Grants Management Close Out Requirements School Improvement Grant 2014 Office of General Counsel and the Office of School Transformation 1

Regulations: What is EDGAR? Office of General Counsel and the Office of School Transformation 2 Education regulations are in Title 34 of the Code of Federal Regulations (a.k.a. 34 CFR) US Department of Education put its general administrative requirements (34 CFR Parts and 97-99) together into the “Education Department General Administrative Regulations” or EDGAR LEAs follow 34 CFR Part 80.

Get Ready for Closeout Office of General Counsel and the Office of School Transformation 3 Prepare to close all activities, contracts with vendors, etc. Process final payments. Retain proper documentation.

My Project is ending. Now What? Office of General Counsel and the Office of School Transformation 4 §80.42, § Closeout Reconcile all activities Process remaining expenditures. Prepare any budget amendments. Ensure proper documentation is retained.

My Project is ending. Now What? Office of General Counsel and the Office of School Transformation 5 §80.42, § Closeout, cont’d Prepare financial closeout reports. Prepare final Grant Activity Report and any Grant Activity Reports that have not been previously submitted. De-obligate funds with the SCDE. Prepare final expenditure claims request.

My Project is ending. Now What? Office of General Counsel and the Office of School Transformation 6 §80.42, § Closeout, cont’d Account for all real and personal property. Re-pay any funds as a result of an audit. Complete record retention and ensure availability for a minimum of 5 years. Prepare disposition of property if program is not continuing by completing and submitting a disposition letter and a tangible personal property report for property with a value of $5,000 or greater.

My Project is ending. Now What? Office of General Counsel and the Office of School Transformation 7 §80.32 Disposition of Equipment When equipment acquired under a grant or subgrant is no longer needed for the original project/program, it may be used for other activities currently or previously supported by a Federal agency. If equipment is being transferred to another federally funded program/project, then inventory will need to be tracked across programs/projects.

My Project is ending. Now What? Office of General Counsel and the Office of School Transformation 8 §80.32 Disposition of Equipment, cont’d If there is no other federally funded program/project to transfer the equipment and the current per unit fair market value is less than $5,000, then the equipment may be retained, sold or otherwise disposed of but if the current per unit fair market value is in excess of $5,000, then the equipment may be retained or sold and the awarding agency shall have a right to an amount calculated by multiplying the current market value or proceeds from sale by the awarding agency’s share of the equipment.

My Project is ending. Now What? Office of General Counsel and the Office of School Transformation 9 §80.33 Disposition of Supplies Title to supplies acquired under a grant or subgrant will vest, upon acquisition, in the grantee or subgrantee respectively. If there is residual inventory of unused supplies exceeding $5,000 in total aggregate fair market value upon termination or completion of the award, and if the supplies are not needed for any other federally sponsored programs or projects, the grantee or subgrantee shall compensate the awarding agency for its share.

Important Dates The due date for reimbursement claims to be submitted for expenditures made on or before June 30, 2014 is August 15, The due date for budget amendments pertaining to expenses incurred from July 1, 2014 until September 30, 2014 is September 5, Amendments must include only costs that are directly related to the grant activities for the program year. The due date for reimbursement claims to be submitted for expenditures made between July 1, 2014 and September 30, 2014 is November 15, All deadlines will be strictly enforced. All funds must be encumbered by September 30, Office of General Counsel and the Office of School Transformation 10

Recommended Grant File Maintain an official grant file that contains the following: 1. original application and any other comments; 2. required forms; 3. grant award notification(s) (GAN); 4. annual grant performance reports; Office of General Counsel and the Office of School Transformation 11

Recommended Grant File 5. all financial reports; 6. all budgets and budget modifications; 7. annual audit report including the management letter; 8. Official related correspondence; 9. Official decisions; and 10. any other documentation relevant to the grant throughout its life cycle. Office of General Counsel and the Office of School Transformation 12

Recommended Grant File File includes documents submitted, processed, and maintained on paper or electronically. Follow the best practices used for filing to allow for easy retrieval of both systems. Office of General Counsel and the Office of School Transformation 13

Recommended Grant File Establish a secure area in the respective office to store the official grant files. Routinely review the official files and reinforce proper controls and procedures with program staff as inconsistencies are noted. Office of General Counsel and the Office of School Transformation 14

Recommended Grant File Make appropriate distinctions between personal notes and official records. Notes should not be included in the official grant file Personal notes by staff and officials that are used for their personal recollection are not shared with other personnel or funding agency personnel. Office of General Counsel and the Office of School Transformation 15

Resources 34 CFR 80 idx?c=ecfr&SID=4c0e552692e19eabca0c1e104d88 a555&tpl=/ecfrbrowse/Title34/34cfr80_main_02.tplhttp:// idx?c=ecfr&SID=4c0e552692e19eabca0c1e104d88 a555&tpl=/ecfrbrowse/Title34/34cfr80_main_02.tpl OMB Circulars A / 04/ Guidelines for Retaining Documentation to Support Expenditures Claims – Aug 30, 2012 letter (Melissa A. Austin, Audit Manager) etainingDocToSupportExpenditureClaims.pdf etainingDocToSupportExpenditureClaims.pdf Office of General Counsel and the Office of School Transformation 16