Financial and Grants Management Institute - March 18-20, 2008 1
Federal Grants Management for Fiscal
Staff
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Basics of Financial Management
• Accounting system with detailed chart of accounts
• Proper documentation of expenditures• Appropriate time and activity reporting• Procedures to ensure costs are allowable• Written cost allocation plan• Regular review of budget to actual expenses• Strong system of internal controls• Written policies and procedures• Risk-based monitoring• Effective program management
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Nat’l & Community Svc. Act of 1990
Code of Fed. Regulations (CFR)
OMB Circulars (part of CFR)
State & Local Regulations
NOFO
Notice of Grant Award
Provisions
Certifications and Assurances
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OMB• The Office of Management and Budget
(OMB) oversees and coordinates the Federal government’s administration procurement, financial management, information, and regulatory policies. OMB’s role is to help improve administrative management, to develop better performance measures and coordinating mechanisms, and to reduce any unnecessary burdens on the public.
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Changes to the OMB Circulars
• The OMB Circulars were first published in 1952.
• Most were recently incorporated into the Code of Federal Regulations
• The content and information is the same, however incorporating them into the CFR gives them more legitimacy.
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Revised Grant Guidelines
Federal Grant Guidelines
UniversitiesStates, Local, Indian Tribal Governments
Non-Profits Hospitals
Administrative Requirements
§ 45 CFR 2543§ 2 CFR 215
(formerly A-110)
§ 45 CFR 2541 OMB A-102
§ 45 CFR 2543§ 2 CFR 215 (formerly A-110)
§ 45 CFR 2543§ 2 CFR 215
(formerly A-110)
Cost Principles § 2 CFR 220 (formerly A-21)
§ 2 CFR 225 (formerly A-87)
§ 2 CFR 230 (formerly A-122)
§ 45 CFR 74 (HHS regulations)
Audit Requirements *
OMB A-133 OMB A-133 OMB A-133 OMB A-133
Notes:CFR = Code of Federal Regulations* = Organization is subject to A-133 if it expends more than $500,000 of Federal funds in its fiscal year
Effective May 11, 2004 and August 31, 2005
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What can be found in the Circulars?
–Cost Principles
–Administrative Requirements
–Audits
The Circulars provides guidance and requirements relevant to the grant in the following areas:
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Source of Critical Compliance Information
1. Provides information on cost allocation2. Lays out guidelines regarding
documentation of time & activity reporting
3. Communicates A-133 Audit thresholds4. Defines allowable costs5. Defines indirect or administrative costs6. Includes specific financial requirements
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Cost Principles• Provide guidance for determining the
allowable costs incurred by organizations • Designed so that Federal awards bear their
fair share of costs • Provide guidance about reimbursement
requirements• Provide uniform standards of allowability and
allocation• Encourage consistency of treatment of costs
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Standards of Allowability
• Reasonable• Necessary• Allocable• Authorized and
legal• Within cost
limits
• Treated consistently• Meets Cost
Accounting Principles and Standards
• Not double charged• Well documented
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Reasonable
A cost is reasonable if, in its nature or amount, it 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 costs.
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Cost PrinciplesExamples of costs described in Circular:• Advertising and public relations costs • Compensation for personal services• Memberships, subscriptions, and professional
activity costs• Recruiting costs• Rental costs• Training and education costs• Travel costs
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Administrative Requirements
Examples of items addressed in Circulars
• Pre-award policies• Special award conditions• Purpose of financial and program
management• Standards for financial management
systems• Cost sharing or matching
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Audit Requirements
OMB-133 Audit• Standards for obtaining
consistency and uniformity among Federal agencies for the audit of organization’s expenditure of Federal funds.
• Applicable to organizations that expend $500,000 or more of federal funds in a fiscal year.
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Document Internal Controls through Policies &
Procedures
Documented Policies and Procedures are important because:
• They are the standards for the organization’s operations
• They help in maintaining information that is crucial to operations that would otherwise remain in employees’ “heads”
• They help in orienting new employees and substitutes if the appropriate personnel are absent
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Written Policies and Procedures
Assist with consistency and clear communication of expectations:
• Policies set expectations of “what is to be done”
• Procedures or processes describe “how is it to be completed”
• Effective ones explain the rationale and include examples of principal transactions and completed forms
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Examples of Key Policies & Procedures
• Authorizations of transactions
• Payroll procedures
• Cash receipts procedures
• Procurement Policies
• Travel regulations
• Financial Reporting
• Budgeting• Record
Retention• Conflict of
Interest• Timekeeping
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Match or Grantee Share• There are matching requirements on most
of the CNCS grants• Match is the share of total costs that the
grantee contributes from cash or in-kind sources
• The regulatory requirements for matching funds are the same as the requirements for Federal grants funds.
• You need to ensure that the match (grantee share) is allowable under the grant requirements.
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Critical Elements for Financial Reporting
Timely – Ensure all deadlines are met.Accurate – Use accounting data that
has been reviewed.Complete – Reports should contain all
pertinent information relating to reporting period.
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System must be capable of:• Distinguishing grant versus non-grant related
expenditures• Identifying costs by program year• Identifying costs by budget category• Differentiating between direct and indirect
costs (administrative costs)• Distinguishing matching funds separately from
grant funds• Recording in-kind contributions as both
revenues and expenses
Key Accounting System Requirements for Accurate Reporting
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Key Elements of Financial Reporting
• There should be proper documentation in the files to support all information reported in financial report.
• All financial reports should be prepared with information that comes directly from the organization’s accounting system.
• There should be a review and reconciliation of the information to ensure accuracy prior to report submission.
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ReportsFinancial Records
FFR
PER
Trial Balance
Work Statements
Ledger
Journals
Source
Document
Allowable Costs
Program
Authorized
OMB
Circulars
GMO
Determined
Budget
Tailoring the
Budget
Clarifying Objectives
Reviewing the
Budget
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Develop a Clear Audit TrailDocumentation Accounting
System
AccountingReportsFFR
FINANCIAL STATUS REPORT 1. Federal Agency and Organizational Element
to Which Report is Submitted
2. Federal Grant or Other Identifying Number Assigned By Federal Agency
OMB Approval No.
Page ______
of ______ Pages
3. Recipient Organization (Name and complete address, including Zip code) 4. Employer Identification Number
5. Recipient Account Number or Identifying Number
6. Final Report
Yes No
7. Basis
Cash Accrual
Funding/Grant Period (See Instructions) From: (Month, Day, Year)
To: (Month, Day, Year)
9. Period Covered by this Report From: (Month, Day, Year)
To: (Month, Day, Year)
10. Transactions:
I Previously Reported
II This
Period
III Cumulative
a. Total outlays
b. Recipient share of outlays
c. Federal share of outlays
d. Total unliquidated obligations
e. Recipient share of unliquidated obligated
f. Federal share of unliquidated obligations
g. Total Federal share (Sum of lines c and f)
h. Total Federal funds authorized for this funding period
i. Unobligated balance of Federal funds (line h minus line g)
a. Type of Rate (Place “X” in appropriate box)
Provisional Predetermined Final Fixed
11. Indirect
Expense b. Rate
c. Base d. Total Amount e. Federal Share
12. Remarks: Attach any explanations deemed necessary or information required by Federal sponsoring agency in compliance with governing legislation.
13. Certification: I certify to the best of my knowledge and belief that this report is correct and complete and that all outlays and
unliquidated obligations are for the purposes set forth in the award documents. Typed or Printed Name and Title
Telephone (Area code, number and extension)
Signature of Authorized Certifying Official
Date Report Submitted
NSN 7540-01-218-4387 259-201 Standard Form 269A (REV 4-88)
Prescribed by OMB Circulars A-102 and A-110
PER
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What are Budget Controls?
• Reviews of budget to actual expenses regularly to avoid cost overruns
• Identification of expenditures that many not be budgeted to ensure they can be claimed
• Identification of expenditures that may need approval before being claimed
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Key Budgetary ControlsBudgetary controls include:• Regular monitoring of budgets to actual year-to-
date and current period expenditures or outlays• Explaining any budget variations that are
unexpected or unusual and determining necessary adjustments
• Ensuring compliance with laws, regulations, and CNCS provisions, particularly matching percentage requirements
• Requesting prior approvals for modification, if necessary
• Assuring budget changes are properly approved
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Items to Have on Radar• Read and understand the award terms and
provisions and revisit award requirements frequently throughout the grant
• Familiarize all program staff with provisions, regulations and program policies and procedures
• Ensure supporting documentation relates directly to program funded by the CNCS grant
• Establish documentation for expenditure requirements to ensure costs are allocable, allowable, necessary, and reasonable
• Maintain records and establish a written records retention policy
• Develop good internal controls• Ask questions and obtain approval when needed
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Things to Keep in Mind!
1. Staff working on grant should review AmeriCorps rules and regulations
2. Strong financial system is critical to proper administration of a federal grant
3. Self assess organization’s strengths and weakness to determine where to focus on improvements
4. Ensure there are written polices and procedures5. Program and fiscal staff meet regularly to ensure
everyone is on the same page and aware of program financials and budget status
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