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Grants Administration Updates - OMB’s Uniform Guidance Division of Grants Administration Office for Grants and Federal Fiscal Compliance Texas Education.

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Presentation on theme: "Grants Administration Updates - OMB’s Uniform Guidance Division of Grants Administration Office for Grants and Federal Fiscal Compliance Texas Education."— Presentation transcript:

1 Grants Administration Updates - OMB’s Uniform Guidance Division of Grants Administration Office for Grants and Federal Fiscal Compliance Texas Education Agency ACET Fall Conference October 9, 2014 © 2014 by the Texas Education Agency

2  Cost Principles ◦ A-87 – LEAs and ESCs ◦ A-21 – IHEs ◦ A-122 – Nonprofit Orgs  Admin Rules ◦ A-102 – LEAs and ESCs ◦ A-110 – IHEs/Nonprofits  Audit Rules ◦ A-133 ◦ A-50 OMB Uniform Guidance One Set of Rules for All Federal Grants

3  Effective December 26, 2014  Applies to all new federal awards on or after this date  Does not apply to grants awarded prior to 12/26/14  Any carryover funds will follow current rules, not the rules from original grant award Uniform Guidance Effective Date

4  Auditors and Monitors: ◦ Outcomes vs. Process  Flexibility for Grantees  Major emphasis on “strengthening accountability” A New Focus: Performance and Compliance

5 Most Significant Changes  Time and effort requirements  “Specific conditions” option  Subrecipient monitoring requirements  Monitoring findings and resolution requirements

6 Time and Effort Requirements  Certifications  Substitute system

7 Specific Conditions  “High-risk” grantee designation  Review of each subrecipient’s risk level

8 Subrecipient Monitoring Requirements  Scope of monitoring determined by each subrecipient’s risk  Possible monitoring activities

9 Monitoring Findings and Resolution Requirements  Raising thresholds for: ◦ Required single audit ◦ Questioned costs

10 Key Sections of Uniform Guidance

11  Salaries of administrative and clerical - charged as indirect costs  Can be charged as direct costs only if: ◦ Services integral to grant ◦ Staff specifically identified with activity or project ◦ Costs explicitly included in the budget ◦ Costs not recovered as indirect costs Direct Costs (Sec )

12  Advertising/Public Relations – allowable for programmatic purposes  Conferences – meals, local travel, and finding dependent care resources  Travel Costs – participation in conference was necessary for the project Selected Items of Cost (Sec – )

13  Time & Effort  Substitute systems encouraged if approved by TEA  Records that meet standards – no further documentation needed Compensation – Personal Services (Sec )

14  Grantee must perform a cost or price analysis for every procurement action in excess of $150,000  Independent estimates must be made before receiving bids and proposals Contract Cost and Price (Sec )

15  Competitive quotations not required for “micro-purchases” of $3,000 or less  Small purchase procedures for services or supplies not exceeding $150,000  Sole Source - used only under certain circumstances ◦ new circumstance – authorized by TEA Methods of Procurement (Sec )

16  Micro-purchases must be distributed equitably among qualified suppliers  The price must be reasonable Micro-Purchases ( )

17 New Definition:  “Machines used to acquire, store, analyze, process, and publish data and other information electronically, including accessories…” Computing Devices (Sec )

18  Cannot encumber property without approval of TEA and/or USDE  Equipment may be used for other projects if it does not interfere with the work on the projects for which it was originally acquired  Preference must be given to certain projects as specified in the Uniform Guidance Equipment (Sec )

19  Grantee or applicant must disclose in writing all violations of Federal criminal law potentially affecting the Federal award, involving: ◦ Fraud ◦ Bribery ◦ Gratuity Mandatory Disclosures (Sec )

20  For grant expenditures, authorized official will certify that: ◦ Reports are true and accurate ◦ All expenditures are allowable under the grant ◦ There is no “false, fictitious, or fraudulent information”  This is a legally binding certification Required Certifications (Sec )

21  Grantee may seek prior written approval from TEA for “indirect costs” or “special or unusual costs”  May prevent future disallowance or dispute based on “unreasonableness” or “non allocability” Prior Written Approval (Sec )

22  Establish effective internal control  Evaluate and monitor compliance  Take prompt action when noncompliance identified  Take reasonable measures to safeguard personally identifiable information Internal Controls (Sec )

23  A process that provides “reasonable assurance” that objectives are met  A system that reduces the risk of fraud, waste, and abuse  Three types of internal controls: ◦ Preventative ◦ Detective ◦ Corrective What Are Internal Controls?

24  New TEA guidance handbook to be released  COSO Integrated Framework  GAO Standards for Internal Control (Green Book) Internal Controls Guidance and Resources

25  The grantee must have written procedures to implement the requirements of the Cash Management Improvement Act (CMIA) rules for payments Written Procedures for Payment (Sec and Sec )

26  The grantee must have written procedures for determining the allowability of costs in accordance with the Omni-Circular. Written Procedures for Allowable Costs (Sec )

27  The grantee must have documented procurement procedures  Can only contract with responsible contractors Written Procedures for Procurement ( )

28  The TEA must establish conflict of interest policies for Federal awards  The grantee or applicant for a Federal award must disclose in writing any potential conflict of interest Conflict of Interest ( )

29  Review new Uniform Guidance  Develop written policies and procedures for new and revised requirements  Ensure all appropriate staff are trained on new Uniform Guidance Next Steps for Subrecipients

30  Grants Administration   Under ‘Grant Resources’ section: TEA Resources

31 Uniform Guidance Online Title 2 – Grants and Agreements Subtitle A, Chapter II, Part 200

32 Division of Grants Administration Office for Grants and Federal Fiscal Compliance Texas Education Agency (512) Contact Information

33 Copyright © Notice. The materials are copyrighted © and trademarked ™ as the property of the Texas Education Agency (TEA) and may not be reproduced without the express written permission of TEA, except under the following conditions: 1. Texas public school districts, charter schools, and Education Service Centers may reproduce and use copies of the Materials and Related Materials for the districts’ and schools’ educational use without obtaining permission from TEA. 2. Residents of the state of Texas may reproduce and use copies of the Materials and Related Materials for individual personal use only without obtaining written permission of TEA. 3. Any portion reproduced must be reproduced in its entirety and remain unedited, unaltered and unchanged in any way. 4. No monetary charge can be made for the reproduced materials or any document containing them; however, a reasonable charge to cover only the cost of reproduction and distribution may be charged. Private entities or persons located in Texas that are not Texas public school districts, Texas Education Service Centers, or Texas charter schools or any entity, whether public or private, educational or non-educational, located outside the state of Texas MUST obtain written approval from TEA and will be required to enter into a license agreement that may involve the payment of a licensing fee or a royalty. For information contact: Texas Education Agency, 1701 N. Congress Ave., Austin, TX ;


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