on satisfaction of business mgmt special conditions; lift restrictions via NGA Identify potential or existing problems (business mgmt & program) & alert PO Identify potential or existing problems (business mgmt & program) & alert PO Ensure effective use of funds by monitoring commitments & projecting future funding requirements Ensure effective use of funds by monitoring commitments & projecting future funding requirements Review financial status reports & evaluate financial performance against budget, program plan, etc. Review financial status reports & evaluate financial performance against budget, program plan, etc. Document site visits & desk reviews & coordinate results with program office Document site visits & desk reviews & coordinate results with program office Conduct financial monitoring site visits & desk reviews & provide post-award TA Conduct financial monitoring site visits & desk reviews & provide post-award TA Establish & maintain official award, program information, & institutional files Establish & maintain official award, program information, & institutional files Grants Management Team Grants Management Team

5 O N Cs Program Offices and Grants Office Partnership 5 AAGAM Chapter Answer grantee questions on programmatic grants matters Answer grantee questions on programmatic grants matters Assist in ensuring budget submissions & expenditures comply with statute, regulation, & policy Assist in ensuring budget submissions & expenditures comply with statute, regulation, & policy Provide program input on proposed withholding of payment/suspension/ termination of award & input before lifting Provide program input on proposed withholding of payment/suspension/ termination of award & input before lifting Provide input on whether programmatic special conditions are satisfied or whether other action should be taken Provide input on whether programmatic special conditions are satisfied or whether other action should be taken Identify potential or existing problems (program & business management) & alert program officials & GMO of findings Identify potential or existing problems (program & business management) & alert program officials & GMO of findings Ensure adequate progress toward meeting milestones Ensure adequate progress toward meeting milestones Review program progress reports & evaluate program performance, progress & changes in scope or objective Review program progress reports & evaluate program performance, progress & changes in scope or objective Document reviews & grantee discussions & provide documentation to GMO for official file Document reviews & grantee discussions & provide documentation to GMO for official file Conduct site visits to gauge progress and compliance or to provide post-award TA Conduct site visits to gauge progress and compliance or to provide post-award TA Establish and maintain PO files Establish and maintain PO files Project Officers Project Officers

6 Partnership – The Key to Success Maximize program success and integrity Foster program credibility Ensure rigor in stewardship Minimize audit findings Reduce disallowed costs Strengthen internal controls to prevent fraud, waste, and abuse Manage inherent risk Encourage professional development Foster synergy/collaboration 6

7 Review FOASubmit ApplicationRevise Application Review Award Package Accept Award Drawdown Funds Submit Financial Reports Submit Performance Reports Submit Post-Award Requests Ensure Audit is Complete Generate Final Performance Reports Complete Drawdown of Funds Generate Final Financial Reports Submit Closeout Package Retain Records Legend: PHASE Grantee Office of Grants Management Program Office ONC Budget Other Federal/HHS Entities PO/GMO Joint Program and Grants Management Training and Technical Assistance Assist Applicants Establish Commitments APPLY Review Closeout Package Conduct Final Financial Reconciliation Notify Grantee of Closeout Retain Records Establish Disposition of Funds Evaluate Final Performance Reports CLOSEOUT Obligate Funds Set Up Congressional Notification in System Release Funds Create Notice of Grant Award AWARD Notify Grantee of Award Conduct Appropriations Analysis Develop Funding Opportunity Announcement (FOA) Release FOA Appropriation OMB Apportionment Authorizing Statute ESTABLISH Allocate Funds Review and Approve Post-Award Actions Conduct Financial Monitoring Review Financial Reports Review Performance Reports Review Audits Conduct Programmatic Monitoring MANAGE Review /Recommend Post-Award Actions Review Application Perform Budget Review Objective Review Assess Fiscal Integrity Develop Funding Memo REVIEW Assess Funds Availability Grants Management Lifecycle

8 Conduct Appropriations Analysis Develop Funding Opportunity Announcement (FOA) Release FOA Appropriation OMB Apportionment Authorizing Statute Review FOA APPLY ESTABLISH REVIEWAWARDMANAGECLOSEOUT Allocate Funds Legend: PHASE Grantee Office of Grants Management Program Office ONC Budget Other Federal/HHS Entities PO/GMO Joint Grants Management Lifecycle – Establish

9 9 Appropriations and Funding Process Phase 1: Budget Formulation Phase 2: Budget Presentation and the Congressional Process Phase 3: Budget Execution

10 10 Budget Formulation HHS Budgets for Grant Programs HHS Budget Request HHS Total Budget Request O M B/Presidents Budget to Congress

11 11 Appropriations Budget Presentation to Congress Congressional Budget Resolution Appropriation

12 12 Budget Execution Office of Management and Budget (O M B) Apportionment –Budget Authority to distribute funds HHS Allotment O N C Allotment Allocations to Each Grant Program

13 13 Types of Appropriations Annual: Must be obligated within the fiscal year –O N C funds in HHS appropriations Multiple Year: Available for obligation for a definite period in excess of one fiscal year –HHS has multi-year funds No-year: Available for obligation without financial year limitations –A R R A funding no longer no year (Bennett Amendment)

14 14 Continuing Resolution Applies if new Fiscal Year and annual appropriation is not passed Continues existing programs until annual appropriation passes Can impact internal operations and activities

15 15 Funding Opportunity Announcement (FOA) All information integral to the competition must be explicitly addressed General description Authorizing statute/Award information Eligibility requirements Cost share/matching requirements Application requirements –Forms –Budget and budget narrative –Program narrative –Other submission requirements Due dates Review Criteria Announcement dates Reporting requirements Other information

16 Submit Application Assist Applicants Establish Commitments APPLY ESTABLISHREVIEWAWARDMANAGECLOSEOUT Legend: PHASE Grantee Office of Grants Management Program Office ONC Budget Other Federal/HHS Entities PO/GMO Joint Grants Management Lifecycle – Apply

17 Applying for Funding HHS policy requires all competitive funding opportunities be announced at O M B mandated initiative No paper No other submission method accepted 17

18 18 Critical Application Information Applications must be complete and timely –All forms and attachments must be submitted –Incomplete applications will not be sent forward for review –Late applications will not be sent forward for review All applicants must have a Dun and Bradstreet (D&B) Data Universal Numbering System (D U N S) number All applicants must register in the Central Contractor Registry (CCR) –Applicants should allow a minimum of five days to complete the CCR registration. CCR online registration (http://www.ccr.gov)http://www.ccr.gov –CCR registrations must be current and renewed every 12 months Applicants that do not have a D U N S number or have not registered with the CCR will not move forward for review.

19 Review Application Perform Budget Review Objective Review Assess Fiscal Integrity Develop Funding Memo Revise Application APPLY ESTABLISH REVIEW AWARDMANAGECLOSEOUT Legend: PHASE Grantee Office of Grants Management Program Office ONC Budget Other Federal/HHS Entities PO/GMO Joint Assess Funds Availability Grants Management Lifecycle – Review

20 Objective Review Process Completeness Review Grants staff All required forms All required attachments On-time submission Responsiveness Review Program staff All required program elements If YES to both Panel review 20

21 Objective Review Process - continued Panels of unbiased subject matter experts Endure no conflicts of interest and consistent examination of applications Intended to provide recommendations and advice on funding proposals Scores and ranking developed Final decisions determined by the program office Funding decision memo sent to Grants Management Office 21

22 22 Program Office Financial Review Program Office Staff –Review application budget to determine if costs are in line with program goals and objectives –Review to ensure costs are for intended program purposes –Signed transmittal slip indicating approval of budget Grants Management Staff –Conduct detailed financial reviews –Based on Program Office recommendations

23 23 Financial Review A-133 Compliance – No Conflict of Interest Applicants Standing (Good, Debarred, Suspended) – https://www.epls.gov/ https://www.epls.gov/ Dun and Bradstreet Budget Review

24 Budget Review and Approval Process Each application must include a detailed budget (SF424A) and budget narrative for the project. The budget must be complete, reasonable, allowable, allocable and cost effective in relation to the proposed project. The budget narrative must provide a detailed justification for each cost included in the budget. All project related costs must be included in the appropriate cost categories. 24

25 25 Budget Review – Cost Principles Uniform cost principles when implementing Federal grant programs –45 CFR and by reference 2 CFR Part 220 (A-21) – Educational Institutions –2 CFR Part 225 (A-87) – State Local and Indian Tribal Governments –2 CFR Part 230 (A-122) – Non-Profit Organizations –48 CFR 31.2 (Federal Acquisition Regulation (F A R)) – For Profit Organizations

26 Budget Review – Object Categories and Key Requirements Example of a 424a 26

27 Budget Review – Personnel Budget Category Personnel Must pay personnel at a rate paid with non-Federal dollars or comparable to like organizations/positions. Is the basis for determining each employees compensation described (annual salary and % time devoted)? Is each position identified by title/responsibility? Are time commitments and the amount of compensation stated and reasonable? Are salary increases anticipated during the grant period and are they justified (C O L A, etc) Are any personnel costs unallowable? Dual Compensation? Federal Employee? 27

28 Budget Review – Fringe Budget Category Fringe Benefits – typically include health care, retirement plans, etc. Must consider: Is the amount specified as a separate line item? Is each type of benefit indicated separately or does the organization have an approved fringe benefit rate? Are fringe increases contemplated during the grant period? Are costs included in fringe benefits that are unallowable? 28

29 Budget Review – Travel Budget Category Travel Is the basis for computation provided? Is the travel necessary for the purpose of the program? Are travel costs separately identifiable and reasonable (location, transportation, hotel, meals, mileage)? Does the organization have a written travel policy? Is this travel policy being followed? If no written policymust follow Federal guidelines 29

30 Budget Review – Equipment Budget Category Equipment Capitalization threshold Federal $5K and useful life more than 1 year Are equipment items specified by unit and cost? Is the request reasonable and allowable under the project? Does the organization have a procurement policy in place? Is a lease vs. purchase study necessary (vehicles, large items of equipment)? Are purchases distinguishable from rentals? 30

31 Budget Review – Supplies Budget Category Supplies Are supplies listed separately? Office Training Research Other types of supplies How was cost determined? Is the basis for the cost reasonable? Monthly estimates are sufficient Consistently treated 31

32 Budget Review – Contractual Budget Category Contractual Is the type of each service to be rendered described? For Consultants/Individuals Is an hourly, daily or weekly base rate given? Are rates allowable, justified, reasonable and comparable to market? Is procurement method described? Are appropriate procurement procedures being followed? 32

33 Budget Review and Approval – Subrecipient Relationships Subrecipient Relationships (Subgrants/Subawards or Contracts) Is a substantial portion of the programmatic work being performed by another entity - a grant or contract? Subawards are documented in the other category Subrecipient relationships in the form of a contract will be put in contractual If so, the following questions must be answered in regard to that specific grant or contract: Name of the subrecipient Method of selection Period of performance Scope of Work Method of Accountability Itemized budget and justification (separate SF 424As for the subrecipient) 33

34 Budget Review – Other Budget Category Other Are items listed by major type (space rental, printing, phone, maintenance, etc.)? Are all costs justified, reasonable and allowable? List each subaward and amount of award Ensure adequate subrecipient information is provided (see 6 elements) Include separate SF 424 A for each sub 34

35 Budget Review – Indirect Costs Indirect Costs Costs incurred for a common/joint objective and cannot be readily identified with a specific activity typically include utilities, rent, administrative staff An organization may not charge specific costs both directly and indirectly Costs may not be assigned as an indirect cost to an award if any other cost incurred for the same purpose has been allocated to an award as a direct cost 35

36 Budget Review – Indirect Costs Indirect Costs (continued) Must have a current Federally approved indirect cost rate agreement Is the rate applied to the correct distribution base? 36

37 Recently in the News TierOne loses $19 million federal grant over CEO's fraud allegations September 6, 2010 University of Florida professor and wife indicted for fraudulent grant proposals October 30, 2009 Cornell University Will Pay $2.6M in Fraud Case March 24, 2009 Former Professor Pleads Guilty to Fraud on NSF Grant May 3,

38 Categories of Misuse of Federal Funds Indicators of Fraud, Waste and Misuse of grant funds can be due to a variety of causes. We must manage with due diligence to ensure that DHHS funds are not misused. 38 MistakesGross NegligenceCriminal Fraud Recipient includes costs in budget which are unallowable under specific O N C awards. Examples include: Food, Scholarships, Contingencies Direct recipient failed to implement proper internal controls and adequately monitor subrecipient activity and expenditures resulting in theft of Federal funds. Recipients used Federal funds to pay for a wedding reception, building construction, and personal credit card bills. Resulted in loss of $500K and jail time.

39 Who Commits Grant Fraud? When business entities, individuals, communities, and other organizations receive federal grant dollars, they are entrusted with their appropriate expenditure. Grant fraud is most often committed by: Grant recipients, company officers, business partners, board members, and managers Bookkeepers, financial staff, and employees Contractors and subcontractors engaged with the recipient Recipient consultants 39

40 Common Grant Fraud Scenarios Grant fraud occurs in many ways, but some of the most common fraud scenarios include: Charging personal expenses as business expenses against the grant Charging for costs which have not been incurred Charging for inflated labor costs or hours Submitting invoices for personal expenses False information on grant applications, progress reports, etc. Creating fictitious records 40

41 Fraud Indicators Fraud is often difficult to detect and is a conclusion that is determined only after a careful examination of all the facts and circumstances. Indicators of fraud include: One person in control Lack of internal controls Altered records No separation of duties No prior audit Lack of responsiveness Allegations of fraudulent conduct

42 Obligate Funds Ensure Congressional Notification Release Funds Create Notice of Grant Award APPLYESTABLISHREVIEW AWARD MANAGECLOSEOUT Notify Grantee of Award Legend: PHASE Grantee Office of Grants Management Program Office ONC Budget Other Federal/HHS Entities PO/GMO Joint Grants Management Lifecycle –Award

43 43 Notice of Grant Award (NGA) The Notice of Grant Award NGA is the official document used for grants/cooperative agreements –Establishes legally binding arrangement between O N C and recipient – Establishes Period of Performance – Contains or references Terms and Conditions of the grant or cooperative agreement – Obligates Federal Funds

44 44 Notice of Grant Award (NGA) NGA includes: Grantee information Award information – Project Period of Performance – Budget Period of Performance Terms and Conditions of the award

45 45 Award Notification and Acceptance Award Notification –Grants Solutions –NGA –Terms and Conditions Award Acceptance – First request for disbursement of funds – Agree to abide by all applicable laws, regulations, program requirements, policy and terms and conditions – Specific A R R A terms and conditions (incorporated by reference)

46 Grant vs. Cooperative Agreement Grants are awarded to States, units of local government, or private organizations at the discretion of the awarding agency or on the basis of a formula. Grants are used to support a public purpose. Cooperative Agreements are awarded to States, units of local government, or private organizations at the discretion of the awarding agency. Like grants, cooperative agreements also support a public purpose. Substantial involvement is anticipated between the awarding agency and the recipient during performance of the contemplated activity. View as a partnership Cooperative agreements are not contracts 46

47 Review and Approve Post-Award Actions Conduct Financial Monitoring Review Financial Reports Review Performance Reports Review Audits Conduct Programmatic Monitoring APPLYESTABLISHREVIEWAWARD MANAGE CLOSEOUT Review /Recommend Post-Award Actions Legend: PHASE Grantee Office of Grants Management Program Office ONC Budget Other Federal/HHS Entities PO/GMO Joint Grants Management Lifecycle – Manage

48 Order of Precedence-Who is Top Dog? Constitution of the United States Statutes Program Statutes (Authorizing Statutes) Generally Applicable Statutes Annual Appropriations Regulations Executive Orders O M B Circulars Policies Procedures 48

49 49 Administrative Requirements vs. Cost Principles Administrative RequirementsCost Principles Prescribe standards for grant administration to achieve uniformity and consistency for recipients of Federal Assistance Define allowable costs for different types of recipients; failure to mention a particular item of cost in the Cost Principles is not intended to imply that it is either allowable or unallowable

50 50 Applicable Regulations Summary of Applicable Regulations Grantee TypeAdministrative Requirements Cost PrinciplesAudit Requirements State & Local Governments45 CFR Part 922 CFR, Part 225 (A-87) A-133 Educational Institutions 45 CFR Part 7445 CFR and by reference 2 CFR Part 220 (A-21) Non-Profits2 CFR, Part 230 (A-122)

51 Recipient Grants Management Responsibilities Grantee responsibilities include: Cash management Maintaining adequate financial records Returning Federal funds for disallowed expenditures Complying with reporting requirements Reviewing and recording financial operations Budgeting and budget review Reporting irregularities Refrain from doing business with debarred and suspended organizations 51

52 Recipient Grants Management Responsibilities Managing Subawards A recipient has full responsibility for the conduct of the project or activity supported and for the results achieved Direct recipients are responsible for adequate monitoring of subawardee activities 45 CFR Part or 74.51, Monitoring and Reporting Program Performance 52

53 Financial Management Systems At a minimum, a grantees financial system should be able to: Meet 45 CFR or 74.21, Standards for financial management systems Provide financial and performance reporting required by 45 CFR Part 92 and 74, and other regulations Associate grant expenditures with the specific funding source and application of funds Provide a clear audit trail Comply with the Cash Management Improvement Act Minimize the time elapsing between the transfer of funds and disbursement by the grantee or subgrantee in accordance with Treasury Regulation 31 CFR 205. A State should follow the same state laws and procedures as they would for non-Federal funds 53

54 Financial Management Systems – continued In order for an accounting system to be considered adequate, it must meet the following criteria: Internal controls / segregation of duties (For example, the person authorizing an expenditure should not sign the check) Ability to track expenditures on an accrual basis (budget control) Grantees can use a cash or accrual basis for their accounting method Ensure allowability of costs charged to Federal grants Documentation for all grant-related expenditures, broken down by award Ability to fulfill government-required financial reporting 54

55 55 Understanding Match Matching and cost sharing are often used interchangeably Matching usually refers to a statutorily specified percentage –Specified as a fixed or minimum percentage of non-Federal participation in allowable program or project costs that must be contributed by a recipient in order to be eligible for Federal funding or a not-to-exceed percentage of Federal participation. Cost Sharing refers to any situation in which the recipient shares in the costs of a project other than as statutorily required matching Approved/accepted matching or cost sharing is shown in the NGA

56 Understanding Match – continued Cash Match Cash spent for project related costs Matching costs must adhere to Federal rules If not allowed with Federal dollars, not allowable with matching dollars In-kind Match are the value of goods and/or services third parties donate for program or project purposes without charge to a recipient Third party in-kind contributions May satisfy a matching or cost-sharing requirement only when payment for them would be an allowable cost if the party receiving the contributions (recipient, subrecipient, or cost-type contractor) were to pay for them 56

57 57 Understanding Match – continued All costs and contributions used to satisfy a matching or cost- sharing requirement must be documented by the recipient at the same level of detail as Federal funds Matching contributions are subject to audit If a recipient fails to provide required cost sharing, the GMO generally will make a downward adjustment in the Federal award amount

58 58 Understanding Match – continued Valuation of in-kind contributions: Rates for volunteers must be consistent with established rates paid for similar work by the recipient or subrecipient If a third party donates the use of equipment or space in a building but retains title, the contribution shall be valued at the fair rental rate of the equipment or space If a third party donates supplies, the contribution shall be valued at the market value of the supplies at the time of donation

59 Program Income Gross income earned as a result of the award directly generated by the grant-supported activity or earned There would be no income of this type or level. Activities that generate program income include Registration fees Sale of videos, publications, other media Rental/usage fees Service fees Subject to same requirements as Federal funds Must be reported on FFR (SF 425) 59

60 Program Income The Notice of Grant Award includes the type of program income applicable to the Program/award Deduction alternative Addition alternative Cost Sharing/Matching alternative Combination alternative 60

61 Prior Approval Several changes to an award require O N C prior approval Changes of grantee organization Change in scope Transfer of substantive programmatic work if not previously approved Significant rebudgeting (lesser of 25% or $250K, cumulative) Other as defined by program office Changes in key personnel Carry over funds Indirect costs (if indirect costs not approved in initial budget) Request from grantee, with written justification, should be 30 days from when need approval 61

62 Payments to Grantees Grantees request funds from HHS Payment Management System (PMS) Payment requests may be made as often as needed: (daily, weekly, monthly, etc.) No checks; electronic transfers only Also used to submit quarterly financial reports PMS is administered by HHS Division of Payment Management PMS Helpdesk: (877) or Grantees must minimize time between draw and expenditure Cash Management Improvement Act (CMIA) Immediate needs basis; funds must be spent within three business days What may impact a grantees ability to draw funds? No budget approval Late report submission Other restrictions 62

63 63 Grantee Reporting Requirements Report RequiredFrequencyReporting PeriodDue DateSubmission Method American Recovery and Reinvestment Act (ARRA) Report Quarterly April 1 – June 30July 10 Federalreporting.gov July 1 – September 30October 10 October 1 – December 31January 10 January 1 – March 31April 10 Federal Financial Report (FFR) Federal Cash Transaction Report (SF-425) Quarterly April 1 – June 30July 30 Payment Management System (PMS) July 1 – September 30October 30 October 1 – December 31January 30 January 1 – March 31April 30 Federal Financial Report (FFR) Federal (SF-425) Annually October 1 – September 30December 30 Online Data Collection System (OLDC) Program Progress Report Semi- Annually Determined by Program Office CRM, , etc.

64 Official Grant and Program Files Office of Grants Management files Official award file All award transactions, financial information, correspondence, approvals, etc Program information file Information for each program announcement Information related to all applications Institution file Contains information on a specific entity which receives multiple awards from multiple programs Project officer files Documents project management activities from inception to closeout Record of that POs activities with respect to the award Auditor or reviewer will request to review for adequate documentation 64

65 Sample Checklist Section 1 Applicant Submissions and Contacts – New Awards and Other Competing Awards Section 2 Review, Evaluation, and Negotiations – New Awards and Other Competing Awards Section 3 Award Notices and Restrictions/Special Conditions Section 4 Post-Award Prior-Approval Requests Section 5 Post-Award Monitoring and Closeout Section 6 Other 65

66 Financial and Programmatic Monitoring Financial MonitoringProgrammatic Monitoring Evidence of expenditures show that purchases are necessary, reasonable, allocable and allowable Flow of Funds Accounting System Internal Controls Cash Management A-133 Submission Interest accrual (as necessary) Programmatic Administration Compare accomplishments to goals and objectives Reinforce priorities and policies Adherence to project scope Performance according to Ops Plans Progress (completion on time) Objectives 66

67 67 Financial Monitoring – Goals The goals of financial monitoring include: –To ensure that grant funds are used as intended and compliant with regulatory requirements –To ensure O N C is meeting the highest of management and fiduciary standards –To ensure grantee compliance with the terms and conditions of the grant award –To meet requirements imposed on O N C by law (A R R A)

68 68 Financial Monitoring – Risk Factors General Selection Criteria –New Grantee –Dollar Amount of Award –Multiple Awards –Entity Type –Subawards –Reporting Findings (FSR, Audit, A R R A) –Unobligated/Unexpended Balances –Program Office Referral/Recommendations –Samples The above general criteria was weighted based on various factors Other risk factors not included above may also be considered based on data analysis -out life of award

69 69 Types of Financial Monitoring that OGM Conducts Desk-based Financial Monitoring –Cash Analysis –Desk Review On-Site Financial Monitoring

70 70 Desk-based Monitoring – Cash Analysis Cash analysis reviews: –Recipient cash transactions –Rate of draws –Payment trends –Unobligated balance –Grant status –Review of last program report

71 71 Desk-based Monitoring – Cash Analysis continued During the O G M quarterly review, O G M and Project Officers discuss the following : Has the grantee submitted timely performance reports? Is the grantee on target as outlined in their approved plan? Has contact been made with the grantee if not on target? If contact has been made, what corrective action has been discussed?

72 72 Desk-based Monitoring – Desk Reviews Limited verification of grantee compliance –Federal regulations –Terms and conditions Identifies potential issues Grants reviewed on a regular basis Core review of a grantees general management practices May require further scrutiny - on-site financial monitoring

73 73 On-Site Monitoring Visits are performed at grantee location Ensure adequate internal controls, policies, processes, and systems exist to appropriately manage awards Assess capability, performance and compliance against administrative regulations and public policy requirements Report on the effectiveness of O N C grantees and grant programs and the stewardship of public funds Collaboration with program office(s) is key to successful monitoring –Joint site visits with program office when feasible –Pre-site visit meeting with program staff On-Site Monitoring Visits

74 74 No written policies and/or procedures Inadequate procurement standards Lack of documentation Inadequate/untimely submission of reports Inadequate Subaward Monitoring Inadequate time and effort records Lack of competition during procurement Conflicts of interest Questioned expenditures Excess Cash on Hand Commingling of funds Common Issues Discovered During Financial Monitoring

75 75 Monitoring vs. Auditing Monitoring is preventative –Performed by grants and program staff –Resolve before audits Auditing is corrective / curative –Performed by auditors –In the record books

76 76 Audits – What is a Statewide Single Audit (A-133)? Required for Entities that Expend $500K or More in Federal Funds during their Fiscal Year Review of All Federal Grant Programs and Requirements Audit Report Is Due 9 Months after the End of the Fiscal Year Submit the Audit Package to the Federal Audit Clearinghouse (FAC) –http://harvester.census.gov/fac/collect/ddeindex.htmlhttp://harvester.census.gov/fac/collect/ddeindex.html

77 77 A-133: Most Common Audit Findings Unallowable activities Unallowable costs Poor cash management Inadequate equipment and real property management practices Expending funds outside of the period of availability of funds Inadequate procurement standards Untimely and inaccurate reporting Lack of subrecipient monitoring

78 78 Audit Resolution Health and Human Services –ASFR, Division of Systems Policy, Payment Integrity, and Audit Resolution (DSPPIAR) is responsible for A- 133 audit resolution OGM will assist in resolution of audit findings only as requested by DSPPIAR –ASFR also serves as a liaison with O M B, the O P D I Vs, and the OIG on grant-related audit issues Recipient responsibilities –Resolve audit findings of subawards Most O N C programs have a large number of subs

79 79 Audit Resolution Corrective Action Plan (C A P) should include: –Description of each finding –Specific steps to be taken to implement the recommendation –Timetable for performance of each corrective action –Description of monitoring to be performed to ensure implementation of the C A P

80 80 HHS Office of the Inspector General (OIG) Performance Audits Evaluates HHS Goals and Objectives with grantee activities Rotating schedule of states and programs Annual audit plan –Identifies key issues –Implementation plan Conducted by OIG staff Compares expenditures to program impact Reports posted on OIG website (http://oig.hhs.gov/reports.asp)http://oig.hhs.gov/reports.asp

81 81 Examples of Inspector General Audit Findings No measurable program goals and objectives Lack of monitoring and oversight Untimely/incorrect financial reporting Questioned costs Inadequate procurement practices Inadequate personal property controls

82 Review Closeout Package Conduct Final Financial Reconciliation Notify Grantee of Closeout Retain Records Establish Disposition of Funds Evaluate Final Performance Reports APPLYESTABLISHREVIEWAWARDMANAGE CLOSEOUT Legend: PHASE Grantee Office of Grants Management Program Office ONC Budget Other Federal/HHS Entities PO/GMO Joint Grants Management Lifecycle – Closeout

83 83 Recipient Closeout Due within 90 Days after End of Award Final Progress Report Final SF-269 Financial Status report –Unobligated funds balance –No unliquidated obligations –Final drawdown –Return excess funds Invention Disclosure (if applicable) Federally Owned Property Control (if applicable)

84 Retention of Records – Grantees Grantee Requirements (45 CFR and 74.53) At least 3 years from the date of submission of the final expenditure report If litigation, claim or an audit is initiated prior to the expiration of the 3 year period, records must be retained until completion of the action and resolution of issues or the end of the 3 year period, whichever is later Records may be retained in an electronic format 84

85 Retention of Records – ONC Office of Grants Management 1 year unsuccessful applications 6 years 3 months official files If open audit, litigation, administrative proceeding retention may be longer Project Officer files 2 years after closeout If open audit, litigation, administrative proceeding retention may be longer 85

86 Review FOASubmit ApplicationRevise Application Review Award Package Accept Award Drawdown Funds Submit Financial Reports Submit Performance Reports Submit Post-Award Requests Ensure Audit is Complete Generate Final Performance Reports Complete Drawdown of Funds Generate Final Financial Reports Submit Closeout Package Retain Records Legend: PHASE Grantee Office of Grants Management Program Office ONC Budget Other Federal/HHS Entities PO/GMO Joint Assist Applicants Establish Commitments APPLY Review Closeout Package Conduct Final Financial Reconciliation Notify Grantee of Closeout Retain Records Establish Disposition of Funds Evaluate Final Performance Reports CLOSEOUT Obligate Funds Set Up Congressional Notification in System Release Funds Create Notice of Grant Award AWARD Notify Grantee of Award Conduct Appropriations Analysis Develop Funding Opportunity Announcement (FOA) Release FOA Appropriation OMB Apportionment Authorizing Statute ESTABLISH Allocate Funds Review and Approve Post- Award Actions Conduct Financial Monitoring Review Financial Reports Review Performance Reports Review Audits Conduct Programmatic Monitoring MANAGE Review /Recommend Post-Award Actions Program and Grants Management Training and Technical Assistance Review Application Perform Budget Review Objective Review Assess Fiscal Integrity Develop Funding Memo REVIEW Assess Funds Availability Grants Management Lifecycle

87 87 Critical Reference Documents American Recovery and Reinvestment Act of 2009 (Recovery Act) What does the law say Statute is highest in order of precedence 45 CFR Part 74 and Part 92 - Administrative Requirements Part 92 – Government organizations (Including Tribal) Part 74 – NGO Uniform administrative rules when implementing Federal grant programs Cost Principles 2 CFR Part 220 – Educational Institutions 2 CFR Part 225 – Government Organizations (Including Tribal) 2 CFR Part 230 – Non-Profit Organizations FAR 31.2 OMB Circular A Audits of States, Local Governments, and Non Profit Organizations

88 88 HHS Grants Policy Statement (GPS) –Grants policy for recipients –Incorporated as a term in NGA –Dos and Donts –ONC staff should also know the GPS in order to provide support to grantees –http://dhhs.gov/asfr/ogapa/grantinformation/hhsgps107.pdfhttp://dhhs.gov/asfr/ogapa/grantinformation/hhsgps107.pdf Funding Opportunity Announcement (F O A) Notice of Grant Award (NGA) with Award Terms and Conditions Grants Management Advisories (GMAs) Grants Management Memorandum (GMM) Program Information Notices (P I Ns) Program Assistance Letters (P A Ls) Critical Reference Documents – continued

89 89 Grants Management Advisories (GMAs) – technical assistance resource which will provide additional information in specific grants management areas for Grantees –O N C-GMA Roles and Responsibilities Grants and Cooperative Agreements –O N C-GMA Review of Proposed Subawards and Procurement Contracts Under Grants –O N C-GMA Matching and Cost Sharing –O N C-GMA Use of Unobligated Balances under Grants and Cooperative Agreements –O N C-GMA Allowability of Food Costs –O N C-GMA Program Income –O N C-GMA Subrecipient Monitoring –O N C-GMA Allowability of Payments to Uniformed Services and Civilian Federal Employees Critical Reference Documents – continued

90 90 ONC Office of Grants Management has a Training and Technical Assistance (T A) Plan based on three different levels of assistance: Level I: Guidance and Information Sharing – Consists of the daily technical assistance of grants administration. Level II: Sample Protocols, Templates and Models – Targeted telephone and electronic assistance involves assisting recipients in the development of protocols and templates, as well as other specific needs, as requested by a recipient. Level III: Targeted Training Deliveries and Direct On-Site Assistance – Includes targeted internal and external training sessions. Training and Technical Assistance Plan

91 91 Grants Management T A request form –Please use this form to request Training and Technical Assistance from the ONC Office of Grants Management –Completed forms are available from, and should be submitted to Office of Grants Management – TA Requests

92 Grants Management Questions 92


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