1. SIF Sub-Grantees Subaward Agreement/ MOU Webinar Prepared by Steve Adams, Deputy Director, NFWS February 11, 2011

2. Agenda  Introduction  Why The Language is There  Reviewing Subaward Agreement  Reviewing MOU  Other Discussion 2

3. Introductions  Steve Adams (NFWS)  Shannon Mason (NFWS)  Jill Moriello (JFF Grants Management Analyst)  Ruth French – auditor at JFF (fed funds experience) 3

4. We’re new at federal subgranting  Re-granting federal funds is fairly new to us. So we haven’t tested our subaward agreements much.  Subaward could have been clearer and with fewer requirements.  We should have provided additional guidance along with fiscal webinar. 4

5. Why the language is there  Our federal grant from CNCS/SIF requires that we notify subgrantees that the same rules apply to them  We have to show we’re in compliance  Again, could have been clearer with you 5

6. The Subaward agreement  Go to Subaward agreement  Go to MOU 6

7. Cost Principals Allowable/Unallowable Allocable Reasonable Consistent 7

8. Allowable Costs Be included in the Approved Budget Be reasonable and allocable for the performance of the award Be given consistent treatment within the entire organization Be in accordance with GAAP Not included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program 8

9. Unallowable Costs  Examples Lobbying Fines and Penalties Expenses not necessary to meet program objectives Costs that would constitute waste, fraud and abuse Unreasonable costs from a “prudent person” perspective 9

10. Allocable Costs  A cost is allocable to the grant if: It is treated consistently with other costs incurred for the same purpose in like circumstances and if:  It is incurred specifically for the award  Benefits both the award and other work and can be distributed in reasonable proportion to the benefits received or  Is necessary to the overall operation of the organization 10

11. Reasonable A cost is reasonable if, in its nature or amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the costs 11

12. Consistent Grantees must be consistent in assigning costs Regardless of the source of funding, i.e. federally or non-federally sponsored activities, and Following written cost allocation plan, as applicable Charges must be consistent with those normally allowed in like circumstances in the organization’s non-federally sponsored activities 12

13. Proper Documentation is a Must Allowable Allocable Reasonable Consistently Applied 13 Document, Document, Document

14. Tracking Federal Intermediary and Sub- Grantee Revenues and Expenditures 14

15. Efficient Accounting System  Accounting system must be capable of: Distinguishing between grant vs. non grant related expenditures Identifying costs by Program Year Identifying costs by Budget Category Accounting for each award/grant separately Properly segregates fund sources Easily provide management with financial reports at both the detail and summary levels 15

16. Fiscal Responsibility Highlights  Effective Financial Management Written and followed policies and procedures Qualified and trained financial staff Effective communications Succession planning and cross-training Self-assessment and continuous improvement Active, knowledgeable and informed Board and finance committee 16

17. Fiscal Responsibility Highlights (continued)  Overall compliance with State and Federal regulations  Accurate, timely and complete financial reporting  Tracking of budget to actual expenses  Ensure key staff understand roles, responsibility, understand each other’s priorities and work together 17

18. Criminal History Check  Statewide Criminal History Search  www.NationalSexOffenderRegistry.gov www.NationalSexOffenderRegistry.gov  Differs by State  FBI can be substituted for a statewide search  Murder is the only disqualifier  Required personnel: Anyone receiving a salary  Prime or Sub-grantee level—all are required  Refer to CNCS FAQ on website for further assistance 18

19. 19 DISCUSSION