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Barbara McCoy, Phil Mckoy, and Sara Vogler

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1 Barbara McCoy, Phil Mckoy, and Sara Vogler
Grants Managements Barbara McCoy, Phil Mckoy, and Sara Vogler

2 Agenda Introductions Understanding the Terms and Conditions (T&Cs) and the Notice of Award (NoA) HHS Standard Form (SF) 425 Amendments NCE vs carryover Scenarios QA

3 Understanding the Terms and Conditions (T&Cs) and the Notice of Award (NoA)

4 Terms and Conditions Terms and Conditions are the rules that applicants must follow in order to be compliant with the terms of the grant. Examples of terms and conditions are as follows:

5 Understanding the NOA & Terms and Conditions
Provides detailed information on the grant award including: Date Issued (section 1) Grant Number (section 4) Project Period (section 6) Budget Period (section 7) Grantee (Section 9a) and Key Personnel (9b & 10a) ACL Project Officer (Section 10b) Approved Budget Breakout by Budget Category (Section 11) The NOA contains a lot if information that the project director will need to know about the grant award. I will show you each of these areas on the NOA next, but in general, project directors should be able to locate and understand…..

6 Where to find Terms and conditions

7 This is what your NOA will look like
This is what your NOA will look like. In addition to this, there will be additional pages that outline the terms and conditions for the award. It is important to read and understand the terms and conditions because this is where you will find information regarding performance requirements, notification requirements for any changes to the budget or scope of work, performance reporting requirements, financial reporting requirements, and information about requesting a carryover or no cost extension. You can view your NOA in Grant Solutions at any time. Also known as NGA in GrantSolutions.

8 Notice of Award: Helpful Information
Date Issued Grant Number Project Period Budget Period Section 1 of the NOA is the date that this particular action was issued by the Office of Grants Management. It is important to locate this, particularly when an amendment or other change to the award has been made. If you have a record of multiple NOAs for your award, the date will help you identify if this is the most current NOA (as will section 4). Section 4 shows the Grant number. For this particular award, the grant number is 90SM Often grantees will also see a “-01” or some other number at the end of the grant number. This is not the grant number but the year of the award. So, in this case, 90SM is referring to the identified grant and the first budget year. When discussing your grant with ACL, you only need to give us the first 8 digits. We do not need the budget year. Grantees should include their grant number in all correspondence to ACL Grants Specialists and any time they want to ask their project officer a technical question about their grant. Section 6 shows the project period for the grant. This will often be different than the budget period, but there are some circumstances where the project and budget periods will be the same. For the grant shown here, the project and budget period are the same but this is not the case for multi-year SHIP grants. SHIP grants are funded in one year increments. Section 7 shows the Budget Period. This represents the current period for which funding is being awarded to the grantee.

9 Key Personnel Authorizing Official/Representative (AOR):
Note: Only these two individuals will be sent official notices on the grant award. Be sure that whomever your agency designates is going to be responsive to these messages from ACL. Section 9a lists the organization that is receiving the grant. You will want to check this to make sure that the information is correct. Section 9b lists the Project Director. This is the person who will be responsible for managing the day to day operations of the grant and will normally be the first point of contact for ACL. Section 10a lists the Authorizing Official/Representative for the agency receiving the award. The AOR is typically the Commissioner of your agency or the SUA director for SHIP, and the organizations director for non-governmental entities. Both the AOR and project director are designated by the state in the application for the grant (this is not an ACL decision). All communication to the Grantee will be sent to the AOR and the PI/PD so you want to be sure that one or both of these names will be responsive and have access to Grant Solutions. In a few minutes, Barbara will discuss requesting an amendment if you need to change the AOR or PI/PD during the grant. Authorizing Official/Representative (AOR): This is the person that has the authority to commit the agency to the award/funding and the conditions attached to it. Designated by the grantee – this is not an ACL decision. Principle Investigator/Project Director (PI/PD): This should be the person responsible for managing the grant.

10 Key Personnel Section 10b lists the Federal Project Officer for the grant. This will vary from state to state and may change throughout the course of the project or budget periods. Your project officer provides programmatic technical assistance to the grantee, receives and reviews the progress and financial reports from the grantee, conducts site visits, and is the first point of contact for any grant related questions. When in doubt, contact your project officer and they will help resolve your issue or refer you to the appropriate contacts.

11 Approved Budget Finally, Section 11 shows the approved budget for this PROJECT PERIOD. This information comes from the SF 424A and the budget justification that was submitted as part of the grant or renewal application. This concludes my portion of the training.

12 Examples of Terms and Conditions
Standard terms and conditions Cooperative agreement Administrative Terms Salary Limitation (includes provisions for a salary rate limitation. The law limits the salary amount that maybe awarded and charged to ACL grants and cooperative agreements.) DOMA: Implementation of United States v. Windsor and Federal Recognition of Same-Sex Spouses/Marriages Federal Awardee Performance and Integrity Information System (FAPIIS) Reporting Requirements Collaborate with ACL for any in-scope modifications and execution of the work plan, initially within 45 days of the award. Evaluate the impact of overall project activities and ensure quality assurance systems are in place. Restrictive terms and conditions(when a grantee scores below a 70 on applications)

13 HHS Standard Form (SF) 425 AND HHS Grants Policy

14 Purpose of the Federal Financial Report (SF-425)
Compliance with 45 CFR Financial management and standards for financial management systems SF-425 provides a standard format for reporting the financial status of grant awards Grant Recipients are required by the Terms and Conditions located on the Notice of Award (NoA) to submit financial reports (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements. SMP semi-annual SHIP annual Final Reports (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. The non-Federal entity must adequately safeguard all assets and assure that they are used solely for authorized purposes. See § (5) Comparison of expenditures with budget amounts for each Federal award. (7) Written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the Federal award. SF-425 submitted in GrantSolutions as a Grant Note

15 Required documents to Complete SF-425
Non-Federal entity’s Financial Management System Notice of Award (NoA) OMB approved SF-425 with expiration date grant

16 Completing SF-425 Box 2 Grant Identifying Number-Enter the grant number assigned to the award by the Federal agency. Box 10d Total Federal Funds Authorized- Enter the total Federal funds authorized as of the reporting period end date. Box 10e Federal Share Expenditures- Enter the amount of Federal fund expenditures. Box 10f Federal Share of Unliquidated Obligations- Unliquidated obligations on a cash basis are obligations incurred, but not yet paid. Box 10g Total Federal Share -Enter the sum of Lines 10e and 10f. Box 10h Unobligated Balance of Federal Funds- Enter the amount of Line 10d minus Line 10g. Grant Number begins “90MP” or “90SAPG”. No need to include budget year distinctions Unliquidated Obligations: Cash Basis Accounting: obligations which are incurred but not yet paid as of the end of the reporting period. Accrual Basis Accounting: obligations which have been incurred, but for which an expenditure has not yet been recorded, as of the end of the reporting period. Amounts should not be rounded and must be exact.

17 Indirect Expense Box 11a Type- State whether indirect cost rate(s) is Provisional, Predetermined, Final, or Fixed. Box 11b Rate-Enter the indirect cost rate(s) in effect during the reporting period. Box 11c Period from and from-Enter the beginning and ending effective dates for the rate(s). Box 11d Base-Enter the amount of the base against which the rate(s) was applied. Box 11e Amount Charged-Enter the amount of indirect costs charged during the time period specified. (Multiply 11b. x 11d.) Box 11f Federal Share-Enter the Federal share of the amount in 11e. Box 11g Totals-Enter the totals for columns 11d, 11e, and 11f. The NoA will reflect approved indirect costs based on the non-Federal entity’s federally negotiated indirect cost rate or if the entity never received such a rate, can charge the de minimis rate of 10% of MTDF indefinitely. For those non-Federal entities with a current federally negotiated indirect cost rate, you can apply for a one-time extension of the rates in that agreement for a period of up to 4 years. 45 CFR (f) and (g) HHS GPS Section II-27 and II-28: “the rate in effective at the beginning of each budget period will be used as the basis for determining indirect costs for that budget period…If the rate agreement in effect at the outset of the competitive segment does not cover the entire competitive segment, then the rate in effect for the last year of the negotiated agreement will be used to determine indirect cost funding for the duration of the competitive segment. For all recipients, if the rate in effect at the beginning of the competitive segment or budget period, as applicable, was provisional and is superseded by a permanent rate, whether higher or lower, the latte rate will be used to determine indirect cost reimbursement. The award will not be adjusted downwards, based on a lower permanent indirect cost rate than a provisional rate used in calculating the award, unless the indirect cost proposal that serves as the basis for the negotiation included unallowable costs. The OPDIV also is not required to provide any additional funding to accommodate this situation but may do so if an error was made in competing the award as indicated above. The recipient is responsible for establishing indirect cost rates for its subrecipients if those subrecipients do not have a current, applicable rate negotiated by a cognizant Federal agency.” 45 CFR (a)(4): An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government or, if no such rate exists, either a rate negotiated between the pass-through entity and the subrecipient (in compliance with this part), or a de minimis indirect cost rate as defined in §75.414(f) The Recipient Share (or match) found in lines 10i, 10j and 10k. As for both SMP and SHIP, match is not required (SMP used to have match requirements for the OAA funds but with sole HCFAC funding, match is no longer a requirement), any inclusion of match on application documents (SF-424, SF-424A, etc) is considered voluntarily proposed and will be accepted. Once accepted, the match becomes a term and condition of award that must be met by the end of the project period. If applicants would like to showcase non-Federal funding sources, please do not include on the Standard Forms and use the budget as the place to reference. It may be best to include a statement that the match being identified is to be excluded from consideration or to just exclude any references to non-Federal funding sources.

18 Reconciling SF-425 with PMS
When completing the semi-annual, annual or Final SF-425, recipients must reconcile the amount in box 10g with the reported amount on the quarterly Federal Cash Transaction report filed within the Payment Management System (PMS). PMS FCTRs are due 30 days after quarter end. (Quarter end date is 3/31, 6/30, 9/30, 12/31) As the semi-annual or annual report due dates may not align with the FCTR due dates, future quarterly cycle should be used to update the reports amounts. The Final SF-425 should be submitted after all obligations have been liquidated and PMS FCTR reconciles with the final report. In some cases, the recipient may have to revise or amend a previously submitted FFR. When the revision results in a balance due to the OPDIV, the recipient must submit a revised FFR whenever the overcharge is discovered, no matter how much time has lapsed since the original due date of the report. Revised expenditure reports representing additional expenditures by the recipient that were not reported to the OPDIV within the 90-day time frame may be submitted to the GMO with an explanation for the revision. The explanation also should indicate why the revision is necessary and describe what action is being taken by the recipient to preclude similar situations in the future. This should be done as promptly as possible, but not later than 1 year from the due date of the original report, i.e., 15 months following the end of the budget period. If an adjustment is to be made, the awarding office will advise the recipient of actions it will take to reflect the adjustment. The OPDIV will not accept any revised report received after that date and will return it to the recipient. Mention SMP SENIORMEDICAREPATROL subaccount

19 Amendments

20 Amendments Amendments = Prior Approvals Requests
Grantees must receive ACL’s approval prior to making the change. Result in the revision of a Notice of Award (NoA). Must be submitted via GrantSolutions A grantee may request an amendment to a current Notice of Award. Amendments require prior approvals from ACL. All requests for amendments must be made through GrantSolutions.

21 Common Amendments Budget Revision Carryover Request
Change in Key Personnel Authorized Organizational Representative (AOR) or Project Director (PI/PD)  Change in Grantee Address Change in Institution Name or EIN (Not Both)  Change in Scope  No Cost Extension  Transfer of Award (Closeout current award, Award to New)  These are the common amendments that are submitting via Grant Solutions. I have bolded the most common types of amendments that we receive questions on. We will focus on these four specifically during this presentation.

22 Carryover of Funds A carryover is forwarding an unobligated balance from current budget year to cover allowable costs in a future budget year. A carryover must be requested in support of activities aligned with a grantee’s existing project goals and objectives to cover costs not already incurred by the recipient. If funds have been obligated but not yet expended i.e., funds not drawn down from PMS to liquidate expenses already incurred, then a carryover request is not required to complete those transactions. Carryover can be requested anytime during the grant period.

23 Carryover Required Documents
A request letter which includes the following information: Total amount of unobligated funds requested to carryover; An explanation of why the carryover is needed, including the reason for having unobligated funds from the prior budget year; A cost break-down/narrative for each activity and budget category requiring the carryover of funds A revised budget worksheet (OMB SF-424A, Budget Information), which should include the following information: The unobligated amount for each line item being carried over The Federal Financial Report (SF-425) for the fiscal year that has the unobligated balance of federal funds. For #1 bulleted item 1 & 2 are usually included in the request letter; bullet 3 is usually in the narrative and bullet 4 seems redundant since it is outlined in #2 For #2 we only need the SF 424A to reflect the carryover amount and breakdown the carryover balance into the budget categories The SF Federal Financial Report from the year in which the unobligated balance is reflected”

24 No Cost Extension A no-cost extension allows grantees additional time to complete activities not already incurred by the recipient and aligned with a grantee’s existing project goals and objectives. Must be submitted at least 30 days prior to the end of the grant. If not submitted within 30 days before the award expiration, a corrective action plan (CAP) should be included with the other information. It should describe the plan to improve management tasks, i.e. timely requests. A no-cost extension allows grantees additional time to complete activities not already incurred by the recipient and aligned with a grantee’s existing project goals and objectives. Must be submitted at least 30 days prior to the end of the grant. If not submitted within 30 days before the award expiration, a corrective action plan (CAP) should be included with the other information. It should describe the plan to improve management tasks, i.e. timely requests.

25 No Cost Extension Required Documents
A cover letter that includes: Grant Award number Specific proposed end date, e.g., to July 31, 20XX (not the # of months). Written justification that: Explains why the work has not been completed Includes a detailed revised work plan (work plans are currently not required for SHIPs) Recent SF-425 (may accompany the request or uploaded in Notes) Revised budget – Only if there are significant modifications to the budget (explained on next slide) Detailed work plan- Not required for SHIPs but is required for all other ACL grants - A detailed work plan of how all unfinished activities will be completed by the proposed end date Revised Budgets - When applicable must include SF-424A with expenditure outlays and accompanying budget narrative explaining how each of the budget line items will increase and/or decrease.

26 Significant Rebudgeting (Budget Modification) Required Documents
Other Amendments Significant Rebudgeting (Budget Modification) Required Documents Applicable if there are modifications to the budget exceeding 25% of the total project budget or a new budget category is being added. SF 424A outlining new category amounts resulting from proposed revision Budget narrative explaining how each of the budget line items you plan to change will increase and/or decrease.   Change in Key personnel Required Documents Request letter from AOR or PI/PD including contact information ( , mailing address, telephone) of new personnel Resume or curriculum vitae (CV) for incoming key personnel

27 Submitting an Amendment to ACL
All amendment requests must be submitted use GrantSolutions (GS) Use the Manage Amendments feature in GS Start a new amendment by clicking “New” Select the type of amendment you are creating Upload all required documents Click Verify Submission Click Final Submission These must be submitted via Grant Solutions as an amendment, not as a Grant Note. When looking at your Grants List in GrantSolutions, you will see links to view NGA (same as NOA), Grant Notes, Send Message, History, Manage Amendments. The next slide will show you a screen shot of this page. Click “Manage Amendments” and then click “New”. Select the Amendment Type (i.e. Change PI/PD) and click “Create Amendment”. You can then upload attachments. Be sure to click “Verify Submission” and then “Final Submission.”

28 Submitting an Amendment to ACL
Be sure to select “Manage Amendments” and not “Grant Notes” Here is a screen shot of your Grants List. If you do not see your grant listed, please contact GS Technical Helpdesk. I will provide that information in a couple slides. The options we discussed earlier are located there on the right—view NGA, Grant Notes, Manage Amendments, etc.

29 Submitting an Amendment to ACL
Once an amendment has been submitted, when you click on amendments, you will see any pending amendments. If you see “Submitted (Post Award)” that means you have an amendment that was submitted and is currently under review at ACL. If you do not have any pending amendments, it will say, “There are no amendments pending for this grant.” Indicates amendment has been submitted and is currently under review at ACL

30 Submitting an Amendment to ACL
ACL has GS video training on our website here: ACL strives to provide a response to a grantee’s request within 30 days of submission. If any revisions are needed on an amendment ACL will typically return the amendment to the grantee for editing and resubmission. ACL will provide a response to a grantee’s request within 30 days of submission.

31 Scenarios

32 Promotional Items Since there is no set list of approved promotional items, it is important for grantees to contact their ACL Project Officer if they plan to purchase promotional items. Promotional items must be tied to the purpose of the grant. Here is a list of items that was recently sent to a project officer. Most of these items were denied because they could not be tied to the mission of the grant. Can anyone tell me what items they think were approved or disapproved and why? For more information, please see 45 CFR (Advertising and Public Relations (Outreach Items and Space Rental and Events)), which addresses promotional items.

33 Grantee conducted a presentation with a partner to discuss Medicare
Grantee conducted a presentation with a partner to discuss Medicare. There was also someone to speak on VA benefits and Long term Care. Grantee assumed they would be speaking to residents of that facility. When grantee got there they found out it was actually marketed to the public (current residents were not invited) and it seemed very focused on why people should be looking at moving into that facility. Should grantees be avoiding events like this where it might appear that partners are pushing a specific residential facility? The gentleman who spoke about VA Aid and Assistance is actually a financial advisor, but he does the VA counseling on a volunteer basis In general, grantees should avoid doing anything that makes it look like they are promoting another business.  However, in this instance because the grantee provided unbiased opinions they did not compromise the program or themselves.

34 “In March, we purchased a flight (cost = $560
“In March, we purchased a flight (cost = $560.59) for a staff member to the upcoming Austin conference. The staff member left in June 12, No refund is available for the flight, but we have been issued a credit ($560.59) for it with a rebooking fee ($200.00) (which may or may not be used for SMP travel due to time restrictions). The flight expense was previously charged to our SMP grant that ended May 31, Please let us know if we need to take some type of corrective action with respect to this expense.” The credit issued falls under the definition of an “Applicable Credit”. Applicable Credits must be credited to the Federal award either as a cost reduction or cash refund, as appropriate; in the case of this credit, it would be credited as a cost reduction, since it is not a cash refund. However, since the credit received can be used towards the cost of the flight referenced below, it should then be used for the cost of this travel.

35 Questions?

36 Contact Information Barbara McCoy Phil McKoy Sara Vogler


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