1. Page 1 Discretionary Grant Administration

2. Page 2  Overview of ED financial policies  Managing budget  Avoiding audit problems  Identifying key resources such as Grantmaking at ED Agenda www.ed.gov/fund/grant/about/grantmaking/index.html

3. Page 3 Legislation Regulations EDGAR Cost Principles (2 CFR/OMB Circulars) Grant Award Notification (GAN) Your approved Application *G5 Tools of the Trade

4. Page 4 2 CFR Part 220 for Educational Institutions (see OMB Circular A-21) 2 CFR Part 225—for State, Local and Indian Tribal Governments (see OMB Circular A-87) Cost Principles http://www.gpoaccess.gov/cfr/index.htmld

5. Page 5 ¯Project’s success and financial accountability ¯Submit annual & final performance reports Grantee Responsibilities 4 Valid & reliable data 4 Report on GPRA standards & indicators EDGAR §§74.51 & 80.40

6. Page 6  Clear, concise, and detailed  Consistent with institutional policy  Meets federal requirements  Aligned with GPRA  Revised within scope of project  Achieve project goals Monetary Road Map

7. Page 7 must do the following… Provide for accurate, current, and complete disclosure of results regarding the use of project funds Document both the federal and non-federal funds used to carry out the project and track partners Financial Management Systems

8. Page 8 Provide for accurate current, and complete disclosure of results regarding the use of project funds Document both the federal and non-federal funds used to carry out the project and track partners Maintain effective internal controls Financial Management Systems

9. Page 9 Allowable – permitted or not specifically prohibited Allocable – necessary for project’s success Reasonable – costs incurred by a “prudent” person Budget Items

10. Page 10 Cost Sharing/Matching

11. Page 11 Cost Sharing/ Matching Definition: The portion of project/program costs not borne by the Federal government Terms are used interchangeably and refer to either: Statutorily-specified percentage of project/program costs that must be Voluntary contribution Grantee must honor the commitment Fully documented

12. Page 12 Cost Sharing/ Matching Examples include: equipment, facilities, cash staff time Must be treated like Federal dollars See EDGAR 74.23 and 80.24

13. Page 13 Cost-Share Calculation Applicant’s cost-share requirement is 25% of the total cost of the project. Total project: Fed share X applicant share = Match Federal share % of total cost Amount Total project costs = Federal share + Match Amount

14. Page 14 Audits

15. Page 15  Missing time and effort reports  Poor record-keeping  Failure to obtain prior approval  Incorrect indirect cost rates  Unallowable costs  Lack of internal controls Common Audit Exceptions

16. Page 16  Non-Federal audit if expending $500,000 or more annually in Federal awards  Mail to Federal Audit Clearinghouse  Review Attachment C Audit Requirements OMB Circular A-133

17. Page 17 Grant Monitoring

18. Page 18  Request funds for immediate needs  Minimize time between requests & expenditures  Draws commensurate with approved scope Drawdown Policy

19. Page 19 Rate of drawdown must be commensurate with approved scope of work and milestones  Draw down only enough cash to meet grant’s immediate need  Minimize time between drawdown and payout of funds ED’s Drawdown Policy

20. Page 20  Documented unsatisfactory performance  Financially unstable  Non-standard management  Non-conformance to terms/conditions  Otherwise not responsible High-risk Designation Necessary to ensure compliance with grant requirements

21. Page 21 Grantee Flexibility

22. Page 22 Goals:  Increase flexibility  Increase accountability  Reduce paperwork burden  Develop relationships Grantee Flexibility Promote successful project outcomes

23. Page 23 Changes in project scope or objectives Changes in key personnel IHE & non-profit project directors > absent for more than 3 months > 25% reduction in time Need for additional Federal funds Prior Approval

24. Page 24  No-cost extensions require RSA Project Officer approval and will be reviewed on a case-by-case basis (Note: Discretionary Grants operated by the Training Programs Unit in RSA are restricted by the terms and conditions of their award under Attachment “Z” in the GAN.  Attachment “Z” does not permit the grantee to extend the grant without RSA approval.  Requests for no-cost extensions must be submitted at least 45 days in advance of the end of the grant period of performance. Time Extension

25. Page 25  No later than 10 days before project ends  State reasons for extension  Include revised expiration date Time Extension Written notice to Program Officer

26. Page 26 Time Extension Restrictions Not just for using unexpended funds No additional Federal funds No change to scope or objectives

27. Page 27  Large amounts of unobligated funds at end of budget period  Excessive or infrequent drawdown of funds  Project goals not met ED Concerns

28. Page 28  Annual substantial progress met  GPRA indicators met  Recordkeeping & fiscal accountability What Agencies Look For

29. Page 29 Questions?