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Plenary Session The 5 W’s of Good Grants Management
SWFI Convening October 31-November 1, 2017 Washington, DC EMPLOYMENT AND TRAINING ADMINISTRATION Office of Workforce Investments, H-1B Funded Program UNITED STATES DEPARTMENT OF LABOR
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Facilitator Danielle Kittrell, Workforce Analyst, Division of Strategic Investments, U.S. Department of Labor, Employment and Training Administration Speakers Kia Mason, Grants Management Specialist, Office of Grants Management, U.S. Department of Labor, Employment and Training Administration Alice Mitchell, Federal Project Officer, Region Five, U.S. Department of Labor, Employment and Training Administration
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The “W’s” of Grants Management
Who: National Program Office and Grants Officer, Regional Offices and FPOs, and YOU! What: Effective management of your project’s activities, performance outcomes, and grant expenditures. Where: It takes place in your local service area, with support from the National and Regional office. When: All the time! From grant implementation to grant completion. Why: Good grants management leads to success! Facilitator: Setting the stage! Today we are going to take it back to grammar basics. So let’s get started with the 5 W’s of Grants Management. So, Who’s on first? What’s on second? Ok, kidding. Let’s get started with the real W’s of Grants management. Who’s involved in TechHire grants management? Who: National Program Office and Grants Officer, Regional Offices and FPOs, and YOU! We are all involved in TechHire grants management. What is grants management? What: Our goal here is to support effective management of your funded projects activities, performance outcomes, and grant expenditures. Where does grants management happen? Where: With you! It takes place were you all are located, with support from your national and regional team. When does grants management take place? When: All the time! From grant implementation to grant completion. Grants management never takes a break! But you should ; ) And Why is good grants management important? Why: Good grants management leads to success! Success of your project, for participants and partners, and the broader workforce system. Your success is our success!
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Let’s Play Mod Libs! So instead of telling you what to do when submitting a successful grant modification, we thought it would be fun to tell you what to do. For real. We are going to play a little game we like to call Mod libs. The person who got the free consultation, you can leave and go get coffee right now. OK, so to actually show you how to submit a modification request for approval, I’ll turn things over to xxxx, one of our esteemed colleagues and FPOs located in the region xxxx office.
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Fill in the Blanks! Most Annoying Celebrity Favorite Shakespeare Play
Name of Superhero Online Game Most Unique 1st Job Favorite Pastime/Hobby Lucky # Repeat Favorite Pastime/Hobby Measurement of Time An Awesome Store 11. # of Drinks Last Night 12. Sports Team 13. What You Think ETA Does All Day 14. Favorite Disney Character 15. # of Hours to Get to DC 16. Size of Largest Family 17. Dream Transport Mode 18. Vacation Destination 19. Reality TV Star Fill in the Blanks!
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Grant Modifications Kia Mason
Grants Management Specialist, Office of Grants Management, U.S. Department of Labor, Employment and Training Administration
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Grant Modifications During your grant’s period of performance, you may experience changes and need to request a modification to some aspect of your grant. 2017 SWFI Grantee Meeting
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Grant Modifications What is a Modification? Why do a Modification?
Key Players Modification Analysis How to Submit a Modification Documentation Required Some of the things I will touch on today is… What a modification is and why it may be needed Some of the people involved in the modification process Some analysis questions to determine if a modification is needed The process for submitting a modification request and the documentation that must accompany the request. 2017 SWFI Grantee Meeting
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Grant Modifications What is a Modification? Why do a Modification?
Key Players Modification Analysis How to Submit a Modification Documentation Required Some of the things I will touch on today is… What a modification is and why it may be needed Some of the people involved in the modification process Some analysis questions to determine if a modification is needed The process for submitting a modification request and the documentation that must accompany the request. 2017 SWFI Grantee Meeting
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Mechanism to Change Aspects of the Grant Agreement
What Is a Modification? Mechanism to Change Aspects of the Grant Agreement So what is a modification? When you were awarded a grant, you received a grant agreement which serves as your official grant file. Any changes that are made to the file must be documented and we must have a record of the changes. In order to implement those changes, a grant modification must be done. Submitting a modification request and receiving approval gives you permission to implement those changes. 2017 SWFI Grantee Meeting
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Why Do a Modification? Statement of Work Change Budget Realignment
Change Indirect Cost Rate Change Authorized Representative Change of Address Change of Organization/Institution Name Purchase or Lease of Equipment Period of Performance Change When do you need to submit a modification…. Let’s say you start to implement grant activities and you realize that serving other industries or targeting other occupations may be beneficial to your grant, that would be a statement of work change. Or, let’s say you want to change your deliverables such as the number of participants to be trained, that would also be a statement of work change. Now the budget, we all know a budget is never final. Throughout your period of performance, you may want to move some funds around and move them to another line item. That is what we call a budget realignment. If you are moving less than 10% of cumulative grant funds, you do not need to submit a modification request. However, you still need to consult with your FPO prior to making the changes. If you are moving more than 10% of grant funds, you need to submit a modification request. When you request a budget realignment, you need to ensure that you update your SF-424A, which is the budget form and the budget narrative. In the budget narrative, we want to see exactly what the funds will be used for so make sure you provide a detailed description of what you are spending funds on, how much each item cost, the salary for personnel, etc. We need this level of detail in order to determine if the items and costs are reasonable, necessary, and allowable. A lot of times, in the supplies line item, a grantee may list office supplies and have a dollar amount. We want to know each item that is included in the line item and the per unit cost. Your budget may include indirect costs and you may have provided us with your negotiated indirect cost rate agreement….however, the agreement expired a few months into your grant. When you receive your updated ICRA from your federal cognizant agency, a modification needs to be done so that the new agreement can be incorporated into your grant agreement. This is helpful, especially during close out so that they can use the agreements to calculate your indirect costs throughout your period of performance. Let’s say, after 60 years in the organization, Rob Smith, the Authorized Representative, has finally decided to retire. Sarah Jones, the new Authorized Representative decides to submit a letter stating that she is the new Authorized Representative…Hold on! That’s unacceptable. She can’t elect herself. The letter must come from someone else like the board, or someone higher up such as the CEO. The letter must also include the contact information (Name, title, phone number, address) of the new appointed person. So, your organization is expanding and you decide you need a bigger office space, which is fine, or you decide to rename your organization, a modification needs to be done so that we can incorporate this new information in your grant file. In your application, you list all the equipment that’s needed to implement grant activities. Before you can purchase the equipment, you must have prior approval from the Grant Officer. We encourage you to submit a detailed list of all equipment as early as possible so that it will help you successfully complete all grant activities. From time to time, we will process a one time period of performance extension to wrap up grant activities. We will not grant period of performance extensions during the first two-thirds of the original period of performance. 2017 SWFI Grantee Meeting
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Key Players Federal Project Officer (FPO)
Provides daily customer service to the grantee POC for the duration of the grant Conducts oversight (desk and on-site) Provides guidance as needed Makes recommendations for grant actions to the Grant Officer There are 3 people involved in the processing of grant modifications. They are the Federal Project Officer which we call the FPO, the Grant Officer, and the Grants Management Specialist. First, let’s discuss the roles of the FPO….FPOs are located in one of our 6 regional offices. They are your main point of contact throughout the duration of the grant and are there to provide you with daily customer service. FPOs are the ones who monitor your grant…they may come pay you a visit to see how everything is going or they may do desk review. If they find that things are not going as planned, they will be there to offer guidance to help get you back on track. In terms of grant modifications, the FPOs are the ones who make recommendations to the Grant Officer. 2017 SWFI Grantee Meeting
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Key Players Grant Officer Grants Management Specialist
Executes final grant Executes modifications Maintains official grant files Grants Management Specialist Serves as the assistant to the Grant Officer Works directly with the FPOs Reviews information for modifications Recommends approval of actions to the Grant Officer So next…the Grant Officer. The Grant Officer is the final approver…Grant Officers are located here in the national office as was as in the regional offices. The national office Grant Officer is the one who executed your initial grant award and is usually the one who executes majority of your modifications. From time to time, you may receive a mod that was approved by a regional Grant Officer. But whether it was a regional or national grant officer who approved your modification, what’s important is…that is was approved! Alright let’s move on to the Grants Management Specialist. So like I mentioned when I introduced myself, I am a Grants Management Specialist, and we help out the Grant Officer, sort of like an assistant. We do all of the leg work…we review the modifications and make recommendations to the Grant Officer. We are the ones who check to make sure everything adds up correctly, check the allowability of the request, etc. We may also request additional information from you prior to making the recommendation and in that case, we will work with your FPO to get the clarifications or revisions needed. 2017 SWFI Grantee Meeting
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Initiating a Modification Request
Contact your FPO Submit documentation to your FPO FPO reviews (along with Program Office, if appropriate) and provides feedback Submit signed modification request to FPO Modification Request: Must be submitted on organization’s letterhead Must be signed by the Authorized Representative Indicate the purpose and why it’s necessary How the change will benefit the program Reflect the guidance provided by the FPO (and others, such as the Program Office, if applicable) As stated before, the FPO is your main POC throughout the grant. You should contact them to discuss the need for the modification and also the documentation necessary to submit the modification. Sometimes, your FPO will request that you submit a draft request to them for review. Your FPO will review your request and provide feedback if needed. Depending on the type of request, the program office, may also review the documentation. Once you get the ok from your FPO that everything looks good, you then submit a signed modification request. Remember …, this request needs to be on your organization’s letterhead, be signed by the Authorized Rep (or someone in the organization above the Authorized Rep), and include the purpose and why the modification is necessary as well as the benefit to the program. 2017 SWFI Grantee Meeting
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Modification Analysis
Is it a clear & detailed request? Does it align with the goals and objectives of the original FOA? Is it an allowable cost for the grant? Grantee Mod Request ETA Objectives Among others, there are 3 things we will consider while reviewing your modification request, so before submitting a modification, ask yourselves these questions… Will we understand what you are asking to change? … Will this modification help you to achieve the objectives in the original funding opportunity announcement? …. And of course, will this be an allowable cost in accordance with the cost principles found in the uniform guidance? Will Expand while presenting … 2017 SWFI Grantee Meeting
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Approving Modifications
FPO submits request for regional management review and approval FPO forwards the modification request to the Grants Office for processing and final review Your Grant Officer reviews and may approve and sign the modification. Both you and your FPO will receive an electronic copy of the modification via . You are now free to implement your requested changes. Once a signed request is submitted, your FPO will send the request to their regional management team for review. After approval has been received from the regional management team, the request is then forwarded to Grants Office, so that we can process the mod and give a final review. If there are no further questions or revisions needed, the Grant Officer will consider your request for approval. If approved, you will receive a copy via for your file. If not approved your FPO will notify you. At this point, you may now implement the changes. It is important to wait until you have received the signed documentation from the Grant Officer before implementing the changes. 2017 SWFI Grantee Meeting
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Questions…… 2017 SWFI Grantee Meeting
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Monitoring and Managing your SWFI Grant
Alice Mitchell Federal Project Officer, Region 5
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Monitoring and Managing Your SWFI Grant
Good afternoon. Since I am talking with you this afternoon about managing and monitoring your grant, I wanted to start the presentation with a little humor. It is not my goal, or any FPO, that you will need to call your locksmith or a lawyer after we have monitored your grant. But we do take our work seriously and are committed to helping you succeed. 2017 SWFI Grantee Meeting
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Monitoring and Managing Your Grant
Types of Grant Monitoring On-Site Reviews: The Basics Purpose of Grant Monitoring How to Prepare for a Monitoring Visit On-site Monitoring Understanding the Monitoring Report Finding(s) Area(s) of Concern Here are the topics we will be covering this afternoon. I will be focusing on the last three items: How to Prepare for a Monitoring Visit On-site Monitoring Understanding the Monitoring Report 2017 SWFI Grantee Meeting
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Types of Monitoring Quarterly Performance Reviews
Quarterly Narrative Report Quarterly Performance Report Quarterly Financial Report Desk Monitoring Reviews Grants e-Management System (GEMS) On-Site Reviews As you can see, there are three types of monitoring, and they have common elements: Quarterly Narrative Report Quarterly Performance Report Quarterly Financial Report 2017 SWFI Grantee Meeting
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On-Site Reviews: The Basics
Who conducts On-Site Reviews? FPO (with additional ETA Staff if needed) When is the review conducted? Usually midpoint during your grant’s period of performance What is the duration of the review? Usually five days Notification of Review: Letter confirming scheduled date of review and Core Monitoring Guide/Review Planning Tool mailed to Grant Recipient Your FPO will be the person conducting the on-site review, but if there are additional staff, it is generally someone from DFMAS or Division of Financial Management and Administrative Services, who will be joining the assessment team. Their focus will be on the financial side of the grant – how you are managing funds, that you are meeting the requirements of the Uniform Guidance. 2017 SWFI Grantee Meeting
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On-Site Reviews: The Basics
What not to do when you receive notification that your grant is about to be monitored. I really want to emphasize that a monitoring trip is not a reason to panic. 2017 SWFI Grantee Meeting
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What is the Purpose of Grant Monitoring?
It is NOT -- “GOTCHA” It is an opportunity to Ensure that the Department of Labor grant funded program is aligned with: Statute/Regulations/Grant terms & conditions Federal financial and administrative requirements including cost principles Funding Opportunity Announcement (FOA) Identify promising practices that can be shared Identify technical assistance needs I want to reassure you that the purpose of grant monitoring is not GOTCHA! It is an opportunity to … 2017 SWFI Grantee Meeting
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How to Prepare for a Monitoring Visit
Review the Core Monitoring Guide Five Core Activities Design and governance Program / Grant Management Systems Financial Management Systems Service/product Delivery Performance Accountability As you can see the Core Monitoring Guide focuses on five areas: Design and governance Program / Grant Management Systems Financial Management Systems Service/product Delivery Performance Accountability I also want to point out that while the current version is dated April 2005, there is under development a new guide that incorporates the requirements of the Workforce Investment Opportunity Act (WIOA). What the timeframe is for its release I am not privy to that knowledge, but just keep this in the back of your mind. 2017 SWFI Grantee Meeting
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How to Prepare for a Monitoring Visit
Review the following: Funding Opportunity Announcement (aka Solicitation for Grant Application [SGA]) Statement of Work (SOW) Monthly Reports that have been submitted Narrative, Financial, and Performance Subrecipient Reports (if applicable) Policies and Procedures Participant Files As you prepare for the monitoring visit, I cannot over emphasize the importance of reviewing each of these elements. Your FPO is going to be asking you questions based upon each of these elements. Ultimately, the FPO’s goal is to understand your grant and how it is performing or not performing. 2017 SWFI Grantee Meeting
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On-site Monitoring Structure
Introductory Conference (Day 1) Review (Days 2-4) Exit Conference (Day 5) Preliminary findings and observations Written Report (45 days following the exit meeting) 2017 SWFI Grantee Meeting
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On-Site Monitoring What do we look at?
Connection/Compliance to the FOA Connection/Compliance to the SOW/Grantee Agreement Performance Service Delivery Financial Management Policies and Procedures 2017 SWFI Grantee Meeting
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Understanding the Monitoring Report
Written Report (45 days following the exit meeting) Findings and required corrective actions Opportunities for improvement, i.e. Area of Concern Positive observations How many of you remember the TV show DRAGNET? I did not see it when it was first broadcast, but did see it when it was in re-runs. Now I think you can watch it on Hulu or MeTV. But the classic line in the series was always said by Detective Joe Friday – JUST THE FACTS MA’AM. We try to write our reports that focus on just the facts – we are not trying to lay blame or throw someone under the bus. 2017 SWFI Grantee Meeting
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Understanding the Monitoring Report
What is a finding? A finding is any “violation of” Law Regulations Grant agreement SGA requirement As you can see a finding is any “violation of” the following: Law Regulations Grant agreement SGA requirement 2017 SWFI Grantee Meeting
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Understanding the Monitoring Report
Examples of Findings Changes were made to the Statement of Work without Grant Officer approval Change in scope or objective Adding/deleting program component Adding/deleting subrecipient Changing target group I want to provide you with some examples of what constitutes a finding. 2017 SWFI Grantee Meeting
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Understanding the Monitoring Report
Examples of Findings Grant funds were used to purchase equipment without Grant Officer approval Unit cost of $5000 and useful life of one year Prior approval required even if included in the grant budget This requirement also applies to subrecipients Here is another example 2017 SWFI Grantee Meeting
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Understanding the Monitoring Report
Examples of Findings Negotiated Indirect Cost Rate Agreement is expired The Equal Opportunity (EO) requirements are not being fully implemented The Grant Recipient realigned the budget without prior Grant Officer approval Subrecipients are not monitored Project significantly behind schedule in implementing grant activities Procurement files do not contain required support documentation And here are other examples of findings. 2017 SWFI Grantee Meeting
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Understanding the Monitoring Report
What is an Area of Concern? Concern about effectiveness or efficiencies Not related to compliance with law, regulation, FOAs, grant agreements or federal policy Can relate to performance, services or operational efficiencies/effectiveness Should convince/compel grantees to take action As I noted earlier, monitoring reports address both findings and areas of concern. What is an Area of Concern? Concern about effectiveness or efficiencies Not related to compliance with law, regulation, FOAs, grant agreements or federal policy Can relate to performance, services or operational efficiencies/effectiveness Should convince/compel grantees to take action 2017 SWFI Grantee Meeting
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Understanding the Monitoring Report
Examples of Area(s) of Concern Performance Concern Projected outcomes based on current data Not mandated by law, regulation or milestones listed in SOW Service Concern Business services, involvement of business, involvement of listed partners, quality and timely services, customer access, etc. Operational Concern Procedural bottlenecks, staff knowledge, internal security and controls, internal communication, training, policy distribution, etc. Here are some examples of Areas of Concern. 2017 SWFI Grantee Meeting
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Responding to the Monitoring Report
Grantees have 45 days to respond Response is submitted to your FPO Findings will have a “Required Action” Submission of a modification request Action plan to address the finding Evidence the finding has been corrected Area(s) of Concern do not require a response, but it is advised that you address it in the report You are REQUIRED to respond to the monitoring report 2017 SWFI Grantee Meeting
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Questions Any questions? 2017 SWFI Grantee Meeting
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