Post on 31-Mar-2015
transcript
Office of Grants ManagementGrants Management Fundamentals
Office of the National Coordinator for Health Information Technology (O N C)
Grants 101
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Office of Grants Management – Organization and Functions
Systems and Data ManagementBianca Costa
Collect, report, and manage grants management data
Analyze grant data to identify trends in implementation of funds
ONC administrator for grants management systems
GMO: Workforce
Training and Technical Assistance
Jen Cramer
Develop and deliver grants management training for external stakeholders and ONC staff
Provide customized, direct technical assistance services
Coordinate overall grants management training and technical assistance efforts
GMO: Beacon and SHARP
Grant OperationsArlene Ramsey
Provide procedural and technical business support to award recipients and ONC program offices
Conduct on-site monitoring visits and desk reviews
Develop grants management standard operating procedures
GMO: REC and State HIE
Office of Grants Management (OGM)Lisa Lewis
Chief Grants Management Officer
Office of Grants Management (OGM)Lisa Lewis
Chief Grants Management Officer
Policy Wendy Kilgore
Develop and manage ONC grants management policies
Facilitate objective reviews
Liaison with other HHS Grants Management Offices
O G M - Responsible for the Portfolio of O N C Cooperative Agreements
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Workforce:CompetencyExamination
Workforce:CompetencyExamination
Workforce:Curriculum
DevelopmentCenters
Workforce:Curriculum
DevelopmentCenters
Workforce:University
BasedTraining
Workforce:University
BasedTraining
Workforce: Community
College
Workforce: Community
College
SHARPSHARP
BeaconBeacon
Regional Extension
Centers
Regional Extension
Centers
State Health
Information Exchange
State Health
Information Exchange
O N C’s Program Offices and Grants Office Partnership
AAGAM Chapter 1.04.104
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Answer grantee questions on complex
technical grants business
management matters
Answer grantee questions on complex
technical grants business
management matters
Perform budget analyses & business
mgmt capability assessments & perform budget
negotiations
Perform budget analyses & business
mgmt capability assessments & perform budget
negotiations
Take action to withhold payment,
suspend or terminate award or to lift withholding or
suspension
Take action to withhold payment,
suspend or terminate award or to lift withholding or
suspension
Provide input on satisfaction of business mgmt
special conditions; lift restrictions
via NGA
Provide input on satisfaction of business mgmt
special conditions; lift restrictions
via NGA
Identify potential or existing problems (business mgmt
& program)& alert PO
Identify potential or existing problems (business mgmt
& program)& alert PO
Ensure effective use of funds
by monitoring commitments & projecting future
funding requirements
Ensure effective use of funds
by monitoring commitments & projecting future
funding requirements
Review financial status reports &
evaluate financial performance against
budget, program plan, etc.
Review financial status reports &
evaluate financial performance against
budget, program plan, etc.
Document site visits & desk reviews
& coordinate results with program office
Document site visits & desk reviews
& coordinate results with program office
Conduct financial monitoring site visits
& desk reviews & provide
post-award TA
Conduct financial monitoring site visits
& desk reviews & provide
post-award TA
Establish &maintain
official award, program information,
& institutional files
Establish &maintain
official award, program information,
& institutional files
GrantsManagement
Team
GrantsManagement
Team
O N C’s Program Offices and Grants Office Partnership
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AAGAM Chapter 1.04.104
Answer grantee questions on programmatic grants matters
Answer grantee questions on programmatic grants matters
Assist in ensuring budget submissions
& expenditures comply with statute, regulation, & policy
Assist in ensuring budget submissions
& expenditures comply with statute, regulation, & policy
Provide program input on proposed
withholding of payment/suspension/termination of award
& input before lifting
Provide program input on proposed
withholding of payment/suspension/termination of award
& input before lifting
Provide input on
whether programmatic special conditions
are satisfied or whether other action
should be taken
Provide input on whether programmatic
special conditions are satisfied or
whether other action should be taken
Identify potential or existing problems
(program & business management) & alert
program officials & GMO of findings
Identify potential or existing problems
(program & business management) & alert
program officials & GMO of findings
Ensure adequate progress toward
meeting milestones
Ensure adequate progress toward
meeting milestones
Review program progress reports & evaluate program
performance, progress
& changes in scope or objective
Review program progress reports & evaluate program
performance, progress
& changes in scope or objective
Document reviews & grantee
discussions & provide
documentation to GMO
for official file
Document reviews & grantee
discussions & provide
documentation to GMO
for official file
Conduct site visits to gauge progress and compliance
or to provide
post-award TA
Conduct site visits to gauge progress and compliance
or to provide
post-award TA
Establish and maintain PO
files
Establish and maintain PO
files
ProjectOfficers
ProjectOfficers
Partnership – The Key to Success
• Maximize program success and integrity
• Foster program credibility
• Ensure rigor in stewardship
• Minimize audit findings
• Reduce disallowed costs
• Strengthen internal controls to prevent fraud, waste, and abuse
• Manage inherent risk
• Encourage professional development
• Foster synergy/collaboration
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Review FOA Submit Application Revise Application Review Award Package
Accept Award
Drawdown Funds
Submit Financial Reports
Submit Performance Reports
Submit Post-Award Requests
Ensure Audit is Complete
Generate Final Performance Reports
Complete Drawdown of Funds
Generate Final Financial Reports
Submit Closeout Package
Retain Records
Legend:
PHASEGrantee
Office of Grants Management
Program Office
ONC Budget
Other Federal/HHS Entities
PO/GMO Joint
Program and Grants Management Training and Technical Assistance
Assist Applicants
Establish Commitments
APPLY
Review Closeout Package
Conduct Final Financial Reconciliation
Notify Grantee of Closeout
Retain Records
Establish Disposition of Funds
Evaluate Final Performance Reports
CLOSEOUT
Obligate Funds
Set Up Congressional Notification in System
Release Funds
Create Notice of Grant Award
AWARD
Notify Grantee of Award
Conduct Appropriations Analysis
Develop Funding Opportunity Announcement (FOA)
Release FOA
Appropriation
OMB Apportionment
Authorizing Statute
ESTABLISH
Allocate Funds
Review and Approve Post-Award Actions
Conduct Financial Monitoring
Review Financial Reports
Review Performance Reports
Review Audits
Conduct Programmatic Monitoring
MANAGE
Review /Recommend Post-Award Actions
Review Application
Perform Budget Review
Objective Review
AssessFiscal Integrity
Develop Funding Memo
REVIEW
Assess Funds Availability
Grants Management Lifecycle
Conduct Appropriations Analysis
Develop Funding Opportunity Announcement (FOA)
Release FOA
Appropriation
OMB Apportionment
Authorizing Statute
Review FOA
APPLYESTABLISH REVIEW AWARD MANAGE CLOSEOUT
Allocate Funds
Legend:
PHASEGrantee
Office of Grants Management
Program Office
ONC Budget
Other Federal/HHS Entities
PO/GMO Joint
Grants Management Lifecycle – Establish
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Appropriations and Funding Process
Phase 1: Budget Formulation
Phase 2: Budget Presentation and the Congressional Process
Phase 3: Budget Execution
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Budget Formulation
• HHS Budgets for Grant Programs
• HHS Budget Request
• HHS Total Budget Request
• O M B/President’s Budget to Congress
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Appropriations
• Budget Presentation to Congress
• Congressional Budget Resolution
• Appropriation
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Budget Execution
• Office of Management and Budget (O M B) Apportionment– Budget Authority to distribute funds
• HHS Allotment
• O N C Allotment
• Allocations to Each Grant Program
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Types of Appropriations
• Annual: Must be obligated within the fiscal year– O N C funds in HHS appropriations
• Multiple Year: Available for obligation for a definite period in excess of one fiscal year– HHS has multi-year funds
• No-year: Available for obligation without financial year limitations– A R R A funding no longer no year (Bennett Amendment)
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Continuing Resolution
• Applies if new Fiscal Year and annual appropriation is not passed
• Continues existing programs until annual appropriation passes
• Can impact internal operations and activities
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Funding Opportunity Announcement (FOA)
• All information integral to the competition must be explicitly addressed • General description• Authorizing statute/Award information• Eligibility requirements• Cost share/matching requirements• Application requirements
– Forms– Budget and budget narrative– Program narrative– Other submission requirements
• Due dates• Review Criteria• Announcement dates• Reporting requirements• Other information
Submit Application
Assist Applicants
Establish Commitments
APPLYESTABLISH REVIEW AWARD MANAGE CLOSEOUT
Legend:
PHASEGrantee
Office of Grants Management
Program Office
ONC Budget
Other Federal/HHS Entities
PO/GMO Joint
Grants Management Lifecycle – Apply
Applying for Funding
• HHS policy requires all competitive funding opportunities be announced at www.Grants.gov
• O M B mandated initiative
• No paper
• No other submission method accepted
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Critical Application Information
• Applications must be complete and timely– All forms and attachments must be submitted– Incomplete applications will not be sent forward for review– Late applications will not be sent forward for review
• All applicants must have a Dun and Bradstreet (D&B) Data Universal Numbering System (D U N S) number
• All applicants must register in the Central Contractor Registry (CCR)– Applicants should allow a minimum of five days to complete the CCR
registration. CCR online registration (http://www.ccr.gov)– CCR registrations must be current and renewed every 12 months
• Applicants that do not have a D U N S number or have not registered with the CCR will not move forward for review.
Review Application
Perform Budget Review
Objective Review
AssessFiscal Integrity
Develop Funding Memo
Revise Application
APPLYESTABLISH REVIEW AWARD MANAGE CLOSEOUT
Legend:
PHASEGrantee
Office of Grants Management
Program Office
ONC Budget
Other Federal/HHS Entities
PO/GMO Joint
Assess Funds Availability
Grants Management Lifecycle – Review
Objective Review Process
• Completeness Review
• Grants staff
• All required forms
• All required attachments
• On-time submission
• Responsiveness Review
• Program staff
• All required program elements
If YES to both → Panel review
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Objective Review Process - continued
• Panels of unbiased subject matter experts
• Endure no conflicts of interest and consistent examination of applications
• Intended to provide recommendations and advice on funding proposals
• Scores and ranking developed
• Final decisions determined by the program office
• Funding decision memo sent to Grants Management Office
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Program Office Financial Review
• Program Office Staff– Review application budget to determine if costs are in line
with program goals and objectives– Review to ensure costs are for intended program
purposes– Signed transmittal slip indicating approval of budget
• Grants Management Staff
– Conduct detailed financial reviews– Based on Program Office recommendations
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Financial Review
• A-133 Compliance– http://harvester.census.gov/sac/
• No Conflict of Interest• Applicant’s Standing (Good, Debarred, Suspended)
– https://www.epls.gov/• Dun and Bradstreet• Budget Review
Budget Review and Approval Process
• Each application must include a detailed budget (SF424A) and budget narrative for the project.
• The budget must be complete, reasonable, allowable, allocable and cost effective in relation to the proposed project.
• The budget narrative must provide a detailed justification for each cost included in the budget.
• All project related costs must be included in the appropriate cost categories.
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Budget Review – Cost Principles
• Uniform cost principles when implementing Federal grant programs
– 45 CFR 74.27 and by reference 2 CFR Part 220 (A-21) – Educational Institutions
– 2 CFR Part 225 (A-87) – State Local and Indian Tribal Governments
– 2 CFR Part 230 (A-122) – Non-Profit Organizations
– 48 CFR 31.2 (Federal Acquisition Regulation (F A R)) – For Profit Organizations
Budget Review – Object Categories and Key Requirements
Example of a 424a
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Budget Review – Personnel Budget Category
Personnel • Must pay personnel at a rate paid with non-Federal dollars or comparable
to like organizations/positions.
• Is the basis for determining each employee’s compensation described (annual salary and % time devoted)?
• Is each position identified by title/responsibility?
• Are time commitments and the amount of compensation stated and reasonable?
• Are salary increases anticipated during the grant period and are they justified (C O L A, etc)
• Are any personnel costs unallowable?
• Dual Compensation?
• Federal Employee?27
Budget Review – Fringe Budget Category
Fringe Benefits – typically include health care, retirement plans, etc. Must consider:
• Is the amount specified as a separate line item?
• Is each type of benefit indicated separately or does the organization have an approved fringe benefit rate?
• Are fringe increases contemplated during the grant period?
• Are costs included in fringe benefits that are unallowable?
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Budget Review – Travel Budget Category
Travel• Is the basis for computation provided?
• Is the travel necessary for the purpose of the program?
• Are travel costs separately identifiable and reasonable (location, transportation, hotel, meals, mileage)?
• Does the organization have a written travel policy? Is this travel policy being followed?
• If no written policy—must follow Federal guidelines
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Budget Review – Equipment Budget Category
Equipment• Capitalization threshold
• Federal $5K and useful life more than 1 year
• Are equipment items specified by unit and cost?
• Is the request reasonable and allowable under the project?
• Does the organization have a procurement policy in place?
• Is a lease vs. purchase study necessary (vehicles, large items of equipment)?
• Are purchases distinguishable from rentals?
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Budget Review – Supplies Budget Category
Supplies• Are supplies listed separately?
• Office
• Training
• Research
• Other types of supplies
• How was cost determined?
• Is the basis for the cost reasonable?
• Monthly estimates are sufficient
• Consistently treated
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Budget Review – Contractual Budget Category
Contractual• Is the type of each service to be rendered described?
• For Consultants/Individuals
• Is an hourly, daily or weekly base rate given?
• Are rates allowable, justified, reasonable and comparable to market?
• Is procurement method described?
• Are appropriate procurement procedures being followed?
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Budget Review and Approval – Subrecipient Relationships
Subrecipient Relationships (Subgrants/Subawards or Contracts)• Is a substantial portion of the programmatic work being performed by another
entity - a grant or contract?• Subawards are documented in the “other” category• Subrecipient relationships in the form of a contract will be put in
“contractual”
• If so, the following questions must be answered in regard to that specific grant or contract:• Name of the subrecipient• Method of selection• Period of performance• Scope of Work• Method of Accountability• Itemized budget and justification (separate SF 424As for the subrecipient)
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Budget Review – Other Budget Category
Other• Are items listed by major type (space rental, printing, phone,
maintenance, etc.)?• Are all costs justified, reasonable and allowable?• List each subaward and amount of award
• Ensure adequate subrecipient information is provided
(see 6 elements)
• Include separate SF 424 A for each sub
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Budget Review – Indirect Costs
Indirect Costs
• Costs incurred for a common/joint objective and cannot be readily identified with a specific activity
• typically include utilities, rent, administrative staff
• An organization may not charge specific costs both directly and indirectly
• Costs may not be assigned as an indirect cost to an award if any other cost incurred for the same purpose has been allocated to an award as a direct cost
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Budget Review – Indirect Costs
Indirect Costs (continued)• Must have a current Federally
approved indirect cost rate agreement
• Is the rate applied to the correct distribution base?
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Recently in the News
• TierOne loses $19 million federal grant over CEO's fraud allegations
• September 6, 2010
• University of Florida professor and wife indicted for fraudulent grant proposals
• October 30, 2009
• Cornell University Will Pay $2.6M in Fraud Case
• March 24, 2009
• Former Professor Pleads Guilty to Fraud on NSF Grant
• May 3, 2007
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Categories of Misuse of Federal Funds
Indicators of Fraud, Waste and Misuse of grant funds can be due to a variety of causes. We must manage with due diligence to ensure that DHHS funds are not misused.
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Mistakes Gross Negligence Criminal Fraud
Recipient includes costs in budget which are unallowable under specific O N C awards. Examples include: Food, Scholarships, Contingencies
Direct recipient failed to implement proper internal controls and adequately monitor subrecipient activity and expenditures resulting in theft of Federal funds.
Recipients used Federal funds to pay for a wedding reception, building construction, and personal credit card bills. Resulted in loss of $500K and jail time.
Who Commits Grant Fraud?
• When business entities, individuals, communities, and other organizations receive federal grant dollars, they are entrusted with their appropriate expenditure.
• Grant fraud is most often committed by:
• Grant recipients, company officers, business partners, board members, and managers
• Bookkeepers, financial staff, and employees
• Contractors and subcontractors engaged with the recipient
• Recipient consultants
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Common Grant Fraud Scenarios
• Grant fraud occurs in many ways, but some of the most common fraud scenarios include:
• Charging personal expenses as business expenses against the grant
• Charging for costs which have not been incurred
• Charging for inflated labor costs or hours
• Submitting invoices for personal expenses
• False information on grant applications, progress reports, etc.
• Creating fictitious records
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Fraud Indicators
• Fraud is often difficult to detect and is a conclusion that is determined only after a careful examination of all the facts and circumstances.
• Indicators of fraud include:
• One person in control
• Lack of internal controls
• Altered records
• No separation of duties
• No prior audit
• Lack of responsiveness
• Allegations of fraudulent conduct
Obligate Funds
Ensure Congressional Notification
Release Funds
Create Notice of Grant Award
APPLYESTABLISH REVIEW AWARD MANAGE CLOSEOUT
Notify Grantee of Award
Legend:
PHASEGrantee
Office of Grants Management
Program Office
ONC Budget
Other Federal/HHS Entities
PO/GMO Joint
Grants Management Lifecycle –Award
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Notice of Grant Award (NGA)
• The Notice of Grant Award NGA is the official document used for grants/cooperative agreements
– Establishes legally binding arrangement between O N C and recipient
– Establishes Period of Performance– Contains or references Terms and Conditions of the
grant or cooperative agreement– Obligates Federal Funds
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Notice of Grant Award (NGA)
NGA includes:• Grantee information• Award information
– Project Period of Performance
– Budget Period of Performance
• Terms and Conditions of the award
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Award Notification and Acceptance
• Award Notification– Grants Solutions– NGA– Terms and Conditions
• Award Acceptance– First request for disbursement of funds– Agree to abide by all applicable laws, regulations, program
requirements, policy and terms and conditions– Specific A R R A terms and conditions (incorporated by reference)
• http://www.hhs.gov/recovery/grantscontracts/recoverytermsconditions.html
Grant vs. Cooperative Agreement
• Grants are awarded to States, units of local government, or private organizations at the discretion of the awarding agency or on the basis of a formula. Grants are used to support a public purpose.
• Cooperative Agreements are awarded to States, units of local government, or private organizations at the discretion of the awarding agency. Like grants, cooperative agreements also support a public purpose.
• Substantial involvement is anticipated between the awarding agency and the recipient during performance of the contemplated activity. View as a “partnership”
• Cooperative agreements are not contracts
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Review and Approve Post-Award Actions
Conduct Financial Monitoring
Review Financial Reports
Review Performance Reports
Review Audits
Conduct Programmatic Monitoring
APPLYESTABLISH REVIEW AWARD MANAGE CLOSEOUT
Review /Recommend Post-Award Actions
Legend:
PHASEGrantee
Office of Grants Management
Program Office
ONC Budget
Other Federal/HHS Entities
PO/GMO Joint
Grants Management Lifecycle – Manage
Order of Precedence-Who is Top Dog?
• Constitution of the United States
• Statutes• Program Statutes (Authorizing Statutes)
• Generally Applicable Statutes
• Annual Appropriations
• Regulations
• Executive Orders
• O M B Circulars
• Policies
• Procedures
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Administrative Requirements vs. Cost Principles
Administrative Requirements Cost Principles
Prescribe standards for grant administration to achieve uniformity and consistency for recipients of Federal Assistance
Define allowable costs for different types of recipients; failure to mention a particular item of cost in the Cost Principles is not intended to imply that it is either allowable or unallowable
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Applicable Regulations
Summary of Applicable RegulationsGrantee Type Administrative
RequirementsCost Principles Audit
Requirements
State & Local Governments 45 CFR Part 92 2 CFR, Part 225(A-87)
A-133
Educational Institutions45 CFR Part 74 45 CFR 74.27 and by
reference 2 CFR Part 220 (A-21)
Non-Profits 2 CFR, Part 230(A-122)
Recipient Grants Management Responsibilities
Grantee responsibilities include:• Cash management
• Maintaining adequate financial records
• Returning Federal funds for disallowed expenditures
• Complying with reporting requirements
• Reviewing and recording financial operations
• Budgeting and budget review
• Reporting irregularities
• Refrain from doing business with debarred and suspended organizations
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Recipient Grants Management ResponsibilitiesManaging Subawards
• A recipient has full responsibility for the conduct of the project or activity supported and for the results achieved
• Direct recipients are responsible for adequate monitoring of subawardee activities
• 45 CFR Part 92.40 or 74.51, Monitoring and Reporting Program Performance
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Financial Management Systems
• At a minimum, a grantee’s financial system should be able to:
• Meet 45 CFR 92.20 or 74.21, Standards for financial management systems
• Provide financial and performance reporting required by 45 CFR Part 92 and 74, and other regulations
• Associate grant expenditures with the specific funding source and application of funds
• Provide a clear audit trail
• Comply with the Cash Management Improvement Act• Minimize the time elapsing between the transfer of funds and
disbursement by the grantee or subgrantee in accordance with Treasury Regulation 31 CFR 205.
• A State should follow the same state laws and procedures as they would for non-Federal funds
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Financial Management Systems – continued
• In order for an accounting system to be considered adequate, it must meet the following criteria:
• Internal controls / segregation of duties (For example, the person authorizing an expenditure should not sign the check)
• Ability to track expenditures on an accrual basis (budget control)
• Grantees can use a cash or accrual basis for their accounting method
• Ensure allowability of costs charged to Federal grants
• Documentation for all grant-related expenditures, broken down by award
• Ability to fulfill government-required financial reporting
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Understanding Match
Matching and cost sharing are often used interchangeably
•Matching usually refers to a statutorily specified percentage
– Specified as a fixed or minimum percentage of non-Federal participation in allowable program or project costs that must be contributed by a recipient in order to be eligible for Federal funding or a not-to-exceed percentage of Federal participation.
•Cost Sharing refers to any situation in which the recipient shares in the costs of a project other than as statutorily required matching
•Approved/accepted matching or cost sharing is shown in the NGA
Understanding Match – continued
• Cash Match
• Cash spent for project related costs
• Matching costs must adhere to Federal rules
• If not allowed with Federal dollars, not allowable with matching dollars
• In-kind Match
• are the value of goods and/or services third parties donate for program or project purposes without charge to a recipient
• Third party in-kind contributions
• May satisfy a matching or cost-sharing requirement only when payment for them would be an allowable cost if the party receiving the contributions (recipient, subrecipient, or cost-type contractor) were to pay for them
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Understanding Match – continued
• All costs and contributions used to satisfy a matching or cost-sharing requirement must be documented by the recipient at the same level of detail as Federal funds
• Matching contributions are subject to audit
• If a recipient fails to provide required cost sharing, the GMO generally will make a downward adjustment in the Federal award amount
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Understanding Match – continued
Valuation of in-kind contributions:• Rates for volunteers must be consistent with established rates paid for
similar work by the recipient or subrecipient
• If a third party donates the use of equipment or space in a building but retains title, the contribution shall be valued at the fair rental rate of the equipment or space
• If a third party donates supplies, the contribution shall be valued at the market value of the supplies at the time of donation
Program Income
• Gross income earned as a result of the award• directly generated by the grant-supported activity or earned
• There would be no income of this type or level.
• Activities that generate program income include• Registration fees
• Sale of videos, publications, other media
• Rental/usage fees
• Service fees
• Subject to same requirements as Federal funds• Must be reported on FFR (SF 425)
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Program Income
• The Notice of Grant Award includes the type of program income applicable to the Program/award
• Deduction alternative
• Addition alternative
• Cost Sharing/Matching alternative
• Combination alternative
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Prior Approval
Several changes to an award require O N C prior approval• Changes of grantee organization• Change in scope
• Transfer of substantive programmatic work if not previously approved
• Significant rebudgeting (lesser of 25% or $250K, cumulative)
• Other as defined by program office
• Changes in key personnel• Carry over funds• Indirect costs (if indirect costs not approved in initial budget)
Request from grantee, with written justification, should be 30 days from when need approval
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Payments to Grantees
Grantees request funds from HHS’ Payment Management System (PMS)• Payment requests may be made as often as needed: (daily, weekly, monthly,
etc.)
• No checks; electronic transfers only
• Also used to submit quarterly financial reports
• PMS is administered by HHS’ Division of Payment Management • PMS Helpdesk: (877) 614-5533 or PMSSupport@psc.hhs.gov
Grantees must minimize time between draw and expenditure• Cash Management Improvement Act (CMIA)
• Immediate needs basis; funds must be spent within three business days
What may impact a grantee’s ability to draw funds?• No budget approval
• Late report submission
• Other restrictions
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Grantee Reporting Requirements
Report Required Frequency Reporting Period Due Date Submission Method
American Recovery and Reinvestment Act (ARRA) Report
Quarterly
April 1 – June 30 July 10
Federalreporting.gov July 1 – September 30 October 10
October 1 – December 31 January 10
January 1 – March 31 April 10
Federal Financial Report (FFR) Federal
Cash Transaction Report (SF-425)
Quarterly
April 1 – June 30 July 30
Payment Management System (PMS)
July 1 – September 30 October 30
October 1 – December 31 January 30
January 1 – March 31 April 30
Federal Financial Report (FFR) Federal
(SF-425)Annually October 1 – September 30 December 30 Online Data Collection
System (OLDC)
Program Progress Report
Semi-Annually Determined by Program Office CRM, email, etc.
Official Grant and Program Files
• Office of Grants Management files
• Official award file• All award transactions, financial information, correspondence, approvals, etc
• Program information file• Information for each program announcement
• Information related to all applications
• Institution file• Contains information on a specific entity which receives multiple awards from
multiple programs
• Project officer files
• Documents project management activities from inception to closeout
• Record of that PO’s activities with respect to the award
• Auditor or reviewer will request to review for adequate documentation
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Sample Checklist
• Section 1Applicant Submissions and Contacts – New Awards and Other Competing Awards
• Section 2Review, Evaluation, and Negotiations – New Awards and Other Competing Awards
• Section 3Award Notices and Restrictions/Special Conditions
• Section 4Post-Award Prior-Approval Requests
• Section 5Post-Award Monitoring and Closeout
• Section 6Other
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Financial and Programmatic Monitoring
Financial Monitoring Programmatic Monitoring
• Evidence of expenditures show that purchases are necessary, reasonable, allocable and allowable
• Flow of Funds
• Accounting System
• Internal Controls
• Cash Management
• A-133 Submission
• Interest accrual (as necessary)
• Programmatic Administration
• Compare accomplishments to goals and objectives
• Reinforce priorities and policies
• Adherence to project scope
• Performance according to Ops Plans
• Progress (completion on time)
• Objectives
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Financial Monitoring – Goals
The goals of financial monitoring include:– To ensure that grant funds are used as intended and compliant
with regulatory requirements
– To ensure O N C is meeting the highest of management and fiduciary standards
– To ensure grantee compliance with the terms and conditions of the grant award
– To meet requirements imposed on O N C by law (A R R A)
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Financial Monitoring – Risk Factors
• General Selection Criteria – New Grantee– Dollar Amount of Award– Multiple Awards – Entity Type– Subawards– Reporting Findings (FSR, Audit, A R R A)– Unobligated/Unexpended Balances– Program Office Referral/Recommendations– Samples
• The above general criteria was weighted based on various factors
• Other risk factors not included above may also be considered based on data analysis -out life of award
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Types of Financial Monitoring that OGM Conducts
• Desk-based Financial Monitoring– Cash Analysis– Desk Review
• On-Site Financial Monitoring
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Desk-based Monitoring – Cash Analysis
Cash analysis reviews:– Recipient cash transactions– Rate of draws– Payment trends– Unobligated balance– Grant status– Review of last program report
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Desk-based Monitoring – Cash Analysis continued
During the O G M quarterly review, O G M and Project Officers discuss thefollowing :
• Has the grantee submitted timely performance reports?• Is the grantee on target as outlined in their approved plan?• Has contact been made with the grantee if not on target?• If contact has been made, what corrective action has been discussed?
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Desk-based Monitoring – Desk Reviews
• Limited verification of grantee compliance– Federal regulations– Terms and conditions
• Identifies potential issues• Grants reviewed on a regular basis• Core review of a grantee’s general management
practices• May require further scrutiny - on-site financial
monitoring
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On-Site Monitoring Visits are performed at grantee location• Ensure adequate internal controls, policies, processes, and systems exist
to appropriately manage awards
• Assess capability, performance and compliance against administrative regulations and public policy requirements
• Report on the effectiveness of O N C grantees and grant programs and the stewardship of public funds
• Collaboration with program office(s) is key to successful monitoring
– Joint site visits with program office when feasible
– Pre-site visit meeting with program staff
On-Site Monitoring Visits
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• No written policies and/or procedures• Inadequate procurement standards• Lack of documentation • Inadequate/untimely submission of reports• Inadequate Subaward Monitoring• Inadequate time and effort records• Lack of competition during procurement• Conflicts of interest• Questioned expenditures• Excess Cash on Hand• Commingling of funds
Common Issues Discovered During Financial Monitoring
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Monitoring vs. Auditing
• Monitoring is preventative– Performed by grants and program staff– Resolve before audits
• Auditing is corrective / curative– Performed by auditors– In the record books
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Audits – What is a Statewide Single Audit (A-133)?
• Required for Entities that Expend $500K or More in Federal Funds during their Fiscal Year
• Review of All Federal Grant Programs and Requirements• Audit Report Is Due 9 Months after the End of the Fiscal Year• Submit the Audit Package to the Federal Audit Clearinghouse
(FAC)– http://harvester.census.gov/fac/collect/ddeindex.html
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A-133: Most Common Audit Findings
• Unallowable activities• Unallowable costs • Poor cash management• Inadequate equipment and real property management
practices• Expending funds outside of the period of availability of funds• Inadequate procurement standards• Untimely and inaccurate reporting• Lack of subrecipient monitoring
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Audit Resolution
• Health and Human Services– ASFR, Division of Systems Policy, Payment Integrity,
and Audit Resolution (DSPPIAR) is responsible for A-133 audit resolution
• OGM will assist in resolution of audit findings only as requested by DSPPIAR
– ASFR also serves as a liaison with O M B, the O P D I Vs, and the OIG on grant-related audit issues
• Recipient responsibilities– Resolve audit findings of subawards
• Most O N C programs have a large number of subs
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Audit Resolution
• Corrective Action Plan (C A P) should include:– Description of each finding– Specific steps to be taken to implement
the recommendation– Timetable for performance of each
corrective action– Description of monitoring to be
performed to ensure implementation of the C A P
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HHS Office of the Inspector General (OIG) Performance Audits
• Evaluates HHS Goals and Objectives with grantee activities• Rotating schedule of states and programs• Annual audit plan
– Identifies key issues– Implementation plan
• Conducted by OIG staff • Compares expenditures to program impact• Reports posted on OIG website (http://oig.hhs.gov/reports.asp)
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Examples of Inspector General Audit Findings
• No measurable program goals and objectives
• Lack of monitoring and oversight
• Untimely/incorrect financial reporting
• Questioned costs
• Inadequate procurement practices
• Inadequate personal property controls
Review Closeout Package
Conduct Final Financial Reconciliation
Notify Grantee of Closeout
Retain Records
Establish Disposition of Funds
Evaluate Final Performance Reports
APPLYESTABLISH REVIEW AWARD MANAGE CLOSEOUT
Legend:
PHASEGrantee
Office of Grants Management
Program Office
ONC Budget
Other Federal/HHS Entities
PO/GMO Joint
Grants Management Lifecycle – Closeout
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Recipient Closeout
• Due within 90 Days after End of Award • Final Progress Report • Final SF-269 Financial Status report
– Unobligated funds balance– No unliquidated obligations– Final drawdown– Return excess funds
• Invention Disclosure (if applicable)• Federally Owned Property Control (if applicable)
Retention of Records – Grantees
• Grantee Requirements (45 CFR 92.42 and 74.53)
• At least 3 years from the date of submission of the final expenditure report
• If litigation, claim or an audit is initiated prior to the expiration of the 3 year period, records must be retained until completion of the action and resolution of issues or the end of the 3 year period, whichever is later
• Records may be retained in an electronic format
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Retention of Records – ONC
• Office of Grants Management
• 1 year unsuccessful applications
• 6 years 3 months official files
• If open audit, litigation, administrative proceeding retention may be longer
• Project Officer files
• 2 years after closeout
• If open audit, litigation, administrative proceeding retention may be longer
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Review FOA Submit Application Revise Application Review Award Package
Accept Award
Drawdown Funds
Submit Financial Reports
Submit Performance Reports
Submit Post-Award Requests
Ensure Audit is Complete
Generate Final Performance Reports
Complete Drawdown of Funds
Generate Final Financial Reports
Submit Closeout Package
Retain Records
Legend:
PHASEGrantee
Office of Grants Management
Program Office
ONC Budget
Other Federal/HHS Entities
PO/GMO Joint
Assist Applicants
Establish Commitments
APPLY
Review Closeout Package
Conduct Final Financial Reconciliation
Notify Grantee of Closeout
Retain Records
Establish Disposition of Funds
Evaluate Final Performance Reports
CLOSEOUT
Obligate Funds
Set Up Congressional Notification in System
Release Funds
Create Notice of Grant Award
AWARD
Notify Grantee of Award
Conduct Appropriations Analysis
Develop Funding Opportunity Announcement (FOA)
Release FOA
Appropriation
OMB Apportionment
Authorizing Statute
ESTABLISH
Allocate Funds
Review and Approve Post-Award Actions
Conduct Financial Monitoring
Review Financial Reports
Review Performance Reports
Review Audits
Conduct Programmatic Monitoring
MANAGE
Review /Recommend Post-Award Actions
Program and Grants Management Training and Technical Assistance
Review Application
Perform Budget Review
Objective Review
AssessFiscal Integrity
Develop Funding Memo
REVIEW
Assess Funds Availability
Grants Management Lifecycle
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Critical Reference Documents
American Recovery and Reinvestment Act of 2009 (Recovery Act)• What does the law say• Statute is highest in order of precedence
45 CFR Part 74 and Part 92 - Administrative Requirements• Part 92 – Government organizations (Including Tribal)• Part 74 – NGO• Uniform administrative rules when implementing Federal grant programs
Cost Principles • 2 CFR Part 220 – Educational Institutions• 2 CFR Part 225 – Government Organizations (Including Tribal)• 2 CFR Part 230 – Non-Profit Organizations• FAR 31.2
OMB Circular A-133 - Audits of States, Local Governments, and NonProfit Organizations
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• HHS Grants Policy Statement (GPS) – Grants policy for recipients– Incorporated as a term in NGA– Dos and Don’ts– ONC staff should also know the GPS in order to provide support to grantees– http://dhhs.gov/asfr/ogapa/grantinformation/hhsgps107.pdf
• Funding Opportunity Announcement (F O A)• Notice of Grant Award (NGA) with Award Terms and Conditions• Grants Management Advisories (GMAs)• Grants Management Memorandum (GMM)• Program Information Notices (P I Ns)• Program Assistance Letters (P A Ls)
Critical Reference Documents – continued
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• Grants Management Advisories (GMAs) – technical assistance resource which will provide additional information in specific grants management areas for Grantees
– O N C-GMA-2010-01 Roles and Responsibilities Grants and Cooperative Agreements– O N C-GMA-2010-02 Review of Proposed Subawards and Procurement Contracts Under
Grants– O N C-GMA-2011-01 Matching and Cost Sharing– O N C-GMA-2011-02 Use of Unobligated Balances under Grants and Cooperative
Agreements– O N C-GMA-2011-03 Allowability of Food Costs– O N C-GMA-2011-04 Program Income– O N C-GMA-2011-05 Subrecipient Monitoring– O N C-GMA-2011-06 Allowability of Payments to Uniformed Services and Civilian Federal
Employees
Critical Reference Documents – continued
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ONC Office of Grants Management has a Training and Technical Assistance (T A) Plan based on three different levels of assistance:•Level I: Guidance and Information Sharing – Consists of the daily technical assistance of grants administration.
•Level II: Sample Protocols, Templates and Models – Targeted telephone and electronic assistance involves assisting recipients in the development of protocols and templates, as well as other specific needs, as requested by a recipient.
•Level III: Targeted Training Deliveries and Direct On-Site Assistance – Includes targeted internal and external training sessions.
Training and Technical Assistance Plan
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Grants Management T A request form– Please use this form to
request Training and Technical Assistance from the ONC Office of Grants Management
– Completed forms are available from, and should be submitted to ONCGrants@hhs.gov
Office of Grants Management – TA Requests