1. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Grants Management – Overseeing Title I Compliance: Finances, and District/School Implementation 2014 GCEL Annual Conference February 24 - 26, 2014

2. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Presenters Dr. Judy Alger Georgia Department of Education Title I Education Program Specialist jualger@doe.k12.ga.us (229) 321- 9305 Dr. Olufunke Osunkoya Georgia Department of Education Title I Education Program Specialist oosunkoya@doe.k12.ga.us (678) 704-3557

3. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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 -- Sufficient oversight of financial operations and management Sufficient budget controls are in place The district is following drawdown procedures The district is following procurement procedures

4. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

5. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Who or What is EDGAR Education Department General Administrative Regulations (EDGAR)

6. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

7. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Financial Management Requirements EDGAR Section 76 Calculation and approval of indirect cost rates (restricted) (Costs used for overhead expenses) Coordination of the federal funds with other programs that serve the same populations – Integration of funds Title I, Title II, and Title III Program evaluations and fiscal audits SEA and LEA reporting requirements

8. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Financial Management Requirements Section 80 of EDGAR Specific regulations governing three threshold systems: Financial Management Procurement Inventory

9. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Financial Management Definition: Controlling and accounting for federal funds and assets – Used to make informed programmatic decisions – Used to substantiate and document expenditures

10. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Financial Management Requirements All grantees and subgrantees must implement the requirements and maintain systems that meet specific requirements of EDGAR. 10

11. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Financial Management Seven standards described in Section 80.20(b)EDGAR – Financial Reporting – Accounting Records – Internal Control – Budget Control – Allowable Cost – Source Documentation – Cash Management

12. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

13. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Allowable Cost Controls Program Regulations – Formal procedures or statue relating to costs – Guidelines for determining allowable costs (OMB Circular A-87, EDGAR) – Access to helpful resources and program guidance

14. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

15. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

16. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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)

17. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

18. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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.

19. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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 If an LEA draws down more than 10% of its total allocation at one time a written explanation must be provided to the GaDOE

20. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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 – State Board Policy 8200 – Purchasing Policies and Procedures Manual

21. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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)

22. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Procurement Procedures Review all proposed purchases to avoid unnecessary or duplicative items – Surplus property – Structure procurement to obtain most economical purchase – Intergovernmental agreement for common goods or services – Lease vs. purchase Conduct all transactions with full and open competition – be cognizant of conflict of interest

23. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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)

24. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Procurement Procedures Contracted Services – Remedies for breach of contract-sanctions and penalties – Termination procedures – Compliance with federal statues – see §80.36(i)(3-6) of EDGAR – Reporting procedures (if applicable) – Requirements pertaining to copyrights

25. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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)

26. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Procurement Procedures Contracted Services Invoice should be reviewed & approved before payment – Segregation of duties/expenditures – Documented approvals

27. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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 OMB A-87 Section 32.

28. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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; – 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)

29. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org District/School Programmatic and Fiscal Implementation Use the GaDOE 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

30. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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 GaDOE: – Provide a copy of the GaDOE 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 GaDOE (Example: FLP funds are budgeted in set-asides)

31. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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 GaDOE

32. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

33. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

34. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

35. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

36. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org District/school Programmatic and Fiscal Implementation District Level Throughout the Year – Follow procedures to ensure: – 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

37. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

38. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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 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

39. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org District/School Programmatic and Fiscal Implementation School Level Begin School Year with Technical Assistance – Meet with teachers and parental involvement facilitators Example: Meet with parent facilitators to give instructions for revising the School Parent Compacts

40. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org District/School Programmatic and Fiscal Implementation School Level Begin School Year with Technical Assistance – Meet with private school officials & N&D personnel Example: Meet with private school officials for the required consultation on providing Title I services to eligible private school students Example: Meet with N&D personnel to discuss Title I services to students

41. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

42. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

43. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org District/School Programmatic and Fiscal Implementation School Level Monitor Implementation – School Visits to Verify Program Implementation Have a specific purpose when you visit a school Go with a written way to document what you see (Example: a checklist) Verify that teachers/paraprofessional are working according to the schedule sent to you Verify that coaches are working according to job description Verify that equipment is used regularly & correctly

44. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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)

45. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

46. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Financial Management 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 Obligation = transaction that requires payment

47. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Financial Management In some programs, unobligated funds can be “carried over” from first allocation year Tydings Amendment – Does not apply to all grants – For Title I allows an additional 12 months to obligate funds Under Tydings, funds are available for 24-27 months – 15 months under the grant award – Plus 12 additional months Restricted to a 15% carryover for Title I, Part A and Title II, Part A

48. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Financial Management Liquidation 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)

49. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

50. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Inventory Management Equipment Inventory vs. Internal Control EDGAR requires an inventory for equipment Inventory not required for supplies; however, 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 items, as well

51. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Inventory Management Equipment – Federal Definition of Equipment Tangible property Useful life of more than one year Acquisition cost of $5,000 or more – State may use another definition as long as it includes all property described above – Georgia requires subgrantees to keep track of pilferable items, such as iPads, graphing calculators, cell phones, iPods, etc. – Georgia does not require that books or consumable items be included on the inventory

52. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Inventory Management Supplies – Small cost items – Consumed quickly ED expects subgrantees to track all property purchased with federal funds, in order to prove there has been a benefit to the federal program

53. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Inventory Management Practical help Practical help for tracking non-equipment items Small and attractive item list – Federal Definition of Equipment – Conduct risk assessment to identify items susceptible to loss – Implement specific measures to control such items – Certain pre-defined assets (technology equipment)

54. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

55. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Inventory Management Physical inventory – Must be performed at least annually – Indicate signature of individual(s) – Must protect against unauthorized use

56. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Inventory Management When property is no longer needed, must follow disposition rules: – Transfer to another federal program – Over $5,000 – Keep or sell, but must pay a share based on the percentage of federal ED participation at initial acquisition – Under $5,000 – May keep, sell, or dispose of it with no obligation to ED

57. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Inventory Management Must have adequate controls in place to account for: – Location of equipment - assure that it is used solely for authorized purposes – Custody of equipment - maintain effective control and accountability – Security of equipment - adequately safeguard all property

58. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Grants Management Test for LEAs 1.A school district is subject to: A.OMB Circular A-21 B.OMB Circular A-87 C.OMB Circular A-122 D.All of the above

59. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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. A.True B.False

60. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

61. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

62. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

63. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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 registeries D.Every piece of paper you can think of

64. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

65. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

66. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

67. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

68. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

69. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

70. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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.

71. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

72. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Grants Management Test for LEAs 15.Contracts supported with federal funds must be in writing. A.True B.False

73. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

74. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

75. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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 D.None of the above

76. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

77. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

78. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

79. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

80. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.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

81. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Questions?

82. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Dr. Judy Alger Georgia Department of Education Title I Education Program Specialist jualger@doe.k12.ga.us (229) 321- 9305 Dr. Olufunke Osunkoya Georgia Department of Education Title I Education Program Specialist oosunkoya@doe.k12.ga.us (678) 704-3557 Presenters