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Title I, Part A and The Grants Accounting Approval Process
June 15-19, 2015 13 Annual Title Programs Summer Conference 2/24/2019
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Title I, Part A and The Grants Accounting Approval Process
Presented by Anthony L. Threat Title I Education Program Specialist Regina Hailey Grants Accountant Manager Georgia Department of Education
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Agenda Monitoring Findings and Grants Management
Overview of Grants Accounting Process Importance of communication between LEA’s, Program Managers and Grants Accounting Inventory Monitoring Monitoring Preparations Response to Monitoring Findings Question and answers
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Purpose of Presentation
Title I, Part A Guidance concerning Grant Management Overview of the FY16 Consolidated Application Checklist and Grants Management Overview of Consolidated Application Approval Process and Grants Management Monitoring Findings and Grants Management Overview of Grants Accounting Process Importance of communication between LEA’s, Program Managers and Grants Accounting
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FY16 Consolidated Application Provisioning
Properly provisioned in the LEA Monitoring Application. District Security Officer Superintendent Title I Coordinator Chief Financial Officer
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Maintenance of Effort (MOE), Comparability, Supplement Not Supplant, and Internal Controls
CITATION: Grantees are responsible for managing the day-to-day operations of grant and sub grant supported activities. Grantees must monitor grant and sub grant supported activities to assure compliance with applicable Federal requirements and that performance goals are being achieved. Grantee monitoring must cover each program, function or activity. [2 C.F.R. Part 200] 2/24/2019
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Maintenance of Effort (MOE), Comparability, Supplement Not Supplant, and Internal Controls
The LEA ensures that it complies with-- The procedures for ensuring that the LEA has sufficient internal controls to ensure federal programs compliance. 2/24/2019
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Maintenance of Effort (MOE), Comparability, Supplement Not Supplant, and Internal Controls
Title I, Part A; School Improvement 1003(a); School Improvement 1003(g) (SIG); Title I, Part C; Title I, Part, D; Title II, Part A; Title III, Part A; Title VI, Part B; Title X, Part C-- McKinney-Vento Act, if applicable. 2/24/2019
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Maintenance of Effort (MOE), Comparability, Supplement Not Supplant, and Internal Controls
LEA's drawdown requests that are consistent with The Department's DE0147, and LEAs request are supported by accounting records of outlays expenditures) prior to but not more than 2 days usually of request. Payments to LEA were determined to meet immediate cash needs. 2/24/2019
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Maintenance of Effort (MOE), Comparability, Supplement Not Supplant, and Internal Controls
2/24/2019
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Maintenance of Effort (MOE), Comparability, Supplement Not Supplant, and Internal Controls
2/24/2019
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Maintenance of Effort (MOE), Comparability, Supplement Not Supplant, and Internal Controls
Cash Management Written policy or procedure that provides: Internal controls to segregate duties associated with cash management, monitoring of cash management activities (including reconciliations), reimbursements are made only after costs have been incurred, or cash advances Are made as close as is administratively possible(not more than 2 days) to actual cash outlay. 2/24/2019
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Maintenance of Effort (MOE), Comparability, Supplement Not Supplant, and Internal Controls
Public Law , 31 U.S.C & 6503, CMIA of 1990, 2 C.F.R. Part 200 Uniform Grants Administrative Requirements 2/24/2019
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Maintenance of Effort (MOE), Comparability, Supplement Not Supplant, and Internal Controls
Public Law , 31 U.S.C & 6503, CMIA of 1990, 2 C.F.R. Part 200 Uniform Grants Administrative Requirements 2/24/2019
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Maintenance of Effort (MOE), Comparability, Supplement Not Supplant, and Internal Controls
Title I, Part A Cash Management The LEA provides evidence of methods and procedures for payment that shall minimize the time elapsing between the transfer of funds and disbursement by the grantee or sub grantee Sub recipients’ requests for federal funds are evaluated, and drawdowns of federal cash are only for immediate needs 2/24/2019
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Maintenance of Effort (MOE), Comparability, Supplement Not Supplant, and Internal Controls
Title I, Part A Cash Management Evidence that LEAs do not draw funds before actual need. Excess cash balances are funds maintained at the recipient/sub recipients level in excess of immediate (usually 3 days) needs. 2/24/2019
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Maintenance of Effort (MOE), Comparability, Supplement Not Supplant, and Internal Controls
Evidence that LEAs do not draw funds before actual need. Excess cash balances are funds maintained at the recipient/sub recipients level in excess of immediate (usually 3 days) needs. 2/24/2019
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Findings Cash Management Findings/Cash Management
Sub recipients' requests for federal funds are evaluated, and drawdowns of federal cash are only for immediate needs. Evidence that LEAs do not draw funds before actual need. Excess cash balances are funds maintained at the recipient/sub recipient’s level in excess of immediate (usually 3 days) needs. Finding/Current Condition The School District did not provide evidence of any drawdowns made from Title I, Part A. The District did not start posting/ applying expenditures to the general ledger for this fiscal year until October 1, Details (PO's, invoices, payroll registers, etc.) that support the drawdowns were not available for review during the monitoring visit. It could not be determined by the spreadsheet provided that the expenditures were paid within the two day requirement. 2/24/2019
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Findings Corrective Action:
The School District must submit to the Georgia Department of Education (Department) written procedures that provide the necessary internal controls that the District will implement to ensure effective and efficient operations associated with cash management, monitoring of cash management activities (including the process for drawing down funds) in compliance with laws and regulations, and Department guidelines specific to Title I, Part A. The procedures must also include how the District will monitor the implementation of the procedures, as well as, the person(s) responsible for monitoring the implementation of the procedures. 2/24/2019
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Maintenance of Effort (MOE), Comparability, Supplement Not Supplant, and Internal Controls
Title I, Part A Cash Management Policies/procedures that indicate how subrecipient requests are evaluated before funds are released for reimbursement 2/24/2019
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Questions and Answers
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Helpful Resources Title I Handbook – Current Edition
NCLB Act of 2001 (Blue Book) Department Web site – US ED Web site – FY16 LEA Monitoring Form Education Support Services Operations Manual
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Helpful Resources 2 C.F.R. Part 200, Uniform Guidance (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards) Education Department General Administrative Regulations (EDGAR)
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Title I Education Program Specialists Contact Information Area Name Phone Number 1 Robyn Planchard (404) 2 Randy Phillips (770) 3 Anthony Threat (706) 4 Evelyn Maddox (404) 5 Judy Alger (229) 6 Grace McElveen (912) 7 Jimmy Everson (229) 8 Marijo Pitts-Sheffield (912) 9 Kathy Pruett (706) 10 Elaine Dawsey (478) 11 Olufunke Osunkoya (678) 12 Bobby Trawick (229) 13 Ken Banter (478) 14 Tammy Wilkes (478)
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Grants Accounting Regina Hailey Manager, Grants Accounting for Title I
2/24/2019
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Budgets Budget by function and object codes
Coordinate submitting budgets within the system Monitor Budgets(communication between LEA, Program and Grants Accounting)
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How will you know if grant is approved?
The grant goes through a sign-off process Coordinator sign-off Superintendent sign-off Program Manager sign-off Grants Accounting Approval 2/24/2019
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When can an Amendment be Created?
An amendment can be created(by Coordinator or Grants Accounting) once a grant is in approved status. Why would an amendment be created? When carryover/additional allocation is added to original allocation by Grants Accounting. When the system needs to revise how the funds were budgeted. Follow same steps as doing an original budget 2/24/2019
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When can an Amendment be created?
Outside of function code variance 25-percent variance Change in the scope of the program Post audit purposes
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Completion Report Grant Period-07/01/XX – 09/30/XX Due 10/31/XX
Expenditures as of September 30th Report expenditures by function and object Refunds/Cash Shortages Request to reopen Completion Reports
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Completion Report 2/24/2019
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Closed Grant 2/24/2019
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Program Managers Status Report
Assist program managers and directors to monitor spending by grantees Shows total percentage of grant spent based on expenditures Read only document Can be exported to Excel 2/24/2019
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GRANTS ACCOUNTING TEAM
DELLA KILPATRICK – ACCOUNTING MANAGER ( ) REGINA HAILEY – MANAGER, GRANTS ACCOUNTING ( ) PHYLLIS RAINES – GRANTS ACCOUNTANT ( )
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Questions and Answers 2/24/2019
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