Fiscal and Grants Management Presented by: Brian Jones, Director Office of Federal and State Grants Management 2012

Ohio Department of Education Office of Grants Management 25 South Front Street, Mail Stop G03 Columbus, Ohio (614) Brian Jones, Director

Financial and Grants Management 1.Communication 2.Managing Financial Compliance 3.Subrecipient Monitoring/Single Audits

1.Communication Communications (district, ODE, Auditor, etc..) Don’t be afraid to ask questions Communication is key to any effective process –Not just between ODE and district –Build and maintain strong communication within the district Recommendation: Periodic status updates (discuss application, budget revision and/or closeout of grants

Communication Don’t be afraid to ask your auditor questions If you are uneasy or just need clarification on financial matters call your Grants Management consultant Don’t assume anything!

2. Managing Financial Compliance Financial Compliance: Some Basic Rules that cause biggest headaches School Wide Pooling Medicaid In School Program: Lone Wolf

Managing Financial Compliance Budgets : approval to obligate funds Transfers between cost categories greater than 10% require a revision Budget Revision serves as the prior approval before district enters into obligations. Contact program office for advice before doing activity if in doubt. (Get it in writing, i.e. History Log or ) No expenditures prior to the substantially approved date

Managing Financial Compliance Per EDGAR 34 CFR 80.3 Definitions, Obligations means the amounts of orders placed, contracts and subgrants awarded, goods and services received, and similar transactions during a given period that will require payment by the grantee during the same period…

Managing Financial Compliance Proper Support Documentation –Time and Effort (OMB A-87 Requirement) –No Estimates, must be actual time spent on activity (Activity Logs or Semi-Annual Certifications) –No expenditures before substantially approved date Proper Coding –Function and Cost Objective –Coding per Districts Reports must match program budgets and Final Expenditure Reports

Managing Financial Compliance EDGAR (section 34 CFR 80.30), (a) General. Grantees and subgrantees are permitted to rebudget within the approved direct cost budget to meet unanticipated requirements and may make limited program changes to the approved project. However, unless waived by the awarding agency, certain types of post-award changes in budgets and projects shall require the prior written approval of the awarding agency.

Project Cash Request (PCRs) Initial Payment (Stopped Beginning FY2012) –No more for either CCIP or Paper Grants. Subsequent Payments –GM starts approving PCRs around the 25 st of the month advances and throughout the month for reimbursements –For immediate cash needs –Only one advance per month, however, unlimited requests for negative cash balances –Amounts must be supported by district records Grants Management may contact districts to verify amounts shown in the PCR

Project Cash Request (PCRs) “Total Expenditures” now reported by object code PCRs meeting specific validation will be auto- approved and will go straight to fiscal for payment –advance plus cash on hand is less than or equal to 10% of the allocation/approved budget –Advance is requested on or after the 25 of the month Districts can now attach supporting documentation to the PCR.

Final Expenditure Report (FER): FER submitted on cash basis (no encumbrances) FERs are due: –9/30 CCIP Applications –8/31 Paper Grants (normally) Significant differences between expenditures reported throughout the year and FER will be reviewed.

Final Expenditure Report (FER): All FER revisions must have documentation Changes cannot be accepted without the supporting documentation - GM is not required to allow an FER revision If FER revision is recommended by the auditor, notify me immediately. (Once the audit is “opined” the district cannot make adjustments the FER) Increased number of substantially approved date audit findings, which increased the number FER revisions. (FER revision is a risk analysis data set)

Consolidated Application Timeline Type of Grant Initial Allocations Application Approval Reallocation and Final Reallocation Final Expenditure Report Carryover Review Carryover (9/30 Report) Adjust/ Remove Carryover FormulaJuly *December and Feb./March September 30 October October/ November

Managing Financial Compliance School-Wide Pool Due to the changes in School Improvement and the New Race to the Top program the School-Wide Pool becomes a new option to consider Different than transferability (USAS fund 598) Recommendation: Do not go into this decision lightly. Think about if the School-Wide Pooling really benefits the district. May leverage funds but will require additional accounting procedures SW-Pool PCR in development (Goal: July 1, 2012)

Managing Financial Compliance Medicaid in Schools Program (MSP) The only Medicaid funded program within ODE –Designed to assist districts offset State/Local share of Special Education Costs (driven by the IEP) ODE responsibilities include: – Time-Studies, Cost Reports and Agreed Upon Procedures review. –Ohio Department of Jobs & Family Services is still State Medicaid Agency responsible for interim payments and overall oversight Number of the participating districts 500 Approximately $20+ millions have flowed through to the districts Contact Mark Smith at for more details.

3. Subrecipient Monitoring / Single Audits Audit Issues ODE Financial Monitoring

Subrecipient Monitoring / Single Audits Federal Requirements (Hot Topics) Reporting (FER and 1512 Reporting) Procurement (Noted in two different monitoring reviews from two separate USDOE Offices) Allowable Costs (Time and effort, and proper support documentation maintained) Period of Availability (Substantially Approved Dates) Cash Management (Cash on Hand/Immediate Cash Need)

Subrecipient Monitoring / Single Audits Financial Monitoring –Grants Management has the responsibility to complete on-site and detail desk review of multiple programs –Developed a Statewide All USDOE grant Risk Analysis –The review will encompass but not limited to, Activities Allowed, Cash Management, Period of Availability, Reporting, Procurement and Equipment (if applicable). –Documentation will be requested as early a possible.

Questions?