Grants Management – Overseeing Title I Compliance: Finances, and District/School Implementation 13th Annual Title Programs Conference June 17-18, 2015 Atlanta, Georgia

Presenters Dr. Judy Alger Georgia Department of Education School Improvement – Federal Programs Title I Education Program Specialist jualger@doe.k12.ga.us (229) 321- 9305 Dr. Olufunke Osunkoya oosunkoya@doe.k12.ga.us (678) 704-3557

SCHOOL IMPROVEMENT & DISTRICT EFFECTIVENESS 1/1/2019

Presentation Overview Georgia Department of Education Presentation Overview This presentation will explore meeting federal compliance regulations by ensuring: The district/school is correctly implementing federal programmatic and fiscal regulations and guidelines -- Sufficient oversight of financial operations and management Sufficient budget controls are in place The district is following drawdown procedures The district is following procurement procedures Kathy Cox, State Superintendent of Schools

Oversight of Financial Operations and Management Georgia Department of Education Oversight of Financial Operations and Management What rules apply to utilizing federal funds? State and local agencies must demonstrate fiscal control and accounting procedures to ensure the proper disbursement of and accounting for federal funds. Section 76 of EDGAR 2 C.F.R. Part 200 Kathy Cox, State Superintendent of Schools

Required Certification 200.415 (pg 148) NEW: An official authorized to legally bind the non-federal entity must certify on annual and final fiscal reports or vouchers requesting payment: “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.”

Who or What is the New EDGAR? Georgia Department of Education Who or What is the New EDGAR? Education Department General Administrative Regulations (EDGAR) Kathy Cox, State Superintendent of Schools

Key Parts of the NEW EDGAR Title 34 Part 75 – Direct Grant Programs Part 76 – State-Administered Programs Part 77 – Definitions Part 81 – General Education Provisions Act (GEPA) Title 2 Part 200 – Cost/Administrative/Audit Rules Part 3474 – USDE Exceptions – Adopts Part 200 Part 3485 – Nonprocurement Debarment and Suspension Incorporates 2 C.F.R. Part 180, OMB’s Guidelines on Debarment and Suspension 1/1/2019

Prior Rules (Incorporated Into the NEW EDGAR) A-21 – Cost Rules – Rules – IHEs A-87 – Cost Rules – State / Local Gov’t A-122 – Cost Rules – Nonprofit A-102 – Administrative Rules State / Local Gov’t A-110 – Administrative Rules IHEs A-133 – Audit Rules 1/1/2019

Effective Dates December 26, 2014 Direct Grants from ED July 1, 2015 State Administered Programs July 1, 2016 Procurement Rules (One Year Grace Period for IHEs and Nonprofits ONLY) Indirect Cost Rates When Due For Renegotiation 1/1/2019

The Major Changes in Federal Grants Management Focus on Outcomes Performance Metrics Risk Assessments Financial Management Policies Equipment Use Micro Purchases Corrective Action Family Friendly Policies False Claims Certifications Audit Thresholds 1/1/2019

The Major Changes in Federal Grants Management Part 200 has a MAJOR emphasis on strengthening accountability by improving policies that protect against waste, fraud and abuse 1/1/2019

Financial Management Rules 200.302(b) Prior Rule 80.20(b) 2 CFR 200.302 (b) Financial Reporting Accounting Records Internal Control Budget Control Allowable Cost Source Documentation Cash Management Identification of Awards (NEW) Financial Reporting Accounting Records (Source Docs) Internal Control Budget Control Written Cash Management Procedures (NEW) Written Allowability Procedures (NEW) 1/1/2019

Financial Management Requirements Georgia Department of Education Financial Management Requirements EDGAR Section 76 Eligibility to receive subgrants Distribution of funds by formula or competitive Private faith-based organizations eligible to receive funds State consolidated grant application to GaDOE and US ED Assurance statements Ability for the SEA and LEA to reallocate funds based on specific federal program Kathy Cox, State Superintendent of Schools

Financial Management Requirements Georgia Department of Education Financial Management Requirements EDGAR Section 76 Eligibility to receive subgrants Distribution of funds by formula or competitive Private faith-based organizations eligible to receive funds State consolidated grant application to GaDOE and US ED Assurance statements Ability for the SEA and LEA to reallocate funds based on specific federal program Kathy Cox, State Superintendent of Schools

Financial Management Requirements Georgia Department of Education Financial Management Requirements 2 C.F.R. Part 200 Formerly EDGAR Section 80 Specific regulations governing three threshold systems: Financial Management Procurement Inventory Kathy Cox, State Superintendent of Schools

Financial Management Requirements Georgia Department of Education Financial Management Requirements Definition: Controlling and accounting for federal funds and assets Used to make informed programmatic decisions Used to substantiate and document expenditures Kathy Cox, State Superintendent of Schools

Financial Management Requirements Georgia Department of Education Financial Management Requirements All grantees and subgrantees must implement the requirements and maintain systems that meet specific requirements of EDGAR Kathy Cox, State Superintendent of Schools

Financial Management Standards Seven standards described in 2 C.F.R. Part 200 Financial Reporting Accounting Records Internal Control Budget Control Allowable Cost Source Documentation Cash Management

Budget Controls Pre-award planning process and technical assistance - developing and approving budgets Communication between fiscal and program staff at the SEA and LEA levels Routine reconciliation to actual expenditures at the SEA and LEA levels

5) Budget Control 200.302(5) (pg 119) Same as current rule 80.20(b)(4) Comparison of expenditures with budget amounts for each award

Allowable Cost Controls Program Regulations Formal procedures or statue relating to costs Guidelines for determining allowable costs 2 C.F.R. 200, Uniform Guidance (Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards, EDGAR) Effective July 1, 2015 for state administered grants. Access to helpful resources and program guidance

7) Written Allowability Procedures 200.302(b)(7) (pg 119) NEW: Written procedures for determining allowability of costs in accordance with Subpart E – Cost Principles Procedures can not simply restate the Uniform Guidance Subpart E Should explain the process used throughout the grant development and budget process Training tool and guide for employees

Factors Affecting Allowability of Costs 200.403 (pg 143) All Costs Must Be: Necessary, Reasonable and Allocable Conform with federal law & grant terms Consistent with state and local policies Consistently treated In accordance with GAAP Not included as match Net of applicable credits (moved to 200.406) Adequately documented

Reasonable 200.404 (pg 143) Consideration must be given to: Whether cost is a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award; The restraints or requirements imposed such as: Arms length bargaining (hint: procurement processes); Federal, state and local laws; and Terms of the grant award.

Reasonable 200.404 (pg 143) Consideration (continued) Market Prices for comparable goods or services in the geographical area; Whether the individuals acted with prudence under the circumstances considering their responsibilities; and No significant deviation from established prices. 1/1/2019

Reasonable 200.404 (pg 143) Practical Questions Do I really need this? Is the expense targeted to valid programmatic/ administrative need? Is this the minimum amount I need to spend to meet my need? Do I have the capacity to use what I am purchasing? Did I pay a fair rate? If I were asked to defend this purchase, would I be able to?

Allocable 200.405 (pg 143) A cost is allocable to a federal award or cost objective if the goods or services involved are chargeable or assignable in accordance with relative benefits received. Incurred specifically for the award; Benefits both award and other work and can be distributed in proportions that may be approximated using reasonable methods; and Necessary to the overall operation of the entity and assignable to the award in accordance with this Part.

Allocable 200.405 (pg 143) Can only charge in proportion to the value received by the program Example: Agency purchases a computer to use 50-percent on the federal grant program and 50-percent on a state program – can only charge half the cost to the grant. 1/1/2019

Factors Affecting Allowability of Costs 200.403 (pg 119) Be consistent with policies and procedures that apply uniformly to both federally- financed and other activities of the non-Federal entity. Be accorded consistent treatment Can not charge cost as both direct and indirect Be determined in accordance with GAAP Not be included as a cost or used to meet cost sharing or matching

Factors Affecting Allowability of Costs 200.403(g) (pg 143) Adequately documented Amount of funds under grant How the funds are used Total cost of the project Share of costs provided by other sources Records that show compliance and performance Other records to facilitate an effective audit (see 76.730 page 68)

There are 55 specific items of cost! Selected Items of Cost There are 55 specific items of cost! Listed on page 94. Starts at 200.420 (pg 150) 1/1/2019

Selected Items of Cost Examples Advertising/PR 200.421 (pg 150) Allowable for programmatic purposes including: Recruitment Procurement of goods Disposal of materials Program outreach Public relations (in limited circumstances)

Selected Items of Cost Examples Alcohol 200.423 (pg 151) Not allowable Collections of Improper Payments 200.428 (pg 152) The costs incurred by the non-federal entity to recover improper payments are allowable as either direct or indirect costs, as appropriate.

Collection of Unallowable Costs 200.410 (pg 145) NEW: Payments made for costs determined to be unallowable by either the Federal awarding agency or pass- through must be refunded (including interest) to the Federal government in accordance with instructions from the Federal agency that determined the costs are unallowable.

Selected Items of Cost Examples Conferences 200.432 (pg 158) Prior Rule: Generally allowable Includes Meals / Conferences / Travel and Family Friendly Policies Allowable conference costs include rental of facilities, costs of meals and refreshments, transportation, unless restricted by the federal award NEW: Costs related to identifying, but not providing, locally available dependent-care resources Conference hosts must exercise discretion in ensuring costs are appropriate, necessary and managed in manner than minimizes costs to federal award

Selected Items of Cost Travel Costs 200.474 (Changed) (pg 176) Travel costs may be charged on actual, per diem, or mileage basis NEW: Travel charges must be consistent with entity’s written travel reimbursement policies NEW: Allows costs for “above and beyond regular dependent care” Grantee must retain documentation that participation of individual in conference is necessary for the project NEW: Travel costs must be reasonable and consistent with written travel policy / or follow GSA 48 CFR 31.205-46(a)

Drawdown Procedures Grantee’s “drawdown” policies and processes must comply with(2 C.F.R. Part 200) Request funds only for immediate needs Minimize time between requests and expenditures Draws should be commensurate with project completion or accomplishments

Drawdown Procedures Are LEAs reimbursed or paid in advance? 2 C.F.R. Part 200 allows states to implement a payment system of reimbursing LEAs monthly, quarterly or, in some cases, semi-annually. This is a state choice and not mandated by ED 2 C.F.R. Part 200 also allows LEAs to be paid in advance, based on estimated need, if they follow procedures that minimize the time between the transfer of the funds and disbursement by the LEA

Drawdown Procedures To minimize risk of a financial finding based on 2 C.F.R. Part 200 Accounting department of school district closes the books each month (this is to ensure that the expenditures are recorded in the right month and to the right fund source) Once books are closed the district runs a report to determine the funds expended for the month from fund source 402 (this fund source includes Title I, Part A)

Drawdown Procedures To minimize risk of a financial finding based on 2 C.F. R. Part 200 continued A drawdown request is then made that equals the expenditure printout (For example, the school district would draw for January in February) A copy of the expenditure report and the corresponding DE147 is kept on file to justify funds drawn

Drawdown Procedures What are excess cash balances? Excess cash balances are funds maintained at the District level in excess of immediate (usually 3 days) needs. Excess cash balances must be promptly, at least quarterly, withdrawn from account and returned to the Georgia Department of Education.

Drawdown Procedures What if the LEA earns interest on federal funds that have been drawn down? Subject to 2 C.F.R. Part 200, a district may keep up to $100/year of interest earned on excess federal fund advances to cover administrative costs. All other amounts must be returned to the Georgia Department of Education (Department). If an LEA draws down more than 10-percent of its total allocation at one time a written explanation must be provided to the Department.

Procurement Procedures General procurement procedures are found in EDGAR and C.F.R. Part 200 and some are found in the individual federal program statute. Follow state’s procurement procedures State Board Policy 8200 Purchasing Policies and Procedures Manual

Procurement Procedures Consider purchases based on the following considerations: Allowable by the specific program and will be used during the grant period Reasonable Necessary for the administration and/or implementation of the grant Be authorized or not prohibited under state or local laws or regulations Be adequately documented (requisition, PO, invoice and proof of payment)

Procurement Procedures Review all proposed purchases to avoid unnecessary or duplicative items Surplus property Structure procurement to obtain most economical purchase Intergovernmental agreement for common goods or services Lease vs. purchase Conduct all transactions with full and open competition – be cognizant of conflict of interest

Procurement Procedures Contracted Services Contract should include clearly defined deliverables and terms Description of services to be performed or goods to be delivered Description of dates when services will be performed or goods delivered Description of locations where services will be performed or goods delivered Description of number of students/teachers/etc. to be served (if applicable)

Procurement Procedures Contracted Services Remedies for breach of contract-sanctions and penalties Termination procedures Compliance with federal statues –2 C.F.R. Part 200 Reporting procedures (if applicable) Requirements pertaining to copyrights

Procurement Procedures Contracted Services Must have written invoice from the individual or company contracted Description of services performed or goods delivered Description of dates services were performed or goods delivered Description of location services were performed or goods delivered Description of students/teachers/etc. served (if applicable)

Procurement Procedures Contracted Services Invoice should be reviewed & approved before payment Segregation of duties/expenditures Documented approvals

Procurement Procedures Contracted Services Important to Note: In recent monitoring findings districts were cited for paying for administration fees when contracting with companies that provide personnel, for example Kelly Services, 2 C.F.R. Part 200, Uniform Guidance (Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards)

Conflict of Interest 200.318(c)(2) (pg 130) NEW: If the non-federal entity has a parent, affiliate, or subsidiary organization that is not a state or local government the entity must also maintain written standards of conduct covering organization conflicts of interest BRUSTEIN & MANASEVIT, PLLC

Conflict of Interest 200.112 (pg 112) The federal awarding agency must establish conflict of interest policies for federal awards. NEW: All non federal entities must establish conflict of interest policies, and disclose in writing any potential conflict to federal awarding agency in accordance with applicable Federal awarding agency policy. BRUSTEIN & MANASEVIT, PLLC

Mandatory Disclosures 200.113 (pg 113) NEW: Must disclose in writing, in a timely manner: All violations of federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the Federal award. Failure to make disclosures can result in remedies in 200.338 (remedies for noncompliance) including suspension and debarment.

Methods of Procurement 200.320 (pg 131) Method of procurement: NEW: Micro-purchase Small purchase procedures Competitive sealed bids Competitive proposals Noncompetitive proposals BRUSTEIN & MANASEVIT, PLLC

Micro-Purchase 300.320(a) (pg 131) NEW: Acquisition of supplies and services under $3,000 or less. $2,000 for construction subject to the Davis-Bacon Act May be awarded without soliciting competitive quotations if nonfederal entity considers the cost reasonable. To the extent practicable must distribute micro-purchases equitably among qualified suppliers. BRUSTEIN & MANASEVIT, PLLC

Small Purchase Procedures 300.320(b) (pg 131) Good or service that costs $150,000 or less (NEW: Simplified Acquisition Threshold was raised under 200.88) Organization may set lower threshold Must obtain price or rate quotes from an adequate number of qualified sources “Relatively simply and informal” BRUSTEIN & MANASEVIT, PLLC

Contract Cost and Price 200.323 (pg 133) NEW: Must perform a cost or price analysis in connection with every procurement action over $150,000, including contract modifications Independent estimate before receiving bids or proposals. Cost analysis generally means evaluating the separate cost elements that make up the total price (including profit) Price analysis generally means evaluating the total price BRUSTEIN & MANASEVIT, PLLC

District/School Programmatic and Fiscal Implementation How do you ensure the federal programs are properly implemented in your schools and system? Title I, Part A—Improving the Academic Achievement of the Disadvantaged Title I, Part C—Education of Migratory Children Title I, Part D—Prevention and Intervention Programs for Children and Youth Who Are Neglected, Delinquent, or At-Risk Title II, Part A—Improving Teacher Quality

District/School Programmatic and Fiscal Implementation How do you ensure the federal programs are properly implemented in your schools and system? Title III, Part A— Language Instruction for LEP and Immigrant Title VI, Part B—Rural Education Achievement Program Title X—Education for Homeless Children and Youth School Improvement Grants under Section 1003(a) and 1003(g) of the Elementary and Secondary Education Act of 1965 (ESEA

6) Written Cash Management Procedures 200.302(6) (pg 119) NEW: Written Procedures to implement the requirements of 200.305

District/School Programmatic and Fiscal Implementation Use the Department Cross-Functional Monitoring document to organize your work Create your own month to month calendar and live by it (See the SEA calendar in Implementing Title I in Georgia Schools.) Setup files at the beginning of each year – may want to have a file for each school

District/School Programmatic and Fiscal Implementation District Level At the beginning of the year after your Title I application/budget is approved by Department: Provide a copy of the Department approved budget to the LEA finance person assigned to Title I Provide guidance on setting up the LEA budget Budget must be setup exactly as approved by Department (Example: FLP funds are budgeted in set-asides)

District/School Programmatic and Fiscal Implementation District Level After the LEA Title I finance person has set-up the budget request a copy of the summary budget and verify that the budget is set-up exactly as approved by the Department

District/School Programmatic and Fiscal Implementation District Level Throughout the Year: Verify the Title I payroll each month from a copy provided by the finance department Ensure the number of personnel paid matches the number of personnel on the school allocation page of the consolidated application Verify expenditures each month from a Title I detailed expenditure report provided by the finance department Correct errors immediately

District/School Programmatic and Fiscal Implementation District Level Throughout the Year: Ensure that all split funded personnel complete a monthly personal activity report (PAR)/time-log if any portion of their salary is federally funded

District/School Programmatic and Fiscal Implementation District Level Throughout the Year: Verify every 3 months that PARs/time-logs are within 10-percent of percentage paid by each program If PARs/time-logs are not within 10-percent of the percentage paid by each program amend budgets to reflect actual time spent

District/School Programmatic and Fiscal Implementation District Level Throughout the Year: Ensure that the LEA provides services to private schools, N&D facilities, and other eligible entities. The LEA never writes a check to private schools, N&D facilities, or other entities The district coordinates with programs, such as 21st Century, allowing them to provide their own services

District/School Programmatic and Fiscal Implementation District Level Throughout the Year: Proper pre-approval of regular purchases Proper pre-approval of credit purchases Proper pre-approval of payments of funds between Title I and other district programs Proper pre-approval for parent supplies Proper pre-approval of professional learning including release time Proper pre-approval of travel expenditures

District/School Programmatic and Fiscal Implementation District Level At the End of the Year Inform school personnel of deadline for submitting purchase orders Work with LEA finance personnel and vendors to ensure that outstanding orders are filled and paid Cancel any orders not filled by a set deadline

District/School Programmatic and Fiscal Implementation School Level Begin School Year with Technical Assistance Provide overview procedures and deadlines for School Title I Requirements Meet with principals Example: Meet with Principals to explain the process they should use to complete the school’s Title I budget, explain allowable expenditures and reasonable and necessary

District/School Programmatic and Fiscal Implementation School Level Begin School Year with Technical Assistance Meet with teachers and parental involvement facilitators Example: Meet with parent facilitators to give instructions for revising the School Parent Compacts

District/School Programmatic and Fiscal Implementation School Level Begin School Year with Technical Assistance Meet with private school officials & N&D personnel Example: Meet with private school officials for the required consultation on providing Title I services to eligible private school students Example: Meet with N&D personnel to discuss Title I services to students

District/School Programmatic and Fiscal Implementation School Level Technical Assistance Conduct one-on-one visits with principals or other school personnel Invite specific school personnel to your office for one- on-one or small group visits Provide written contact with emails, memoranda, handbooks, written policies, checklists, and written handouts

District/School Programmatic and Fiscal Implementation School Level Monitor Implementation Use checklists to verify that schools submit documentation to you by deadlines and complete projects correctly File documentation as you receive it from schools Keep a copy of dated agendas, dated sign-in sheets, minutes, handouts

District/School Programmatic and Fiscal Implementation School Level Monitor Implementation School Visits to Verify Program Implementation Have a specific purpose when you visit a school Go with a written way to document what you see (Example: a checklist) Verify that teachers/paraprofessional are working according to the schedule sent to you Verify that coaches are working according to job description Verify that equipment is used regularly and correctly

District/School Programmatic and Fiscal Implementation School Level Monitor Implementation Verify that the Flexible Learning Program (FLP) program is operating according to the school’s FLP plan (Example: ask to see a copy of a student folder & verify that assessments are filed)

Financial Management Obligation Obligation: transaction that requires payment Valid obligation: transaction giving rise to an obligation within the period of grant availability Records retained for 5 years from date of obligation

Obligation = transaction that requires payment Financial Management Obligation = transaction that requires payment Acquisition of property Date of binding or written commitment – PO or contract Personal services by employee After services are performed Personal services by contractor Date of binding written commitment Travel After travel is taken

Financial Management In some programs, unobligated funds can be “carried over” from first allocation year: Tydings Amendment Does not apply to all grants For Title I allows an additional 12 months to obligate funds Under Tydings, funds are available for 24-27 months 15 months under the grant award Plus 12 additional months under Tydings Restricted to a 15-percent carryover for Title I, Part A and Title II, Part A

Financial Management Liquidation–settle an obligation by paying funds All obligations must be liquidated within 90 days after the end of the obligation period SEA or LEA may impose a shorter deadline on sub grantee (SEA or LEA may be more restrictive on any federal regulation; in those cases the LEA must follow the more restrictive policy to be in compliance)

Remedies for Noncompliance 200.338 (pg 139) NEW: If noncompliance can not be remedied with Specific Conditions, the entity may take one or more of the following actions: Temporarily withhold cash payment pending correction Disallow all of part of the cost Wholly or partly suspend or terminate the Federal award (see 200.339 Termination) Initiate suspension or debarment proceedings under 2 C.F.R. Part 180 Withhold further Federal awards for the project or program Take other remedies that may be legally available.

Inventory Management Inventory items purchased with federal funds are divided into three categories: Real Property (if an allowable program cost) Equipment Supplies Pilferable or Walkable Items

BRUSTEIN & MANASEVIT, PLLC Equipment 200.33 (pg 99) Equipment: tangible, nonexpendible, personal property having a useful life of more than one year and an acquisition cost of $5,000 or more per unit. Grantee may also use its own definition of equipment as long as the definition would at least include all equipment defined above. BRUSTEIN & MANASEVIT, PLLC

BRUSTEIN & MANASEVIT, PLLC Supplies 200.94 (pg 106) All tangible personal property other than equipment NEW: Computing devices are supplies is less than $5,000 NEW: Computing devices 200.20 (pg 97) Machines used to acquire, store, analyze, process, public data and other information electronically Includes accessories for printing, transmitting and receiving or storing electronic information BRUSTEIN & MANASEVIT, PLLC

Inventory Management Equipment Inventory vs. Internal Control EDGAR requires an inventory for equipment Inventory not required for supplies; however, US ED determined that an adequate internal control system must include a process for labeling and locating property purchased with federal funds and this would include pilferable (walkable) items, as well

Internal Controls 200.302(b)(4) (pg 119) Regardless of cost, grantee must maintain effective control and “safeguard all assets and assure that they are used solely for authorized purposes.” BRUSTEIN & MANASEVIT, PLLC

Equipment 200.313(a) and (c)(4) (pg 127) NEW: Conditional title vests with the non-federal entity. NEW: Cannot encumber the property without approval of federal agency or pass-through agency But NEW: When acquiring replacement equipment, may use the equipment to be replaced as a trade-in or sell the property and use the proceeds to offset the cost of the replacement property. BRUSTEIN & MANASEVIT, PLLC

Use of Equipment 200.313(c)(1) and (2) (pg 127) Equipment must be used by the non-federal entity in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award. When no longer needed, may be used in other activities with the following priority: Projects supported by federal awarding agency Project funded by other federal agencies BRUSTEIN & MANASEVIT, PLLC

Use of Equipment 200.313(c)(1) and (2) (pg 127) When used it may be shared (according to the above priorities) provided such use will not interfere with work on the original projects/programs. Exception – Private Schools 76.661 (page 61) 1/1/2019

Inventory Management Equipment Federal Definition of Equipment Tangible property Useful life of more than one year Acquisition cost of $5,000 or more State may use another definition as long as it includes all property described above

Inventory Management Equipment Georgia requires subgrantees to keep track of pilferable (walkable) items, such as iPads, graphing calculators, cell phones, iPods, etc. Georgia does not require that books or consumable items be included on the inventory Supplies are small cost items that are consumed quickly US ED expects subgrantees to track all property purchased with federal funds, in order to prove there has been a benefit to the federal program

Inventory Management Practical help for tracking non-equipment items Small and attractive item list Federal Definition of Equipment Conduct risk assessment to identify items susceptible to loss Implement specific measures to control such items Certain pre-defined assets (technology equipment)

Inventory Management Equipment inventory-updated annually a description of the property a serial number or other identification number the acquisition date and cost of the property the percentage of federal participation in the cost of the property the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property

Equipment Procedures 200.313 (d) (pg 127) Procedures for managing equipment must meet the following requirements: Property records Description, serial number or other ID, source of funding, title, acquisition date and cost, percent of federal participation, location, use and condition, and ultimate disposition date including sale price Physical inventory at least every two years BRUSTEIN & MANASEVIT, PLLC

Equipment Procedures 200.313 (d) (pg 127) Procedures (continued) 3. Control system to prevent loss, damage, theft All incident must be investigated 4. Adequate maintenance procedures 5. If authorized or required to sell property, proper sales procedures to ensure highest possible return. 1/1/2019

Disposition of Equipment 200.313(e) (pg 127) When property is no longer needed in any current or previously federally-funded supported activity, must follow disposition rules: NEW: Non-federal entity must request disposition instructions from the federal awarding agency if required by the terms of the grant. BRUSTEIN & MANASEVIT, PLLC

Disposition of Equipment 200.313(e) (pg 127) Otherwise, may be retained, sold or otherwise disposed as follows: Over $5,000 – pay federal share If equipment is sold: Federal awarding agency may permit non-federal entity to deduct and retain $500 or 10-percent of the proceeds for selling and handling instructions. Under $5,000 – no accountability (still must formally dispose) 1/1/2019

Disposition of Supplies 200.314 (pg 128) If there is a residual inventory of unused supplies exceeding $5,000 in total aggregate value upon termination or completion of the project or program and the supplies are not needed for any other federal award, must compensate the federal government for its share. BRUSTEIN & MANASEVIT, PLLC

Inventory Management Physical inventory Must be performed at least annually Indicate signature of individual(s) Must protect against unauthorized use

Inventory Management When property is no longer needed, must follow disposition rules: Transfer to another federal program Over $5,000 – Keep or sell, but must pay a share based on the percentage of federal US ED participation at initial acquisition Under $5,000 – May keep, sell, or dispose of it with no obligation to US ED

Inventory Management Must have adequate controls in place to account for: Location of equipment - assure that it is used solely for authorized purposes Custody of equipment - maintain effective control and accountability Security of equipment - adequately safeguard all property

Grants Management Test for LEAs A school district is subject to: 2 C.F.R. Part 200, Uniform Guidance (Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards) EDGAR Elementary and Secondary Education Act of 1965 (ESEA) All of the above

Grants Management Test for LEAs The same rules apply for district and state-administered grants since they both come initially from the U.S. Department of Education 2 C..FR. Part 200, Uniform Guidance (Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards) True False

Grants Management Test for LEAs A flight for a conference obligates to the federal grant award: On the date the employee makes his/her travel arrangements On the date the seat assignments are confirmed On the date the travel arrangements are paid in full On the date the traveler takes the flight to their destination

Grants Management Test for LEAs Expenditures for services performed by a contractor are obligated to the federal award: On the date the services are performed On the date that the grantee/subgrantee receives the invoice On the date that the subgrantee signs the contract At any point of the period of availability

Grants Management Test for LEAs LEAs must implement financial management systems that: Routinely reconciles actual expenditures to budgeted amounts Is capable of producing accurate, current and reliable financial reports Includes detailed accounting records that show the source and application of federal funds All of the above

Grants Management Test for LEAs What forms of source documentation should be maintained as records? Receipts for actual travel Copy of contracts for services performed Payroll registries Every piece of paper you can think of

Grants Management Test for LEAs A grantee/subgrantee must obligate all federal funds Within the statute of limitations By the end of the period of availability As soon as possible None of the above

Grants Management Test for LEAs Grantee and subgrantees must remit to US ED any interest earned on cash advances over: $100 $250 No earned interest must be remitted. All interest may be kept by the grantee or subgrantee All interest must be remitted to US ED

Grants Management Test for LEAs All obligations must be liquidated within 90 days after the end of the grant award funding period True False

Grants Management Test for LEAs Pursuant to EDGAR, a physical inventory of all equipment must be taken: Yearly Once every two years Once every six months Whenever you feel like it

Grants Management Test for LEAs If equipment is missing upon inventory review, the grantee or subgrantee must: Simply remove it off the inventory list Buy a new piece of equipment quickly Interview every staff member until one confesses to the theft Investigate

Grants Management Test for LEAs A conflict of interest arises when the following persons have a financial interest in a firm or company that is selected for a contract by the grantee/subgrantee: Me (an employee of the grantee/subgrantee) My son/daughter My husband’s/wife company is selected All of the above

Grants Management Test for LEAs The following situations restrict competitions for contracts paid for with grant funds: Specifying on a specific brand name Requiring unnecessary experience Organizational conflicts of interest B. and C. A. B. and C.

Grants Management Test for LEAs Grantees and subgrantees should retain their records for: 1 year from the date of obligation 3 years from the date of obligation 5 years from the date of obligation 10 years from the date of obligation

Grants Management Test for LEAs Contracts supported with federal funds must be in writing. True False

Grants Management Test for LEAs If a local district’s policy is more restrictive than the federal regulation, an LEA is in compliance as long as it follows the federal regulation True False

Grants Management Test for LEAs For a cost to be allowable to the federal grant award, it must meet the following criteria: Necessary and reasonable Allocable to the federal grant award Allowable under the federal grant regulations All of the above

Grants Management Test for LEAs A cost is reasonable if: It is on sale It does not cause the subgrantee to exceed its line item in the budget It does not exceed the cost that would be incurred by a prudent person under similar circumstances

Grants Management Test for LEAs If there are funds remaining at the end of the project period, they may be used to purchase goods or services to be used in the future True False

Grants Management Test for LEAs Generally, overhead costs such as utilities, space and electricity may be allocated to grants as direct costs if there is some benefit to the federal program. True False

Grants Management Test for LEAs If an employee is paid less than 8-percent with federal funds, the employee does not have to fill out a time and effort log. True False

Grants Management Test for LEAs An administrator that works approximately half time on IDEA administrative activities and half time on Title I, Part A administrative activities is required to keep: A semi-annual certification A monthly PAR Is not required to keep track of his/her time A weekly PAR

Grants Management Test for LEAs Assuming all costs are reasonable which of the following cost incurred during an overnight business trip is not allowable: Dinner (without any alcoholic beverages) Hotel room Mileage costs Ticket to a movie

Questions?

Title I, Part A Program Specialists’ Contact Information Area Name Office Telephone Email 1 Robyn Planchard (404) 985-3808 rplanchard@doe.k12.ga.us 2 Randy Phillips (770) 221-5232 rphillips@doe.k12.ga.us 3 Anthony Threat (706) 615-0367 anthony.threat@doe.k12.ga.us 4 Evelyn Maddox (404) 975-3145 emaddox@doe.k12.ga.us 5 Judy Alger (229) 321-9305 jualger@doe.k12.ga.us 6 Grace McElveen (912) 334-0802 gmcelveen@doe.k12.ga.us 7 Jimmy Everson (229) 723-2664 jeverson@doe.k12.ga.us 1/1/2019

Title I, Part A Program Specialists’ Contact Information Area Name Office Telephone Email 8 Marijo Pitts-Sheffield (912) 269-1216 mpitts@doe.k12.ga.us 9 Kathy Pruett (706) 540-8959 kpruett@doe.k12.ga.us 10 Elaine Dawsey (478) 971-0114 edawsey@doe.k12.ga.us 11 Olufunke Osunkoya (678) 704-3557 oosunkoya@doe.k12.ga.us 12 Bobby Trawick (229) 246-1976 btrawick@doe.k12.ga.us 13 Ken Banter (478) 960-2255 kbanter@doe.k12.ga.us 14 Tammy Wilkes (478) 237-2873 twilkes@doe.k12.ga.us 1/1/2019

Presenters Dr. Judy Alger Georgia Department of Education School Improvement – Federal Programs Title I Education Program Specialist jualger@doe.k12.ga.us (229) 321- 9305 Dr. Olufunke Osunkoya oosunkoya@doe.k12.ga.us (678) 704-3557

Grants Management – Overseeing Title I Compliance: Finances, and District/School Implementation 13th Annual Title Programs Conference June 17-18, 2015 Atlanta, Georgia