1 Additional Resources Uniform Guidance: 2 CFR Part 200 - PDF document

Grants Financial Topics Presentation for the 2016 STOP Administrators and Coalition Directors Joint Meeting Presented by: Grants Financial Management Division, March 2016 Donna Simmons and Heidi Hull OVW 1 Topics of Discussion • Uniform Guidance Effective Dates • Pass-through Requirements • Required Subaward Information • Evaluate Risk of non-compliance • Subrecipient Monitoring and Management • Supplanting • Indirect Costs • Questions OVW 2 GFMD Contact Information How to contact us -- OVW GFMD Helpdesk: 1-888-514-8556 Fax: 202-514-7045 OVW.GFMD@usdoj.gov OVW award acceptance: OVW.acceptance@usdoj.gov or Fax 202-514-7045 OVW GMS technical assistance (other than password resets): OVW.GMSSupport@usdoj.gov or 1-866-655-4482 OVW 3 1

Additional Resources Uniform Guidance: 2 CFR Part 200 https://cfo.gov/cofar/ OVW Financial Guide Webinar Part 1: New Uniform Guidance https://www.youtube.com/watch?v=m0kwPaQBq6 4&feature=youtu.be Webinar Part 2: New Uniform Guidance https://www.youtube.com/watch?v=uw4-s- Fl64Q&feature=youtu.be OVW 4 Uniform Guidance Effective Dates OVW 5 Uniform Guidance Effective Dates • Administrative Requirements and Cost Principles are effective for federal awards made after December 26, 2014 – Applies to OVW’s FY 2015 Awards and after • Audit Standards (Subpart F – Audit Requirements) became effective for audits of fiscal years that begin on or after December 26, 2014 OVW 6 2

Pass-through Requirements OVW 7 Required Subaward Information Subawards must contain: • Subrecipient Information: - Name - Unique entity identifier (ie. DUNS) - Period of performance - Subaward amount - Indirect Cost Rate or De Minimis Rate (if used) • Requirements/Special Conditions for: - Federal statutes/regulations - Award terms/conditions - Federal agency - Potential risk based on Risk Assessment - Additional conditions as needed, see: 200.207 OVW NOTE: See section 200.331(a) for complete list 8 Required Subaward Information Subawards must also contain: • CFDA number Terms and conditions for closeout • Allow access to records and financial statements to • ensure compliance Clearly identify as subaward • Project description (should respond to FFATA) • • Federal award number, period of performance, and award amount • Name of Federal agency, Pass-through Entity, and contact information OVW NOTE: See section 200.331 for complete list 9 3

Assessment of Subrecipients Provisions for Disclosures Subrecipient must disclose in writing: • – Any potential conflict of interest – Violations of Federal criminal law affecting the award:  Fraud, bribery, gratuity violations Non-compliance may result in Suspension or • Debarment OVW NOTE: See sections 200.112-200.113 and 200.331 10 Evaluate Risk of Non-compliance Consider the following: • Subrecipient’s prior experience Suspension and Debarment • • Audit results and findings New personnel or substantially changed systems • Past monitoring history • OVW NOTE: See sections 200.331(b) 11 Subrecipient Monitoring and Management Pass-through Entities are required to: Clearly identify the agreement as a subaward and • include all required information Evaluate subrecipient’s potential risk for non - • compliance with Federal statutes, regulations, and award requirements, and add additional special conditions as needed Monitor activities, financial/performance reports, and • audit compliance (as required in Subpart F) When necessary, take enforcement action for non- • compliance OVW NOTE: See section 200.331 12 4

Subrecipient Monitoring and Management Standards for Financial & Program Management Relate financial data to performance • accomplishments of the award • Financial Management Requirements – Written policies and procedures – Similar to A-110 requirements Effective Internal Controls • – Comply with Federal regulations and award conditions – Safeguard Personally Identifiable Information OVW NOTE: See sections 200.301-200.303 13 Subrecipient Monitoring and Management Monitoring Tools include - • Review financial and programmatic reports • Provide training and technical assistance • Perform on-site reviews • Agreed-upon-procedure engagements - See: Audit Services section 200.425 OVW NOTE: See section 200.331 14 Supplanting OVW 15 5

Supplanting - To deliberately reduce appropriated funds because of the existence of Federal funds. - For example, a State has appropriated funds for a stated purpose (ie. Victim Services) and then the State receives a Federal award for the same purpose. Because of the receipt of the Federal award, the State reduces their appropriated funds for Victim Services thereby reducing the total available funds for Victim Services. - Federal funds should increase the funding OVW available for a specific purpose. 16 Indirect Costs OVW 17 Indirect (F&A) Costs Federally negotiated rates must be accepted • Federal agencies may place limitations under the following circumstances: – For a single award or class of awards – If required by statute/regulation or Federal agency head Federal agency must have established • policy/procedure in place to deviate from negotiated rate OVW NOTE: See section 200.414 18 6

Indirect (F&A) Costs Extensions on existing Federally-negotiated rates One-time extension for period of up to 4 years • Subject to review and approval from cognizant • agency who negotiates the rate • If approved – may not request rate review until end of extension period • Must re-apply to negotiate new rate at end of extension period OVW NOTE: See section 200.414 19 Types of Rates Final Rate: • Rate applicable to a specific time period based on the financial statement from this period • Final rates are not adjusted; they are final Provisional Rate: • Temporary indirect cost rate used until a “Final” rate is established for the period specified in the agreement Predetermined: • Rate applied to a specific current or future time period • Generally not adjusted after the fact Fixed Carry Forward: • Rate applied to a specific current or future time period • Based on estimated costs for a future time period OVW • Generally adjusted after actual costs are known 20 Types of Bases The indirect cost rate is computed on the “Base” specified in the rate agreement Various types of bases you may see: • Modified Total Direct Costs (MTDC): – Includes: All direct salaries/wages, applicable fringe, materials and supplies, services, travel, and up to the first $25,000 of each subaward – Excludes: Equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs, and the portion of each subaward in excess of $25,000 • Salaries and wages including fringe benefits • Salaries and wages (excluding fringe OVW benefits) 21 7

10% De Minimis Indirect Rate De Minimis Rate may be used by: Recipients that have NEVER had a Federally • approved indirect cost rate agreement – NOTE: See appendix VII for exceptions • Subrecipients (not contractors), using the same guidelines for recipients OVW NOTE: See section 200.414 22 10% De Minimis Indirect Rate Applying the De Minimis Rate: • Charge 10% of Modified Total Direct Costs (MTDC) without negotiating the rate Costs must be consistently charged as indirect • or direct May be used indefinitely • Rate must be consistently used for all Federal • awards until (if) a rate is negotiated OVW NOTE: See section 200.414 23 10% De Minimis Indirect Rate Example Using the De Minimis Rate in a Budget Personnel: $200,000 (Staff Salary) Fringe: $44,000 (22% of Staff Salary) Travel: $10,000 (OVW TA and Training) Equipment: $0 Supplies: $2,000 (General Office Supplies) Consultants/Contracts: $42,000 (One Partner’s Compensation) Other: $2,000 (Victim/Client Emergency Assistance) Total Direct Costs: $300,000 Modified Total Direct Costs: $283,000 (total direct costs minus amount over $25,000 of each subaward = $300,000 - $17,000) Indirect Costs: $28,300 (10% of MTDC) OVW Total Project Amount: $328,300 24 8

Indirect Cost as Match “Unrecovered indirect costs, including indirect costs on cost sharing or matching, may be included as part of cost sharing or matching only with the prior approval of the Federal awarding agency. Unrecovered indirect cost means the difference between the amount charged to the Federal award and the amount which could have been to the Federal award under the non-Federal entity’s approved negotiated indirect cost rate .” NOTE: See section 200.306. OVW 25 Questions? OVW 26 9