Application Amendments and Budget Transfers (Part 2) Virginia Department of Education Office of Program Administration and Accountability Title I University, February 12, 2015 Chris McLaughlin

Learning Outcomes for Today’s Session Application Amendments and Budget Transfers (Part 2) The participant will be able to: State the purpose of application amendments Monitor grant spend down of funds Adjust program implementation to accommodate critical fiscal deadlines

Review… Amendments and Budget Transfers, Part 1 (November 13)

Amendments are Required! § Fiscal control and fund accounting procedures. A State and a subgrantee shall use fiscal control and fund accounting procedures that insure proper disbursement of and accounting for Federal funds. § A State shall have procedures to ensure compliance. Each State shall have procedures for reviewing and approving applications for subgrants and amendments to those applications, for providing technical assistance, for evaluating projects, and for performing other administrative responsibilities the State has determined are necessary to ensure compliance with applicable statutes and regulations. Education Department General Administrative Regulations (EDGAR), Title 34

Life-Cycle of Grant = 27 Months Title I, Part A Grant Life Cycle July 1 Application Due 85% Obligated Prior to September 30 (15 months) 100% (27 months )

Grant Award Timeline Year of Grant Award Total Grant Award Period Deadline to Obligate 85% of Award Deadline to Obligate 100% of Award Deadline to Request Reimbursement for ALL funds FFY 2014 ( ) July 1, 2014 – Sept. 30, 2016 Sept. 30, 2015Sept. 30, 2016Nov. 15, 2016 FFY 2013 ( ) July 1, 2013 – Sept. 30, 2015 Sept. 30, 2014Sept. 30, 2015Nov. 15, 2015

Probable Scenario… July 1 Due Date Award Figures Released (Amendment 1) Programmatic Change (Amendment 2) Federal Award Adjustment (Amendment 3) 85% Spend Down Plan (Amendment 4) Budget Adjustment (Amendment 5) Carryover Funds Zero Balance (Amendment 6) 27 Month Process

Clear & Concise Communication

Missed Opportunity to Communicate (Omega Comment Area) What statements could have been made to document and summarize the grant activity?

Summary Provided (OMEGA Comment Area)

Amendment Process

Application: Amendments

Summary Provided (Application Cover Page)

Application: Amendments You may want to note changes within the detailed budget description. This process is optional, but the grantee and VDOE reviewer may find it beneficial. Original Amendment

Application: Amendments Please do not do the following: 1.List a string of codes indicating several line items without providing a description of changes. This typically takes the writer a great deal of effort and is often difficult for the reviewer to understand.

Application: Amendments Please do not do the following: 2.Reference prior communication, either verbal or written, with the Title I specialist without providing a description of changes. The information within the grant amendment needs to be clear and stand alone. Based on the example below, the reviewer(s) cannot identify the modifications to the grant that are being made.

Title I, Part A Grant Amendments Amendments are necessary when: Allocations are announced via VDOE Superintendent’s Memos The division needs to make programmatic changes The division needs to change the projected budget; including moving funds between object codes Amendments should include: Amendment number and description of changes on cover page of application Modifications to application such as: Program narrative Detailed budget description Object code budget Budget summary

Life-Cycle of Grant = 27 Months Title I, Part A Grant Life Cycle July 1 Application Due 85% Obligated Prior to September 30 (15 months) 100% (27 months )

The “Obligation Clock” is Ticking!

What does “Obligate” mean? IF AN OBLIGATION IS FOR --THE OBLIGATION IS MADE -- (a) Acquisition of real or personal property. On the date on which the state or subgrantee makes a binding written commitment to acquire the property. (b) Personal services by an employee of the State or subgrantee. When the services are performed. (c) Personal services by a contractor who is not an employee of the State or subgrantee. On the date on which the state or subgrantee makes a binding written commitment to obtain the services. (d) Performance of work other than personal services. On the date on which the state or subgrantee makes a binding written commitment to obtain the work.

What does “Obligate” mean? IF AN OBLIGATION IS FOR --THE OBLIGATION IS MADE -- (e) Public utility services.When the state or subgrantee receives the services. (f) Travel.When the travel is taken. (g) Rental of real or personal property.When the state or subgrantee uses the property. (h) A pre-agreement cost that was properly approved by the State under the applicable cost principles. On the first day of the subgrant period. _procedures/definition_of_obligation.pdf

Will you beat the clock? Obligate 85% prior to September 30 Review expenditures Review obligations OMEGA balance verification

Obligate 85% prior to September 30 Reminder… Staff salaries may not be considered obligated beyond September 30 each fiscal year when determining percent obligated

SEC CARRYOVER AND WAIVER. (a) LIMITATION ON CARRYOVER- Notwithstanding section 421(b) of the General Education Provisions Act or any other provision of law, not more than 15 percent of the funds allocated to a local educational agency for any fiscal year under this subpart (but not including funds received through any reallocation under this subpart) may remain available for obligation by such agency for one additional fiscal year. (b) WAIVER- A State educational agency may, once every 3 years, waive the percentage limitation in subsection (a) if — (1) the agency determines that the request of a local educational agency is reasonable and necessary; or (2) supplemental appropriations for this subpart become available. (c) EXCLUSION- The percentage limitation under subsection (a) shall not apply to any local educational agency that receives less than $50,000 under this subpart for any fiscal year.

Reallocation Process School divisions that do not obligate 85% are subject to reallocation Reallocation procedures are provided in Superintendent’s Memo # Superintendent’s Memo #100-14

Amendments and Budget Transfers To meet obligation requirements, grant managers are expected to: –submit amendments and correlating budget transfers. –communicate with key stakeholders in the school division to plan adjustments. –monitor OMEGA balances on a monthly basis. Critical deadlines may require frequent monitoring of the spend down balance

VDOE Contact Information: Title I, Part A Lynn Sodat, Ph.D., Title I Coordinator Lynn. Phone: (804) Gabie Frazier, Title I Specialist Phone: (804) Chris McLaughlin, Title I Specialist Phone: (804)

Questions?