Maryland State Department of Education Brief Update on Select Fiscal Matters Related to Grant Issuance and Management Title I Spring Meeting 2016 Kim Stewart, Financial Reporting & Coordination Branch (FRCB) Division of Business Services

FRCB’s Role in Title I Compliance  Serve as the liaison between MSDE’s Title I and Fiscal Offices to ensure that financial data is properly maintained and readily available.  Prepare the Title I Calculations.  Provide guidance to Title I program concerning federal grant management (ex. UG).  Work in concert with MSDE Financial Reporting Branch in approving LEA Indirect Cost Rates.

Uniform Guidance (UG)  The Office of Management and Budget's (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly called "Uniform Guidance") was officially implemented in December 2014 by the Council on Financial Assistance Reform (COFAR).  The Uniform Guidance – a "government-wide framework for grants management" – synthesizes and supersedes guidance from earlier OMB circulars

Uniform Guidance (UG) Eliminating Duplicative and Conflicting Guidance Previous Guidance: New Uniform Guidance New Uniform Guidance : All OMB guidance streamlined into 2 CFR 200 Circulars A-102 & A-89 A-87 A-133 &A-50 Circulars A-102 & A-89 A-87 A-133 &A-50 Awards Received Sub-Awards to Non-Profits Circulars A-110 A-122 Circulars A-110 A-122 Sub-Awards to Universities Circulars A-110 A-21 Circulars A-110 A-21 Source: Maryland Governor’s Grants Office, 2014

Uniform Guidance (UG) 2 CFR Basic Layout:  6 Subparts A through F  Subpart A, 200.XX – Acronyms & Definitions  Subpart B, 200.1XX – General  Subpart C, 200.2XX – Pre Award (Federal agencies)  Subpart D, 200.3XX – Post Award (Recipients)  Subpart E, 200.4XX – Cost Principles  Subpart F, 200.5XX – Audit  11 Appendices - I through XI

Uniform Guidance (UG) , Requirements for Pass-through Entities (Includes audit responsibilities (formerly in A-133)) Pass-through entities’ responsibilities:  Provide sub-award information  Provide indirect cost rate  Perform risk assessment for sub-recipient  monitoring  Verify compliance to audit requirements  Report in accordance to FFATA (Federal Funding Accountability and Transparency Act)

Indirect Costs  The Title I Grants to Local Educational Agencies program is subject to non-supplanting requirements and must use a restricted indirect cost rate which is referenced under 34 CFR  Indirect costs represent the expenses of doing business that are not readily identified with a particular grant, contract, project function or activity, but are necessary for the general operation of the organization and the conduct of activities it performs.

Indirect Costs  An indirect cost rate is simply a mechanism for determining fairly and conveniently within the boundaries of sound administrative principle, what proportions of Departmental/organization administration costs each programs should bear.  This means that the funds are for support in addition to state and local funding. Such amounts are intended to supplement, but in no way replace local funds.  Most of the federal grants that the LEA obtains through the department have supplement-not-supplant requirements and a restricted indirect cost rate must be used on the programs.

Indirect Costs  An indirect cost rate is simply a mechanism for determining fairly and conveniently within the boundaries of sound administrative principle, what proportions of Departmental/organization administration costs each programs should bear.  This means that the funds are for support in addition to state and local funding. Such amounts are intended to supplement, but in no way replace local funds.  Most of the federal grants that the LEA obtains through the department have supplement-not-supplant requirements and a restricted indirect cost rate must be used on the programs.

Distribution of Informational Materials  Reference and Training Materials (MSDE Title I Website):  Managing Title I Grants  The Official Grant File  Grant Management: The State Perspective  Currently Approved Indirect Cost Rates  2016 Title I Grant Spend-down Rates  2017 Preliminary Title I Allocations