1 National Association of Title IIII Administrators Technical Assistance Workshop June 24, 2010

2 STRATEGIES FOR EFFECTIVELY BALANCING YOUR TITLE III BUDGETS AND KEEPING YOUR INSTITUTION COMPLIANT IN THE MIDST OF BUDGET CUTS Presenters: Ms. Mary Anne (Vicki)) Payne, Compliance Officer Morgan State University Mrs. Katrina B. Miller, Title III Director Norfolk State University Ms. Deborah Newkirk, Independent Consultant

3 Today’s Objectives  Balancing your Title III Budget  Allowable and Unallowable Costs associated with LAAs  Supplementing vs. Supplanting  Strategies for staying compliant

4 LEGISLATIVE ALLOWABLE ACTIVITIES (LAA) for HBCU, HBGI and CCRAA GRANTS

5 REFERENCE for LEGISLATIVE ALLOWABLE ACTIVITIES (LAA) HBCU – Higher Education Act (HEA) of 1965 revised Sec. 323 (a); HEOA, Public Law (Aug. 2008) Sec. 309 (12, 13, 14) HBGI – Higher Education Act (HEA) of 1065 – revised Sec. 326 (c); HEOA, Public Law (Aug. 2008), Sec. 311 (b) CCRAA– HEOA, Sec. 302, Title IV, Part J MANDATORY FUNDING (SAFRA) -HEOA

6 UNALLOWABLE ACTIVITIES  Activities inconsistent with a State plan for desegregation  Activities related to sectarian instruction or religious worship  Activities provided by a school of divinity  Cultural Activities for Students

7 UNALLOWABLEand ALLOWABLE COSTS UNALLOWABLE and ALLOWABLE COSTS APPROVED activities DOES NOT mean ALLOWABLE costs

8 PUBLIC RELATION/ ADVETISEMEN T COSTS (Circular A-21 (J 1 a, b,,c,,d,,e,,& f) Allowable  Recruitment of personnel  Procurement of goods and services  Disposal of surplus materials  Costs required by sponsored agreement  Communication costs Unallowable  ALL costs related to advertisement and public relations except costs specified under ALLOWABLE including promoting the institutions  Costs associated with Convocations  Costs of meeting rooms, & other facilities associated with shows and other special events  Costs of promotional items

9 SPECIAL PURPOSE and GENERAL PURPOSE EQUIPMENT (Circular A-21 J 16) ALLOWABLE  Research, medical, scientific, medical, or other technical activities  Laboratory, library, and classroom furniture  Furnishing and equipment for Title III office UNALLOWABLE  General purpose equipment such as; office equipment and furnishings, air conditioning equipment, if not approved in the sponsored agreement

10 DEVELOPMENT OFFICE (Circular A21 J 22) Allowable  Establishing a development office  Physical custody and control of monies Unallowable  Organized fundraising  Financial campaigns  Endowment drives  Solicitation of gifts and bequests  Any expenses incurred solely to raise capital or obtain contributions  Investment counsel and staff whose responsibility is solely to enhance income from investments

11 EXAMPLES of OTHER UNALLOWABLE COSTS identified in CIRCULAR A-21  Alcoholic Beverages- J2  Alumni/a e activities- J3  Bad Debts- J4  Civil defense costs- J5  Commencement costs- J6  Entertainment costs- J15  Fines and penalties- J18  Housing and personal living expenses- J20  Lobbying costs- J24

12 EXAMPLES OF UNALLOWABLE COSTS (continued)  Membership, subscriptions, an d professional activity costs –J28 (d, c)  Student activity costs – J45

13 SUPPLEMENT not SUPPLANT  What is supplementing? To increase funding of existing institutional programs.  What is supplanting? To use grant funds to replace the costs associated with existing institutional programs.

14 EXAMPLES OF………. SUPPLANTING  Replacing salaries paid by other sources with grant funds  Using grant funds for existing programs or activities SUPPLEMENTING  Using grant funds to increase personnel  Use grant funds to enhance or develop new programs

15 EXAMPLES (continued) SUPPLANTING  Using grant funds to replace Institution funds currently being used for furnishing a computer lab  Replace institution funds for travel, faculty training etc with grant funds SUPPLEMENTING  Using grants funds to increase the furnishing for the computer lab  Use grant funds to increase the number of faculty being trained and the amount of travel to professional workshops

16 IN SHORT…….  ANY COSTS PREVIOUSLY PAID BY THE INSTITUTION OR OTHER FUNDING SOURCES SHOULD NOT BE REPLACED WITH GRANT FUNDS

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18 Building and Strengthening the Title III Community through Engagement Principles 1.Communicate a compelling message. 2.Build a guiding coalition. 3.Create principled-based versus compliance-based guidelines for decisions and behaviors. 4.Identify early engagement indicators. 5.Generate continuous opportunities for dialogue at al levels. 6.Plan assimilation strategies for new members and new leaders. Gravenkemper, S. (2007) Building Community in Organizations. Counseling Psychology Journal: Practice and Research.

19 Principle-Based versus Compliance Based Guidelines for Decisions and Behaviors Compliance-Based Guidelines  Enforces Federal Regulations  Enforces State policies and procedures  Increases the “red tape” and decreases effective communication. Principle-Based Guidelines  Promotes dialogue among campus community  Increases engagement/ collaboration  Promotes a sense of community

20 Taking Charge: A Plan for Remaining Compliant  Survey Title III Community (Transparency)  Provide expectations and roles/responsibilities for those working with Title III (Accountability)  Build Trust through staff forums, activity directors information session and Start-Up meetings (Accountability).  Provide opportunities for growth through internal workshops (Accountability).  “Show and tell” budget progress/spending levels (Transparency).  Design new activity director support program (Accountability).

21 Manage Risk Appropriately  Establish and enforce Internal Controls  Develop effective budget management practices  Maintain “healthy” working relationships with the fiscal office and internal auditor  Determine how to profit from uncertainty while limiting your risk

22 Know What You’re Really Going After....Know What You’re Really Going After  Be Visionary  Reveal the “bottom line” for Title III at your institution.  Determine the ultimate goal for Title III at your institituion.  Leverage Title III Resources  Strengthen through entreprenureial iniaitives

23 TITLE III, PART B CONTACTS Dr. James E. Laws, Director Institutional Development and Undergraduate Education Service Ms. Karen Johnson, Team Leader HBCU/HBGI; MSEIP; PBI; CCRA 1990 K St., NW 6 th Floor Washington, DC / IDUES WEBSITE: