ON TARGET WITH GRANTS COMPLIANCE Traci Gatewood, Colleen - - PowerPoint PPT Presentation

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ON TARGET WITH GRANTS COMPLIANCE Traci Gatewood, Colleen - - PowerPoint PPT Presentation

Mar 17, 2023 300 likes •801 views

ON TARGET WITH GRANTS COMPLIANCE Traci Gatewood, Colleen Fitzgerald, Grants Director Accounting Director Gena Tran, Joan Stack, Grants Coordinator Grants Accountant Presented By: Traci V. Gatewood ON TARGET Learning Objectives Objective

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WITH GRANTS COMPLIANCE

Traci Gatewood, Colleen Fitzgerald,

Grants Director Accounting Director

Gena Tran, Joan Stack,

Grants Coordinator Grants Accountant

Presented By: Traci V. Gatewood

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Objective Three – Review “governing documents” and their importance in grants management

Learning Objectives

Objective One – Explain compliance and discuss its importance Objective Two – Review order of precedence of laws, regulations, policies, and agency guidance Objective Four – Review roles and responsibilities of grant managers as well as grants, accounting services and research and accountability departments Objective Five – Identify district resources that assist with grants management

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All Grants Are Not the Same

Types of Grants

  • Federal Discretionary Grants
  • Smaller Learning Communities
  • Federal Formula Grants (State Pass-Thru or Direct Federal)
  • NCLB
  • Title VI-B & 619 Preschool
  • Carl Perkins
  • Indian Education Formula
  • Hybrids (Grant Contracts)
  • Alaska Youth First
  • Construction Academy

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What is compliance? Following statutory and regulatory requirements, the rules of the funding agency, and FNSBSD policies. Avoiding fraud, mismanagement and waste Implementing and monitoring grant activities and budget Meeting reporting requirements Meeting deadlines set by funding agencies Why is it important? Grants are NOT gifts. There are lots of “strings” attached! Non-compliance with a single grant can jeopardize the district’s ability to compete for grants in the future. American Recovery and Reinvestment Act (ARRA)…new age of transparency

Compliance

Applies to all Grants

Remember: It is not enough to comply! It is essential to maintain records to show compliance.

  • Federal Financial

Accountability and Transparency Act

  • Improper Payments

Elimination and Recovery Act of 2010

  • Federal Awardee

Performance and Integrity Information System

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COMPLIANCE BASICS

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Step 1 Know, understand, and follow all governing documents Step 2 Maintain excellent record keeping and file management Step 3 Use the district’s Guide to Grants Management as a tool to help you properly manage your grant

Three Steps for Compliance

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ORDER OF PRECEDENCE

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Stay on Target by Understanding All Source Documents That Impose Conditions on Grants

Order of Precedence

Statutes Regulations Executive Orders OMB Circulars FNSBSD Policies & Regulations Individual Grant Documents

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STATUTES

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Statutes: Programmatic and Administrative

Program Statutes Administrative Statutes

Authorizing Statutes that outline formal legal requirements and address requirements such as: Do not address programmatic issues How funds are generated Outline the base threshold requirements or processes that apply to federal funds How funds must be allocated and permissible use of funds Administrative statutes examples: Who is eligible to be served Single Audit Act How programs must be designed General Education Provision Act What types of reports or evaluations are required Improper Payments Information Act Other specific fiscal requirements such as supplement not supplant, set asides, match, carryover limits, maintenance of effort Federal Civil False Claims Act Examples: NCLB, Perkins Act, IDEA Program Fraud Civil Remedies Act 10

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Single Audit Act

Establishes threshold amount (currently $500,000) of federal expenditure in a given year that triggers the requirement for a single audit Requires “pass-through entities” to conduct subrecipient monitoring Establishes audit reporting, submission, and corrective action requirements

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General Education Provisions Act

Basic administrative requirements that pertain to most ED programs Some portions do not apply to certain programs Essential to check program statutes to determine whether rules in program statutes or rules in GEPA apply. Certain programmatic statues such as NCLB state that some portions of GEPA do not apply to certain programs. General provisions of GEPA address the following: Forward funding and the period of availability of federal funds State reporting requirements State agency monitoring and enforcement responsibilities Single state and local application requirements Family Educational Rights and Privacy Act (FERPA) requirements Requirements relating to protection of pupil rights Enforcement provisions for noncompliance

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REGULATIONS

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EDGAR: Education Department General Administrative Regulations

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EDGAR: What is it?

Contains regulations for administering discretionary and formula grants awarded by the Department of Education Many of the concepts laid out in the GEPA statute are further articulated and explained in EDGAR Addresses pre-award requirements, post-award requirements, property standards, procurement standards, reports and records, termination and enforcement The particular portions of EDGAR that apply to a specific grant depends on who is receiving the grant (SEA vs. LEA) and what type of grant is being received (direct federal grant vs. “State” pass thru). Often the EDGAR sections that apply to specific grants are detailed in the Grant Award Notice Establishes audit reporting, submission, and corrective action requirements

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EDGAR: Commonly Used Parts

Part 75-Direct Grant Programs Part 76-State- Administered Programs Part 77-Definitions That Apply to Department Regulations Part 80-Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments Part 81-General Education Provisions Act-Enforcement

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OFFICE OF MANAGEMENT & BUDGET (OMB) CIRCULARS

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OMB Circular A-87, Cost Principles for State, Local Governments & Local Tribes

  • A placeholder for text for more

information

OMB Circular A-133, Audits of State, Local Governments, & Non Profit Organizations

  • A placeholder for text for more

information

OMB Circular A-133: Compliance Supplement

Establishes the basic threshold standards that must be present for a cost to be permissible with federal funds Must comply with cost principles because EDGAR makes them applicable by reference Governs audit rules and standards and establishes the general audit requirements for grantees Provides a source of information for auditors to understand the Federal program’s objectives, procedures, and compliance requirements

OMB Circulars

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The 10 OMB Circular A-87 Cost Principles (2CRF, Part 225)

Necessary & Reasonable Allocable to Federal Award(s) Authorized or Not Prohibited Under State or Local Laws or Regulations Conforming to Limitations or Exclusions Consistent with Policies, Regulations & Procedures Accorded Consistent Treatment Determined in Accordance with GAAP Not Included as a Match or Cost Share Net of All Applicable Credits Adequately Documented

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OMB Circular A-87 Attachment B to Circular A-87 Lists in alphabetical order specific allowable and unallowable cost allocable to grants Paragraph h Semi-annual certifications Personnel activity reports

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OMB Circular A-133, Audits of States, Local Governments & Nonprofit Organizations

A-133 describes the audit requirements that apply to recipients of federal funds. Each year the school district must have a single audit performed by an independent auditor. Auditors must study and evaluate our internal controls system. Auditors determine if we are in compliance with the provisions of laws and regulations governing grant. Results of school district’s annual audit, including all instances of reportable non- compliance, are reported to the federal government through the Federal Audit Clearinghouse.

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A-133 Compliance Supplement

Assists auditors in performing single audits Provides a source of information for auditors to understand the Federal program’s objectives, procedures, and compliance requirements Important for grantees because it is the “roadmap” that auditors will use when conducting the single audit Can be useful because it can serve as a self “spot-check” to determine if we are complying with federal requirements Additional guidance for ARRA funded programs is included in the Compliance Supplement

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YOUR GRANT DOCUMENTS

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Your Grant Documents

  • 1. Request for Applications (RFA)
  • 2. Grant application/budget/evaluation
  • 3. Grant Award Notification

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Request for Application (RFA)

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Official document that invites entities to submit grant applications to accomplish a specific program purpose Guide to completing the grant application, including budget and evaluation Federal program purpose Funding selection criteria and priorities Mandatory project components Budget and match requirements Requirements such as conference attendance, training, etc. Government Performance and Result Act Measures-GPRA Reporting requirements

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Grant Application

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Generally prepared by the grants and special projects department Project narrative-the district’s plan or scope of work which includes: Timelines Budget-how funds will be utilized Evaluation plan-how project will be evaluated Remember: You cannot change any aspect of the approved grant application, including the budget, without first obtaining written consent from the funding agency.

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Grant Award Notification

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The funding agency’s official notice that a grant has been awarded Establishes the amount of the grant award and typically describes the regulations that are applicable and any other specific conditions relevant to the grant award Incorporates by reference

Grant application/proposal OMB Circulars Executive Orders Program Regulations Agency regulations Request for Application

Remember: You must read and understand the Grant Award Notification and all accompanying documents!

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Grant Award Notification: Direct Federal

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Grant Award Notification: Direct Federal

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Grant Award Notification & Attachments Direct Federal

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Grant Award Notification

  • Recipient name
  • Project description
  • Education or other Program

(Labor, Defense, etc.) staff contact information

  • Key personnel
  • Award information
  • Award periods
  • Authorized funding
  • Administrative information
  • Legislative fiscal data

Attachments

  • Explanation of GAN
  • Introductory letter
  • Special Grant Conditions

for Payments

  • Special Grant Terms and

Conditions for Financial and Performance Reports

  • Single Audit Requirements
  • Other
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Grant Award Notification: State “Pass Thru”

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Grant Award Notification: State “Pass Thru”

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Grant Award Notification & Attachments State “Pass Thru”

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Grant Award Notification

  • Grantee and address
  • Authorized representative
  • Contact person
  • Program
  • Project number
  • Amendment number
  • Total grant amount
  • Original grant/previous

amendments

  • Grant award period
  • Comments

Attachments

  • Signed budget
  • (includes carryover, if applicable)
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TIPS FOR STAYING ON TARGET

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Tips for Staying On Target

Read and understand your governing documents Refer to your Guide to Grants Management

  • ften as it contains important information to

help ensure your grant project runs smoothly Checkout the resources link on the grants department website http://www.k12northstar.org/departments/grants/resources If you don’t know, ask!

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Roles & Responsibilities

Presented By: Traci V. Gatewood

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Grant Manager

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Fulfill fiscal, program, and reporting requirements of the funding agency while following the district’s policies Monitor the grant in relation to your funding agency’s rules and regulations, acts or statutes Day-to-day management of your grant award, including budget monitoring and revisions Maintain accurate and complete records Communicate with internal and external stakeholders

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Grants and Special Projects Department

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Prepare with grant managers' input, when applicable, competitive and formula grant applications Submit competitive and formula grant applications Provide technical assistance on grant related issues to include budgets, evaluation, reports, etc. Assist with program and fiscal compliance issues Coordinate the grant review process

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Accounting Services Department

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Assist with fiscal compliance issues Provide guidance on allowable expenditures Assist with budget revision Provide financial reports (budget to actual, transaction journal, payroll report) Prepare and submit periodic expenditure reimbursement reports to state and federal agencies Produce the annual single audit reports as required by state and federal mandate

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Research and Accountability Department

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Develop the evaluation design and plan for most grant projects Monitor and evaluate program activities throughout the award period as stated in the original proposal or subsequent revisions Complete interim and final evaluation reports as

  • utlined in proposal
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GRANT PROCEDURES FLOWCHART

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Grants Procedure Flowchart

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TIPS FOR STAYING ON TARGET

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Tips for Staying On Target

Refer to the Grants Procedure Flowchart Understand and fulfill your responsibilities in a timely manner Communicate as often as needed with departments to ensure project success If you don’t know, ask!

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KNOWLEDGE CHECK

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Knowledge Checks

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  • Why is compliance important?
  • Name two governing documents.
  • Name two (2) responsibilities of a grant

manager.

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EVALUATION

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Evaluation

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  • What was the most helpful part(s) of the training for you?
  • What do you believe could be changed in the training to improve it (more/less

information, presentation order/layout, etc.)

  • How do you intend to use the training in the future?
  • Other Comments?