1. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management – Overseeing Title I Compliance: Finances, and District/School Implementation 2015 GCEL Annual Conference March 2 - 4, 2015

2. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Presenters Dr. Judy Alger Georgia Department of Education School Improvement – Federal Programs Title I Education Program Specialist jualger@doe.k12.ga.us (229) 321- 9305 Dr. Olufunke Osunkoya Georgia Department of Education School Improvement – Federal Programs Title I Education Program Specialist oosunkoya@doe.k12.ga.us (678) 704-3557

3. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org 10/1/20153 SCHOOL IMPROVEMENT & DISTRICT EFFECTIVENESS

4. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Presentation Overview This presentation will explore meeting federal compliance regulations by ensuring: The district/school is correctly implementing federal programmatic and fiscal regulations and guidelines -- o Sufficient oversight of financial operations and management o Sufficient budget controls are in place o The district is following drawdown procedures o The district is following procurement procedures

5. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Oversight of Financial Operations and Management What rules apply to utilizing federal funds? State and local agencies must demonstrate fiscal control and accounting procedures to ensure the proper disbursement of and accounting for federal funds. Section 76 of EDGAR Section 80 of EDGAR

6. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Who or What is EDGAR? Education Department General Administrative Regulations (EDGAR)

7. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Financial Management Requirements EDGAR Section 76 Eligibility to receive subgrants Distribution of funds by formula or competitive Private faith-based organizations eligible to receive funds State consolidated grant application to GaDOE and US ED Assurance statements Ability for the SEA and LEA to reallocate funds based on specific federal program

8. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Financial Management Requirements EDGAR Section 76 Eligibility to receive subgrants Distribution of funds by formula or competitive Private faith-based organizations eligible to receive funds State consolidated grant application to GaDOE and US ED Assurance statements Ability for the SEA and LEA to reallocate funds based on specific federal program

9. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Financial Management Requirements EDGAR Section 80 Specific regulations governing three threshold systems: Financial Management Procurement Inventory

10. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Financial Management Requirements Definition: Controlling and accounting for federal funds and assets Used to make informed programmatic decisions Used to substantiate and document expenditures

11. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Financial Management Requirements All grantees and subgrantees must implement the requirements and maintain systems that meet specific requirements of EDGAR

12. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Financial Management Standards Seven standards described in Section 80.20(b)EDGAR Financial Reporting Accounting Records Internal Control Budget Control Allowable Cost Source Documentation Cash Management

13. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Budget Controls Pre-award planning process and technical assistance - developing and approving budgets Communication between fiscal and program staff at the SEA and LEA levels Routine reconciliation to actual expenditures at the SEA and LEA levels

14. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Allowable Cost Controls Program Regulations Formal procedures or statue relating to costs Guidelines for determining allowable costs 2 CFR 200, Uniform Guidance (Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards, EDGAR) Effective July 1, 2015 for state administered grants. Access to helpful resources and program guidance

15. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Drawdown Procedures Grantee’s “drawdown” policies and processes must comply with (EDGAR §80.20(b)(7) and §80.21) Request funds only for immediate needs Minimize time between requests and expenditures Draws should be commensurate with project completion or accomplishments

16. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Drawdown Procedures Are LEAs reimbursed or paid in advance? Section 80.21 of the EDGAR allows states to implement a payment system of reimbursing LEAs monthly, quarterly or, in some cases, semi- annually. This is a state choice and not mandated by ED Section 80.21 of EDGAR also allows LEAs to be paid in advance, based on estimated need, if they follow procedures that minimize the time between the transfer of the funds and disbursement by the LEA

17. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Drawdown Procedures To minimize risk of a financial finding based on 34 CFR 80.21 Accounting department of school district closes the books each month (this is to ensure that the expenditures are recorded in the right month and to the right fund source) Once books are closed the district runs a report to determine the funds expended for the month from fund source 402 (this fund source includes Title I, Part A)

18. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Drawdown Procedures To minimize risk of a financial finding based on 34 CFR 80.21 continued A drawdown request is then made that equals the expenditure printout (For example, the school district would draw for January in February) A copy of the expenditure report and the corresponding DE147 is kept on file to justify funds drawn

19. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Drawdown Procedures What are excess cash balances? Excess cash balances are funds maintained at the District level in excess of immediate (usually 3 days) needs. Excess cash balances must be promptly, at least quarterly, withdrawn from account and returned to the Georgia Department of Education.

20. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Drawdown Procedures What if the LEA earns interest on federal funds that have been drawn down? Subject to EDGAR 34 Part 80, a district may keep up to $100/year of interest earned on excess federal fund advances to cover administrative costs. All other amounts must be returned to the Georgia Department of Education (Department). If an LEA draws down more than 10% of its total allocation at one time a written explanation must be provided to the Department.

21. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Procurement Procedures General procurement procedures are found in EDGAR and some are found in the individual federal program statute. Follow state’s procurement procedures o State Board Policy 8200 o Purchasing Policies and Procedures Manual

22. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Procurement Procedures Consider purchases based on the following considerations: Allowable by the specific program and will be used during the grant period Reasonable Necessary for the administration and/or implementation of the grant Be authorized or not prohibited under state or local laws or regulations Be adequately documented (requisition, PO, invoice and proof of payment)

23. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Procurement Procedures Review all proposed purchases to avoid unnecessary or duplicative items o Surplus property o Structure procurement to obtain most economical purchase o Intergovernmental agreement for common goods or services o Lease vs. purchase Conduct all transactions with full and open competition – be cognizant of conflict of interest

24. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Procurement Procedures Contracted Services Contract should include clearly defined deliverables and terms Description of services to be performed or goods to be delivered Description of dates when services will be performed or goods delivered Description of locations where services will be performed or goods delivered Description of number of students/teachers/etc. to be served (if applicable)

25. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Procurement Procedures Contracted Services Remedies for breach of contract-sanctions and penalties Termination procedures Compliance with federal statues – see EDGAR §80.36(i)(3-6) Reporting procedures (if applicable) Requirements pertaining to copyrights

26. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Procurement Procedures Contracted Services Must have written invoice from the individual or company contracted Description of services performed or goods delivered Description of dates services were performed or goods delivered Description of location services were performed or goods delivered Description of students/teachers/etc. served (if applicable)

27. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Procurement Procedures Contracted Services Invoice should be reviewed & approved before payment Segregation of duties/expenditures Documented approvals

28. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Procurement Procedures Contracted Services Important to Note: In recent monitoring findings districts were cited for paying for administration fees when contracting with companies that provide personnel, for example Kelly Services, EDGAR §80.22(a)(2) and 2 CFR 200, Uniform Guidance (Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards)

29. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org District/School Programmatic and Fiscal Implementation How do you ensure the federal programs are properly implemented in your schools and system? Title I, Part A—Improving the Academic Achievement of the Disadvantaged; Title I, Part C—Education of Migratory Children; Title I, Part D—Prevention and Intervention Programs for Children and Youth Who Are Neglected, Delinquent, or At-Risk; Title II, Part A—Improving Teacher Quality;

30. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org District/School Programmatic and Fiscal Implementation How do you ensure the federal programs are properly implemented in your schools and system? Title III, Part A— Language Instruction for LEP and Immigrant; Title VI, Part B—Rural Education Achievement Program; Title X—Education for Homeless Children and Youth; School Improvement Grants under Section 1003(a) and 1003(g) of the Elementary and Secondary Education Act of 1965 (ESEA); and Race to the Top (RT3)

31. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org District/School Programmatic and Fiscal Implementation Use the Department Cross-Functional Monitoring document to organize your work Create your own month to month calendar and live by it (See the SEA calendar in Implementing Title I in Georgia Schools.) Setup files at the beginning of each year – may want to have a file for each school

32. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org District/School Programmatic and Fiscal Implementation District Level At the beginning of the year after your Title I application/budget is approved by Department: Provide a copy of the Department approved budget to the LEA finance person assigned to Title I Provide guidance on setting up the LEA budget Budget must be setup exactly as approved by Department (Example: FLP funds are budgeted in set-asides)

33. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org District/School Programmatic and Fiscal Implementation District Level After the LEA Title I finance person has set-up the budget request a copy of the summary budget and verify that the budget is set-up exactly as approved by the Department.

34. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org District/School Programmatic and Fiscal Implementation District Level Throughout the Year: Verify the Title I payroll each month from a copy provided by the finance department Ensure the number of personnel paid matches the number of personnel on the school allocation page of the consolidated application Verify expenditures each month from a Title I detailed expenditure report provided by the finance department Correct errors immediately

35. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org District/School Programmatic and Fiscal Implementation District Level Throughout the Year: Ensure that all split funded personnel complete a monthly personal activity report (PAR)/time-log if any portion of their salary is federally funded

36. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org District/School Programmatic and Fiscal Implementation District Level Throughout the Year: Verify every 3 months that PARs/time-logs are within 10% of percentage paid by each program If PARs/time-logs are not within 10% of the percentage paid by each program amend budgets to reflect actual time spent

37. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org District/School Programmatic and Fiscal Implementation District Level Throughout the Year: Ensure that the LEA provides services to private schools, N&D facilities, and other eligible entities. The LEA never writes a check to private schools, N&D facilities, or other entities The district coordinates with programs, such as 21 st Century, allowing them to provide their own services

38. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org District/School Programmatic and Fiscal Implementation District Level Throughout the Year: Proper pre-approval of regular purchases Proper pre-approval of credit purchases Proper pre-approval of payments of funds between Title I and other district programs Proper pre-approval for parent supplies Proper pre-approval of professional learning including release time Proper pre-approval of travel expenditures

39. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org District/School Programmatic and Fiscal Implementation District Level At the End of the Year Inform school personnel of deadline for submitting purchase orders Work with LEA finance personnel and vendors to ensure that outstanding orders are filled and paid Cancel any orders not filled by a set deadline

40. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org District/School Programmatic and Fiscal Implementation School Level Begin School Year with Technical Assistance Provide overview procedures and deadlines for School Title I Requirements Meet with principals o Example: Meet with Principals to explain the process they should use to complete the school’s Title I budget, explain allowable expenditures and reasonable and necessary

41. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org District/School Programmatic and Fiscal Implementation School Level Begin School Year with Technical Assistance Meet with teachers and parental involvement facilitators o Example: Meet with parent facilitators to give instructions for revising the School Parent Compacts

42. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org District/School Programmatic and Fiscal Implementation School Level Begin School Year with Technical Assistance Meet with private school officials & N&D personnel o Example: Meet with private school officials for the required consultation on providing Title I services to eligible private school students o Example: Meet with N&D personnel to discuss Title I services to students

43. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org District/School Programmatic and Fiscal Implementation School Level Technical Assistance Conduct one-on-one visits with principals or other school personnel Invite specific school personnel to your office for one- on-one or small group visits Provide written contact with emails, memoranda, handbooks, written policies, checklists, and written handouts

44. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org District/School Programmatic and Fiscal Implementation School Level Monitor Implementation Use checklists to verify that schools submit documentation to you by deadlines and complete projects correctly File documentation as you receive it from schools Keep a copy of dated agendas, dated sign-in sheets, minutes, handouts

45. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org District/School Programmatic and Fiscal Implementation School Level Monitor Implementation School Visits to Verify Program Implementation o Have a specific purpose when you visit a school o Go with a written way to document what you see (Example: a checklist) o Verify that teachers/paraprofessional are working according to the schedule sent to you o Verify that coaches are working according to job description o Verify that equipment is used regularly and correctly

46. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org District/School Programmatic and Fiscal Implementation School Level Monitor Implementation Verify that the Flexible Learning Program (FLP) program is operating according to the school’s FLP plan (Example: ask to see a copy of a student folder & verify that assessments are filed)

47. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Financial Management Obligation Obligation: transaction that requires payment Valid obligation: transaction giving rise to an obligation within the period of grant availability Records retained for 5 years from date of obligation

48. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Financial Management Obligation = transaction that requires payment Acquisition of propertyDate of binding or written commitment – PO or contract Personal services by employeeAfter services are performed Personal services by contractorDate of binding written commitment TravelAfter travel is taken

49. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Financial Management In some programs, unobligated funds can be “carried over” from first allocation year: Tydings Amendment o Does not apply to all grants o For Title I allows an additional 12 months to obligate funds Under Tydings, funds are available for 24-27 months o 15 months under the grant award o Plus 12 additional months Restricted to a 15% carryover for Title I, Part A and Title II, Part A

50. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Financial Management Liquidation–settle an obligation by paying funds All obligations must be liquidated within 90 days after the end of the obligation period SEA or LEA may impose a shorter deadline on sub grantee (SEA or LEA may be more restrictive on any federal regulation; in those cases the LEA must follow the more restrictive policy to be in compliance)

51. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Inventory Management Inventory items purchased with federal funds are divided into three categories: Real Property (if an allowable program cost) Equipment Supplies Pilferable Items

52. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Inventory Management Equipment Inventory vs. Internal Control EDGAR requires an inventory for equipment Inventory not required for supplies; however, US ED determined that an adequate internal control system must include a process for labeling and locating property purchased with federal funds and this would include pilferable (walkable) items, as well

53. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Inventory Management Equipment Federal Definition of Equipment o Tangible property o Useful life of more than one year o Acquisition cost of $5,000 or more State may use another definition as long as it includes all property described above

54. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Inventory Management Equipment Georgia requires subgrantees to keep track of pilferable (walkable) items, such as iPads, graphing calculators, cell phones, iPods, etc. Georgia does not require that books or consumable items be included on the inventory

55. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Inventory Management Supplies are small cost items that are consumed quickly US ED expects subgrantees to track all property purchased with federal funds, in order to prove there has been a benefit to the federal program

56. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Inventory Management Practical help Practical help for tracking non-equipment items Small and attractive item list o Federal Definition of Equipment o Conduct risk assessment to identify items susceptible to loss o Implement specific measures to control such items o Certain pre-defined assets (technology equipment)

57. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Inventory Management Equipment inventory-updated annually a description of the property a serial number or other identification number the acquisition date and cost of the property the percentage of federal participation in the cost of the property the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property

58. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Inventory Management Physical inventory Must be performed at least annually Indicate signature of individual(s) Must protect against unauthorized use

59. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Inventory Management When property is no longer needed, must follow disposition rules: o Transfer to another federal program o Over $5,000 – Keep or sell, but must pay a share based on the percentage of federal US ED participation at initial acquisition o Under $5,000 – May keep, sell, or dispose of it with no obligation to US ED

60. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Inventory Management Must have adequate controls in place to account for: o Location of equipment - assure that it is used solely for authorized purposes o Custody of equipment - maintain effective control and accountability o Security of equipment - adequately safeguard all property

61. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 1.A school district is subject to: A.2 CFR 200, Uniform Guidance (Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards) B.EDGAR C.Elementary and Secondary Education Act of 1965 (ESEA) D.All of the above

62. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 2.The same rules apply for district and state-administered grants since they both come initially from the U.S. Department of Education 2 CFR 200, Uniform Guidance (Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards) A.True B.False

63. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 3.A flight for a conference obligates to the federal grant award: A.On the date the employee makes his/her travel arrangements B.On the date the seat assignments are confirmed C.On the date the travel arrangements are paid in full D.On the date the traveler takes the flight to their destination

64. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 4.Expenditures for services performed by a contractor are obligated to the federal award: A.On the date the services are performed B.On the date that the grantee/subgrantee receives the invoice C.On the date that the subgrantee signs the contract D.At any point of the period of availability

65. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 5.LEAs must implement financial management systems that: A.Routinely reconciles actual expenditures to budgeted amounts B.Is capable of producing accurate, current and reliable financial reports C.Includes detailed accounting records that show the source and application of federal funds D.All of the above

66. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 6.What forms of source documentation should be maintained as records? A.Receipts for actual travel B.Copy of contracts for services performed C.Payroll registries D.Every piece of paper you can think of

67. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 7.A grantee/subgrantee must obligate all federal funds A.Within the statute of limitations B.By the end of the period of availability C.As soon as possible D.None of the above

68. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 8.Grantee and subgrantees must remit to US ED any interest earned on cash advances over: A.$100 B.$250 C.No earned interest must be remitted. All interest may be kept by the grantee or subgrantee D.All interest must be remitted to US ED

69. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 9.All obligations must be liquidated within 90 days after the end of the grant award funding period A.True B.False

70. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 10.Pursuant to EDGAR, a physical inventory of all equipment must be taken: A.Yearly B.Once every two years C.Once every six months D.Whenever you feel like it

71. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 11.If equipment is missing upon inventory review, the grantee or subgrantee must: A.Simply remove it off the inventory list B.Buy a new piece of equipment quickly C.Interview every staff member until one confesses to the theft D.Investigate

72. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 12.A conflict of interest arises when the following persons have a financial interest in a firm or company that is selected for a contract by the grantee/subgrantee: A.Me (an employee of the grantee/subgrantee) B.My son/daughter C.My husband’s/wife company is selected D.All of the above

73. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 13.The following situations restrict competitions for contracts paid for with grant funds: A.Specifying on a specific brand name B.Requiring unnecessary experience C.Organizational conflicts of interest D.B. and C. E.A. B. and C.

74. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 14.Grantees and subgrantees should retain their records for: A.1 year from the date of obligation B.3 years from the date of obligation C.5 years from the date of obligation D.10 years from the date of obligation

75. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 15.Contracts supported with federal funds must be in writing. A.True B.False

76. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 16.If a local district’s policy is more restrictive than the federal regulation, an LEA is in compliance as long as it follows the federal regulation A.True B.False

77. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 17.For a cost to be allowable to the federal grant award, it must meet the following criteria: A.Necessary and reasonable B.Allocable to the federal grant award C.Allowable under the federal grant regulations D.All of the above

78. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 18. A cost is reasonable if: A.It is on sale B.It does not cause the subgrantee to exceed its line item in the budget C.It does not exceed the cost that would be incurred by a prudent person under similar circumstances

79. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 19.If there are funds remaining at the end of the project period, they may be used to purchase goods or services to be used in the future A.True B.False

80. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 20.Generally, overhead costs such as utilities, space and electricity may be allocated to grants as direct costs if there is some benefit to the federal program. A.True B.False

81. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 21.If an employee is paid less than 8 percent with federal funds, the employee does not have to fill out a time and effort log. A.True B.False

82. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 22.An administrator that works approximately half time on IDEA administrative activities and half time on Title I, Part A administrative activities is required to keep: A.A semi-annual certification B.A monthly PAR C.Is not required to keep track of his/her time D.A weekly PAR

83. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management Test for LEAs 23.Assuming all costs are reasonable which of the following cost incurred during an overnight business trip is not allowable: A.Dinner (without any alcoholic beverages) B.Hotel room C.Mileage costs D.Ticket to a movie

84. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Questions?

85. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Title I, Part A Program Specialists’ Contact Information 10/1/201585 AreaName Office Telephone Email 1Robyn Planchard(404) 985-3808rplanchard@doe.k12.ga.us 2Randy Phillips(770) 221-5232rphillips@doe.k12.ga.us 3Anthony Threat(706) 615-0367anthony.threat@doe.k12.ga.us 4Evelyn Maddox(404) 975-3145emaddox@doe.k12.ga.us 5Judy Alger(229) 321-9305jualger@doe.k12.ga.us 6Grace McElveen(912) 334-0802gmcelveen@doe.k12.ga.us 7Jimmy Everson(229) 723-2664jeverson@doe.k12.ga.us

86. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Title I, Part A Program Specialists’ Contact Information 10/1/201586 AreaName Office Telephone Email 8Marijo Pitts-Sheffield(912) 269-1216mpitts@doe.k12.ga.us 9Kathy Pruett(706) 540-8959kpruett@doe.k12.ga.us 10Elaine Dawsey(478) 971-0114edawsey@doe.k12.ga.us 11Olufunke Osunkoya(678) 704-3557oosunkoya@doe.k12.ga.us 12Bobby Trawick(229) 246-1976btrawick@doe.k12.ga.us 13Ken Banter(478) 960-2255kbanter@doe.k12.ga.us 14Tammy Wilkes(478) 237-2873 twilkes@doe.k12.ga.us

87. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Presenters Dr. Judy Alger Georgia Department of Education School Improvement – Federal Programs Title I Education Program Specialist jualger@doe.k12.ga.us (229) 321- 9305 Dr. Olufunke Osunkoya Georgia Department of Education School Improvement – Federal Programs Title I Education Program Specialist oosunkoya@doe.k12.ga.us (678) 704-3557

88. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Grants Management – Overseeing Title I Compliance: Finances, and District/School Implementation 2015 GCEL Annual Conference March 2 - 4, 2015