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Grants Management I: Compliance & Performance Case Study-PERK: Preparing Educators for Rural Kansas *Federal TQP grant Linda Alexander, Ph.D. Jasmine Markanday, MBA
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AGENDA Welcome and Introductions Compliance in Grant Management Project Performance in Grant Management Questions
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About the Presenters LINDA ALEXANDER, PH.D. *Ph.D. in Teaching and Leadership (2003) from the University of Kansas *Professor in the Teacher Education Department *Project Director for PERK and STELLAR *Strengths: Academic content Literature review Project Management JASMINE MARKANDAY, MBA *BS in Business Administration with Computer Information Systems from Emporia State University (2008) *MBA from MidAmerica Nazarene University (2012) *Grants Accountant in the Business Office *Strengths: Indirect Cost Rate Fiscal Grants Management and Reporting Fiscal Policies and Procedures
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Definitions *Award means financial assistance that provides support or stimulation to accomplish a public purpose. Awards include grants and other agreements in the form of money or property in lieu of money, by the Federal Government to an eligible recipient *A “sponsored program” is any grant, cooperative agreement, or contract between the federal or state government or another sponsoring agency, and the organization *Grants Team includes all grant personnel who will be part of the grant until close out
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Definitions *Pre-Award is the period before an award is submitted and received by the organization. This includes all proposal development activities *Post-Award is the period after an award is received and accepted by the organization. This includes the financial and programmatic management of the grant *Closeout means the process by which a Federal awarding agency determines that all applicable administrative actions and all required work of the award have been completed by the recipient and Federal awarding agency
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Federal Regulations Office of Management and Budget (OMB) *OMB Circular A-21 - Cost Principles *OMB Circular A-110 – Uniform Administrative requirements *OMB Circular A-133 - Internal control and audit standards for states, local governments and non-profit organizations *Links to all three circulars are available at: http://www.whitehouse.gov/omb/circulars_default http://www.whitehouse.gov/omb/circulars_default
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Federal Regulations Office of Management and Budget (OMB) *OMB Circular A-102 *OMB Circular A-87 *OMB Circular A-122 *Links to all three circulars are available at: http://www.whitehouse.gov/omb/circulars_default http://www.whitehouse.gov/omb/circulars_default *The Super Circular https://www.federalregister.gov/articles/2013/12/26/2013-30465/uniform- administrative-requirements-cost-principles-and-audit-requirements-for- federal-awards https://www.federalregister.gov/articles/2013/12/26/2013-30465/uniform- administrative-requirements-cost-principles-and-audit-requirements-for- federal-awards
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MNU’S Grants Life Cycle 1. Identify Funding 2. Prepare and Submit Proposals 3. Review Notice of Award 4. Review Grant Agreement 5. Attend Development Team Meeting 6. Set Up Award 7. Implement and Manage Award 8. Determine Sustainable Activities 9. Close Out Award MNU Grants Life Cycle MNU Grants Life Cycle = Pre Award = Post Award Post Award Pre Award
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Review Notice of Grant Award * Funder notifies the Project Director/Project Investigator (PI/PD) and/or the University President’s Office * The Notice of Grant Award NGA is the official document used for grants/cooperative agreements Establishes legally binding arrangement between the federal agency and recipient Establishes Period of Performance Contains or references Terms and Conditions of the grant or cooperative agreement Obligates Federal Funds *Relationship between PI/PD, Grants Team, and the Funding Agency
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Teamwork is the Key!!
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Review Grant Agreement *Establishes legally binding arrangement between the grant making agency and recipient. It includes the following: Grant Period Award Approved & Prohibited Expenditures Revisions to grant activities or budget Payment Method Project Director Responsibilities Compliance with Regulations, Policies & Procedures Reporting Requirements Time & Effort *Read the grant agreement terms & conditions *Highlight items that need clarification *Builds the relationship between PI, Grants Team, and the Funding Agency
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Attend Development Team Meeting *To implement the grant schedule a new PI/Debriefing Meeting Invite attendees who will be part of the award until close out −Including Marketing & Communications Provide an overview of the grant Share key points from the grant agreement Project Timeline Roles & Responsibilities Report Requirements and Deadlines Effort Reporting Administrator Responsibilities *Provide an update to Controller
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Set Up Award *Create Grant Fund to set up the award *Enter in Grant in Banner Grants Module *Banner access and approvals are given *Training on financial reporting system is provided *Add reporting due dates to your calendar *Provide the accounting string to the PI and the grants team 3XXXX-ORG-ACCT-PROG Federal grants use ACTIVITY & LOCATION Multi-year grants will have the same Fund *Provide Budget to Controller & Vice President for Finance
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Implement and Manage Award *Per your budget period and project timeline, start incurring expenses *PI/PD must sign on all expenses *PI/PD is responsible for managing the funds *Funds must be spent according to funder requirements *As a Grants Accountant Check request is filled out correctly Review budget period Review budget availability Review Documentation Review all signatures *Electronic Records must be readable
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Factors Affecting Allowability of Costs (per OMB CIR A-21) Costs must: 1. Be REASONABLE 2. Be ALLOCABLE 3. Be given CONSISTENT treatment 4. CONFORM to regulations, the terms and conditions of agreement, and the University policy
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Implement and Manage Award *Review Salaries & Fringe entries semi-monthly *Enter expenses in Access Database by month-end Reconcile with Banner or your Financial System *Generate a monthly report for PI/PD *Process a voucher to make corrections Cost Transfer Procedure (90 days)
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Policies and Procedures POLICIES *Conflict of Interest Policy and Forms *Time & Effort Policy and Forms *Allowable/Unallowable Cost Policy *Indirect Cost Policy *Sub-Recipient Monitoring Policy *Equipment Policy *Record Retention Policy PROCEDURES *Cost Transfer Procedure *Drawdown Procedures
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Time and Effort Reporting *OMB Circular A-21 requires MidAmerica Nazarene University to track and certify how employees are compensated on sponsored programs *Effort reporting certifies that salary sources for a given period align with actual effort distribution
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Effort Reporting Periods * MidAmerica Nazarene University grant personnel certify their effort three times a year: Fall Semester (September – December) Spring Semester (January – May) Summer Semester (June – August) * Reports due within 30 days of the end of each semester
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Payroll vs. Effort *Payroll distribution represents accounts (funding sources) of an individual’s salary *Effort distribution represents allocation of an individual’s activities
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How is Effort Determined? *NOT based on 40 hour work week *Based on 100% of activities for which you are compensated by MidAmerica Nazarene University including: Sponsored project activities Non-sponsored activities *Expressed in percentages
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What is 100% Effort? Sponsored project activities include: *Effort on federal grants, contracts, and cooperative agreements (e.g., DOE, NIH, NSF) *Effort on non-federal research projects (e.g., a foundation grant) *Administrative effort related to a sponsored project Writing progress reports Holding a meeting with staff Presenting research results at a scientific conference Reading scientific journals to keep up to date with the latest advances in the project topic area *Even if your salary is not completely paid by the sponsor (i.e. salary cost sharing)
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What is 100% Effort? Non-sponsored activities include: Teaching Department Chair duties Attending general departmental faculty meetings Serving on College committees Proposal preparation
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Effort distribution should reasonably reflect actual activity *OMB Circular A21 J10b (1) (c) “In the use of any methods for apportioning salaries, it is recognized that, in an academic setting, teaching, research, service and administration are often inextricably intermingled.” “ A precise assessment of factors that contribute to costs is not always feasible, nor is it expected. Reliance, therefore, is placed on estimates in which a degree of tolerance is appropriate.”
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Red Flags/Audit Triggers *Late effort reports *Effort certified by someone lacking first-hand knowledge of the individual’s actual effort *Percentage outside of sponsored project is insufficient to credibly cover teaching, administrative, or other College work *Multiple post-certification revisions *Significant data inconsistency between effort report and other documentation such as: Calendar Leave reports Other support forms Outside activity forms
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Close Out Award *Terminate the Fund in Banner *Final Reports to PI/PD *Refund any balances of unobligated cash *PI/PD submits final reports *Records Retention 3 years from the date of submission of the final expenditure report
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Project Management: Grant Awarded…Now What?????
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Project Management Cycle: Creation, Implementation and Evaluation DATA
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1. Know the awarding organization Is this the right funder? 2. Closely examine the grant application Are there certain project requirements that need to be followed? Project Management during the Proposal Creation Stage
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*Closely read the definitions included in the application *Determine eligibility *Understand the stated priorities for the grant award (Absolute and Competititive Preference and Invitational Priority—points and no points) *Arrange your grant proposal according to the directions/sections in the application The Grant Application is your Best Friend
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*Follow the proposed activities Who needs to be involved from the development team? What systems/processes need to be put into place? What is the timeline for implementation? *Application—Project Design section is your roadmap Project Management during the Implementation Stage
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Communication is the Key!
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Work is the Name of the Game
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*Goals of evaluation of the grant project: *1. Accountability, accountability, accountability monitors success of your project provides information for improving your project collects a continuous data stream *Application—Project Evaluation section your roadmap Project Management during the Evaluation Stage
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*Annual report *End of project report *Internal reports and external reports *Data Collection documents Qualitative or quantitative --Checklists--rubrics --Surveys--self-evaluative/3 rd person --Observation notes--numbers --Test scores--biographical data --Pre-post assessments Types of Evaluation Documents
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*Work with the Development Team using the grant proposal for guidance *Review project activities and determine which need to be sustained *Factors to determine sustainability include: Financial costs Personnel *Transitional plan is created for absorbing financial costs and reassigning personnel Determine Sustainable Activities
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Your grant application is your road map for project creation, implementation and evaluation.
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Creation — Funding source, own organization, grant application Implementation — continuous, ongoing monitoring of activities Evaluation — Accountability of success of the program Data
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Questions?
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