1. Financial and Administrative Management
TAA-CCCT Grants
November 2, 2011

2. Fiscal and Administrative Requirements
Impact program design
Failure to comply may result in sanctions
Accurate financial information is critical to achieving program success

3. It’s all very simple… Written Policies and Sound Business Practices
Followed Consistently Over Time
With Each Funding Stream Treated Equally
With All Costs Being Necessary and Reasonable
Would be done similarly by a Prudent Person
Ensuring Proportionate Share and Benefits Received

4. Rules Affecting Programs
Enabling legislation
Uniform administrative requirements
Grant management rules
Cost principles
Determination of allowable costs
Program regulations
Program activities
Both allowable and unallowable
Cost category restrictions
Statement of Work
Description of grant outcomes

5. The Pyramid of Grant Requirements
Suspension Debarment
Drug Free Workplace
Lobbying
Guidance
Policy Manuals
Davis
Bacon Act
Terms and Conditions
Program Regulations
OMB Circulars
Program Statutes
A&A
Govt.-Wide
Govt.-Wide
Agency & Programs

6. Authorizing Legislation
Trade Adjustment Assistance Act of 1974 (Section 279(b))
The Health Care and Education Reconciliation Act of 2010 (P.L )

7. Uniform Administrative Requirements
DOL adapted OMB Circular A-110 under
29 CFR Part 95
DOL continues to apply the requirements
of 29 CFR Parts 95 and 97 until 2 CFR part
215 becomes final. 7

8. All Financial Systems Must adhere to 7 separate standards
1. Financial reporting
System must permit preparation of
Federal financial reports
Must report accruals
2. Accounting records
Adequately identify grant funds
Awards, obligations, assets, liabilities, income and expenditures
Supported by source documentation
Must be maintained in accordance with GAAP 8

9. Financial Standards 3. Internal controls 4. Budget controls
System to protect integrity of funds
Accountability for cash, property & other assets
4. Budget controls
Comparison of actual expenditures (outlays) to approved budget plan
Compliance with line item requirements
Prevents overspending 9

10. More Financial Standards
5. Allowable costs
Only allowable costs charged
Only allocable costs charged
6. Source documentation
Costs must trace to authorizing document
Proof that costs are allowable & allocable
7. Cash management
System to control cash assets 10

11. Procurement Procurement Requirements Procurement Regulations:
Open and free competition
Sole source
Procurement Regulations:
29 CFR Part 95 or Part 97
Procurement standards for partners and subcontracts

12. Grant Management Requirements
Program Income
Non-federal audits
Property Management
Equipment
Supplies
Reports and Records
After-the-Award requirements
Closeout

13. Federal Cost Principles
Set of government wide rules
Now codified at 2 CFR
Incorporated by reference - Uniform Administrative Standards
29 CFR 97.22
29 CFR 95.27
Cost principles
Define conditions for charging costs
Types of Allowable costs
Allowable
Unallowable
Allowable with conditions

14. The Four Sets of Cost Principles
2 CFR 220 (OMB A-21) Educational Institutions
2 CFR 225 (OMB A-87) State/Local Governments and Indian Tribes
2 CFR 230 (OMB A-122) Non-profit Organizations
48 CFR 31 Contract Cost
Principles and Procedures
dealing with Commercial
Organizations 14

15. Purpose
Provides that the Federal government bears its fair share of costs except where restricted or prohibited by law
Reasonable & Necessary
“Prudent Person Rule”
Allocable
Clearly benefit program
Both direct & indirect costs 15

16. Selected Items of Cost 3 types of Costs If Cost not Treated Allowable
Unallowable
Allowable with Conditions
If Cost not Treated
Principles of necessary and reasonable apply 16

17. Allowable Costs
Hiring and training of instructors and staff to develop curricula
Leasing space
Implementing or upgrading IT infrastructure
Professional services from subject matter experts 17

18. Allowable with Conditions
Examples
Advertising/Public Relations
Equipment (with prior approval)
Alteration of facilities (with prior approval)
Prior Approval
Needed BEFORE incurring cost
May exist in grant agreement 18

19. Unallowable Costs Costs of other grant programs
Interest, fines & penalties
Contingency reserves
Donations and contributions
Real property purchase/
construction
Exception: Compliance with
ADA Requirements 19

20. Allowable Cost Standards
Necessary
To achieve grant outcomes
Reasonable
Sound business practices
Allocable
Only charge costs that clearly BENEFIT grant
Additional standards

21. Financial Reporting 21

22. Financial Reports ETA 9130 Electronic reporting system
Use of passwords and pins
Quarterly reports
Cumulative from beginning of project
Accrual basis
Due 45 days after quarter end

23. Why is Accrual Reporting Important?
Required for ALL ETA programs
Provides more reliable data
Cash basis understates true spending
Failure to report on accrual basis may result in loss of funds 23

24. What does Accrual Reporting Mean?
Transactions are recognized in accounting period in which they occur
Revenue is recognized when received or earned
Expense is recognized when incurred
May be cash disbursement
May be delivery of goods/services 24 24

25. Types of Accrued Costs Salaries of employees Training Travel expenses
Rental costs 25 25

26. The ETA 9130 26 26

27. 9130 Reporting lines Cash Receipts Cash Disbursements Expenditures
Total administrative expenditures
Unliquidated obligations
Leveraged resources
Program Income
Other Federal funds expended

28. Financial Reporting Contacts
Initial Contact – Federal Project Officer
On-Line Reporting System - Password and PIN
-Shantay Logan – 28 28

29. Additional Resources Financial Management Training Tutorial
Workforce3One Website (
IN DEVELOPMENT:
Tutorial Titles:
Introduction to Financial Reporting (ETA -9130)
Cash Management
Cost Allocation, Cost Pooling & Time Distribution
Indirect Costs and Applying for an Indirect Cost Rate for Non-Profits
Cost Classification
Cost Principles 29

30. Next Session – November 9
TAA CCCT Funding Restrictions
Indirect Cost Rates
Administrative Costs
Salary and Bonus limits
Use of funds for Wages
Supportive Services
Real Property

31. Questions?? 31 31