Office of Grants Fiscal 9/20/2018 Office of Grants Fiscal Fiscal Requirements for Grant Management Today we will review updated information on the OMB “Omni”, “Super” Circular(Office of Management and Budget. The largest office within the executive office of the president which issues administrative, cost and audit rules for federal grant administration) and regulations, what we know at this time regarding the new uniform federal circular aka OMNI or Super Circular including key changes to note for both grantee (State) and subgrantee (districts and BOCES), the layers of federal regulations and other issues around federal grant management and compliance. April 23, 2015

Omni Circular 2

Effective Dates December 26, 2014 – Direct Grants from ED 9/20/2018 Effective Dates December 26, 2014 – Direct Grants from ED July 1, 2015 – State Administered Programs July 1, 2016 – Procurement Rules Indirect Cost Rates When Due For Renegotiation To avoid any confusion about which federal funds are under the old regulations and which are under the new regulations, all FY15-16 fiscal agreement, ALL grants awarded by CDE on and after July 1, 2015 will need to be in compliance with the OMNI Circular.

9/20/2018 New OMNI Circular All of the administrative rules and cost principles will be found in one document http://www.gpo.gov/fdsys/pkg/FR-2013-12-26/pdf/2013-30465.pdf For nonfederal entities who have multi-year awards will all be required to be in compliance with the new circular for awards made in FY2015-16. The Office of Management and Budget (OMB) has put all of the administrative rules and cost principles in one document, releasing the Uniform Administrative Rules, Cost Principles and Audit Requirements for Federal Awards, on Dec. 26, 2013. The uniform guidance applied directly to federal agencies on Dec. 26, 2013, and will apply to federal awards received by nonfederal entities beginning on or after Dec. 26, 2014. For nonfederal entities who have multi-year awards, however, they will follow the old guidance for the pre-Dec. 26 funding periods and the new guidance for the post-Dec. 26 funding periods. 4

What Rules Take Precedence? 9/20/2018 What Rules Take Precedence? A recipient of federal awards, which the uniform guidance calls a “nonfederal entity” must follow at least four layers of federal regulations. Auditors will address these layers as audit criteria when conducting an audit, including a single audit. The grantee must follow: Grant terms and conditions; Audit regulations; Cost principles; and Administrative rules Most authoritative to least. 5

Grant Terms and Conditions 9/20/2018 Grant Terms and Conditions When a grantee accepts an award from the federal government, it usually signs a contract typically referred to as the grant terms and conditions. The grant terms and conditions can add a layer of program and financial requirements, and in some cases, exceptions to the “standard” rules. The grant terms and conditions are the most authoritative source of requirements. CDE is required to pass these requirements to all of its subgrantees. This comes from the GAN (Grant Award Notice), passed on to subgrantees through their fiscal agreements. This is why your fiscal agreement is now on a legal size document. 6

Requesting Federal Funds – Submission of AFR 9/20/2018 Requesting Federal Funds – Submission of AFR The following statement will be found on all federal grant request for funds forms and the AFR issued by the Office of Grants Fiscal. This can be found at §200.415 Required certifications. “By signing this report, I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims, or otherwise. This was read to the Brustein & Manasevit training last week….actually they made us read it out loud. Then they asked…”would you sign this?” This certification will not only be on the request for funds, it will be part of the annual financial reports submitted at the end of each year. 7

9/20/2018 Cost Principles The cost principles tell grantees which expenses are allowable, reasonable, necessary and allocable For instance, federal dollars are not to be used for alcoholic beverages Federal dollars may be used to make lease payments I.e. copiers The concept of reasonable was addressed in regards to bus passes. It is a reasonable to give a day pass, however is it reasonable to give a month pass. 8

Changes to Fiscal Agreements 9/20/2018 Changes to Fiscal Agreements This list is not all inclusive however the following are new items that will be required: Federal Award Identification Number (FAIN) Name of subrecipient as it appears on DUNS DUNS number, that is active on the System for Award Management (SAM.gov) CDE issued 4 digit grant code Period of Performance – Start and end date Total amount of federal funds obligated to the subrecipient 9

Changes to Fiscal Agreements 9/20/2018 Changes to Fiscal Agreements Total amount of the federal award Indirect cost rate The subrecipient must permit the pass-through entity and auditors to have access to the subrecipients records and financial statements 10

Sub-Grantees (LEA/BOCES) 9/20/2018 Sub-Grantees (LEA/BOCES) More emphasis given to written policies and procedures: Five written policies: Financial Management 200.305 Procurement 200.318 Allowability 200.302 b(7) Cash Management 200.302b(6) Inventory Management 200.302b(4) Procurement must include conflict of interest. 11

9/20/2018 Food Generally, there is a very high burden of proof to show that paying for food and beverages with Federal funds is necessary to meet the goals and objectives of a Federal grant. When a sub-grantee is hosting a meeting, the sub-grantee should structure the agenda for the meeting so that there is time for participants to purchase their own food, beverages, and snacks. Grant award notices from USDE now include an enclosure that address the use of grant funds for conferences and meetings. For exceptions, refer to the fiscal agreement Food for parents and children, refer to specific grant guidelines. 12

9/20/2018 Time & Effort Charges for salaries must be based on records that accurately reflect the work performed Must be supported by a system of internal controls which provides reasonable assurance charges are accurate, allowable and properly allocated Be incorporated into official records Reasonably reflect total activity for which employee is compensated Not to exceed 100% Recommendation: Continue to use current guidance provided by CDE. Currently, it is unclear as to what changes might occur to Time & Effort documentation. Substitute salaries must be supported by documentation 13

9/20/2018 Discuss Cost Objectives

Records Retention OMNI §200.333 9/20/2018 Records Retention OMNI §200.333 “Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report.” These records can be kept electronically. 15

Grantee (SEA) Augmented Pass-Through Responsibilities: 9/20/2018 Grantee (SEA) Augmented Pass-Through Responsibilities: §200.331(b) CDE must evaluate each subrecipient’s risk of non compliance (federal statute / regulations / terms of award) for purpose of monitoring CDE must monitor its LEA/AUs to assure compliance and performance goals are achieved 16

Federal Financial Accountability and Transparency Act (FFATA) 9/20/2018 Federal Financial Accountability and Transparency Act (FFATA) System for Award Management (SAM) must be updated annually https://www.sam.gov/ Must be registered and active Information must be current Contact information Address Zip + 4 Any federal award which CDE subgrants, must be reported by subgrantee and by grant any time it is awarded for any dollar amount of $25,000 or greater. Effective July 1, 2015 CDE will be required to ensure all sub grantees are not only Active on Sam.gov, they also must be in good standing. CDE has obtained information for each district and there are a significant number of districts that are not listed as Active or Inactive on Sam.gov. If your district restricts the access to your account on Sam.gov, this may result in delays in issuing fiscal agreement and funds. CDE is required to list every subgrantee whether district, non-profit or IHE as they are listed on Sam.gov. If your school name has changed, you must make sure it has been changed on Sam.gov to ensure you receive grant documents with the correct name. Must have a DUNS number to sign up in SAM. Must be consistent between DUNS and SAM.gov (Address and zip +4). 17

CAGE – Commercial and Government Entity DUNS – Dun & Brandstreet 9/20/2018 +4 on the ZIP CAGE – Commercial and Government Entity DUNS – Dun & Brandstreet 18

Question It is April 15th, there are 76 days left of this fiscal year. What is the percentage of McKinney-Vento funds that have not been requested? 27% 34% 57% 19

9/20/2018 ANSWER 57% 20

Contacts Marti Rodriguez David Schneiderman (303)866-6769 rodriguez_m@cde.state.co.us Supervisor – Office of Grants Fiscal David Schneiderman (303)866-6689 schneiderman_d@cde.state.co.us 21