Agenda– Introductions– Webinar logistics– Financial management systems
• OMB circulars – ‘Super Circular’• Accounting system• Policies and procedures
– Fiscal Reporting– Requirements for cash reimbursement requests– Preparing for fiscal site visits
• Common IG audit findings– Member support costs and grant drawdown– Administrative Costs– Close Outs– Program Income
Your Fiscal Team
• July Afable, Manager of Accounting & Finance– 617-542-2544, x225
• Dan Glidden, CFO– 617-542-2544, x227
Financial Mgmt. Systems
– OMB Circulars – Super Circular
– Key characteristics
– Required policies and procedures
– Suggested policies and procedures
– Policies and Procedures and Form 990
– Electronic storage
OMB Super Circular
• This final guidance supersedes and streamlines requirements from OMB Circulars A-21, A-87, A-110, and A-122 (which have been placed in OMB guidances); Circulars A-89, A-102, and A-133; and the guidance in Circular A-50 on Single Audit Act follow-up.
• Effective date 12-26-2014 – all federal awards made on or after this date
• Raises Single Audit threshold to $750,000 from $500,000
http://www.gpo.gov/fdsys/pkg/FR-2013-12-26/pdf/2013-30465.pdf
Accounting System
In order to meet the CNCS reporting standards…
Your Accounting System must be capable of:
– Distinguishing grant versus non-grant related expenditures
– Identifying costs by program year
– Identifying costs by budget category (chart of accounts)
– Differentiating between direct and indirect costs (administrative costs)
Accounting System (cont.)
– Accounts for each award/grant separately– Maintains Federal/non-Federal matching funds
separately from grant funds– Records in-kind contribution as both revenues and
expenses– Directly correlates to financial reports submitted to
MSA (PERs)
Fiscal Reporting
• Quarterly Due Dates– October 15, 2014 (13-14 AND 14-15 through Sept. 30)
– January 15 (through December 31)
– April 15 (through March 31)
– July 15 (through June 30)
– October 15, 2015 (14-15 AND 15-16 through Sept. 30)
• Email PER Excel document with individual worksheets updated through the required date
Reimbursement and ReportingKey Definitions
• “Cover Sheet”/Request for Cash Reimbursement Cover Page
• Budget Summary Worksheet
• PER/Periodic Expense Report
• Backup/Supporting Documentation
• FFR/Federal Financial Report– MSA submits this report, aggregating information from
the PERS
Reimbursement Request Process
• At least quarterly– At minimum, request funds 30 days after submission of
PER (except for July 15)
– Encouraged to request more frequently
• Payments made via check or electronic fund transfer (EFT)– EFT requires small transaction fee deducted from
reimbursement
– Contact July to discuss/choose EFT
Reimbursement Request Process
• Accurate reimbursement received by 15th processed by 30th; received by 30th processed by 15th
– Inaccurate reimbursements returned for revision and will be resubmitted for processing in the next reimbursement cycle
– MSA adheres to 15 day processing timeline to account for staff capacity, time off, etc.
• MSA does not advance funds
Reimbursement Request Documents
• Reimbursement Request Cover Page
• Budget Summary Worksheet
• PER
• Supporting Documentation
Reimbursement Request Documents
• Complete reimbursement request includes:– Cover sheet with original signature (fax, scan or mail)
– Budget summary worksheet printout
– PER printout for current request• Also email PER to your Program Officer at MSA
– General ledger, reconciliation report, other backup documentation
– Individual member hours to date/accountability log• Your PO person likely will send the log
• Reimbursements will not be processed until all components are received
Fiscal Site Visits
– Purpose
• MSA is responsible for ensuring the fiscal integrity of organizations funded
• Ensure proper systems and safeguards exist around the financial operations of an AmeriCorps program
Fiscal Site Visits (cont.)
– Includes, but not limited to:• Review of organization's internal control
structure• Review of prior audit reports and
management letters• Review of progress made from any prior
audit and management letter finding(s)• Review of recent request for
reimbursement including all support documentation– Grant and match
Fiscal Site Visits (cont.)
– Likely areas for review
• Member benefits
• Living allowance stipends
• Cash match
• In kind contributions
• Insurance
• Human resources/payroll documentation
Fiscal Site Visits (cont.)– Likely areas for review (cont.)
• Financial policies and procedures• Cost allocations• Program analysis
– Actual vs. Budget reports• Program documentation – signed contract and
provisions• Staff charged to grant
– I-9– W-4– Timesheets– Current wage authorization– Job description– Current personnel evaluation
Fiscal Site Visits (cont.)
– Recurring Fiscal Findings• Staff Files missing I-9s• Incomplete I-9s• Staff Files missing Job Descriptions or
contracts• Staff Files missing properly completed
payroll authorization forms• No Staff timesheets• Staff and member timesheets missing
supervisory signoff• Electronic timesheet systems that were not
complaint
Member Support Costs
According to the AC Provisions– Regardless of member type:
• Stipends are not determined by the number of hours served, it’s a flat rate
• Stipends can only be paid while a member is serving
• Timesheets properly completed– Signed by supervisor and member
– Service, training and fundraising hours segregated
Member Support Costs (cont.)
– Guidance from CNCS
• A member stipend stays the same for the duration of their service
• All members with the same position description must be paid identical stipends and receive the same benefits
• Member stipends can not be pro-rated
• Member stipends can not be paid in lump sums
• If members are suspended through a whole pay period they are not eligible for that stipend
Grant Drawdown
– Commissions and AmeriCorps Programs do not spend all of their Federal money each year.
– Most of the unexpended funds are from Section II Member Support Costs and other costs associated with members (Trainings, Travel).
Grant Drawdown (cont.)
• Section I
– Reconcile budgeted amount with year to date expenses
– Forecast projected expenditures
– File amendment with Program Officer
• Section II
– Start program year with full enrollment
– Fill slots vacated by members who served less than 30% of their hours
– Convert Member Slots
Grant Drawdown (cont.)
– Budget Amendments
• Contact your AmeriCorps Program officer before initiating a budget amendment
• All provisions still apply to budget amendments
• Include justification with budget amendment
• Budget amendments are subject to review
• Budget amendments can be rejected
Section III: Admin. Costs
– A fixed percentage of Section I + Section II designed for administrative costs
– Composed of
• Corporation Fixed Amount (this is yours)
• Commission Fixed Amount (this is MSA’s)– Starting with the 14-15 program year, this is now
1.5%
– The only way to draw down all of Section III is to draw down all of Section I and Section II
Section III - Calculations
Corporation Fixed Amount Commission Fixed Amount Calculation: Section I + Section I I x 3.68%
Calculation: Section I + Section I I x 1.58%
A reimbursement request will include this money
A reimbursement request CANNOT include this money.
Grant Close Out
• A grant is closed out when it is over
• This process at CNCS documents:– Total Funds drawn down– Sub-grantee certification– Residual equipment & supply
inventory– Refunds as necessary
• Process– MSA checks total funds drawn
down for program and compares to final program FFR/PER
– MSA sends close out letter/instructions with forms to programs and amounts drawn down
– Program completes forms and reconciles its total draw down with MSA amount provided
– Program submits documentation to MSA within 30 days
– MSA aggregates all programs and submits one package to CNCS