1. Federal Grant Management Basics Perkins Grant Management WebEx June 21, 2011 Donna Brant Oregon Department of Education Oregon Department of Education | June 2011

2. Overview: 1.The Basics  Application and Revision  Allowable and Reasonable  Allocable and Supplemental 2.Property Control 3.Time Distribution Oregon Department of Education | June 2011

3. Disclaimer… This webinar is intended for program staff and is presented from a program perspective…. Discuss any questions or procedures with your accounting staff or auditors! Oregon Department of Education | June 2011

4. EDGAR… Who is he and what does he have to do with my grant?? http://www2.ed.gov/about/offices/list/osdfs/edgar2008.pdf Google: EDGAR Education Department General Administrative Regulations Oregon Department of Education | June 2011

5. EDGAR describes…  Financial Reporting  Accounting Records  Internal Control  Budget Control  Allowable Costs  Source Documentation  Cash Management Oregon Department of Education | June 2011

6. The Perkins Grant Process Grant Application and Budget Narrative Revisions EDGAR 80.30(d) Grantees or subgrantees must obtain prior approval of the awarding agency whenever any of the following actions is anticipated:  Any revision of the scope or objectives of the project (regardless of whether there is an associated budget revision requiring prior approval). EDGAR 80.30(f) a request by a subgrantee for prior approval will be addressed in writing to the grantee. Oregon Department of Education | June 2011

7. Allowable Costs OMB Circular A-87 Costs must meet the following criteria:  Be reasonable and necessary  Be allocable  Be authorized or not prohibited under state or local laws or federal grant regulations Oregon Department of Education | June 2011

8. Reasonable Costs  Do not exceed that which would be incurred by a prudent person  Are ordinary and necessary for the operation of the program  Represent sound business practices and arms length bargaining Oregon Department of Education | June 2011

9. Allocable Cost  Must provide a benefit to the program in proportion to the amount of expenditure  Costs are allocated over the period of the grant  Goods may be charged to the program in accordance with the relative benefit received Oregon Department of Education | June 2011

10. Supplement Not Supplant Federal funds must be used to augment the regular education program Supplanting is using federal dollars to provide: ◦ A required program or service ◦ A program that was provided by non-federal funds in the prior year ◦ Services to some students while using local sources to provide the same services to others. Oregon Department of Education | June 2011

11. Records and Source Documents  Lack of documentation is a primary reason for audit findings  Documentation must be available to support every expenditure  From initial requisition to final disbursement  You must follow your own rules  3 year Federal ~ 7 year Oregon Oregon Department of Education | June 2011

12. Property Control All assets purchased with federal funds ◦ Life expectancy of more than one year ◦ Initial cost of more than $200 ◦ Label with year purchased and funding source Oregon Department of Education | June 2011

13. Inventory Purchase cost and date Specific location of asset Funding used for purchase Disposition Oregon Department of Education | June 2011

14. OMB A-87 Rules If federal funds are used for salaries then Time Distribution records are required. Must demonstrate ◦ If employee is paid from federal funds, then employee worked on that specific federal program or cost objective. Oregon Department of Education | June 2011

15. Time Distribution – Why worry? Salary costs are material to many grants. The absence of adequate documentation is basis for repayment of funds. Considered explicitly as a “risk factor” by OMB. Numerous grantees have had to repay millions because of time distribution issues. Oregon Department of Education | June 2011

16. Terminology Time and Attendance RecordsTime and Effort Records Payroll recordsTime distribution records TimesheetTime distribution record Semi-annual certification Personnel activity report (PAR) Time and effort report Monday worked 8:00-4:00Monday worked 60% Perkins Leadership; 5% Perkins Administration; 35% General Fund Schedule Contract Work product Calendar Time log Oregon Department of Education | June 2011

17. Cost Objective A function, organizational subdivision, contract, grant or other cost activity for which cost data are needed and for which costs are incurred. ◦ What federal program cost objective did the employee work on? ◦ These cost objectives must be connected to the salary source. Oregon Department of Education | June 2011

18. Adequate Reporting Retained by the fiscal agent After-the-Fact Prepared After-the-Fact Full disclosure – Report of full time worked Credible endorsement Reliance from the “bottom up” Oregon Department of Education | June 2011

19. If work 100% on single cost objective… Semi-Annual Certification ◦ Signed every six months by supervisor or employee “ From August 15, 2010 until December 31, 2010, Donna Brant spent 100% of her time on Perkins Leadership activities at the Oregon Department of Education.” Oregon Department of Education | June 2011

20. REMEMBER…Adequate Reporting Retained by the fiscal agent After-the-Fact Prepared After-the-Fact Full disclosure – Report of full time worked Credible endorsement Reliance from the “bottom up” Oregon Department of Education | June 2011

21. If multiple cost objectives… Personnel Activity Report (aka…PAR, Time and Effort Report)  Signed and dated every month by employee  Actual accounting of time spent  After the fact  Showing the total effort  Should have report and backup documentation to verify - e.g. calendar, work product, time log Oregon Department of Education | June 2011

22. Comparison and Adjustment Quarterly Quarterly comparison of actual cost to budgeted distribution. quarterly If difference between actual and budgeted cost is 10% or greater make adjustments quarterly. annually If difference is less than 10% make adjustment annually. Oregon Department of Education | June 2011

23. Monitoring Beginning 2011-2012 Expenditure Report ◦ Current and Prior Year ◦ Compare to approved grant/budget ◦ Looking for allowable Inventory and Labeling Time Distribution Records Oregon Department of Education | June 2011

24. Now that you know… Schedule and appointment with your business manager to clarify your policy and procedures Schedule at least quarterly meetings to review budget, expenditures and needed adjustments If in doubt… contact Donna or Reynold! Oregon Department of Education | June 2011

25. For more information: EDGARhttp://www2.ed.gov/about/offices/list/osdfs/edgar2008.pdf OMB A-87http://www.whitehouse.gov/omb/circulars_a087_2004 OMB A-133http://www.whitehouse.gov/omb/circulars_a133_compliance _09toc/ PCRNhttp://cte.ed.gov/ Donna Brant, ODE Donna.brant@state.or.us Reynold Gardner, ODE Reynold.gardner@state.or.us Oregon Department of Education | June 2011