Federal Grant Federal Grant Management BasicsManagement Basics
Perkins Grant Management WebExJune 21, 2011Donna BrantOregon Department of Education
Oregon Department of Education | June 2011
Overview:Overview:
1. The Basics Application and Revision Allowable and Reasonable Allocable and Supplemental
2. Property Control
3. Time Distribution
Oregon Department of Education | June 2011
Disclaimer…Disclaimer…
This webinar is intended for program staff and is presented from a program perspective….
Discuss any questions or procedures with your accounting staff or auditors!
Oregon Department of Education | June 2011
EDGAR…EDGAR…
Who is he and what does he have to do
with my grant??
http://www2.ed.gov/about/offices/list/osdfs/edgar2008.pdf
Google: EDGAR
Education Department General Administrative RegulationsOregon Department of Education | June 2011
EDGAR describes…EDGAR describes…
Financial Reporting Accounting Records Internal Control Budget Control Allowable Costs Source Documentation Cash Management
Oregon Department of Education | June 2011
The Perkins Grant ProcessThe Perkins Grant Process
Grant Application and Budget
Narrative
RevisionsEDGAR 80.30(d) Grantees or subgrantees must obtain prior
approval of the awarding agency whenever any of the following actions is anticipated: Any revision of the scope or objectives of the project
(regardless of whether there is an associated budget revision requiring prior approval).
EDGAR 80.30(f) a request by a subgrantee for prior approval will be addressed in writing to the grantee.
Oregon Department of Education | June 2011
Allowable CostsAllowable CostsOMB Circular A-87OMB Circular A-87
Costs must meet the following criteria:
Be reasonable and necessary
Be allocableBe authorized or not prohibited under state or local laws or federal grant regulations
Oregon Department of Education | June 2011
Reasonable CostsReasonable Costs Do not exceed that which would
be incurred by a prudent person
Are ordinary and necessary for the operation of the program
Represent sound business practices and arms length bargaining
Oregon Department of Education | June 2011
Allocable CostAllocable Cost Must provide a benefit to the
program in proportion to the amount of expenditure
Costs are allocated over the period of the grant
Goods may be charged to the program in accordance with the relative benefit received
Oregon Department of Education | June 2011
Supplement Not SupplantSupplement Not SupplantFederal funds must be used to
augment the regular education program
Supplanting is using federal dollars to provide:◦A required program or service◦A program that was provided by non-
federal funds in the prior year◦Services to some students while
using local sources to provide the same services to others.Oregon Department of Education | June 2011
Records and Source Records and Source DocumentsDocuments Lack of documentation is a primary
reason for audit findings
Documentation must be available to support every expenditure From initial requisition to final
disbursement You must follow your own rules
3 year Federal ~ 7 year OregonOregon Department of Education | June 2011
Property ControlProperty Control
All assets purchased with federal funds
◦Life expectancy of more than one
year
◦Initial cost of more than $200
◦Label with year purchased and
funding sourceOregon Department of Education | June 2011
InventoryInventory
Purchase cost and date
Specific location of asset
Funding used for purchase
Disposition
Oregon Department of Education | June 2011
OMB A-87 RulesOMB A-87 RulesIf federal funds are used for
salaries then Time Distribution records are required.
Must demonstrate◦If employee is paid from federal
funds, then employee worked on that specific federal program or cost objective.
Oregon Department of Education | June 2011
Time Distribution – Why Time Distribution – Why worry?worry?Salary costs are material to many grants.
The absence of adequate documentation is basis for repayment of funds.
Considered explicitly as a “risk factor” by OMB.
Numerous grantees have had to repay millions because of time distribution issues.
Oregon Department of Education | June 2011
TerminologyTerminology
Time and Attendance Records
Time and Effort Records
Payroll records Time distribution records
Timesheet Time distribution record•Semi-annual certification•Personnel activity report (PAR)•Time and effort report
Monday worked 8:00-4:00 Monday worked 60% Perkins Leadership; 5% Perkins Administration; 35% General Fund
ScheduleContract
Work productCalendarTime log
Oregon Department of Education | June 2011
Cost ObjectiveCost ObjectiveA function, organizational
subdivision, contract, grant or other cost activity for which cost data are needed and for which costs are incurred.
◦What federal program cost objective did the employee work on?
◦These cost objectives must be connected to the salary source.
Oregon Department of Education | June 2011
Adequate ReportingAdequate Reporting
Retained by the fiscal agent
Prepared After-the-FactAfter-the-Fact
Full disclosure – Report of full time
worked
Credible endorsement
Reliance from the “bottom up”Oregon Department of Education | June 2011
If work 100% on single cost If work 100% on single cost objective…objective…
Semi-Annual Certification◦Signed every six months by
supervisor or employee
“From August 15, 2010 until December 31, 2010, Donna Brant spent 100% of her time on Perkins Leadership activities at the Oregon Department of Education.”
Oregon Department of Education | June 2011
REMEMBER…Adequate REMEMBER…Adequate ReportingReportingRetained by the fiscal agent
Prepared After-the-FactAfter-the-Fact
Full disclosure – Report of full time
worked
Credible endorsement
Reliance from the “bottom up”Oregon Department of Education | June 2011
If multiple cost If multiple cost objectives…objectives…Personnel Activity Report (aka…PAR, Time and Effort Report)
Signed and dated every month by employee
Actual accounting of time spent After the fact Showing the total effort Should have report and backup
documentation to verify - e.g. calendar, work product, time log
Oregon Department of Education | June 2011
Comparison and Comparison and AdjustmentAdjustmentQuarterlyQuarterly comparison of actual
cost to budgeted distribution.
If difference between actual and budgeted cost is 10% or greater make adjustments quarterlyquarterly.
If difference is less than 10% make adjustment annuallyannually.
Oregon Department of Education | June 2011
MonitoringMonitoringBeginning 2011-2012Expenditure Report
◦Current and Prior Year◦Compare to approved grant/budget◦Looking for allowable
Inventory and LabelingTime Distribution Records
Oregon Department of Education | June 2011
Now that you know…Now that you know…Schedule and appointment with your
business manager to clarify your policy and procedures
Schedule at least quarterly meetings to review budget, expenditures and needed adjustments
If in doubt… contact Donna or Reynold!
Oregon Department of Education | June 2011
For more information:For more information:EDGAR http://www2.ed.gov/about/offices/list/osdfs/edgar
2008.pdf
OMB A-87 http://www.whitehouse.gov/omb/circulars_a087_2004
OMB A-133 http://www.whitehouse.gov/omb/circulars_a133_compliance_09toc/
PCRN http://cte.ed.gov/
Donna Brant, ODE
Reynold Gardner, ODE
Oregon Department of Education | June 2011