Grants Management Issues in Brief National Child Traumatic Stress Initiative Cooperative Agreements. Table of Contents

Transcription

1 Grants Management Issues in Brief National Child Traumatic Stress Initiative Cooperative Agreements Updated October, 2005 This document discusses some issues in the management of your Federal grant that might arise during the course of your project. The NCTSI Program Office has tried to be as accurate as possible with the information in this document. While we have consulted with our colleagues in the Division of Grants Management (DGM), this document does not represent the official opinion of the DGM. The material included is provided for informational and referral purposes only. Table of Contents Program and Grants Management Staff and Their Responsibilities... 2 Contact Information for Program and Grants Management Staff Project Requirements Related to Federal Funding Grant Budget Period and Project Period Grant Funding Indirect Costs Project Changes Requiring Prior Approval Re-Budgeting Change in Goals or Scope of the Project Change in Grantee Organization or Key Project Personnel... 8 Deviation from Restrictions on the Notice of Grant Award... 9 Obtaining Prior Approval Reporting Future Budget Periods Carry-Over Funds No-Cost Extensions Other Questions Program and Grants Management Staff and Their Responsibilities Each grant is assigned a Government Project Officer, a Program Associate and a Grants Management Specialist.

2 The National Child Traumatic Stress Initiative (NCTSI) program is a Congressionally-appropriated program housed within the (EMHTSSB) in the Center for Mental Health Services of the Substance Abuse and Mental Health Services Administration. NCTSI Program staff have the responsibility for supporting and monitoring progress in achieving the overall goals of the NCTSI, which are to improve treatment and services for children, adolescents, and their families who have experienced traumatic events and to increase access to such treatment and services. The NCTSI program staff consists of Government Project Officers and Program Associates. Seth Hassett, M.S.W., is the EMHTSSB Branch Chief and is the administrative director for the program. The NCTSI Government Project Officer (GPO) is concerned with the substantive programmatic issues of your project. Your GPO monitors a number of NCTSI grants and has either expertise or general experience in the mental health field, and a strong interest in child traumatic stress. Among his/her duties are to: (1) monitor progress of the grant in achieving both center-specific and NCTSI Network goals, including regular contact and reviewing required grant progress reports; (2) provide helpful advice or other resources to help the Project Director deal with problematic issues in such areas as program implementation, program evaluation, and sustainability; (3) facilitate collaboration among NCTSI grantees in order to achieve the goals of the NCTSI, and (4) recommend approval/disapproval of changes in the project that potentially impact substantive aspects of the conduct of the project such as rebudgeting, changes in key personnel, or major changes in the goals or operation of the project that were approved in the awarded application. Program Associates (PAs) are special non-federal expert consultants who work closely with an assigned GPO in support of all aspects of the NCTSI program, including communication with NCTSI grantees. Your assigned PA will work jointly with the GPO in communicating with grantees, developing NCTSI program initiatives, and assessing grantee progress. He/she will also act as an efficient conduit of information related to your program to the GPO, the National Center for Child Traumatic Stress, and other public and private agencies and institutions that have an interest in your work. Your GPO and PA usually act jointly in all aspects of grant-related and NCTSI activities with the single exception of when a grantee requests approval of an official Federal Government action requiring a recommendation by the Federal GPO (e.g., a recommendation of funding of continuing years of a grant or for use of leftover funds in continuing years of a grant). The Grants Management Specialist (GMS) is in the Division of Grants Management (DGM) at SAMHSA and is responsible for all business and financial matters related to your CMHS grant including: (1) issuing an official notification of your Federal grant award, the Notice of Grant Award (NOGA); negotiating any matters necessary in order to issue the NOGA; and specifying general and specific terms and conditions that accompany the NOGA that govern how the award will be administered; (2) monitoring compliance of your organization with Federal requirements for financial accounting and grants administration; (3) issuing the non-competing grant application packet so that you can request funding for the second and later years of your project, and issuing the award; and (4) approving any changes to the project that require Federal Government approval. The GMS is the only Federal official with the authority to approve grant actions requiring 2

3 Government approval. Therefore, all grantee requests for grant actions requiring Government approval should be addressed to the Grants Management Specialist. For grant actions that have impact on the substance aspects of the grant project, the GMS will usually ask for a recommendation from the GPO about the appropriateness of the proposed action in terms of its impact on the grant achieving its project goals. FOR ALL CORRESPONDENCE REGARDING YOUR GRANT BE SURE TO REFERENCE YOUR SAMHSA-ASSIGNED GRANT NUMBER! In general, as a Project Director, you are more likely to interact with your GPO/PA about substantive program aspects of your project. You or your business office staff will interact with the Division of Grants Management regarding budgetary and management aspects of the grant. SAMHSA STAFF Government Project Officers (GPOs) Mikisha Brown, M.P.H. Room Phone mikisha.brown@samhsa.hhs.gov Cecilia Rivera-Casale, Ph.D. Room Phone cecilia.casale@samhsa.hhs.gov Angela Gonzalez Willis, Ph.D. Room Phone

4 Malcolm Gordon, Ph.D. Room Phone Program Associate (PAs) Kenneth Curl, MSW Room Phone Sarah Smith, M.A., M.P.H. Room Phone Grants Management Specialist Sherie Fairfax Grants Management Specialist SAMHSA Division of Grants Management Room Rockville MD Phone

5 Fax NOTE: For FedEX, UPS or other commercial carriers use Zip Code Project Requirements Related to Federal Funding In accepting Federal funding of your project you also agree to the following: The general and the specific terms and conditions specified in the NOGA. Other Federal policies that relate to financial and administrative management that govern DHHS Public Health Service grants. The general project requirements stated in the NCTSI Cooperative Agreement Guidance for Applicants (GFA) including reporting requirements (discussed below). Conduct of the project as proposed in your approved grant application. If you are providing direct services or are using Federal grant funds to support direct services by other providers, these services will be provided in accordance with SAMHSA requirement for Participant Protection, including informed consent to services, attention to minimization of risk, and confidentiality. Obtaining approval from the Federal Government for changes in the Project that require Government approval before you initiate such changes (discussed below). Grant Budget Period and Project Period A Budget Period is the 12-month period for which funds are allocated. This period begins from the start date and ends with the end date indicated in the Notice of Grant Award (NOGA). The Project Period is the total time period for Government support of the project, usually specified for a fixed number of years in the Request for Applications and indicated on the NOGA. The project period for NCTSI Cooperative Agreements is four years. You can expect to receive your requested funding for the four years for which your grant was approved, provided the program is funded and the program appropriation is not reduced. Budget periods cannot exceed 12 months, so support for the entire Project Period requires that the project apply for funding for additional budget periods. The Division of Grants Management will send you an application packet for your future (second, third, and fourth year) budget periods. This application resembles your original grant application form but is called a non-competing continuation application because you do not need to compete for your funding, just describe satisfactory progress on your original proposal. Generally, you will receive your noncompeting continuation application fairly early in your budget period (and, in your first year, you may not be very far along in your project). This early submission of the non-competing continuation application is necessary to allow sufficient time for grants management processing prior to the 5

6 beginning of the second budget period. Grant Payment Grant payments are usually made electronically through the DHHS Payment Management System. There may be special conditions imposed on your access to draw down grant funds, especially if you have not had prior Federal grants. Your business office should be your organizational component responsible for drawing down grant funds. An Account Liaison is assigned to every grant by type of recipient and state location from the DHHS office that is responsible for grant fund payment. For more information on the Payment Management System visit the website, If your organization has not had prior Federal grants or if its accounting, financial, or administrative management systems do not conform to Federal regulations, your organization may be placed on Restricted Status. The Office of Advisory Services, an office in the Division of Grants Management, makes this determination. If your organization is placed on Restricted Status, you will receive a letter stating the reason(s) for the determination. The Terms and Conditions attached to your NOGA will provide instructions on what actions are necessary to get off Restricted Status, thereby allowing you to draw-down funds. Requests to your organization for information should be honored in a timely manner to avoid lengthy delays and so that you can be removed from Restricted Status. It is the responsibility of the grantees to work with the DGM to correct whatever problems exist and aid in their compliance with the special conditions. Further information on Restricted Status can be obtained at the websites and If you are experiencing difficulty receiving grant payments or expense reimbursements, contact first your Account Liaison, listed on the Federal Cash Transaction Report PSC272 you should receive. If problems are not resolved, you should contact your GMS and your GPO to alert them to unresolved problems. They can provide assistance and monitor progress on resolving payment issues. Indirect Costs Organizational administrative and facilities costs associated with rent and administering Federal grants can be charged to Federal grants as indirect costs (as opposed to the actual expenses of conducting the project which are direct costs ). Organizations are entitled to receive indirect costs on grants. Allowable indirect costs are negotiated by the Federal government with the grantee organization and are expressed as a percent of total direct costs or salary and wages, etc. If your organization did not request indirect costs in the submitted budget, it is allowed to do so after the grant is awarded (within 90 days). Information on how to go about applying for an indirect cost rate is indicated in the Terms and Conditions of your NOGA. However, be advised that the grant award is for total costs and the total grant award will not be increased to support additional claimed indirect costs. An increase in indirect costs must be matched by a corresponding decrease in direct project costs. If your organization does not have a Federal indirect cost agreement, it may negotiate one with the 6

7 appropriate Federal office but it is not necessary. These costs are allowable as direct costs. Unless your organization has multiple Federal grants, it is probably more appropriate to include overhead costs such as rent, phone, and office supplies, directly in your budget as direct costs. While organizations can waive all or part of their indirect costs, it is better to either request all indirect costs to which the organization is entitled and, possibly, rebudget the direct costs, or request no indirect costs but include overhead expenses in direct cost budget categories. For further information on indirect costs, see the websites and or contact the GMS. Project Changes Requiring Prior Approval Although grantees have a great deal of flexibility in conducting the project to meet its overall goals, certain changes in the conduct of the project require approval by the DGM before they can be implemented. This is called prior approval. Among the most common changes are the following: Re-Budgeting Please read carefully and share this with your business office because we often get rebudgeting request that do not require Government approval. SAMHSA considers the approved budget for the grant to be the figures specified in the budget categories, which are the Object Class Categories (i.e., Personnel with Fringe Benefits, Travel, Equipment, Supplies, Contractual, and Other), on the SF424A budget form submitted with your application. It is common for grantees to find that, to achieve the goals of the project, budgetary changes are necessary to the original submitted budget. Grantees are allowed to make budget changes within these budget categories without obtaining Government approval unless such changes affect the approved goals of the awarded grant, exceed Government policy limitations (e.g., costs of equipment or of contracts) or require specific Government approval (e.g. foreign travel, which is not usually approved for SAMHSA grantees). Grantees are also allowed some degree of latitude to make budget changes between budget categories to achieve the goals of the project without prior approval. In general, prior DGM approval is not needed for rebudgeting less than 25% of your total budget between budget categories. Rebudgeting within budget categories does not count against this 25% limit. If, however, you decide to implement a substantial change in the implementation of your project from the activities originally proposed and it requires changes in budget expenses within or between budget categories (e.g., additional or different service program training), you must first discuss the substantive program implications with the GPO before budgeting concerns can be addressed. Also, if the rebudgeting is to a budget category that was NOT approved in the original application, prior approval is required, regardless of the amount and percentage of the rebudgeting. The 25% limit for rebudgeting across budget categories applies to the whole budget period (usually cumulative for one year). In other words, your total rebudgeting over the budget period cannot exceed this 25% limit without getting prior Federal government approval. So, if on one occasion within the budget period you rebudget 15% of your total from one budget 7

8 category into another budget category and on another occasion you rebudget 20% of the total, you have exceeded the 25% limit for the budget period. You would need prior Government approval for the second re-budgeting. If you intend to re-budget into a budget category that was not included in your initial budget, you must obtain prior Government approval to add the new budget category. For example, if your initial budget had no equipment costs included and you propose to buy equipment necessary to implement a particular type of service program, you need prior Government approval to add and budget into the Equipment category. Even if you are re-budgeting within the 25% limit of project discretion, you should always alert your GPO about significant re-budgeting that affects the overall conduct of the project. Change in Goals or Scope of the Project Significant changes to the project as originally proposed require prior Government approval. These significant changes are changes in the goals (for example, changing the target population of the project to a different community or age group), scope (for example, reduction in services originally proposed or reduction in number of clients), or conduct (for example, change of a subcontractor, transfer of substantive programmatic work to a contractor, or change in your evaluation plan). You should discuss these changes with your GPO and provide your reasons and an indication of the potential budgetary implications. A written request to change the scope of the project must be submitted to DGM for approval. Change in Grantee Organization or Key Project Personnel SAMHSA grants are awarded to organizations and not to individuals (e.g., are not awarded to the Project Director or the agency head). The grant, thus, administratively belongs to the awarded organization and any grant related action requiring Government approval requires signature by a responsible business official representing the organization (in some cases electronic submission of requests is acceptable if indicated by the GMS). It is possible to transfer a grant from one organization to another if, for example, the project director and other key staff move to a different organization and wish to continue the grant project in the new organization. Such a transfer requires approval of both the original organization to relinquish the grant and the new organization to accept the grant and Government approval. Contact the Grants Management Specialist for information on the procedures for grant transfer. Any change in the organization or key personnel that is financially and administratively responsible for the management of the grant requires prior Government approval. For NCTSI Cooperative Agreements, the Project Director(s) and Principal Investigator(s) are specified as key personnel. If the NCTSI-funded project commitment for key personnel either increases or decreases, formal approval by DGM is required. Any decrease in DGM approved project FTE of key personnel, whether NCTI-funded or not (as would be the case for in-kind donation of time), also 8

9 requires DGM prior approval. For example, if your Project Director is funded for 40% of her time, but also gives 20% in-kind for a total of 60% of her time allocated to the program, but she then eliminates her in-kind contribution so her total project commitment is 40%, prior approval by DGM is required. In general, changes in key personnel require submission of a written request, including a copy of the proposed candidate's curriculum vitae that documents the background and experience that qualifies the candidate for the key personnel role. For the NCTSI Program Office purposes, any decrease in project commitment greater than 25% for individuals that have substantial programmatic, administrative, or financial decision-making responsibilities (such as Project Manager, if different than PD or PI) require that you discuss the change with your GPO/PA. These individuals do not require formal notification to the DGM, but do require that you confer with your GPO/ PA. Deviation from Restrictions on the Notice of Grant Award (NOGA) Project implementation that violates restrictions imposed by the Terms and Conditions of the NOGA require prior Government approval. Obtaining Prior Approval Prior approval is written approval from the DGM allowing you to make a requested change(s). For proposed changes that impact the substantive goals or conduct of the project, the GMS will request the GPO s recommendation for approval. If the change is allowable under grants management rules, the GMS then decides whether to approve or disapprove the request based on the GPO s recommendation. While some changes in your grant do not require formal, written approval, your first step should always be to discuss the matter with your GPO before initiating the change. Whether or not the DGM needs to approve a change, your GPO, who is both your advisor and your support system, needs to consider and make recommendations about the appropriateness of the change(s). He/she can then advise you about what documentation needs to accompany a requested change to the GMS. The requested change(s) must be made in writing on the organization s letterhead and signed by the Project Director/Principal Investigator and an authorized representative of the organization. The request must be addressed to the GMS with a copy to the GPO and it must include programmatic and budget justifications for the change(s) you seek. Approval for the requested change will be conveyed to you by DGM in the issuance of a new NOGA. Please note that verbal approvals are never given by DGM and are not considered official approval by your GPO. Reporting Reporting requirements are specified in the RFA and NOGA and are an important aspect of your work. They are used to communicate progress of the project to the GPO/PA and monitor the use of funds. They include: 9

10 Quarterly and Annual Progress Reports: These reports are the responsibility of the Project Director. The NCTSI program office will share the format for these reports with you. Final Report: This report is due within 90 days of the end of the project period. The NCTSI program office will share the format for these reports with you. Grant Expense Reports: Federal Cash Transaction Reports must be submitted by the grantee organization on a periodic basis in order to draw down money. You should consult with your Account Liaison regarding their reporting requirements. Annual Financial Status Reports (FSRs): Standard Form 269 is the Financial Status Report that documents spent, obligated, and unspent grant funds. It must be submitted to the DGM by the grantee organization no later than 90 days after the end of each budget period. This is usually the responsibility of your business office. Be sure to include your SAMHSA grant number on all official grant communication with SAMHSA. Future Budget Periods You must submit a budget proposal with your non-competing applications for future (second, third, and fourth) years of funding. Your requested budget cannot exceed (1) the maximum total award allowed per year for your grant (which, as of FY 2005, is $600,000 for Category II awards and $400,000 for Category III awards), (2) the amount requested for years 2-4 in your original grant application, or (3) the budget amount approved by the review committee as indicated on the Summary Statement (which might be listed only as direct costs). Be sure to include your SAMHSA grant number on this and all official grant communication with SAMHSA. Decisions regarding budgets are made on a case-by-case basis. As indicated in the Request for Applications, if your requested year 2-4 budgets greatly exceed your year 1 budget, this creates funding difficulties for the program because the amount we have to spend on these grants is relatively fixed and there are few additional funds available for increasing budgets from year to year. If there are significant budget increases in some budgets from year 1 to years 2-4 and additional funds are not available, we may distribute relatively small budget decreases across all grants, but grants requesting significant budget increases are likely to bear the burden of budget reductions from their increased requests and should plan accordingly. Carry-Over Funds For various reasons, grantees may have unspent funds remaining in their budget at the end of a budget period. Unexpended funds can result from savings due to delays in starting up the grant, delays in hiring, or changes in grant-related activities. Grantees can request use of unspent funds from a completed budget period (the "carry-over request") during their next budget period. Carryover requests must be submitted to the Division of Grants Management on the organization s 10

11 letterhead and signed by both the Program Director and an authorized representative of the organization. The letter must state the amount, from/to which budget periods, and why the funds were not spent in the previous year. A carry-over budget breakdown by budget categories (i.e., personnel, fringe benefits, travel, etc.) along with a budget justification must accompany the request letter. The carry-over request can only be made at the same time or after the Financial Status Report (FSR) for the expired budget period has been completed and submitted. (The FSR is due no more than 90 days after the end of the grant year.) Proposed expenses must be within the scope of the original project. The carry-over funds cannot be expended until the request and budget are approved by DGM. For further information on carry-over requests, contact your GMS. No-Cost Extensions When a grant s project period ends, the project no longer has authority to draw down Federal funds for the project. If the project is not completed, has not expended all of its funds, and you need additional time for proper phase-out of project activities, the Project Director may request to extend the end date for the grant. This can be accomplished by writing the GMS) requesting a no-cost extension of the grant (with a copy to GPO). The request is termed a no-cost extension because the Government does not give you any additional funds during this period, but allows you to spend the already allocated but unobligated funds from your original grant. This request should include a budget and budget narrative estimating, as of the date of submission, the no-cost extension request. Additionally, it is necessary that you briefly explain why the funds were not expended and how they will be used. Be sure to include your SAMHSA grant number on this and all official grant communication with SAMHSA. The use of these funds must be within the scope of the originally proposed project. You cannot propose completely new activities. Requests may be made for any number of months up to a 12-month extension. This request must be submitted at least 60 days prior to the original termination date of the grant as listed on the NOGA. During the grant extension period, the project can continue to draw down remaining funds. An extension also postpones the receipt of the Final Report (due within 90 days of the end of extended grant period) and the final accounting of grant expenditures. For further information on no-cost extension requests, contact the GMS. Other Questions For questions not answered above, contact your GPO/PA. She/he can either answer your questions or direct you to the right person or resource. 11