Language Resource Center Program

FY 2010 – 2013 Grant Cycle

Clarity & communication◦ Please ask questions if/when you have them!

Documentation◦ Provides greater protection against audit inquiries

Meeting deadlines

Budget revisions – clear and concise

“Open Door Policy” – please let me know if/when you will be in town!

Expectations

Authorized/Certifying Representative: authorized person on campus to sign for the grant; this person is established at the time of application on the SF-424

Project Director: person in charge of grant activities; director of the established center

Principal Investigator = We do not use this term

LRC Terminology: On Campus

Additional contacts (IRIS): person(s) who help with the administration of the grant via IRIS; please limit access to a select few

Contract: a procurement contract under an award or subaward, and a procurement subcontract under a recipient's or subrecipient's contract.

Subrecipient: the legal entity to which a subaward is made and which is accountable to the recipient for the use of the funds provided.

LRC Terminology

A subcontract covers a specific service(s) to be rendered, while a subgrant means an award of financial assistance to another entity

A subgrant is UNALLOWABLE, per 75.708 Prohibition of subgrants:◦ (a) A grantee may not make a subgrant under a program

covered by this part unless specifically authorized by statute.

Subcontractors are not allowed to render services that are outside the parameters of the LRC regulations

Subcontract vs. Subgrant

The Language Resource Centers Program provides assistance to establish, strengthen, and operate centers that serve as resources for improving the nation’s capacity for teaching and learning foreign languages effectively

Language Resource Centers

The conduct and dissemination of research on new and improved methods for teaching foreign languages, including the use of advanced educational technology;

The development and dissemination of new materials for teaching foreign languages, to reflect the results of research on effective teaching strategies;

Authorized Activities

The development, application, and dissemination of performance testing that is appropriate for use in an educational setting to be used as a standard and comparable measurement of skill levels in foreign languages;

The training of teachers in the administration and interpretation of foreign language performance tests, the use of effective teaching strategies, and the use of new technologies;

A significant focus on the teaching and learning needs of the less commonly taught languages, including an assessment of the strategic needs of the United States, the determination of ways to meet those needs nationally, and the publication and dissemination of instructional materials in the less commonly taught languages;

The development and dissemination of materials designed to serve as a resource for foreign language teachers at the elementary and secondary school levels; and

The operation of intensive summer language institutes to train advanced foreign language students, to provide professional development, and to improve language instruction through preservice and inservice language training for teachers.

◦ Allowable costs: Honoraria

◦ Unallowable costs: T-shirts, souvenirs, gifts

Budget

Allocable: charged in proportion to value received by project

Allowable: either permitted or not specifically prohibited

Budget Revision = changes made to the budget throughout the grant period

Reasonable: costs that would be incurred by a “prudent” person

Revised Budget: agreed upon, edited budget that was resubmitted after receiving the Grant Award Notification (GAN)

Budget Terminology

Budget amounts: Year 1: Actual amount awarded Years 2-4: Anticipated amounts, based on current funding.

Indirect costs are limited to 8%

Equipment costs cannot exceed 15%

Grantees need to adhere to budget submitted and approved by US/ED. Some changes may require US/ED approval.

Prior approval is not required for most budget transfers unless they are over 10% or $100K, though program officers like to be notified of changes.

Budget Guidelines

Carryover from one fiscal year to the next fiscal year is allowable

The amounts of carry over funds must be reported in IRIS

An explanation will be needed for the large sum, as well as a plan to expend it

Be sure to separate carryover from new fiscal year funds in budget and budget reporting.

Carryover Funds

Draw down only enough cash to meet grant’s immediate need

Minimize the time between draw down and pay out of funds (three-day rule of thumb)

Reimbursement method is the safest

Drawing down too much or too little will cause you to be flagged by the Department of Education

Draw-Downs

Ultimate goal: clear and concise for 4 years

Discuss any changes with the program officer before making permanent amendments on campus

Any programmatic changes and/or reprogramming of funding must be documented in a new budget

Cost shares submitted in the application (ED 524 Section B) must be honored for the duration of the grant

Maintaining Your Budget

If you indicate a non-federal contribution on the SF 524 budget form, you are required to provide that amount and follow the regulations on documenting cost share/match found in EDGAR §74.23

Matching contributions must be verifiable from the recipient’s records, not included as a contribution for any other federal project (no double counting), necessary and reasonable for the accomplishment of the project, allowable under the cost principles, and not paid by the Federal Government under another award

Cost Share/Match

OMB Circular A-21: Cost Principles for Educational Institutions◦ Learn it, live it, love it!

Examples of unallowable costs:◦ Alcohol◦ Fundraising◦ Entertainment

Is that allowable?

Monitoring

Implementing the project

Compliance with statutory & regulatory requirements

Fiscal management and accountability

Recordkeeping and reporting requirements

Project Director Responsibilities

34 CFR 655 and 34 CFR 669

EDGAR Regulations: Parts 74, 75, 77, 79, 80, 81, 82, 85, 86, 97, 98, and 99.

OMB Circular A-21: Cost Principles

OMB Circular A-133: Audit Principles

Department Directives and Bulletins

Individual Grant Terms and Conditions

Approved and Awarded Grant Application

LRC Monitoring Tools

Must be Fly America Act compliant

Security concerns

Per Diem Rates:◦ Domestic: as established by General Service

Administration (GSA)◦ International: as established by the Department

of State (DOS)

Travel

EDGAR 34 CFR § 74.21 (b) Standards for financial management systems

◦ (1) Disclosure of financial results◦ (2) Records that identify the source and application of

funds ◦ (3) Effective control and accountability ◦ (4) Comparison of outlays with budget amounts ◦ (5) Procedures for draw downs◦ (6) Procedures for determining the reasonableness,

allocability, and allowability of costs◦ (7) Accounting records including cost accounting

records that are supported by source documentation

Financial Management

Purpose:◦ Reliability of financial reporting◦ Compliance with laws and regulations◦ Safeguarding of assets

Requirements:◦ Written policies and procedures◦ Segregation of duties◦ Proper authorizations◦ Sufficient documentation◦ Reporting

Internal Controls

Personnel costs must be reasonable and reflect actual work performed

Effort includes the time spent working on a sponsored project in which salary is directly charged or contributed (cost-shared)

Effort is expressed as a percentage distribution that adds up to 100%

Effort reports are different from payroll records. Reports must be certified and signed on a regular basis

Personnel Time and Effort

Exemplary project

Multiple grants

Large grant award amount

Random selection

We just like you.

Need for technical assistance

A-133 single audit findings

Complaint

Late performance report

Frequent turnover of personnel

Site Visits: Why us?

Poor record-keeping/ lack of documentation Weak internal controls Unallowable costs Poor sub-recipient monitoring Contracting out project activities without

approval Missing time and effort reports

Common Problems to Avoid

Set out clear roles and responsibilities Develop and follow written policies and

procedures Document, document, document If in doubt:

◦ Consult the “Monitoring Tools”◦ Contact your Program Officer

Helpful Reminders

Evaluation

Evaluation is the systematic data collection, analysis and information gathering needed to make decisions.

It is a continuous process – start now to determine where you want to be in four years.

Be selective: What elements/components of your program are you evaluating and why? How do these tie to your objectives?

Evaluation: What is it?

Programmatic: AIR study and survey

Institutional: Impact of Title VI on campus

Project: Overall impact of LRC grant activities

Component: Curriculum, Outreach, Language Proficiency

Sub-Component: A specific aspect such as a teaching training workshops or summer institutes

Levels of Evaluation

Evaluation is vital to the overall international education initiatives at your institutions. It informs priorities, resource allocations, and any adjustments needed to improve instruction, outreach, professional development activities, student services, etc.

Why is it important?

Accountability◦ Are we doing what we said we would?

Outcome◦ The immediate or direct effect of the project.

Impact◦ Is the program making a difference. (gets back to the

evidence, i.e., data collection) Sustainability

◦ What elements exist or will be in place to ensure that improvement will be sustained. Institutionalization. Brand recognition. Leveraging appeal.

Lessons learned◦ Factors that supported or inhibited the accomplishment of

stated objectives. Unexpected outcomes.

Core Components

A key to successful evaluation is a set of clear, measurable, and realistic project objectives.

If objectives are not realistic or not appropriate to what you have envisioned, you will not be able to demonstrate or provide evidence that project activities have been successful.

Other Considerations

Grant Maintenance

Bi-annual reports, fall and spring, are captured through IRIS

◦ The LRCs and NRCs have different spring report due dates!

Please make sure budgets are submitted with the spring report

Information collected in these reports contribute to decisions on non-competing continuations (NCC)

Reporting

Reporting is also used for Departmental measures and requirements

Progress on projects should be clearly explained and indicated

Yes, your reports in IRIS matter!

Call or email to let us aware of the situation Questions to consider:

◦ Do funds need to be reprogrammed?◦ How does this affect the grant in the short term?◦ How does this affect the grant in the long-term?◦ What could be possible solutions?

Each “problem” will be approached and resolved individually

Please speak to us directly!

What if something changes?

Must immediately notify us when –◦ Change of key personnel◦ Reduction of 25% of the time devoted to the project◦ Absence of a project director for more than 3 months◦ (See EDGAR 74.25)

If a new project director is hired, the Authorized Representative must send his or her CV immediately

Please keep us abreast of any “significant” staff changes

Staff Changes

Prospective goal: two sites visits for fiscal year 2011

Not attending ACTFL

Please alert me to any LRC-related events within the DC Metro Area

Out & About

The LRCs and NRCs function under different sets of regulations.

If you haven’t heard it from me or via Elaine, then it is likely not true.

Friendly Reminders

DOS Per Diem: http://aoprals.state.gov/web920/per_diem.asp

Electronic Code of Federal Regulations: http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=/index.tpl

Fly America Act (Airline Open Skies Agreement): http://www.gsa.gov/portal/content/103191

GSA Per Diem: http://www.gsa.gov/portal/category/21287

Helpful Websites

IRIS: http://iris.ed.gov Joint LRC Website: http://nflrc.msu.edu/ LRC Website:

http://www2.ed.gov/programs/iegpslrc/index.html

OMB Circular A-21 for Educational Institutions: http://www.whitehouse.gov/omb/circulars_a021_2004

Helpful Websites