Grant Management and Compliance

Who Wants to Keep A Million D$llars?

Which one of the following funding sources is likely to be the least restrictive? State agencies (Texas Workforce Commission, Texas Higher Education Coordinating Board, Texas Education Agency) Local Workforce Development Board Private Foundations U.S. Department of Education

Grant Management and Compliance Purpose of the Session To provide resources and information to assist grant managers with general program and fiscal management of federal direct and state pass-through funding.

Which of the following grant projects at Eastfield College are federally funded? Eastfield College Career and Technical Early College High School Social Work – Substance Abuse & Mental Health Program PLA Portal for Prior Learning Assessment Professional Development All of the above None of the above

Grant Management and Compliance Any project funded with federal funds, either directly from the federal agency (i.e. USDE, USDOL, DHHS) or passed-through a state or local agency (THECB, TWC, LWDB), is subject to federal laws and regulations pertaining to grant compliance. How can you determine if your grant includes federal funds? Source of funding from Request for Application (RFA) Regulatory Requirements Notice of Grant Award

Hierarchy Triangle of Grant Compliance Approved Proposal Guidelines for Application or Annual Performance Report Office of Management & Budget (OMB) Circulars Agency Regulations Program Regulations Law/Act

Prior approval is necessary from a funding agency for all of the following EXCEPT? When a vacancy in Key Personnel (Project Director) occurs. When a change in the program objectives included in the approved proposal is necessary. When the number of tutoring sessions that will be offered to participants in a grant program has changed. When a change of 3 months or more than 25% in the level of time and effort of the Project Director is necessary.

Revision of Budget and Program Plans Requests for federal direct programs are submitted to federal funding agencies. Requests for federal state pass-through programs are submitted to state funding agencies in compliance with federal and state requirements. NOTE: OMB 2CFR 215.25 or EDGAR § 74.25 (m) - Within 30 calendar days from the date of receipt of the request for budget revisions, the Secretary shall review the request and notify the recipient whether the budget revisions have been approved. If the revision is still under consideration at the end of 30 calendar days, the Secretary informs the recipient in writing of the date when the recipient may expect the decision.

What items, if purchased with federal funds, should be inventoried and tracked by the project? Electric stapler Laptops and printers CNC Milling machine A & B B & C

Equipment Purchased with Grant Funds Inventory tracking is necessary for equipment purchased with federal funds. OMB 2CFR 225 – On Definitions of Equipment (2) ‘‘Equipment’’ has a useful life of more than one year and an acquisition cost which equals or exceeds the lesser of the capitalization level established by the governmental unit for financial statement purposes, or $5000. (3) ‘‘Special purpose equipment’’ means equipment which is used only for research, medical, scientific, or other technical activities. Examples of special purpose equipment include microscopes, x-ray machines, surgical instruments, and spectrometers. (4) ‘‘General purpose equipment’’ means equipment, which is not limited to research, medical, scientific or other technical activities. Examples include office equipment and furnishings, modular offices, telephone networks, information technology equipment and systems, air conditioning equipment, reproduction and printing equipment, and motor vehicles. How should equipment no longer needed or used for the purpose of the project be discarded? OMB 2CFR 215.34

Who should complete time and effort reports? Non-grant funded institutional staff who are grant managers of grant funded projects. Only key personnel (Project Director) of a grant project. Only personnel employed on a grant project who do not complete timesheets. All personnel in positions included in the approved grant proposal committing any level of time and effort to a grant funded project.

Time and Effort Reporting Various interpretations of new regulations Defining payroll documentation approved by supervisor for exempt staff Certification of level of time and effort vs. personnel activity reports Multiple audit requests to review detailed reports Both documents should be available before audit of time and effort records

When might federal rules and regulations take a “backseat” in compliance? When an expenditure is pertaining to matching funds contributed by the institution. When the institution’s written policy regarding an expenditure is stricter. When the expenditure is one that is expected to be institutionalized. All of the above. None of the above.

Where to Find Compliance Policies and Regulations The Request for Application/Proposal of your grant project The Office of Resource Development website Department of Education (Uniform Grant Guidance) Office of Management and Budget (Uniform Grant Guidance) Funding Agency website Council of Opportunity in Education