2015 VOCA National Training Conference Grant Financial Management

Topics of Discussion  Background  Objectives  Major Changes  Classifying Costs ─ Grant Management ─ Pass-through entities ─ Indirect Cost ─ Audit Requirements

2 CFR Part 200 Uniform Guidance

Background  On December 26, 2013, the Office of Management and Budget (OMB) published the Uniform Guidance (UG).  The UG consolidated (8) eight grant circulars into a single document (2 CFR Part 200).  Combined the Administrative Requirements, Cost Principles, and Audit Requirements.

Objectives  Streamline regulations to ease administrative burdens.  Strengthen oversight of federal awards to reduce the risk of waste, fraud, and abuse.  To achieve these goals, some of the UG policy reform includes: ─ Increase accountability standards for non- federal entities; ─ Provide for consistent and transparent treatment of costs.

Changes  The Uniform Guidance contains more than 60 regulatory changes to federal grants management.  OMB has published technical corrections to the UG to fix discrepancies and those edits did not change policy – (December 19, 2014).

Grant Award Process  Agencies are required to conduct a pre- award risk assessment of all applicants before making an award.  Specific performance goals, indicators, milestones, and/or expected outcomes will be included in the terms and conditions of the award.

Grant Management  Non-federal entities are required to implement adequate internal controls to ensure full compliance with all regulations. ─ Standards for Internal Controls in the Federal Government – ( Green Book). ─ Internal Control – Integrated Framework / (Committee of Sponsored Organizations of the Treadway Commission – COSO).

Grant Management Cycle Clear Expectations Training & Support Accountability (Performance Measures)

Four Basic Types of Costs  Allowable costs  Unallowable costs  Costs not authorized  Costs deemed excessive or unreasonable

Four Basic Types of Costs Allowable Costs - costs that are necessary, reasonable, allocable, not prohibited under State/local laws or regulations. Costs must conform to any limitations set forth in Federal laws, and comply with the terms and conditions of the Federal award.

Four Basic Types of Costs Unallowable Costs - costs not allowed under Federal programs include, but are not limited to lobbying, land acquisition, fund raising, entertainment, contingencies, and alcoholic beverages.

Four Basic Types of Costs Costs not authorized - costs are not authorized when there is no consent from the awarding agency to incur costs, not included in the approved budget, or occurs before or after the grant award period.

Four Basic Types of Costs Costs deemed excessive or unreasonable - when its nature and amount exceeds that which would be incurred by a prudent person when the decision was made.

Indirect Cost Rate  Non-federal entities that have never received a negotiated indirect cost rate (ICR) may elect to charge the de minimis rate of 10% of modified total direct costs (MTDC).  The de minimis rate must be used consistently for all federal awards.

Indirect Cost Rate  Rate may be used indefinitely or until entity elect to negotiate for a rate.  The UG allows non-federal entities to apply for an extension of the ICR for up to four years.

Administrative and Training Funds  A State may set aside up to 5% of the respective grant funds for administrative and training purposes. However, the combination of a grantee’s administrative and training budget may not be more than 5% of the grant award for that fiscal year.

 To deliberately reduce State or local funds because of the existence of Federal funds.  Example: State funds are appropriated for a stated purpose and Federal funds are awarded for that same purpose. The State replaces its State funds with Federal funds, thereby reducing the total amount available for the stated purpose. SUPPLANTING

CRIME VICTIM COMPENSATION STATE CERTIFICATION FORM

GPRS Need Help? OJP - OCFO Customer Service Center Payment of Grant Funds

Grantee accesses GPRS via the web to request funds 810 GPRS checks against certain parameters and either approves or denies request Funds are deposited into the Grantee’s bank account, usually within 72 hours Approved requests are forwarded to the U.S. Department of Treasury for payment processing Payment of Grant Funds

 In support of the continuing effort to meet the accelerated financial statement reporting requirements mandated by the U.S. Department of Treasury, OJP strongly suggest that grantees make payment request before the last five (5) days of each month.

Minimum Cash on Hand  Grant recipient should request funds based upon immediate disbursement requirements. Funds will not be paid in lump sum, but rather disbursed over time as project costs are incurred or anticipated. Recipients should time their drawdown requests to ensure that Federal cash on hand is the minimum needed for disbursement to be made immediately or within 10 days.

 A-133 Gov't, Education and Non-Profit.  Thresholds $750K or more expended during the FY - Single Audit required.  Audit Report - due nine (9) months after end of FY.  Submit online to Federal Audit Clearinghouse (FAC).  Questioned costs greater than $25,000 must be included in the Single Audit report. AUDIT REQUIREMENTS

1. Procedures not documented or need improvement – Internal Controls. 2. Procedures not documented or need improvement – Accounting 3. Special conditions not met by grantee – unsupported/unauthorized expenditures 4. Accounting system inadequate or not effectively utilized to account for grant funds. 5. Procedures not documented or need improvement – Payroll. TOP TEN AUDIT FINDINGS (FY-2014)

6. Quarterly Financial and Annual Program reports not submitted timely. 7. Procedures not documented or need improvement - Inventory. 8. Quarterly Financial and Annual Program reports not accurately prepared. 9. Suspension and debarment – verification not performed or not properly documented. 10. Subrecipient monitoring not being conducted. TOP TEN AUDIT FINDINGS (FY-2014)

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