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How to Stay Out How to Stay Out of of
[the Grant Officer’s [the Grant Officer’s Overview]Overview]
2009 New Grantee Conference - Chicago - May 15th2009 New Grantee Conference - Chicago - May 15th
TT..RR..OO..UU.. BB..LL..EE!!
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TThanks for being
our Grantee!
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What we expect from you…What we expect from you…
- Be responsible stewards of Federal funds.
- Use grant dollars for their intended purpose.
- Account for costs & justify expenditures.
- Report back to ETA
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- Design a program focused on customer needs
- Address those needs
- Meet the requirements of Federal law & regulation
What we expect from you…What we expect from you…
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- money
- guidance (rules & regulations)
- modification flexibility
- on-site technical assistance & monitoring
What you can expect from us…What you can expect from us…
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4 ways to get into
eally big trouble…
RR
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- Embezzlement
- Theft or Bribery
- False Statements or Claims
- Mail & Wire Fraud
Four Flavors of Fraud…Four Flavors of Fraud…
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- Grant recipients, company officers, business partners, board members & managers
- Bookkeepers, financial staff & other employees
- Contractors & subcontractors
- Consultants
Who Commits Grant Fraud…Who Commits Grant Fraud…
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- Charging personal expenses as business expenses
Common Grant Fraud Scenarios…Common Grant Fraud Scenarios…
- Charging costs which have not been incurred, e.g. labor costs for fictitious employees, contractors, or consultants
- Charging for inflated costs or hours
- Kickbacks or other abuses of Quid pro quo
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http://www.usdoj.gov/criminal/npftf/
http://www.contractormisconduct.org/
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OObligations you take on with your grant…
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- that WE will provide the funds
- that YOU will comply with Every-Part-of-the-Agreement
Any sub-award relationships are governed by OMB Circulars. You are responsible for all sub-award relationships.
The Grant Agreement certifies…The Grant Agreement certifies…
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The Salary Cap…The Salary Cap…
- Pub.L. 109-234
- Guidance in TEGL 5-06: http://wdr.doleta.gov/directives/attach/TEGL/TEGL05-06.pdf
- Limits salary & bonus payments to individuals
2009 Limit: http://www.opm.gov/oca/09tables/pdf/ex.pdf
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- Accounting, financial & cash management
- Procurement
- Property management
- Personnel management & payroll
- Audit functions
- General legal services
Administrative Costs are…Administrative Costs are…
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- Get a Federally-approved rate if…
- 90-day timeframe
- It’s not the same as Admin!
The Indirect Cost Rate Agreement…The Indirect Cost Rate Agreement…
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- How to establish a Direct Deposit Account: http://www.dpm.psc.gov/grant_recipient/new_grantee_information/nonhhs_1199a.aspx?
- How to access funds: http://www.dpm.psc.gov/
- How to access on-line electronic reporting:http://www.etareports.doleta.gov/CFDOCS/grantee_prod/reporting/index.cfm
Your Grant Award letter tells you…Your Grant Award letter tells you…
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with any change to the Eight P’s:
- Partner- Personnel- Place- Purpose- Performance- Period- Parts- Price
Request a modification…Request a modification…
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- Quarterly Narrative Program Report
- On-line Financial reporting - ETA 9130
- All reports due 45 days after quarter end
- YOU certify it
Reporting…Reporting…
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nallowable activities
prohi itions
imitations
UU
BB
LL
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- Not grant-related
- Fundraising
- Alcohol
- Entertainment
- Bad debt
OMBOMB says it’s Unallowable… says it’s Unallowable…
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- Legal expenses for claims against the government
- Audit appeals
- Real property or Construction (except for ADA compliance)
WIAWIA says it’s Unallowable… says it’s Unallowable…
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- Charging fees for placement or training
- Public service employment
- Sectarian activities
WIAWIA says it’s Unallowable… says it’s Unallowable…
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WIA Section 181
- Business relocation
- Customized training which facilitates relocation
- Employment generating activities
- Economic development activities
Statutory Prohibitions…Statutory Prohibitions…
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WIA Section 181
- Revolving loan funds
- Capitalization of businesses
- Contract bidding resource centers
- Foreign travel
Statutory Prohibitions…Statutory Prohibitions…
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-0-% Limitations - Pre-award, legal, real property
The Four Cost Limitations…The Four Cost Limitations…
10-15% Limitations - Administrative costs
20% Limitations - Budget realignments
100% Limitations – Expend all your grant funds!
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EEverything will be OK!
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- Main point of contact
- Conduit for all formal Grantee-ETA communications
- Advises & assists on paperwork sufficiency
- Technical Assistance
- Oversight
Your “Friendly” Project Officer…Your “Friendly” Project Officer…
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… allegations of fraud can & should be made directly to DOL’s OIG - Office of Investigations, or a designated Telephone Hotline
…AND tell your FPO
ETA v. Office of the Inspector General…ETA v. Office of the Inspector General…
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U.S. Department of Labor National Call Center
[OIG Hotline]
866-4-USA-DOL866.487.2365
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- Are my costs necessary & reasonable?
- Does ETA get a proportional share of the costs & benefits received?
Ask Yourself…Ask Yourself…
What would a Prudent Person do?