Title III B, Historically Black Colleges and Universities (HBCU) and Historically Black Graduate Institutions (HBGI) Programs Project Directors’ Meeting Washington, DC April 19, 2011

Agenda 1:00-2:00 PM Introductions Dr. James E. Laws APR Trend Data Analysis Dr. Brandon Daniels 2:00-2:30 PM Grant Administration Staff Internal Controls Carryover Prior Approvals Travel Other Issues 2:30-2:40 PM Phase I/Phase II Requirements Nalini Lamba-Nieves 2:40-2:50 PM Q&A Staff

Internal Controls Policies and Procedures Manual Clearly delineate grant’s purpose, lines of authority and communication, federal and institutional processes and policies. All staff must be familiarized with the manual; it should be provided to new staff and updated regularly with any changes to the grant or to institutional processes. Suggested content of manual: Copy of the grant Objectives of grant project Title III, Part B legislation and regulations Organizational chart Job descriptions Staff performance agreement form Personnel policies and procedures Standard Operating Procedures for managing and administering your Title III grant project. Forms for internal reports Format for annual report to ED Fiscal and accounting procedures and forms Contractor/Consultant policies and procedures Evaluation plan and timeline Completed reports when available After several site visits where we saw similar issues, we have come up with this list of common problems and how to solve them. Problem: Title III staff not properly trained, reporting and lines of authorization unclear, disorganized records. Solution: The Policies and Procedures Manual. This manual should contain A policies and procedures manual.

Internal Controls (continued) Financial records—All Title III, B offices should have clear fiscal records for each Title III, Part B grant—funds available, funds used, tracking purchases, personnel (time and effort should include list of tasks to match the effort), etc. View-only access from G-5—To be able to track if the business office is drawing down funds in a timely manner. [EDGAR 74.29] All communications between the Department and the institution should be routed though the Project Director (PD). The PD is the one ultimately accountable for the management of the grant. S/he should be aware of all that is happening with the grant. There should be regular communication between the PD and the ED Program Officer. Changes in mailing addresses, presidents, emails, phones, etc. should be reported to the Department. This ensures a timely and accurate flow of information. Last but not least, you and your staff should be well acquainted with the statute, the regulations, EDGAR and the OMB Circulars, in that order. You can access all these documents from our webpage: http://www2.ed.gov/programs/iduestitle3b/index.html, under Laws, Regs & Guidance.

Carryover While Program Officers monitor your grants and may be aware of any and all grant issues, there are other offices in the Department who also monitor grants, specifically your grant funds. Large balances (as well as large draw downs) will trigger others in the Department to take a closer look at your grant funds and flag you. Program Officers are then required to request financial information as to why you have such a large balance or made a large drawdown and send it to the fiscal monitors. Carryover should not be the rule in your grants; it should be the exception. If you have such large carryover, are activities in your grant being completed? If not, why not? As mentioned before, having clear and complete financial records is key. If you have been spending your money but the business office is not drawing it down, you need to be aware of this to rectify the situation. This is why we recommend obtaining view-only access to G-5. Carryover money is part of the grant. Please make sure your requests to use these funds are allowable, justifiable and reasonable. There are no extra points for creative use of federal funds.

Prior Approvals Prior approval requests are often necessary to make changes to activities. It may be that you need to tweak activities that are not going as expected, or new opportunities to improve an activity have arisen, among other things. When making prior approval requests, please ensure that you include the following: Grant award number (example: PR031B07 _ _ _ _). A well written request that includes specific details as to who, what, why, where and when, as applicable. How is this request related to the scope and objectives of the grant? If it involves moving monies, where are the funds coming from? Carryover? Savings? Activities not completed? If you are moving funds from line items, how will this impact your original line item? Federal funds need to be tied to activities/objectives. If you enhance an activity or create a new activity (within the scope of the grant), you need to modify or write new objectives, respectively.

Travel Travel is an allowable activity. However, as with anything in your grant, it must be tied to your objectives. For example, if your objective is to increase retention and one of your strategies is sending faculty to education conferences so they can update their skills/better engage students, etc., that is a direct correlation--therefore allowable. However, travel because you have large carryover and want to spend it or travel that is not directly tied to your grant, is not allowable. International travel is allowable on a case-by-case basis. SAFRA allows it, but again, it must be directly linked to the grant. [In the request, include as much information as possible.] For HBCUs ONLY: Student travel is generally not allowed. Remember that the purpose of the grant is to strengthen the institution. Think long-term. Travel for faculty that can come back and share experiences, modify curriculum, etc., is an investment in the institution. Student travel, while it may be equally valuable, should be a cost the institution bears.

Other Issues Workload: While it would be wonderful to be assigned to a handful of institutions, we work with grants by states and across programs (HBCU/HBGI/PBI/MSEIP/HBCU Masters). Additionally, we have internal office responsibilities—not only with our programs, but with other programs as well. Response time: Per EDGAR 75.25(m), Program Officers (PO) have 30 days to respond to requests. We generally do not take that long, but you should be aware of this so you can submit travel requests, etc. as early as possible. Your Program Officer works for the federal government and is here to help: There may be things that you have either done in the past or have been doing for years that your Program Officer suddenly tells you are unallowable. Please know that we are trying to save you unpleasantness with the Inspector General (IG), Government Accountability Office (GAO) or your own auditors. It may be in your application or it may have been approved in the past. But, if we allow you to continue, when your records are reviewed it is the institution that will be required to return the funds. Ultimately the institution is responsible for all federal funds. We will work with you to find allowable alternatives. This is an institutional grant, not “the president’s grant”: Some of you may not be able to do much about this, but please make it clear to your administration that it is the institution that is ultimately responsible for the funds.

Phase I & Phase II No dates have been specified for the collection of Phase I data for either HBCUs or HBGIs. The application booklet for both programs expired and is currently being reviewed by OMB for renewal. Until this happens, we cannot collect your data, as both forms are in the booklet. But, you can gather the data now and be ready. Submission of Phase I and Phase II data must be electronic. Phase I should be submitted by email as a PDF if you do not have electronic signature, or Word if you do. Phase II will be submitted via Grants.gov. This is now mandatory for all ED programs. You need to register to use the site and this could take up to 2 weeks. We recommend you go in now and register: www.grants.gov. If you are registered, go in and make sure the people who need to push the submit button for your grant are still at the institution and will be available to submit ON TIME! Follow the instructions on the application booklet. Grants.gov is a government-wide system and will have references to things that DO NOT apply to our programs (Closing Date Notice, page limits, submitting by 4:30:00 pm, etc.).

Title III Part B Web Site Title III, Part B Program Office Contact Information Title III Part B Web Site http://www2.ed.gov/programs/iduestitle3b/index.html Title III, Part B Program Office Karen W. Johnson (202) 502-7642 Team Leader (Acting) Yolande Badarou (202) 219-7118 Meghan Benson (202) 219-7032 Jonathan Braxton (202) 502-7645 Bradley Haas (202) 502-7636 Nalini Lamba-Nieves (202) 502-7562 HBGI Lead Bernadette Miles (202) 502-7616 PBI Lead Dianne Pitts (202) 502-7587 Sara Qadir (202) 502-7608 HBCU Masters Lead Bernadette Hence (202) 219-7038 MSEIP Lead Matthew Willis (202) 502-7598