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Seminar on Financial Management Office of Justice Programs Office of the Chief Financial Officer
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Financial Management Systems
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All recipients are required to: Establish/maintain auditable accounting records and Establish/maintain auditable accounting records and Accurately account for funds awarded. Accurately account for funds awarded. Records shall include Federal, matching, and program income. Financial Management Systems
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States and locals shall expend/account for grant funds per Federal or State laws & procedures for their funds. (whichever are more restrictive) Financial Management Systems
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Accounting and Internal Controls: Proper stewardship of Federal resources is an essential responsibility of the grantee organization. Grantees must ensure that Federal programs and resources are used efficiently and effectively to achieve desired objectives. Financial Management Systems
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Internal Controls and Segregation of Duties: Strong internal controls ensure effective and efficient operations, reliable financial reporting, and compliance with applicable laws and regulations. Proper segregation of duties is a critical element of adequate internal control. Financial Management Systems
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Adequate Accounting System: Grantee must maintain an adequate system of accounting and internal controls and ensure that an adequate system exists for each of its subrecipients. Financial Management Systems
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In summary, a Financial Management System must be able to record and report on the: Receipt; Obligation; and Expenditures of grant funds Financial Management Systems
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Applicable laws and regulations affecting Federal grant funds
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1) Authorizing Legislation - Congress - Congress 2) Federal Agency Regulation - Code of Federal Regulation (CFR) - Code of Federal Regulation (CFR) 3) Terms and Conditions of the Award - Grant Award Document - Grant Award Document 4) Federal Agency Policies - OJP Financial Guide - OJP Financial Guide ORDER OF PRECEDENCE
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The Code of Federal Regulations (CFR) is the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government. Code of Federal Regulations
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Department of Justice 28 CFR 66 - Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments 28 CFR 70 - Uniform Administrative Requirements for Grants and Agreements (including subawards) with Institutions of Higher Education, Hospitals, and other Non- Profit Organizations Code of Federal Regulations
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OMB AdministrativeRequirements: OMB A-102 (2 CFR, Part 215) CostPrinciples: OMB A-21 (2 CFR, Part 220) OMB A-87 (2 CFR, Part 225) OMB A-122 (2 CFR, Part 230) Audit Requirements: OMB A-133 OMB A-110 28 CFR 66 28 CFR 70 Included as reference in CFR DOJ APPLIES TO State & Local Units of Government Non-Profit Organizations Educational Institutions Non-Profit Organizations State & Local Units of Government Educational Institutions Non-Profit Organizations State & Local Units of Government
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CIRCULARS CIRCULARS Directives from Office of Management and Budget (OMB) Implemented by policy from each Federal agency Agencies policy can be more restrictive OMB CIRCULARS
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REQUIRES THAT A COST BE: Allowable Necessary to the performance of a project Reasonable Allocable to the project and consistently treated Major Provisions Code of Federal Regulations
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REQUIRES THAT A COST BE: (continued) Non-profitable Claimed against only one award, and Permissible under State & Federal laws and regulations Major Provisions Code of Federal Regulations
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CLASSIFICATION OF COSTS Major Provisions Code of Federal Regulations
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DIRECT COSTS: DIRECT COSTS: Costs identified specifically with an activity CLASSIFICATION OF COSTS
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DIRECT COSTS, generally include: Salaries and Wages (including holidays, sick leave, etc.) - Direct Labor Costs Other employee fringe benefits allocable to direct labor employees CLASSIFICATION OF COSTS
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DIRECT COSTS, generally include: Consultant services contracted to accomplish specific project objectives Travel of direct labor employees Material/supplies purchased directly for use on a specific project CLASSIFICATION OF COSTS
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INDIRECT COSTS: Costs that are not readily identifiable with a particular grant or contract CLASSIFICATION OF COSTS
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MATCH
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MATCHCASHversusIN-KIND
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Matching funds are generally not required for Recovery Act awards. However, if match was included in the approved budget, this amount is subject to audit and must be tracked separately.MATCH
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SUPPLANTING FINANCIAL MANAGEMENT SEMINAR FINANCIAL MANAGEMENT SEMINAR
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To deliberately reduce State or local funds because of the existence of Federal funds. Example: State funds are appropriated for a stated purpose and Federal funds are awarded for that same purpose. The State replaces its State funds with Federal funds, thereby reducing the total amount available for the stated purpose. SUPPLANTING
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Application Review OMB has implemented a grant tracking system through Dun & Bradstreet (D&B) known as Data Universal Numbering System (DUNS). All grant applicants (excluding individuals) must have a DUNS number when applying for initial or supplemental awards. Organizations may receive a DUNS number at no cost by calling the toll-free DUNS number request line at 1-888-814-1435 or on-line at https://eupdate.dnb.com/requestoptions.asp FINANCIAL MANAGEMENT SEMINAR
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Both current and potential grant applicants are required to register in Central Contractor Registration (CCR) Grant applicants are required to complete a one-time registration Grant applicants must update or renew their registration at least once per year to maintain active status Registration does not guarantee a federal contract or assistance Application Review FINANCIAL MANAGEMENT SEMINAR
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History with OJP (if any) Financial Capability Questionnaire (Non-profits) Grantee Audits Applicant Federal Debt Accuracy of Taxpayer ID Financial Integrity FINANCIAL MANAGEMENT SEMINAR
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High Risk Grantees Have not conformed to the terms and conditions of previous awards Are otherwise not responsible Have open Single Audit or Office of Inspector General (OIG) audit report recommendations Have significant non-compliance issues FINANCIAL MANAGEMENT SEMINAR
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Award Notification and Acceptance FINANCIAL MANAGEMENT SEMINAR
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The ANA module deployed through the Grants Management System (GMS) will electronically issue an award instead of mailing it. The grant recipient will receive an e-mail on the award date instructing them to utilize GMS to accept their award. Award Notification and Acceptance (ANA)
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Grantee has 45 days from the date of the award to accept the award If not accepted within 45 days, the obligation may be terminated without further cause Award Notification and Acceptance (ANA)
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To accept the award the recipient should: Recipient must go into GMS and designate a Financial Point of Contact (FPOC) in order to print the award documents. Review and print their award in GMS. Have authorizing official accept and sign the award and initial each page of special conditions. Fax the complete award package to OCFO at (toll free) 1-866- 388-3055 or (local) 202-354-4081, or email the pdf file to acceptance@usdoj.gov. Electronic notification will allow grantees to receive the award and implement their programs sooner. Award Notification and Acceptance (ANA)
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Conditions of Award FINANCIAL MANAGEMENT SEMINAR
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1. The recipient agrees to comply with the financial and administrative requirements set forth in the current edition of OJP's "Financial Guide." The United States Department of Justice Office of Justice Programs Office if the Comptroller Financial Guide Conditions of Award http://www.ojp.usdoj.gov/financialguide
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2. The recipient agrees to comply with the organizational audit requirements of OMB Circular A-133, Audits of State, Local Governments and Non-Profit Organizations, as further described in OJP's Financial Guide, Chapter 19. Note: There is a different special condition for individuals and for-profit commercial organizations. Conditions of Award
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3. The recipient acknowledges that failure to submit an acceptable Equal Employment Opportunity Plan (if recipient is required to submit one pursuant to 28 CFR Section 42.302), that is approved by the Office of Civil Rights, is a violation of its Certified Assurance and may result in funds from the award being frozen, until such time as the recipient is in compliance. Conditions of Award
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New Changes to Anti-Lobbying Act: 4. Recipient understands and agrees that it cannot use any federal funds, either directly or indirectly, in support of the enactment, repeal, modification or adoption of any law, regulation or policy, at any level of government, without the express prior written approval of OJP. Conditions of Award
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5. The recipient must promptly refer to DOJ/OIG any credible evidence that a principal, employee, agent, contractor, subgrantee, subcontractor, or other person has either 1) submitted a false claim for grant funds under the False Claims Act; or 2) committed a criminal or civil violation of laws pertaining to fraud, conflict of interest, bribery, gratuity, or similar misconduct involving grant funds. This condition also applies to any subrecipient. Conditions of Award
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Potential fraud, waste, abuse, or misconduct should be reported to the OIG by – Mail: Office of the Inspector General U.S. Department of Justice Investigations Division 950 Pennsylvania Avenue, N.W. Washington, DC 20530 E-mail: oig.hotline@usdoj.gov Conditions of Award
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Hotline: (800) 869-4499 (contact information in English and Spanish) Hotline fax: (202) 616-9881 Additional information is available from the DOJ OIG website at www.usdoj.gov/oig Conditions of Award
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New Language to the Standard Assurances The Standard Assurances form has been updated to incorporate compliance requirements codified under 28 CFR Part 38 regarding the eligibility for religious organizations to receive grant funds and the prohibition from discrimination, among other provisions. FINANCIAL MANAGEMENT SEMINAR
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Availability of Funds FINANCIAL MANAGEMENT SEMINAR
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Obligation Period (Grantee’s books) EX: Award period = 10/1/07 - 9/30/09 Award date = 12/1/07 (Federal books) Expenditure Period EX: 10/1/07 - 12/29/09 Liquidation Period (90 days after end of award) Ex: 10/01/09 - 12/29/09 Funds will be frozen 90 days after the end of the award. Funds will be frozen 90 days after the end of the award. AVAILABILITY OF FUNDS
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Costs incurred prior to the project start date Written prior approval Pre-agreement Costs AVAILABILITY OF FUNDS
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PROGRAM INCOME FINANCIAL MANAGEMENT SEMINAR
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Gross income earned by the recipient during the funding period as a direct result of the award. PROGRAM INCOME
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Spend prior to requesting additional grant funds Supplement Project with $$ Reduce Project with $$ Send Back $$ PROGRAM INCOME
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FINANCIAL MANAGEMENT SEMINAR Payment of Grant funds
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PHONE ACTIVATED PAPERLESS REQUEST SYSTEM (PAPRS) Grantee calls directly to OJP by using a touch tone telephone requesting funds 810 PAPRS checks against certain parameters and either approves or denies request Funds are deposited into the Grantee’s bank account, usually within 72 hours Approved requests are forwarded to the U.S. Department of Treasury for payment processing
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PAPRS PROCESS 1. Have signed & returned award document 2. Have current SF-425 on file TOP TEN TIPS
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3. Have met all special conditions PAPRS PROCESS 4. Have submitted an ACH Enrollment Form TOP TEN TIPS
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PAPRS PROCESS 5. Have OJP vendor number 6. Have a PIN number TOP TEN TIPS
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7. Have a Grant ID number PAPRS PROCESS 8. Double checked dates for duplicate request TOP TEN TIPS
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9. Know the amount you are requesting PAPRS PROCESS 10. Pay attention to system responses At the end of the award period, drawdown all allowable expenses within 90 days TOP TEN TIPS
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PAPRS Need Help? OJP - OCFO Customer Service Center 1-800-458-0786 COPS - DOJ Response Center 1-800-421-6770 Payment of Grant Funds
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FINANCIAL MANAGEMENT SEMINAR How to make changes to the grant award
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FINANCIAL MANAGEMENT SEMINAR Grant Adjustments Notice (GAN)
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10% Deviation from Total Award $$ (does not apply to grants $100K or less) Change in Scope of Project Change in Project Period (no cost extension) Retire Special Conditions GRANT ADJUSTMENTS NOTICE FINANCIAL MANAGEMENT SEMINAR
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Change of Key Staff Change of authorized signing official Change in mailing address Change in organization name Prior Approval of grant costs Reobligate/Deobligate Funds GRANT ADJUSTMENTS NOTICE FINANCIAL MANAGEMENT SEMINAR
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Reporting Requirements
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REPORTSYSTEM Section 1512(c) Cumulative reporting for Recovery Act Awards FederalReporting.gov FFR/SF-425 Federal Financial Report (Formerly SF-269) Grants Management System (GMS) Progress Reports Program/Project Activity Reports Grants Management System (GMS) Performance Measures Performance Measurement tool (PMT) Grants Management System (GMS) Other Reports (Conference cost reporting, etc.) Grants Management System (GMS) Reporting Requirements
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Federal Financial Report (SF-425)
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Quarterly Federal Financial Reports are submitted through the Grants Management System (GMS) at https://grants.ojp.usdoj.gov. Effective October 1, 2009, grant recipients will be required to report grant expenditures utilizing the Federal Financial Report Form 425 (SF-425). This form replaced the Financial Status Report (FSR), known as the SF-269. Federal Financial Report (SF-425)
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Financial information reported on the SF-425 is similar to the SF- 269. The SF-425 quarterly report must be submitted no later than 30 days after the end of each calendar quarter. Federal Financial Report (SF-425)
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CLICK HERE
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cinderella *********
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Smallville Police Department 123 Main Street Nicetown, USA 12356 2009-XX-XX-1234
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Chief Financial Officer jdoe@smallvile.gov Doe 912345678 10/25/2009 John Mr
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2009-XX-XX-1234
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SF-425 – due Quarterly Funds will be frozen if report is not submitted within 30 days Reporting PeriodDelinquent After Oct 1 - Dec 31January 30 Jan 1 - Mar 31April 30 Apr 1 - Jun 30July 30 Jul 1 - Sept 30 October 30 Federal Financial Report (SF-425)
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Problems with SF-425? Contact: OCFO Customer Service Center 1-(800)-458-0786 or (202) 305-9988 Email: ask.ocfo@usdoj.gov Fax#: (202) 353-9279 Federal Financial Report (SF-425)
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FINANCIAL MANAGEMENT SEMINAR State, Local Governments, & Non-Profit Organizations Audit Requirements OMB A-133
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A-133 Gov't, Education and Non-Profit Thresholds (expended) $500K or more - Single Audit (expended) Audit Report - due nine (9) months after end of FY Submit to Federal Audit Clearinghouse (FAC) in Jeffersonville, IN $10,000 Questioned Costs AUDIT REQUIREMENTS
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Commercial Organizations and Individuals Submit one copy to the Office of Justice Programs, Office of the Chief Financial Officer. If audit report is delinquent, funds may be withheld. SINGLE AUDIT
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For fiscal periods ending on or after January 1, 2008, the Federal Audit Clearinghouse requires all grant recipients to submit form SF SAC and the Single Audit Report package online utilizing the Internet Data Entry System (IDES). If audit report is delinquent, funds may be withheld. SINGLE AUDIT
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To use the online system: http://harvester.census.gov/fac/collect/ddeindex.html# Questions about submission can be addressed to: Phone #:800-253-0696 Email:govs.fac@census.gov If audit report is delinquent, funds may be withheld. SINGLE AUDIT
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A Potential Hazard Suggested Grant File Format The file should tell the story.
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The three stages of an award: Administration Application Award Administration Suggested Grant File Format Manila File Folder
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MONITORING DISCUSSION FINANCIAL MANAGEMENT FINANCIAL MANAGEMENT SEMINAR
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Grants Financial Management Division’s Mission Ensure stewardship over Federal funds awarded by: On-Site financial reviews On-Site financial reviews OCFO-Based financial reviews OCFO-Based financial reviews Technical assistance to grantees Technical assistance to grantees Monitoring Discussion
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What will be reviewed during the on-site visit? Internal Controls Accounting System Accounting procedures including cash management procedures Federal Financial Reports (SF-425s) Compliance with Recovery Act Reporting Requirements and Special Conditions (if applicable) Test and Analyze expenditures Provide technical assistance Monitoring Discussion
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The primary grant recipient is responsible for monitoring the subrecipient and ascertaining that all fiscal and programmatic responsibilities are fulfilled, including compliance with Federal rules and regulations (e.g., OMB Circular A-133 compliance, EEO compliance) Primary Grantee’s Responsibility
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FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT OF 2006
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FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT OF 2006 (FFATA) FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT OF 2006 (FFATA) Commenced in FY 2007 Full disclosure of all entities receiving Federal funds Provide the public with information about how tax dollars are spent OMB single searchable website: www.USAspending.gov
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Final 2008 guidance on the FFATA Applicants required to use Dun and Bradstreet Data Universal Numbering System (DUNS) as the unique identifier Applicants required to maintain current information in the Central Contractor Registration (CCR) database Recipients and subrecipients must report obligations for subawards starting January 1, 2009 Exceptions for Individuals
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Action Checklist for recipients of Federal Funds Get a DUNs number Register with CCR Ensure that you are making all preparations necessary for reporting accurate information pertaining to your organization’s subawards. Be prepared to meet timely reporting requirements for all funds under a subaward: –Federal agencies will expect requisite data –Will be a condition of your award Be prepared for heightened public scrutiny of your federal government grants, cooperative agreements, other types of Federal financial assistance and contracts.
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CLOSEOUTS
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Award recipients have 90 days after the end date of the award to close out the award. Cash Reconciliation Request reimbursement of funds to cover expenditures. Request reimbursement of funds to cover expenditures. The Federal expenditures must be equal to or greater than the cash disbursements from the awarding agency. The Federal expenditures must be equal to or greater than the cash disbursements from the awarding agency. Drawdown of Funds Request final payment Request final payment Funds will be frozen after 90 days Funds will be frozen after 90 daysCLOSEOUTS
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CLOSEOUT REQUIREMENTS: Final Federal Financial Report (SF-425) Final Federal Financial Report (SF-425) Final Progress Report Final Progress Report Refund Excess Cash Refund Excess CashCLOSEOUTS
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Refund excess cash Make check payable to DOJ/Office of Justice Programs Make check payable to DOJ/Office of Justice Programs Cover letter or voucher containing the grant number for the refund, itemization of funds and the unobligated balance. Cover letter or voucher containing the grant number for the refund, itemization of funds and the unobligated balance. Printout of the final SF-425 report which supports the amount of the refund Printout of the final SF-425 report which supports the amount of the refund Failure to remit payment to OJP will be referred to the U.S. Department of the Treasury for collection. Failure to remit payment to OJP will be referred to the U.S. Department of the Treasury for collection.CLOSEOUTS
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FINANCIAL MANAGEMENT SEMINAR Resources
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OJP Financial Guide The United States Department of Justice Office of Justice Programs Office if the Comptroller Financial Guide Electronic Access for the OJP Financial Guide via Internet http://www.ojp.usdoj.gov/financialguide
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Part I - General Information Part II -- Pre-award Requirements Part III -- Post Award Requirements Part IV -- Organization Structure Financial Guide Organization OJP Financial Guide
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OCFO Financial Questions via Internet OCFO e-mail Address: ask.ocfo@usdoj.gov ask.ocfo@usdoj.gov
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OCFO Financial Questions via Telephone OCFO Customer Service Center Monday through Friday Monday through Friday 8:30 a.m. - 6:00 p.m. est. 1-(800) 458-0786 or (202) 305-9988 FAX (202) 353-9279
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Contact Information John Martin 202-305-9731 John.Martin3@usdoj.gov Questions and Answers Al Roddy 202-353-1881 Al.Roddy@usdoj.gov GMS Helpdesk 888-549-9901, opt 3
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Over 1,500 Programs Represents $400b 52 Agencies Search by Keyword http://www.cfda.gov Catalogue of Federal Domestic Assistance (CFDA) HOW TO ACCESS GRANT $$
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To access CFDA on-line GSA Home Page Publications https://www.cfda.gov HOW TO ACCESS GRANT $$
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For more information Call the Federal Service Desk: 1-866-606-8220 FEDERAL DOMESTIC ASSISTANCE CATALOG STAFF 307 - 7th Street, S.W. Room #101 WASHINGTON, D.C. 20407 HOW TO ACCESS GRANT $$
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One Stop Shopping – www.grants.gov Allows organizations to electronically find and apply for competitive grant opportunities from all Federal grant making agencies. Individuals looking for information on Government benefits should refer to GovBenefits.gov HOW TO ACCESS GRANT $$
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Electronic Access to Circulars & Common Rules via Internet OMB Home Page: www.whitehouse.gov/omb/ Select "Circulars"
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THE END
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