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Discretionary Grant Administration

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Overview of ED financial policies

Managing budget

Avoiding audit problems

Identifying key resources such as Grantmaking at ED

Agenda

www.ed.gov/fund/grant/about/grantmaking/index.html

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Legislation

Regulations

EDGAR

Cost Principles (2 CFR/OMB Circulars)

Grant Award Notification (GAN)

Your approved Application

*G5

Tools of the Trade

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• 2 CFR Part 220 for Educational Institutions (see OMB Circular A-21)

• 2 CFR Part 225—for State, Local and Indian Tribal Governments

(see OMB Circular A-87)

Cost Principles

http://www.gpoaccess.gov/cfr/index.htmld

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Project’s success and financial accountability

Submit annual & final performance reports

Grantee Responsibilities

Valid & reliable data

Report on GPRA standards & indicators

EDGAR

§§74.51 & 80.40

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Clear, concise, and detailed

Consistent with institutional policy

Meets federal requirements

Aligned with GPRA

Revised within scope of project

Achieve project goals

Monetary Road Map

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must do the following…•Provide for accurate, current, and complete disclosure of results regarding the use of project funds

• Document both the federal and non-federal funds used to carry out the project and track partners

Financial Management Systems

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Provide for accurate current, and complete disclosure of results regarding the use of project funds

Document both the federal and non-federal funds used to carry out the project and track partners

Maintain effective internal controls

Financial Management Systems

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Allowable –

permitted or not specifically prohibited

Allocable –

necessary for project’s success

Reasonable –

costs incurred by a “prudent” person

Budget Items

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Cost Sharing/Matching

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Cost Sharing/ Matching

Definition: The portion of project/program costs not borne by the Federal government •Terms are used interchangeably and refer to either:

• Statutorily-specified percentage of project/program costs that must be

• Voluntary contribution

• Grantee must honor the commitment

• Fully documented

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Cost Sharing/ Matching

• Examples include: equipment, facilities, cash staff time

• Must be treated like Federal dollars

• See EDGAR 74.23 and 80.24

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Cost-Share Calculation

Applicant’s cost-share requirement is 25% of the totalcost of the project.

Total project: Fed share X applicant share = Match Federal share % of total cost Amount

Total project costs = Federal share + Match Amount

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Audits

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Missing time and effort reports

Poor record-keeping

Failure to obtain prior approval

Incorrect indirect cost rates

Unallowable costs

Lack of internal controls

Common Audit Exceptions

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Non-Federal audit if expending $500,000 or more annually in Federal awards

Mail to Federal Audit Clearinghouse

Review Attachment C

Audit Requirements

OMB Circular A-133

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GrantMonitoring

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Request funds for immediate needs

Minimize time between requests & expenditures

Draws commensurate with approved scope

Drawdown Policy

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Rate of drawdown must be commensurate with approved scope of work and milestones

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

Minimize time between drawdown and payout of funds

ED’s Drawdown Policy

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Documented unsatisfactory performance

Financially unstable

Non-standard management

Non-conformance to terms/conditions

Otherwise not responsible

High-risk Designation

Necessary to ensure compliance with grant requirements

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GranteeFlexibility

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Goals: Increase flexibility

Increase accountability

Reduce paperwork burden

Develop relationships

Grantee Flexibility

Promote successful project outcomes

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Changes in project scope or objectives

Changes in key personnel

IHE & non-profit project directors> absent for more than 3 months> 25% reduction in time

Need for additional Federal funds

Prior Approval

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No-cost extensions require RSA Project Officer approval and will be reviewed on a case-by-case basis (Note: Discretionary Grants operated by the Training Programs Unit in RSA are restricted by the terms and conditions of their award under Attachment “Z” in the GAN.

Attachment “Z” does not permit the grantee to extend the grant without RSA approval.

Requests for no-cost extensions must be submitted at least 45 days in advance of the end of the grant period of performance.

Time Extension

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No later than 10 days before project ends

State reasons for extension

Include revised expiration date

Time Extension

Written notice to Program Officer

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Time Extension Restrictions

Not just for using unexpended funds

No additional Federal funds

No change to scope or objectives

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Large amounts of unobligated funds at end of budget period

Excessive or infrequent drawdown of funds

Project goals not met

ED Concerns

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Annual substantial progress met

GPRA indicators met

Recordkeeping & fiscal accountability

What Agencies Look For

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Questions?