21 st CENTURY COMMUNITY LEARNING CENTERS PROGRAM
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Transcript of 21 st CENTURY COMMUNITY LEARNING CENTERS PROGRAM
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
21st CENTURY COMMUNITY LEARNING CENTERS
PROGRAM
Tehsin Akram, Budget Analyst 2August 8, 2012
Federal Grants Financial Management &Cost Principles and Administrative
Requirements
FY13
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Federal Grants Financial Management Cost Principles and
Administrative Requirements
Specific topics in understanding of:
Federal Grant Financial Management-21st CCLC Use of Funds Basic Cost Principles – determining allowability Selected Cost Principles Property/Inventory Controls Supplement not Supplant
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Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Fundamental Federal Grant Management Process
All are inter-related:
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Use of Funds 21st CCLC program funds must be used to supplement and
not supplant (take the place) of other Federal, State, local, or non-Federal funds
21st CCLC funds must be used to provide supplemental service to meet the needs of children from low income and low performing schools
21st CCLC funds must only be used for authorized out-of-school activities to meet the needs of participating students and their families
Charges to the grant must be allowable under the 21st CCLC program
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Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Cost Eligibility
OMB has issued Grants Management Guidance in three areas:
Cost Principles Administrative Requirements Audit
In addition:GEPAEDGAR (including CFR 34 Part 80)
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Cost Principles
Which Circular do I follow?
OMB A-87 – Cost principles for State, Local and Indian Tribal Governments (includes school districts/LEAs)
OMB A-21 – Educational Institutions (includes colleges, universities)
OMB A-122 – Non-Profit
http://www.whitehouse.gov/omb/grants_circulars/
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Cost Principles - Basic Guidelines To Determine Allowability
Necessary and Reasonable
Be Allocable to Federal Awards
Be Authorized or Not Prohibited Under State or Local Laws or Regulations
Conform to Any Limitations or Exclusions Set Forth in the Federal Cost Principles, Federal Laws, Terms and Conditions of the Federal Award
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Cost Principles - Basic Guidelines To Determine Allowability continued…
Be Consistent with Policies, Regulations, and Procedures That Apply Uniformly to Both Federal Awards and Other Activities of the Governmental Unit
Be Accorded Consistent Treatment
Be Determined in Accordance with Generally Accepted Accounting Principles (GAAP)
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Cost Principles-Basic Guidelines To Determine Allowability continued…
Not Be Included As a Cost or Used to Meet Cost Sharing or Matching Requirements of Any Other Federal Award
Be Adequately Documented
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
What do These Guidelines Mean?
Necessary and Reasonable– Reasonable
• A cost, in its nature and amount does not exceed that which would be incurred by a prudent person under the circumstances
• Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the governmental unit or the performance of the Federal Award
• The restraints or requirements imposed by such factors as sound business practices, arms-length bargaining, Federal, State, and other laws and regulations and Federal Award Terms and Conditions
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
What do These Guidelines Mean?
Necessary and Reasonable– Reasonable (Cont’d…)
• Market prices for comparable goods or services
• Whether the individuals concerned acted with prudence in the circumstances, considering their responsibilities to the governmental unit, its employees, the public at large, and the Federal government
• Significant deviations from the established practices of the governmental unit which may unjustifiably increase the Federal award’s cost
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Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
What do These Guidelines Mean?
Necessary and Reasonable– Necessary
• The cost claimed for a service or item is directly related to the performance objective of the grant
• Cost claimed is consistent with the expenditure category of the grant award
• The type of cost is incurred by other grantees
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
What do These Guidelines Mean?
Necessary and Reasonable– Necessary (Cont’d…)
Questions to ask for determining “necessary”• Is anyone going to question this and why?
• Did I really need this (other cost effective alternatives)?
• Can I support (document) the basis for my decision?
• Have I considered whether there are any risks?
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Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
What do These Guidelines Mean?
Costs Must Be Allocable– Direct Costs
• Cost is allocable to a particular cost objective if the goods or services involved are directly related, chargeable or assignable to such cost objective in accordance with relative benefits
• Can only charge to the grant in proportion (share) to the value received by the program
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
What do These Guidelines Mean?
Costs Must Be Allocable– Direct Costs - examples
• Compensation of employees for the time devoted and identified specifically to the performance of the award
• Equipment and other approved capital expenditures
• Travel expenses incurred specifically to carry out the award
Case Study: An Elementary School purchased 10 laptops for use in its afterschool program. The laptops were used half the time in the afterschool grant program and half the time by students in the regular school during the day. The afterschool grant was charged the total cost of $10,000 for all 10 laptops. Allowable or unallowable?
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
What do These Guidelines Mean?
• Costs Must be Authorized and Not Prohibited Under State and/or Local Law
• Authorized – OMB means the grantee has received specific authority (typically in writing) in the form of an Approved Project Award Notification, and in Accordance with Approved Project Budget
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
What do These Guidelines Mean?
Costs Must be Consistently Administered
• A Grantee must consistently administer all of its Federal Awards using the same Accounting Policies and Procedures
• Consistent with GAAP
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
What do These Guidelines Mean?
Costs Must be Accorded Consistent Treatment
• A cost considered as an indirect expense under one Federal award must be considered as an Indirect Cost under all awards
• Must follow uniform policies that apply equally to Federal and non-Federal activities
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
What do These Guidelines Mean?
Costs Must be Adequately Documented– Proof that:• Grant receipts were properly applied
• Grant expenditures actually occurred
• Expenditures are eligible, allowable, and authorized
• Expenditures benefited the grant
• Transactions are accurately and timely documented
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
What do These Guidelines Mean?
Costs Must be Adequately Documented
– All records pertinent to the award (e.g. award and close-out periods)• Financial• Programmatic• Other Awards
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Selected Items of Cost
21st CCLC Program Use of Funds– Funds may be used for program implementation, as well
as operation expenses such as:• Personnel and personnel benefits
• Staff development
• Consultants, subcontractors and evaluators
• Classroom equipment, materials and supplies
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Selected Items of Cost
Some Unallowable costs specified by OMB cost principles:
• Alcoholic beverages
• Bad debts
• Donations (by recipient)
• Entertainment costs
• Fines and penalties (exceptions)
• Fundraising and investment management costs
• Goods or services for personal use
• Idle facilities (exceptions)
• Lobbying
• Selling and marketing costs
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Selected Items of Cost
OMB A-87―Personnel and personnel benefits:
• “Compensation for personnel services includes all remuneration, paid currently or accrued, for services rendered during the period of performance under Federal Awards, including but not necessarily limited to wages, salaries, and fringe benefits.”
• “Cost of fringe benefits are allowable to the extent that the benefits are reasonable and are required by law, governmental-unit, employee agreement, or an established policy of the governmental unit.”
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Selected Items of Cost
OMB A-87―Personnel and personnel benefits:
• “Cost of fringe benefits in the form of employer contributions or expenses:
Social Security, employee life, health, unemployment, and worker’s compensation insurance (except as indicated in section 22 Insurance and Indemnification), pension plan costs and other similar benefits are allowable provided such benefits are granted under established written policies
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Selected Items of Cost
OMB A-87―Personnel and personnel benefits:
Support for salaries and wages
*Proper time distribution records* Based upon approved and documented payrolls
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Who must maintain time distribution records?
All employees who are paid from Federal funds, or whose salaries are used to match federal funds, are required to document their time and effort
But Why?It serves as a “receipt” for payroll expenditures using Federal
funds
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Selected Items of Cost
OMB A-87―There are two types of participating employees:
• Employees who work solely on a single Federal cost objective – SEMI-ANNUAL CERTIFICATIONS
• Employees who work on more than one (multiple) cost objective (split funded) – monthly PERSONNEL ACTIVITY REPORT (PAR)
• Non-profit organizations: PARs (whether single or multiple cost objectives)
Note: Please refer to the “21st CCLC Time and Effort Reporting July 2012” presentation for more details (available on the training CD)
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Single Cost Objective
• Semi-Annual Certifications must be prepared and signed by the employee or the supervisor who has first hand knowledge of the work performed
100% from a single funding source 100% with a single type of activity 100% of time beyond the full-time day on a single activity (e.g., 4
hours afterschool in the 21st CCLC program)
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Multiple Cost Objective
Employee works on – multiple activities/cost objectives
1. Personnel Activity Report (PAR) – monthly to coincide with 1 or more pay periods (unless a substitute system has been approved by cognizant agency)
2. Reflect after-the-fact distribution of the actual activity
3. Account for the total activity for which employee is compensated
4. Signed by employee
Must contain:
An “effort statement”
Number of hours worked
Time worked on all cost objectives
The specific Federal cost objective (not just “Federal”)
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Selected Items of Cost
OMB A-87―Equipment, materials, and supplies
For personal use – unallowable Necessary to carry out a Federal award – allowable –
direct cost Charged at actual prices, net of applicable credits Donated to Federal program – without charge to Federal
program
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Selected Items of Cost
OMB A-87 & EDGAR―Equipment, materials, and supplies
Equipment means – article of nonexpendable, tangible personal property having a useful life of more than ONE year AND AN ACQUISITION COST of $5,000 or more per unit. However, consistent with the recipient policy, lower limits may be established.
Please note that subgrantees must receive written approval from GaDOE to purchase any item over $5,000 per unit.
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Property/Inventory Controls for Equipment Acquired with Federal
Funds OMB - Uniform Administrative Requirements for Grants:
― Equipment records shall be maintained accurately and include:
Description of the equipment Manufacturer’s serial number, model number and
identification number Source of equipment, including the award number Whether title vests in the recipient or Federal Government Acquisition date (or date received, if donated) and cost Percentage of Federal participation in the cost of
equipment Location and condition of the equipment and date
information reported Unit acquisition cost
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Property/Inventory Controls for Equipment Acquired with Federal Funds
Equipment records shall be maintained accurately and include:
A physical inventory of the property must be taken and the results reconciled with the property records
How often? – at least once every year A control system must be developed to ensure adequate
safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft shall be investigated
Adequate maintenance procedures must be developed to keep the property in good condition
EDGAR 34 CFR 80.32
Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Disposing of Equipment
How do we dispose of 21st CCLC equipment?
Federal regulations, 34 CFR 80.32 and the Financial Management for Georgia Local Units of Administration handbook provide clear guidance
The equipment eligible for disposition must: Not be needed in any 21st CCLC activity Not be needed in any other Federal program Not be needed further for the purpose for which it was
purchased
Note: it would not be appropriate to purchase similar equipment in subsequent years
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Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Selected 21st CCLC Compliance Requirement – Supplement not Supplant
21st CCLC program funds must be used to supplement and not supplant (take the place) of other Federal, State, local, or non-Federal funds
What does this mean?
• Here is a simple thought! Think of local funds, (or other funds that are mandated or required under some authority) as the cake, and 21st CCLC funds as the “icing” on the cake!
• The icing (21st CCLC) is supplementing, and not taking the place of the cake (Federal, state, local, or non-Federal funds), but simply adding something to improve it!
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Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Selected 21st CCLC Compliance Requirement Supplement-not-Supplant
How do I determine if this may be a supplanting issue?
Determine whether your agency provided the goods or services with non-Federal funds in the prior year
Determine whether the services were required to be made available under other Federal, state or local laws
Ascertain if the total level of services applicable to the requirement will increase in proportion to the level of Federal contribution (and not used to cover budget deficits)
Maintain sufficient relevant documentation to demonstrate that the services would not have been provided if the 21st CCLC funds were not available, including supporting documentation such as legislative actions, budget histories
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Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Resources
EDGAR - Education Department General Administrative Regulations http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html
OMB Circular A-21 (Educational Institutions) http://www.whitehouse.gov/omb/assets/omb/circulars/a021/a21_2004.pdf
OMB Circular A-87 (State, Local, and Indian Tribal Governments http://www.whitehouse.gov/omb/circulars_a087_2004/
OMB Circular A-122 (Non-Profit Organizations) http://www.whitehouse.gov/omb/assets/omb/circulars/a122/a122_2004.pdf
GEPA - General Education Provisions Act http://www4.law.cornell.edu/uscode/html/uscode20/usc_sup_01_20_10_31.html
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Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org
Questions?
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