1. Financial Management 101 For SCSEP Program Administrators
General overview of financial and administrative policies and procedures.
State grantees….nothing new….refresher
For SCSEP Program Administrators
2010 SCSEP Business Meeting
November 18, 2010

2. How Feds View Themselves

3. How Grantees View Feds

4. The DOL Grantee Our Expectations of You:
A program that is designed to focus on customer needs and to address those needs
A program that meets the requirements of Federal law and regulation
A program in compliance with SCSEP requirements, OMB Requirements and Generally Accepted Accounting Principles.

5. The NEW DOL Grantee What you can expect from us:
Assistance with regulations & requirements
On site technical assistance & monitoring
Assistance with fiscal & programmatic issues

6. Why know this stuff? Financial requirements impact program design
Need for financial information is critical to achieving program success
Failure to comply may result in sanctions

7. It’s All Very Simple Written Policies and Sound Business Practices,
Followed Consistently Over Time,
With Each Funding Stream Treated Equally,
With All Costs Being Necessary and Reasonable,
Would be done similarly by a Prudent Person,
Ensuring Proportionate Share and Benefits Received
to take the same sort of care as an ordinary prudent person might take

8. Rules affecting programs
Enabling legislation
Uniform administrative requirements
Grant management rules
Cost principles
Determination of allowable costs
Program regulations
Program activities
Both allowable and unallowable
Cost category restrictions
Statement of Work
Description of grant outcomes

9. The Pyramid of Grant Requirements
Suspension Debarment
Drug Free Workplace
Lobbying
Guidance
Policy Manuals
Davis
Bacon Act
Terms and Conditions
Program Regulations
OMB Circulars
Program Statutes
A&A
Govt.-Wide
Govt.-Wide
Improved financial management is having accurate and timely financial information to manage costs and achieve efficiencies.
Accurate and timely financial data is the foundation for financial reporting integrity.
Financial management is how an organization uses its data (from financial reporting) to drive results.
OFFM assists agencies in both building the financial reporting foundation and creating a framework to drive improvement and results.
The Role of Standards
Fulfills the government’s duty to be publicly accountable
Assess the government’s accountability and its efficiency and effectiveness
Contribute to the understanding of the allocation and various uses of Federal resources
Provides users of financial reports with understandable, relevant, and reliable information
Facilitates government-wide comparison
Fosters the improvement of accounting systems and effective internal controls
Agency & Programs

10. Cost principles Set of government wide rules Cost principles
Now codified at 2 CFR
Cost principles
Define conditions for charging costs
Types of Allowable costs
Allowable
Unallowable
Allowable with conditions

11. Uniform Administrative Requirements
Governments (State, Local, Indian Tribal)
A-110
Non-profit organizations
Institutions of Higher Education
Hospitals
Commercial organizations

12. Required? Incorporated by reference Uniform Administrative Standards
29 CFR 97.22
29 CFR 95.27
SCSEP Regulations
20 CFR
Older Americans Act Title V

13. Items of Cost Travel Pre-Award costs Interest Allowable
Reasonable and in support of grant activity
Pre-Award costs
Not allowable unless specifically authorized
Interest
Costs of borrowing
Payments for equipment over time

14. SCSEP Requirements Legal expenses Real property
Unallowable for prosecution of claims against the government
Audit appeals
Real property
Unallowable
Exception for ADA compliance

15. SCSEP Unallowable Activities
Sectarian activities
Union organizing activities
Lobbying costs
Building repair and acquisition
Exceptions- Labor costs for following:
Minor remodeling necessary for project purpose
Minor repair/rehab for benefit of community

16. Allowable Cost Standards
Necessary
To achieve grant outcomes
Reasonable
Sound business practices
Allocable
Only charge costs that clearly BENEFIT grant
Additional standards

17. Grant Management Requirements
29 CFR Part 95
Uniform Administrative Requirements
Procurement
Program Income
Property Management
Post-Award requirements

18. Cost Categories Only 2 Cost Categories Reporting categories
Administration
Program Activities
Reporting categories
Expenditures
Program Income
Match
Other Federal funds
Budget line items

19. Administrative Costs SCSEP Definition -- 20 CFR 641.856 & 859
Not related to direct services
Either to clients or employers
List of specific functions
Unlike traditional definitions
Limitation is 13.5% (in grant agreement)
Measured at conclusion of grant period

20. Indirect Costs
Costs through an approved Indirect Cost Rate or Cost Allocation Plan
Included on the SF-424A
Reported on the ETA 9130
May be both Administrative & Program costs
SCSEP definition applies

21. PL 109-234 Applies to Limits salary and bonus payments to individuals
All ETA appropriated funds
All grants, contract and interagency agreements
All funds available on June 15, 2006
Limits salary and bonus payments to individuals
Implementation guidance in TEGL 5-06
2008 limit is $172,200

22. Who is covered? Individuals paid by ETA appropriated funds
Direct recipients and all subrecipients
Direct costs or through an Indirect Cost Rate
Vendors are not subject to limitation

23. SCSEP Match Requirements
At least 10% non-Federal funds
No match for:
§502(e) grants
Disasters
Distressed areas
Grantees can’t use match as award condition
Subgrantees & host agencies
Ref: 20 CFR (e)
Slide 3 – SCSEP Match Requirements
At least 10 percent of SCSEP grant costs must be supported by non-Federal funds. Any source of resources is acceptable so long as it is non-Federal in origin and meets applicable allowable cost requirements.
The matching share provisions of the DOL administrative requirements in Parts 95 and 97 of 29 CFR provide approved methodologies for valuing in-kind contributions – non-Federal resources other than those provided by the grantee or subgrantee. Past practice in the SCSEP program has been for much of the match to be provided by host agencies in the form of supervisory time and related space costs.
DOL has the option of awarding Sec. 502(e) grants without the otherwise applicable match requirement. DOL’s regulations at 20 CFR (e) prohibit grantees from requiring their subgrantees and/or host agencies to supply matching resources as a condition of making an award of grant funds or community service slots to them.

24. Match (Non-Federal Share)
All contributions must be:
Spent on allowable activities
In accordance with cost principles
Can’t be BOTH match & allowable cost
No administrative cost limitation
A grantee or subrecipient must decide whether to charge costs against the Federal share of costs or as match. The same item can’t be charged as match and as allowable Federal costs.

26. Leveraged Resources Allowable match Non-match
In excess of match requirement
Non-Federal funds used for grant purposes
Reported on the ETA 9130
Non-match
Funds available for the project that don’t meet criteria for allowable match
Reported on the performance report
Federal funds also reported on ETA 9130

27. Examples Federal funds expended by other organizations
WIA ITAs
CDBG grants
Foundation grants expended by subgrantees

28. Reports ETA 9130 Electronic reporting system Quarterly reports
Use of passwords and pins
Quarterly reports
Cumulative from beginning of project
Accrual basis
Due 45 days after quarter end

29. Financial Reports Keep in mind— Accrual basis of reporting
Administrative costs
Breakout on line 10.f
Leveraged resources
Non-Federal resources expended
Lines 10.k-m
Federal resources expended
Line 11.a

30. SCSEP Fund Availability
I year grants
May request extension
Justification required
Unexpended funds recaptured
EFFECTIVELY MANAGE YOUR $$$

31. Questions?