1. Strengthening Historically Black Colleges and Universities Division
U.S. Department of Education Office of postsecondary education Institutional Service
Strengthening Historically Black Colleges and Universities Division
June 2018

2. Strengthening Historically Black Colleges and Universities Division: Title III, Parts A, B, E, F, and Title VII, Part A Programs  
Title III Part B Strengthening Historically Black Colleges and Universities – Title III Part B Strengthening Historically Black Graduate Institutions Minority Science and Engineering Improvement Master’s Degree Programs at Historically Black Colleges and Universities Master’s Degree Programs at Predominantly Black Institutions Predominantly Black Institutions - Competitive Grants Predominantly Black Institutions - Formula Grants Minorities and Retirement Security Program

3. HBCU – PBI Division Director
Dr. Josephine Hamilton,
HBCU – PBI Division Director
Program Officers Telephone Program Lead
Sarah Beaton (202) HBGI
Darryl Davis (202) Paul Douglas
Kelly Harris (202) PBI-Comp
Bernadette Hence (202) MSEIP
Wendy Lawrence (202) HBCU & SAFRA
Bernadette Miles (202) PBI Formula
Sheryl Wilson (202) MHBCU/MRS/MDPBI

4. Type: Discretionary/Formula Duration of Grants: 5-years
Title III Part B Strengthening Historically Black Colleges and Universities
HBCU – Title III, Part B
FY 2018 Appropriation - $279M
Number of HBCU-SAFRA 96
Type: Discretionary/Formula
Duration of Grants: 5-years
HBCU-SAFRA – Title III, Part F
FY 2018 Appropriation –$79M
Number of HBCU-SAFRA 96
Type: Discretionary/Formula
Duration of Grants: 5-years
HBCU) Program comes under the Title III, Parts B and F legislation.  These are the largest funded grant program on the team.  The HBCU, Part B is the regular funding program with an allocation for FY 2016 of $228 million rounded up.  The SAFRA Part F is the mandatory funding program with an allocation for FY 2016 of $79 million rounded down. 
These are 5-year discretionary grants with a formula based calculation for the awarding process. The eligibility of grantees have been designated by Congress in the legislation, so there is no competitive process for new application period.  Only the designated grantees can apply for HBCU funding. Currently, there is 97 HBCU grantees and each are automatically eligible for the SAFRA Program, totaling 196 grants.  (See the grant assignment list.)  

5. Grant Financial Planning and Management
Institution-Level
U.S Department of Education
Be inclusive when writing Comprehensive Development Plans (CDP)
Establish and nurture relationship with State and or institution partners to ensure accuracy of planning and management
Adhere to your State and / or institutional accounting and financial management procedures
Have knowledge of procurement / contracting standards
Enable accurate financial and performance reporting
Institutional Leadership support, buy-in, and stability for the success of the Comprehensive Development Plan and Budget
Lead your leaders – Share knowledge regularly
Establish and nurture relationship with Department’s assigned Program Specialist to ensure accuracy of planning and management
Apply and adhere to Laws, regulation and financial management guidance
5-Year goals with strict annual planning
Lead your Leaders – Share
Set 5-Year Goals with Specific Annual Planning and Continuous Management
Grant financial planning and management begins with an inclusive development of the CDP. As Title III Program Leaders, you must be able to incorporate the financial requirements of your state and institution as well as strictly adhering Federal laws, regulations and standards. Tandemly work to set 5-year goals with specific annual planning and continuous management of outcomes and finances. Listed are suggested work-relationship inclusion for grant and financial management success.
State and institutional grant financial management procedures will vary. Establishing and maintaining working relationship with pertinent individuals (State and Institutional) will enable successful grant planning and financial management. Some State or institutional procedures may include:
Financial management includes contracting, cash management, and the ability to report on expenditures and performance and
the ability to retain records that document these financial transactions.
Federally requirement for grant financial management are found in 2 CFR (a) and will be discuss more in this presentation.

6. Financial Management
Let’s talk about grant financial management for the Federal perspective.

7. Costs - General Criteria
Allowable
Permitted or not specifically prohibited
Allocable
Assignable to the project – in total, or distributed based on proportional benefits
Reasonable
Passes the “prudent” person test
Ordinary and necessary
Comparable with market prices
Same practices for incurring costs for federally funded and other projects
Grantee’s budget should answer the following question - whether expenditures are Allowable, Allocable and Reasonable?
Grantee’s spending of federal funds must be Allowable, Allocable and Reasonable. These concepts come directly from 2 CFR Part 200 Subpart E (Cost Principles)
Any cost related to a Federal project must be:
Allowable – permitted or not specifically prohibited by the law, regulations, terms and conditions of the grant; costs that “conform to any limitations or exclusion in statute or regulation as to the type or amount of the cost.”
Allocable to a particular award – the goods or services can be assignable to the award in accordance with the relative benefit received. That is, the cost is incurred specifically for the federally supported project OR if the cost benefits both the federal award and other work of the organization, the costs can be distributed in proportions (which may be approximated but must be allocated on a reasonable basis that is documented).
Reasonable – in its nature and amount, the cost incurred does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Consider whether: 1) Cost is generally recognized as ordinary and necessary for the operation of the project; 2) incurred through sound business practices, arms’-length bargaining; 3) pay market prices for comparable goods or services for the area; 4) that the individuals concerned acted with prudence in the circumstances; 4) process does not significantly deviate from grantee’s established practices and policies regarding the incurrence of costs.
Be mindful that just because a cost is permitted, it may not be necessary for the project’s success.
2 CFR Part 200
Subpart E

8. Appropriate Use of Federal Funds
Financial Management System and Principales
2 CFR Part 200
Institutions Must:
Provide for accurate, current, and complete disclosure of results regarding the use of project funds
Document both the federal and non-federal funds used to carry out the project
Appropriate Use of Federal Funds
Cost principles for many items are described in 2 CFR
See guidance for spending on meetings: 2 CFR & ED’s “Use of Federal Grant Funds for Conferences and Meetings”

9. Seven Financial Management Standards
Identification of all Federal receipts & expenditures by:
CFDA Title and Number
Award ID and year
Federal agency name
Name of pass-through entity, if any
Accurate, current, and complete disclosure
Records that identify source and application of funds
Effective control over and accountability for assets
Comparison of expenditures to budgets
Written procedures for payments
Written procedures for allowable costs
The Uniform Guidance has standards for what your financial management system much be able to track and report on. Section (b)
Track federal expenditures and receipts (funds drawn from the G5 account) by the specifics of the award.
Allow your organization to accurately report on financials and performance.
Source and application of funds – information pertaining to federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest – all supported by documentation.
Control over assets – Accountability for all funds, property, equipment and other assets, assuring that assets are used solely for authorized purposes.
Ability to compare expenditures to approved budget.
Procedures for determining allowability of costs – in accordance with the general Cost Principles (Subpart E of 2 CFR Part 200) and terms & conditions of the award.

10. Examples of Financial Reporting
G5 maintains records of your draws of federal funds for the project
Federal Financial Report, SF-425 (FFR)
Other OMB approved financial report may be required
G5 Monitoring Report: Large balances might indicate project is not moving forward
Key indicator is 70% or more of funds left within 90 days before end of the budget period
Reason for balance will be clarified before any continuation award will be made
Note to presenter: add the reporting requirements, deadlines, and method (i.e., if financial reports required; what information is required, how are those report collected)
ED grantees are required to submit an FFR if:
Their grants or cooperative agreements involve cost-sharing and the U.S. Department of Education Grant Performance Report Cover Sheet (ED 524B) is not used (e.g., a program office uses a program-specific performance report approved by OMB that does not collect cost-sharing information);
Program income was earned;
The grantee had indirect cost information to report that was not captured on the ED 524B (or ED 524B was not used). The ED 524B collects indirect cost information; however, if this information is not reported on the ED 524B, the grantee must submit the information on FFR. Similarly, if a program uses a program-specific performance report approved by OMB that does not collect indirect cost information, grantees using that reporting document must report indirect cost information on the FFR; or
Program regulations, or a grant term or condition (e.g., high-risk designation), require the submission of the FFR.

11. Internal Controls Requirements and Standards
Grantees must:
Establish & maintain internal controls that provide reasonable assurance that they are managing the grant in compliance with laws, terms & conditions
Comply with laws, terms & conditions
Evaluate their compliance
Act on non-compliance e.g., audit findings
Safeguard PII and sensitive information
Uniform Guidance identifies this guidance:
Internal controls receive heightened attention in the Uniform Guidance. The points on the slide are in section
Examples of Internal Controls important to discretionary grantees:
Time-keeping – track and record employee hours spent on grant
Reconciling expenditures against the approved budget
Your organization’s procurement rules
Equipment management and inventory
Controls over computers even though they may be considered supplies
Data quality plan
Safeguard personally identifiable information (PII) that is created in the course of the grant work.

12. Revision of Budget & Program Plans
Formerly known as Expanded Authorities. Provides grantees with latitude to conduct certain activities without prior approval. However, the changes must be consistent with the approved scope or objective and should not alter it.
Office of the Deputy Secretary
Risk Management Service

13. Grantee RESPONSIBILITIES
Pre-award costs
Budget transfers
Carryover
2 CFR Section
34 CFR Sections
and
These are four areas where grantees have the flexibility to take administrative actions without prior approval by the agency.
Office of the Deputy Secretary
Risk Management Service

14. Changes Requiring Approval
Seek program officer’s approval prior to:
Changes in project scope or objectives
Changes in key personnel
Project director disengaged for 3+ months or 25%+ reduction in time
Changes in amount of matching funds
Transfer of funds budgeted for participant support to other expenses
Generally, grantees are required to report deviations from budget or project scope or objectives and request prior approval from ED for budget and program plan revisions. Prior approval is required for:
Change in the scope or objective of the project (even if it doesn’t affect the total budget).
Changes in Key personnel – your key personnel are specified in your approved application or grant award, such as the Project Director, Lead Researcher, Lead Investigator.
Disengagement from the project for more than 3 months (or a 25 percent reduction in time devoted to the project) by the approved project director (or PI).
Transfer of funds budget for participant support costs or other categories of expenses.
Changes in the amount of approved cost sharing or matching.
The subawarding, transferring, or contracting out the work of the grant, unless described in the approved application (the “work of the grant” does not include contracts such as supply purchases).
Office of the Deputy Secretary
Risk Management Service

15. Required Documentation and Attachments
Needed For ED Review of Activity/Budget Revisions:
Narratives describing your justification for program or budget revisions;
Identify which activity (LAA) your revision relates to;
Budget Narrative outlining the currently approved budget line items and identify what will change and cost associated with each;
Program Activity narrative describing what will change from approved activity submitted in your CDP;
Personnel change requests must include (1) a current outline of current personnel and what positions will be added or removed; (2) resume of person of interest, and (3) a copy of the job description;
Combine your activity and budget requests into (1) submission to program officer to reduce or eliminate multiple requests for approval to program officer;
Examples of what to how to request revisions and what to include with your request.

16. Pre-award Costs Budget Transfer
No prior approval required for costs incurred up to 90 days before budget period begins
Reasonable expectation of receiving a grant
Incurred at own risk
ED funds not available until budget period begins
Prior approval is generally not required to transfer funds across budget categories
Exceptions in 2 CFR …
Prior approval is required:
For training funds or
Transfer or contracting work
Budget Transfers: Department grantees may make budget revisions and transfers without prior approval unless the revision would result in a change to project scope or objectives or include costs that require prior approval in accordance with Subpart E (Cost Principles) 2 CFR (c).
Note to presenters: some programs limit the amount that can be transferred between budget categories (e.g., to 10% of the budget line). If your program has such limits, add them here.
Transfer Training funds or stipends requires prior approval. Also transferring or contracting any work of the grant requires prior approval.
Office of the Deputy Secretary
Risk Management Service

17. Carry-over
Unexpended funds are “carried over” without prior approval for any allowable cost within the approved scope of the project
Complete unfinished activities
New activities within scope
ED Program Officer may request a written statement about how the funds will be used
Large Available balances will require written justification
Note to presenter – check if this is relevant and allowed in your program. Modify slide accordingly.
For multi-year grants, unspent federal funds are forwarded to the next budget period without prior approval. Grantees may use the funds for any allowable costs within the project’s scope and objectives. You may use the funds to complete unfinished activities or to introduce new activities within the scope. However, you are reminded to contact your ED Program Officer prior to beginning any new activities. Your Program Officer may require a written statement to answer questions about how the funds will be used.
Don’t attempt to save funds in an effort to increase the amount available in the next year. Your continuation award may be reduced by the amount of funds carried forward. ED is aware that due to late project starts, late hires, etc., there may be some carryover. However, it should not continue to get larger with each passing budget period.
A written statement and budget will be required if the carryover is associated with a Large Available Balance – 70% or more of the funds remaining within 90 days of the end of the budget period.
Regulations: carry over is allowed under EDGAR Parts 75 and 76 for discretionary and State-administered grants, respectively, and in the Uniform Guidance 2 CFR (d)(3).
Office of the Deputy Secretary
Risk Management Service

18. G5 Monitoring Report: Excessive Drawdowns
General indicators of excessive draw 1st Quarter More than 50% 2nd Quarter More than 80% 3rd Quarter 100%
Unspent cash must be returned
Interest may be charged
The Excessive Drawdown report reviews each grant at 3 times during the budget period – at the end of the 1st , 2nd and 3rd quarters using these percentages as benchmarks. If draws are well in excess of these levels and up-front expenditure is not clearly part of your projects plan (in the approved application) your program officer may contact you to find out why.
If your project is expending funds faster than expected, you may run out of funding before the end of the project period and endanger the success of your work.
If withdrawals are found to exceed the projects’ expenditures, the excess cash must be returned to the government and interest may be charged. Remember the cash management rules – draw funds for reimbursement or only for immediate cash needs if you are allowed to draw advances.
Note to presenters – if your program has a different expected spend out rate, change the benchmarks in the slide above.
Office of the Deputy Secretary
Risk Management Service

19. Communicating with Your
Grant Monitoring
Communicating with Your
Program Specialist
How the Department monitors your projects.
Office of the Deputy Secretary
Risk Management Service

20. EMAIL REQUEST SUBJECT LINE
Subject Line: Award Number (P031B18XXXXX) and Topic
With the full contact information is Required: Project Director’s Name, Name of
the institution, phone number, and address
Phone Messages
Phone Messages
Writers Full Name
Institution Name
Institution Address
Award Number
Subject
(In the body) Full Contact Information
Full Name of Call
Name of Institution
Award Number
Phone Number
Reason for the Call
Example of how to setup the “Subject Line” when ing a request.

21. Any Questions???