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Grant Administration
FY06 ERCM Initial Grantee MeetingSan Antonio, TX December 7, 2006
Rich LuceyEducation Program Specialist, U.S. Department
of Education, Office of Safe and Drug-Free Schools
Bryan WilliamsProgram Analyst, U.S. Department of
Education, Office of Safe and Drug-Free Schools
Monitoring and Reporting Requirements
Faith-Based Organizations Fiscal Management Audit Requirements Expanded Authorities Freedom of Information Act Useful Resources
Agenda
Monitoring & Reporting Requirements
Notify Monitor of ChangesPost-Award Performance
CallSemiannual Monitoring CallGrant Performance Reports
–Interim and Final Reports
Grant Performance Report (ED 524B)
ED's generic performance report for discretionary grants
Used by ED's program offices as an interim and final performance report
May be submitted electronically through e-Reports
Purpose of the ED 524B
ED collects performance measures data from grantees to demonstrate program success to Congress (Government Performance and Results Act)
Performance information: – Guides ED's budget request for programs– Ensures program implementation is
focused on results– Ensures success is measured by results
achieved
Purpose of the ED 524B
Financial and performance monitoring tool for ED program offices for individual grants
– Interim Reports: Grantees provide data to demonstrate that they are making substantial progress toward meeting approved goals, objectives, and performance measures to receive continuation funding.
– Final Reports: Grantees provide data to demonstrate overall project success and impact.
Highlights of the ED 524B
Project Objectives: State what you hope to achieve with your funded grant project
Performance Measures: Demonstrate whether you have met or are making progress toward meeting your project objectives, including GPRA measures
Highlights of the ED 524B
ED 524B Cover Sheet (Item 7)
– Interim Performance Reports: Reporting period is from start of current budget period through 30 days before due date of report.
– Interim performance reports are generally due 7 to 10 months after the start of each budget period.
Highlights of the ED 524B
Budget Expenditures Data (Item 8) – All financial questions must be completed
by your Business Office
– Submit actual budget expenditures for:
1) Entire Previous Budget Period 2) Current Reporting Period
– Break down expenditures between federal and non-federal funds
Highlights of the ED 524B
Budget Information (Section B of the Project Status Chart) - must address– Provide an explanation if funds have not
been drawn down from GAPS to pay for budget expenditures reported in item 8 on Cover Sheet
– Describe significant budget changes resulting from modification of project activities
Site Visits
Site visits are a grant monitoring tool as provided for in EDGAR Part 74.51(g), "The Secretary may make site visits, as needed."
Also called an on-site review
A site visit may last multiple days
Site Visits
Reasons to conduct a site visit Program performance - Excellent
•Goals and objectives achieved in unique or innovative ways
•Development of effective strategies that may be replicable at other sites
Site Visits
Reasons to conduct a site visit Program performance - Problem
•Difficulty achieving goals and objectives
•Compliance issues•Fiscal improprieties•Technical assistance
Site Visits
What goes into site visit decision Review of materials
– Performance reports– Financial reports– Performance calls– Correspondence– Request for technical assistance
Site Visits
What to expect during the site visit–Entrance and exit interviews–Review of grant activities to date–Review recent budget and expenditures with fiscal staff
–Review evaluation plan
Site Visits
What to expect after site visit Reviewer's written report
– Positive findings•Exemplary practices
– Negative findings•Required Actions: Compliance•Recommended Actions: Non-
binding suggestions
Site Visits
What to expect after site visit Grantee's response
– Required Actions•Detail corrective actions that will
bring grant into compliance with programmatic/fiscal guidelines
•Dispute findings and present supporting documents
– Recommended Actions•Respond to recommended actions
Site Visits
What to expect after site visit Follow-up and closeout
–Grant monitor will follow up to ensure that all corrective actions have been accomplished
–Grant monitor will inform grantee in writing when review is closed
Faith-Based Organizations
White House Office of Faith-Based and Community Initiatives - January 2001
Federal Agency Centers - January 2001
Equal Protection of the Laws for Faith-Based and Community Organizations - December 2002
Faith-Based Organizations
Focus of the Initiative– Identify and eliminate barriers that
impede FBCOs in the federal grants process
– Increase accessibility to the federal grants process through training and technical assistance
Faith-Based Organizations
Core Principles– Equal treatment for faith-based
organizations applying for grants– Preservation of religious
liberty/character– Protection of beneficiaries– Federal funds may not be used for
inherently religious activities
Faith-Based Organizations
The U.S. Department of Education amended its regulations (EDGAR) to reflect these principles.– 74.44: Procurement procedures– 75.52: Grant eligibility– 75.532: Use of funds for religion
prohibited
Faith-Based Organizations
Monitoring– Faith-based organizations are subject
to the same accounting and reporting requirements as all other grantees
– Federal funds may not be used for inherently religious activities
Faith-Based Organizations
Section 75.532: Use of funds for religion prohibited– (a) No grantee may use its grant to
pay for any of the following:• (1) Religious worship, instruction, or
proselytization• (2) Equipment or supplies to be used
for any of those activities
Faith-Based Organizations
Guidance to Faith-Based and Community Organizations on Partnering with the Federal Government– www.fbci.gov
U.S. Department of Education's Center for Faith-Based and Community Initiatives– www.ed.gov/about/inits/list/fbci/
index.html
Fiscal Management
Memo to discretionary grantees Draw down funds only as necessary Project director should continually
monitor fiscal activity Excessive Drawdowns
– First Quarter: 50 percent or more– Second Quarter: 80 percent or more– Third Quarter: 100 percent
Fiscal Management
Large Available Balances– 70 percent of the project's
budget is available 90 days or less before the budget period ends
– Grant monitor works with grantee to reconcile situation
Fiscal Management
Indirect Cost Rates (ICR)– Grantee must have a current ICR
agreement to charge indirect costs– Applicants without a current
negotiated indirect cost rate that are selected for funding are subject to the terms and conditions included in Attachment D: Prohibition against Indirect Cost Recovery
Fiscal Management
Attachment D: Prohibition against Indirect Cost Recovery– Grantee shall submit ICR proposal to
cognizant agency (i.e., ED) within 90 days after award of the grant
– Grantee may not charge its grant for indirect costs until negotiated ICR agreement is in place
– Grantee must provide proof of its negotiated ICR agreement to grant monitor
Audit Requirements
Two types of audits– Grantee-Initiated Audit
•Independent Auditor•Compliance with OMB Circular A-133
•Annually expend $500,000 or more in federal funds must have a single audit or program-specific audit performed for that year
Audit Requirements
Two types of audits– OIG Audit
•Office of Inspector General•Not every grantee is audited•Office of Chief Financial Officer
reviews A-133 audit reports•OIG audit triggered by serious audit
findings identified by OCFO•Questions? Contact grant monitor
Expanded Authorities
Budget TransfersNo-Cost Time Extensions
Expanded AuthoritiesBudget Transfers
Parts 74.25 and 75.264 No prior approval required unless:
– Change in project scope or objectives– Change in key personnel
Notify grant monitor of transfer– Amount of money– Identify categories– Purpose
Expanded AuthoritiesNo-Cost Time Extensions
Parts 74.25(e)(2) and 75.261 One-time extension for up to 12 months
without prior approval Written justification needed at least 10
days prior to extension Cannot be for the purpose of exhausting
unexpended funds Cannot require additional funds nor
change the project's scope or objectives
Freedom of Information Act (FOIA)
Any person has the right to request access to federal agency records or information
All records must be made available, except:– Privileged or confidential
information– Personal information
Freedom of Information Act (FOIA)
FOIA Process– Project Director contacted– 10 days to respond to ED– Memo to FOIA Officer from ED– Information sent to requestor– Fee involved: research and
personnel
Useful Resources
Web Sites Publications Telephone Numbers
Useful Resources
What Works Clearinghouse–Gathers studies on effectiveness of educational interventions
–www.w-w-c.org
Useful Resources
The Challenge Newsletter– OSDFS Publication– Provides information and resources to help create safe and healthy learning environments
– www.thechallenge.org
Useful Resources
Training and Technical Assistance Centers– Character Education and Civic
Engagement– Emergency Response/Crisis
Management– Higher Education– Mentoring
Useful Resources
Character Education and Civic Engagement Technical Assistance Center– Provides state program administrators,
local educators, and the public with information on character education and civic engagement
– www.cetac.org– Contact: Rita Foy Moss
Useful Resources
Emergency Response and Crisis Management Technical Assistance Center– Provides technical assistance and
resources to grantees and non-grantee local educational agencies regarding crisis planning
– www.ercm.org
Useful Resources
Higher Education Center for Alcohol and Other Drug Abuse and Violence Prevention– Provides training, technical assistance,
and publications related to drug abuse and violence prevention on college campuses and in their surrounding communities
– www.higheredcenter.org– Contact: Rich Lucey
Useful Resources
Mentoring Program Training and Technical Assistance Center– Ensure that programs funded under
the Mentoring Program receive help in management and implementation of projects
– Contact: Bryan Williams•[email protected]
