Financial Management

Stacey Jones, Resolution SpecialistOGCM- Division of Policy, Review and Resolution

Young Offender GrantsNew Grantee Orientation

November 4-5, 2009

How Feds View Themselves

How Grantees View Feds

The NEW DOL Grantee

Our Expectations of You:A program that is designed to focus on

customer needs and to address those needs

A program that meets the requirements of Federal law and regulation

A program in compliance with OMB requirements and Generally Accepted Accounting Principles.

The NEW DOL Grantee

What you can expect from us: Assistance with

regulations On site technical

assistance and monitoring

Assistance with fiscal and programmatic issues

The Fiscal Program Divide

There is a need for program operators to be aware of financial requirements

There is a need for fiscal people to be aware of program requirements

No one gets to opt out

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 Proportional Share and

Benefits Received

Rules affecting programs

WIA regulationsAdministrative cost

20 CFR 667.220

Uniform administrative requirements29 CFR Parts 95 and 97Grant management rules

Cost principlesDetermine allowable costs

Uniform Administrative Requirements

OMB Circulars A-102 & A-110Codified for DOL grant programs29 CFR Part 97

State, local and Indian tribal governments29 CFR Part 95

Everybody elseSlight differences

Follow DOL rules

All Financial SystemsMust adhere to 7 separate standards

1. Financial reportingSystem must permit preparation

of Federal financial reportsMust report accruals

2. Accounting recordsAdequately identify grant funds

Awards, obligations, assets, liabilities, income and expenditures

Supported by source documentationMust be maintained in accordance with GAAP

Financial Standards

3. Internal controlsSystem to protect integrity of fundsAccountability for cash, property & other assets

4. Budget controlsComparison of actual expenditures (outlays) to

approved budget planCompliance with line item requirementsPrevents overspending

More Financial Standards

5. Allowable costsOnly allowable costs chargedOnly allocable costs charged

6. Source documentationCosts must trace to authorizing documentProof that costs are allowable & allocable

7. Cash managementSystem to control cash assets

Cost principles

Set of government wide rules Cost principles

Define conditions for charging costs

Types of Costs Allowable Unallowable Allowable with conditions (Prior Approval)

If Cost not Treated- Principles of necessary and reasonable apply

OMB Circulars (Cost Principles)

A-87Governments (State, Local, Indian Tribal)

A-122Non-profit organizations

A-21 Institutions of Higher Education

48 CFR Part 31Commercial organizations

Handout

Factors Affecting Allowability of CostsAuthorized or not prohibitedConsistent with the Federal rules &

CircularsConsistent treatmentConform to limitations/exclusions

contained in the cost principlesDocumentedConsistent with GAAP

Allowable Grant Costs

Based on grant program and Statement of Work:

Curriculum DevelopmentParticipant Support ServicesCase Manager Mentoring Program ProviderGED classesEmployment Specialist

Allowable Costs with Approval Conditions

Equipment Computer NetworksVehicles

If prior approval requirement existsBEFORE incurring cost

Must be requested in writingMust be approved

Approval requests to Grant Officer

Unallowable Costs

Pre-award costsParticipant stipendsMonthly pizza parties for participantsInterest, fines & penaltiesContingency reservesReal property purchase/construction

Exception: ADA Compliance

Unallowable

Alcoholic beveragesLobbyingLegal expenses for prosecution of

claims, ALJ audit appeals or civil actionsEntertainment

Be careful with employee morale costs.

Prohibited Activities

Employment generatingSpecific exceptions

Public service employmentAllowable with conditions under some

programsBusiness relocationSectarian activities

Equal Treatment in DOL programs for Faith-based and Community Organizations

PL 109-234

Applies to All ETA appropriated funds

All grants, contract and interagency agreementsAll funds available on June 15, 2006

Limits salary and bonus payments to individuals

Implementation guidance in TEGL 5-062008 limit is $172,200

Who is covered?

Individuals paid by ETA appropriated funds

Direct recipients and all subrecipientsDirect costs or through an Indirect Cost

RateVendors are not subject to limitation

Administrative Costs

20 CFR 667.220(a)Not related to direct services

Either to clients or employersList of specific functions

Unlike traditional definitions10% limitation

Based on grant award amount

Handout

Indirect Costs

Costs through an approved Indirect Cost Rate or Cost Allocation Plan

Included on the SF-424AReported on the ETA-9130May be both Administrative & Program

costs WIA definition applies

Leveraged Resources

Recipient share of costsNon-Federal funds used for grant purposesReported on line 10k on the ETA 9130

Other Federal Funds Federal Funds available for the project Reported on line 11a on the ETA 9130

Handout

Financial Reports

ETA 9130Electronic reporting system

Use of passwords and pinsQuarterly reports

Cumulative from beginning of projectAccrual basisDue 45 days after quarter end

Final and Closeout Reports

Handout

Financial Reports

Keep in mind—Accrual basis of reportingAdministrative costs

Breakout on line 10.fLeveraged resources

Non-Federal resources expended Lines 10.k-m

Federal resources expended Line 11.a

Reporting Contacts

Initial Contact – Federal Project Officer

On-Line Reporting System - Password and PIN

-Shantay Logan – logan.shantay@dol.gov

-Avery Malone – malone.avery@dol.gov

Additional Resources

Financial Management Training Tutorial Workforce3One Website (www.workforce3one.org)

Tutorial Titles: Introduction to Grant Application Forms (SF 424 and SF424A) Introduction to Procurement Requirements Financial Management Principles Introduction to Financial Reporting (ETA -9130)

Questions?