Federal Grants Updates and Overview Nancy Anne Baugher, CPA, CGFM, - - PowerPoint PPT Presentation

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Federal Grants Updates and Overview Nancy Anne Baugher, CPA, CGFM, - - PowerPoint PPT Presentation

MCSAP Planning Meeting and Grants Training 2017 MCSAP Planning Meeting and Grants Training March 22-23, 2017 Minneapolis Marriott City Center Federal Grants Updates and Overview Nancy Anne Baugher, CPA, CGFM, RSBO Grants Officer Grants


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MCSAP Planning Meeting and Grants Training – 2017

MCSAP Planning Meeting and Grants Training March 22-23, 2017 Minneapolis Marriott City Center

Nancy Anne Baugher, CPA, CGFM, RSBO Grants Officer Grants Management Office Office of the Chief Financial Officer

Federal Grants Updates and Overview

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Federal Grants Updates and Overview

Objective: To inform the national FMCSA grants community about areas of immediate importance as well as those on the horizon

  • 1. Key developments and Federal-wide initiatives in federal grant practice
  • 2. Strategic perspectives on grants: cost concepts, investments and

performance

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Key developments and Federal- wide initiatives in federal grant practice

Part I CENTRAL THEMES: Mission-centric, Transparency, Accountability, Efficiency, Effectiveness, Reduce Costs, Consistency, Results

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The Catalog of Federal Domestic Assistance (CFDA) provides a full listing of all Federal programs available to State and local governments (including the District of Columbia); federally-recognized Indian tribal governments; Territories (and possessions) of the United States; domestic public, quasi-public, and private profit and nonprofit organizations and institutions; specialized groups; and individuals. CFDA contains detailed program descriptions for 2,308 Federal assistance programs. The following chart shows the program distribution for the top five issuing agencies

CFDA

Last updated March 16, 2017 Source CFDA website

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CFDA – What Programs?

House of Representative John Boehner (R-OH8) released Republican Lawmakers’ Pledge to America, September 23, 2010.

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Format of the program description will change: Guidelines will be provided to address programs New format more user friendly Procedures for requesting new CFDA numbers will change This will affect the Compliance Supplement* OMB and GSA still dealing with logistics How and when to transition, x-walks, etc More ideas concerning implementation and timetable for changes still at OMB – no request for annual CFDA updates yet

CFDA

*The OMB A-133 Compliance Supplement is a Federal government guide created by the Office of Management and Budget (OMB) and used in auditing federal assistance and federal grant programs, as well as their respective recipients. It is considered to be the most important tool of an auditor for a Single Audit.

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CFDA

The format and structure of CFDA is changing to: Allow for additional CFDA numbers needed for some agencies Align with the Common Government-wide Accounting Classification (CGAC) agency code in the Treasury Account Symbol (TAS) – DATA Act requirement The numbering system will change from aa.xxx to aaa.xxxx For DOT, 20.xxx will become 069.xxxx .xxxx will be up to agency, for now Some discussion about placing conditions placed on sequences (e.g., Reserved sequences for government-wide themes, types of assistance) – nothing concrete here at this time

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CFDA

  • Motor Carrier Safety Assistance
  • MCSAP
  • Number: 20.218 069.xxxx
  • Agency: Department of Transportation

Office: Federal Motor Carrier Safety Administration (FMCSA)

  • PROGRAM INFORMATION
  • Authorization (040):
  • FAST Act, Pub. L. No. § 114-94, §§ 5101(a) and 5101(c) (2015). 49 U.S.C. §§ 31102(a)-(k), 31104 (2016), as amended. See 49 CFR part 350, as
  • amended. States agree to adopt and enforce 49 CFR parts 390-397 and 107 (subparts F and G only), 171–173, 177, 178 & 180. , Public Law 114-

94, 49 U.S.C 390-397 and 107.

  • Objectives (050):
  • The Motor Carrier Safety Assistance Program (MCSAP) is a Federal formula grant program that provides financial assistance to States to reduce

the number and severity of accidents and hazardous materials incidents involving commercial motor vehicles (CMV). The goal of the MCSAP is to reduce CMV-involved accidents, fatalities, and injuries through consistent, uniform, and effective CMV safety programs. Investing grant monies in appropriate safety programs will increase the likelihood that safety defects, driver deficiencies, and unsafe motor carrier practices will be detected and corrected before they become contributing factors to accidents.

  • Types of Assistance (060):
  • FORMULA GRANTS
  • Uses and Use Restrictions (070):
  • The primary MCSAP activities eligible for reimbursement include the National Program Elements currently outlined in 49 CFR § 350.109:
  • 1. Driver and Vehicle Inspections;
  • 2. Tr . . . . . etc

Reference: https://www.cfda.gov

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Federal Funding Accountability and Transparency Act

The Federal Funding Accountability and Transparency Act of 2006 (FFATA), ensures that the public can access information on all entities and organizations receiving Federal funds. Central to the law was the development of the following FFATA- related websites: USASpending.gov - Single, searchable website of all Federal grants and contracts containing information required by FFATA. FSRS.gov - The Federal Subaward Reporting System collects data on executive compensation and first-tier subawards.

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Funding Awarded By State/Territory FY17

https://www.usaspending.gov/transparency/Pages/StateSummaries.aspx The graph displays the funds awarded by contracts, grants, loans, and other financial assistance for fiscal year .

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DATA Act

The Digital Accountability and Transparency Act of 2014 (DATA Act) (P.L. 113-101) requires all Federal agencies to make certain spending information available to the public in a manner that is accessible, searchable and reliable by establishing data standards and requirements.

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Overview of the DATA Act

  • The Act applies to funding issued by the Federal government

in the form of grants, cooperative agreements, loans, contracts, insurance, direct appropriations and other similar forms of assistance.

  • Establishes government-wide data reporting standards for

financial information that is displayed at USASpending.gov.

  • Agencies must implement all other requirements established

under the Act.

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Overview of the DATA Act (cont’d)

  • Amends the Federal Funding Accountability and Transparency Act of

2006 (FFATA); does not supersede it.

  • Grantee subaward reporting requirements*under FFATA are still in place:

 Report all sub-awards issued for $25,000 or more  Report any additional or supplemental funds issued for a subaward that has already been reported  Submit all reportable transactions to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS)  Submissions must include all required data elements (subaward number, DUNS, place of performance, CFDA, etc.)  See https://www.fsrs.gov/ for more information

*These requirements apply to subawards only; there are separate reporting requirements for contracts.

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Impact of the DATA Act on FMCSA Awards

  • FMCSA (and all other modes) developed an implementation plan

to meet the requirements of the Act.

  • Concurrent with the implementation of the DATA Act is a change

to the federal award identification number (FAIN) format: all DOT modes will use the same format for all new grants awarded after a certain date (the effective date is TBD, but tentatively scheduled for mid-2018).  This applies only to new awards issued on or after the effective date  All awards issued prior to the effective date will retain their

  • riginal award identification number
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Impact of the DATA Act on FMCSA Awards (cont’d)

 For purposes of this discussion FAIN has the same meaning as grant number, award number, grant ID, award ID.  FAIN is a reportable data element under FFATA and the DATA Act; and is required component of a Federal award (2 CFR §200.210).  FAINs must be globally unique (i.e., not duplicated anywhere within the Federal government)

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Impact of the DATA Act on FMCSA Awards (cont’d)

Elements of FAIN Field Character Positions 1-6: Agency identity for FMCSA; assigned by GSA 69A360 Positions 7 & 8: FY in which the award was issued 17 Position 9: Type of assistance (formula grant, block grant, loan, cooperative agreement, etc.); designated by FMCSA 4 Positions 10 - 13: Sequential award number assigned by FMCSA through GrantSolutions 1234 Positions 14 - 17: Program Type established and designated by FMCSA MCG0 Positions 18 -19: State of Performance MN

The standard DOT-wide FAIN will be structured as follows:

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Impact of the DATA Act on FMCSA’s Awards (cont’d)

The table below shows a side-by-side comparison of the new FAIN and the current award structure:

FAIN Award Format FAIN Character Current Award Format Award Component Positions 1-6: Agency identity for FMCSA; assigned by GSA 69A360 Positions 1-3: Agency identity with dash FM- Positions 7 & 8: FY in which the award was issued 17 Positions 4-6: Program type with dash MCG- Position 9: Type of assistance (formula grant, block grant, loan, cooperative agreement, etc.); designated by FMCSA 4 Positions 7-11: Sequential award number with dash 9876- Positions 10 - 13: Sequential award number assigned by FMCSA through GrantSolutions 1234 Positions 12-14: Fiscal year of award with dash 17- Positions 14 - 17: Program Type established and designated by FMCSA MCG0 Positions 15-17: Budget period with dash 01- Positions 18 -19: State of Performance MN Positions 18-19: Modification number 00

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Impact of the DATA Act on FMCSA Awards (cont’d)

The final table is a crosswalk of the current and new award structures:

Crosswalk New FAIN Format Current Award Format Positions 1-6: Agency identity for FMCSA; assigned by GSA Positions 1-3: Agency identity with dash Positions 7 & 8: FY in which the award was issued Positions 12-14: Fiscal year of award with dash Position 9: Type of assistance (formula grant, block grant, loan, cooperative agreement, etc.); designated by FMCSA N/A Positions 10 - 13: Sequential award number assigned by FMCSA through GrantSolutions Positions 7-11: Sequential award number with dash Positions 14 - 17: Program Type established and designated by FMCSA Positions 4-6: Program type with dash Positions 18 -19: State of Performance N/A

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Impact of the DATA Act on FMCSA Awards (cont’d)

New FAIN Format Current Award Identification Format 69A3601741234MCG0MN FM-MCG-9876-17-01-00

The illustration below shows the new and the current award formats.

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Impact of the DATA Act on FMCSA Awards (cont’d)

Recap -

  • New FAIN will become effective sometime in 2018 (date to be

determined by the CFO for DOT)

  • Grants issued prior to the implementation date of the new

FAIN structure will retain their current identity

  • FMCSA staff and grantees will be provided additional

guidance at a later date

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Common Grants Forms Reform

OMB and HHS (designated lead agency) are convening a work group for the “Common Grants Forms” Includes SF-424 family, as well as other forms for application, monitoring and reporting of grants information Coincides with compliance with DATA Act requirements OMB Working Group for the SF-SAC (Standard Form - Single Audit Collection (Data Collection Form))

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Grants Oversight and New Efficiency Act (GONE Act) P.L. 114-117

Enacted by Congress to hold Federal awarding agencies accountable for timely closeout of grant awards. The purpose of the law is to reduce costs associated with maintaining bank accounts of expired grants that contain undisbursed funds

  • r a zero balance.

The law requires Federal awarding agencies to submit a report to Congress (Due in 2017) and to the Department of Health and Human Services (HHS) that: · Identifies each Federal grant that has not been closed out two years after the end of the award’s period of performance · Describes the challenges leading to delays in grant closeout · Explains why awards have not been closed out Within one year of the initial report, Federal awarding agencies are required to provide a follow-up report that specifies which of the identified grant awards have been closed out and those that remain open.

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Grants Oversight and New Efficiency Act (GONE Act) P.L. 114-117

Also requires the Director of the Office of Management and Budget (OMB) and the HHS Secretary recommend to Congress legislation to improve the accountability and oversight of grants management. Under the Uniform Guidance, Federal awarding agencies and pass-through entities should complete all closeout activities within one year. 2 CFR 200.343(g) states: The Federal awarding agency or pass-through entity should complete all closeout actions for Federal awards no later than one year after receipt and acceptance of all required final reports. The law currently does not require agencies to complete closeout activities within one year. However, agencies will be required to explain to Congress why closeout has not occurred within the one-year time frame.

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GONE Act – and FMCSA

July, 2017, FMCSA will conduct its second annual close-out drill under the GONE Act

Count UDO Balance Year

5 $805,264.44 2009 13 $994,364.74 2010 2 $212,631.59 2011 35 $4,197,983.59 2012 42 $7,782,486.71 2013 58 $10,608,503.07 2014 102 $24,733,100.31 2015 134 $98,999,592.49 2016

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System for Award Management (SAM)

Beta.SAM.gov Public Display

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Federal Awardee Performance & Integrity Information System (FAPIIS)

The Duncan Hunter National Defense Authorization Act of 2009 (Public Law 110-417) was enacted on October 14, 2008. Section 872 of this Act required the development and maintenance of an information system that contains specific information on the integrity and performance of covered Federal agency contractors and grantees. The Federal Awardee Performance and Integrity Information System (FAPIIS), was developed to address these

  • requirements. FAPIIS provides users access to integrity and performance

information from the FAPIIS reporting module in the Contractor Performance Assessment Reporting System (CPARS), proceedings information from the Entity Management section of SAM database, and suspension/debarment information from the Performance Information section of SAM.

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The Project on Government Oversight Dear Members of Congress: We are writing in support of efforts to bring new transparency to federal grants and cooperative agreements. Spread across 1,714 programs and 26 agencies, federal grant outlays reached $538 billion in FY2012. Of that amount, nearly $80 billion was allocated through discretionary grants. While grants and cooperative agreements fulfill a crucial role in our society, too little is known about where the money goes, how it is awarded, and how to apply.

GRANT Act (H.R. 3316)

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On the Horizon – Common Themes

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  • 2860, the OPM IG Act; H.R. 3316,
  • the Grant Reform and New Transparency Act of 2013

(GRANT Act); H.R. ___,

  • the Stop Unworthy Spending Act (SUSPEND Act)

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On the Horizon – Common Themes

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Life Cycle of an Award

SAM CFDA Data Act Forms Reform GONE Act FAPPIS

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Life Cycle of an Award

SAM CFDA Data Act Forms Reform GONE Act FAPPIS

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Life Cycle of an Award

SAM CFDA Data Act Forms Reform GONE Act FAPPIS

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Part II Strategic perspectives on grants: cost concepts, investments and performance

Accountability, Compliance, Effectiveness In Grant Management

Ensuring Mission Outcomes

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More than half of FMCSA budget is spent through Federal financial assistance program activities (grants and cooperative agreements). FMCSA responsibility in the stewardship of Federal resources: to ensure that FMCSA funds are expended in accordance with the law, that programs are effective, and that we achieve the outcomes established by Congress through these programs *********** Taxpayer investment in our programs

Strategic Investments

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Strategic Investments in Grants

  • Aligning Dollars to Donuts
  • Planning through budgets
  • Actual expenditures reimbursed to the

recipient

demonstrate taxpayer investments (costs)

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>Understanding the general cost elements and principles needed for Federal grant programs (the legitimacy of costs) (in applications for Federal funding, implementing programs, and through reimbursement of costs). >Understanding the relationship to GAAP

Legitimate Investments

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Under 2 CFR, for any costs to be charged directly to a federal award the expense must be: Allowable (includes provisions for eligibility) Allocable Reasonable Charged consistently ********** These factors address directly the legitimacy of a cost charged against specific federal awards.

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For any costs to be charged directly to a federal award under 2 CFR the expense must be: Allowable under both the provisions of federal guidance AND the terms of a specific award (includes provisions for eligibility) Allocable: associated to a project with a high degree of accuracy Reasonable: the cost reflects what a “prudent person” would pay in a similar circumstance Charged consistently as direct expense (versus an indirect cost), and as Federal and non-Federal cost objectives.

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Recipient Compliance to Support Outcomes

Terms & Conditions of Award By accepting a Federal award a grantee is responsible for fulfilling/upholding all compliance requirements defined in the terms and conditions of award. The recipient/grantee entity is responsible for ensuring that costs charged to grants and cooperative agreements are allowable, reasonable, necessary and consistently applied . . . . . . . . . Each financial transaction charged against a Federal award is evaluated against these concepts (legitimacy).

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Stewardship of Federal resources: responsibility to ensure that FMCSA funds are expended in accordance with the law, that programs are effective, and that we achieve the

  • utcomes established by Congress through these programs

*********** Taxpayer investment in our programs The recipient/grantee entity is responsible for ensuring that costs charged to grants and cooperative agreements are allowable, reasonable, necessary and consistently applied . . . . . . .Each financial transaction charged against a Federal award is evaluated against these concepts.

Compliance to Support Outcomes

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Generally Accepted Accounting Principles (GAAP)

The Federal government operates under the principles of

  • GAAP. Today, all 50 state governments prepare their financial

reports according to GAAP. While a little less than half of U.S. states officially require local governments to adhere to GAAP, the Governmental Accounting Standards Board (GASB) estimates that approximately 70% of county and local financial offices do anyway.

(http://www.accounting.com/resources/gaap/)

Consistency

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Generally Accepted Accounting Principles (GAAP)

Three important sets of rules: (1) the basic accounting principles and guidelines, (2) the detailed rules and standards issued by FASB, and predecessor the Accounting Principles Board (APB), and (3) the generally accepted industry practices, to standardize and regulate accounting definitions, assumptions, and methods. Provides foundation for consistency from year to year in the methods used to prepare an entity’s financial statements. OMB regulations are also founded on basic accounting and financial premises. Recognizing those points central to fundamental accounting principles and guidelines helps ensure outcomes.

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GAAP - 10 general principles

These 10 general principles on the concepts of GAAP: Principle of Regularity Adhering to standards, such as those represented through GAAP. Principle of Consistency Applying the same standards throughout the reporting process to prevent errors or discrepancies. As well as to fully disclose and explain the reasons behind any changed or updated standards. Principle of Sincerity Striving to provide an accurate depiction of the financial status

  • r situation.

Principle of Permanence of Methods The procedures used in financial reporting are consistent and repeatable. Principle of Non-Compensation Both negatives and positives are fully reported with transparency and without the expectation of debt compensation. (insider obligations)

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GAAP - 10 general principles (cont)

Principle of Prudence Fact-based financial data and information is represented not clouded by speculation. Principle of Continuity Valuation of assets, investment of resources and commitments assumes entity will continue to operate as proposed. Principle of Periodicity Entries should be distributed across the appropriate periods

  • f time.

Principle of Materiality / Good Faith Striving for full disclosure in reporting, including reporting status and updates. Principle of Utmost Good Faith Derived from the Latin phrase “uberrimae fidei” used within the insurance industry. It presupposes that parties remain honest in transactions.

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Monitoring & Oversight (Grant Management)

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Life Cycle of an Award

SAM CFDA Data Act Forms Reform GONE Act FAPPIS What is Post-award? The timely investment of tax payer funds, intended to fulfill a social or societal goal or mission.

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  • Financial Assistance Guidance Manual (FAGM) (GMM)
  • FATE (Financial Assistance Team of Executives)

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Post-script INSIDE DOT