Seminar on Financial Management. VOCA s National Conference

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2 Seminar on Financial Management VOCA s National Conference

3 Financial Management Systems In summary, a Financial Management System must be able to: Record and report on the -- Receipt; Obligation; and Expenditure of grant funds.

4 Administrative and Training Funds A State may set aside up to 5% of the respective grant funds for administrative and training purposes. However, the combination of a grantee s administrative and training budget may not be more than 5% of the grant award for that fiscal year.

5 SUPPLANTING To deliberately reduce State or local funds because of the existence of Federal funds. Example: State funds are appropriated for a stated purpose and Federal funds are awarded for that same purpose. The State replaces its State funds with Federal funds, thereby reducing the total amount available for the stated purpose.

6 Conditions of Award 1. The recipient agrees to comply with the financial and administrative requirements set forth in the current edition of OJP's "Financial Guide." The United States Department of Justice Office of Justice Programs Office if the Comptroller Financial Guide

7 Conditions of Award 2. The recipient agrees to comply with the organizational audit requirements of OMB Circular A-133, Audits of State, Local Governments and Non-Profit Organizations, as further described in OJP's Financial Guide, Chapter 19. Note: There is a different special condition for individuals and for-profit commercial organizations.

8 Conditions of Award 3. The recipient acknowledges that failure to submit an acceptable Equal Employment Opportunity Plan (if recipient is required to submit one pursuant to 28 CFR Section ), that is approved by the Office of Civil Rights, is a violation of its Certified Assurance and may result in funds from the award being frozen, until such time as the recipient is in compliance.

9 Conditions of Award Anti-Lobbying Act: 4. Recipient understands and agrees that it cannot use any federal funds, either directly or indirectly, in support of the enactment, repeal, modification or adoption of any law, regulation or policy, at any level of government, without the express prior written approval of OJP.

10 Conditions of Award 5. The recipient must promptly refer to DOJ/OIG any credible evidence that a principal, employee, agent, contractor, subgrantee, subcontractor, or other person has either 1) submitted a false claim for grant funds under the False Claims Act; or 2) committed a criminal or civil violation of laws pertaining to fraud, conflict of interest, bribery, gratuity, or similar misconduct involving grant funds. This condition also applies to any subrecipient.

11 Conditions of Award Potential fraud, waste, abuse, or misconduct should be reported to the OIG by Mail: Office of the Inspector General U.S. Department of Justice Investigations Division 950 Pennsylvania Avenue, N.W. Washington, DC

12 Conditions of Award OIG Hotline: (800) (contact information in English and Spanish) OIG Hotline fax: (202) Additional information is available from the DOJ OIG website at

13 Conditions of Award 6. Recipient understands and agrees that it cannot use any federal funds, either directly or indirectly, in support of any contract or subaward to either the Association of Community Organizations for Reform Now (ACORN) or its subsidiaries, without the express prior approval of OJP.

14 Conditions of Award 7. The recipient agrees to comply with any additional requirements that may be imposed during the grant performance period if the agency determines that the recipient is a highrisk grantee. (Cf. 28 C.F.R. parts 66,70).

15 Conditions of Award 8. Pursuant to Executive Order 13513, Federal Leadership on Reducing Text Messaging While Driving 74 Fed. Reg (October 1, 2009), the Department encourages recipients and subrecipients to adopt and enforce policies banning employees from text messaging while driving any vehicle during the course of performing work funded by this grant, and to establish workplace safety policies and conduct education, awareness, and other outreach to decrease crashes caused by distracted drivers.

16 Conditions of Award 9. The recipient agrees to comply with applicable requirements regarding Central Contractor Registration (CCR) and applicable restrictions on subawards to first-tier subrecipients that do not acquire and provide a Data Universal Numbering System (DUNS) number. The details of recipient obligations are posted on OJP s website under Award conditions. This special condition does not apply to an award to an individual who received the award as a natural person. (unrelated to any business he or she may own or operate).

17 Conditions of Award The grantee agrees that the State s certified payments of crime victim compensation, upon which the award is based, represent payments made from STATE FUNDING SOURCES ONLY. The grantee further understands that the following items shall be deducted in compiling the certification of State payments: a) payments for property losses; b) payments for administrative costs; and c) dollar amounts of restitution and refunds received through subrogation for compensable expenses paid to, or on behalf of, victims and survivors.

18 Conditions of Award Recovery Act Annual VOCA Compensation Certification Form: The recipient agrees to complete and submit an annual Crime Victim Compensation State Certification Form in accordance with instructions developed by OVC. This form should be submitted with recipient s annual VOCA Victim Compensation Formula program application (i.e., per the usual process and timeframe). Recovery Act Funds should be reported in the Other Reimbursement category on Part I, and in the Other Sources category on Part II, of the annual Crime Victim Compensation Certification Form.

19 Conditions of Award Recovery Act Certify VOCA Compensation Payouts from State Sources Only: The recipient agrees that the State s certified payments of crime victim compensation represent payments made from STATE FUNDING SOURCES ONLY. The recipient understands that Recovery Act funds may NOT be reported as part of that State s certified payments of crime victim compensation. Instead, for purposes of the Crime Victim Compensation Certification form, the recipient should report Recovery Act funds in the Other Reimbursements/Other Sources categories (as specified above). The recipient further understands that the following items shall be deducted in compiling the certification of State payments: a) payments for property losses; b) payments for administrative costs; and c) dollar amounts of restitution and refunds received through subrogation for compensation expenses paid to, or on behalf of, victims and survivors.

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24 Payment of Grant Funds GPRS Need Help? OJP - OCFO Customer Service Center COPS - DOJ Response Center

25 Payment of Grant Funds 810 GPRS checks against certain parameters and either approves or denies request Approved requests are forwarded to the U.S. Department of Treasury for payment processing Grantee accesses GPRS via the web to request funds Funds are deposited into the Grantee s bank account, usually within 72 hours

26 TOP TEN TIPS GPRS PROCESS 1. Have signed & returned award document 2. Have current SF-425 on file

27 TOP TEN TIPS GPRS PROCESS 3. Have meet all special conditions 4. Have submitted an ACH Enrollment Form

28 TOP TEN TIPS GPRS PROCESS 5. Register for GPRS: a. OJP/OVW GMS id & password (must be an FPOC in GMS) b. COPS - separate id & password 6. If registering with COPS, have OJP vendor number

29 TOP TEN TIPS GPRS PROCESS 7. Know if you are requesting an advance or reimbursement 8. Double check dates for duplicate request

30 TOP TEN TIPS GPRS PROCESS 9. Know the amount you are requesting 10. Pay attention to any error messages At the end of the award period, drawdown all allowable expenses within 90 days

31 Payment of Grant Funds A Few Benefits of GPRS Ability to view and print a transaction history for an award Summary of award information: o Award amount o Hold amounts o Last SF-425 submission Ability to cancel pending payment request Secure individual log in

32 Payment of Grant Funds In support of the continuing effort to meet the accelerated financial statement reporting requirements mandated by the U.S. Department of Treasury, OJP strongly suggests that grantees make payment request before the last five (5) days of each month.

33 Minimum Cash on Hand Grant recipient organizations should request funds based upon immediate disbursement requirements. Funds will not be paid in a lump sum, but rather disbursed over time as project costs are incurred or anticipate. Recipients should time their drawdown requests to ensure that Federal cash on hand is the minimum needed for disbursement to be made immediately or within 10 days.

34 Reporting Requirements REPORT Section 1512(c) Cumulative reporting for Recovery Act Awards FFR/SF-425 Federal Financial Report (Formerly SF-269) Progress Reports Program/Project Activity Reports Performance Measures Other Reports (Conference cost reporting, etc.) SYSTEM FederalReporting.gov Grants Management System (GMS) Grants Management System (GMS) Performance Measurement Tool (PMT) Grants Management System (GMS) Grants Management System (GMS)

35 Federal Financial Report (SF-425) Quarterly Federal Financial Reports are submitted through the Grants Management System (GMS) at Grant recipients will be required to report grant expenditures utilizing the Federal Financial Report Form (SF-425). This form replaced the Financial Status Report (FSR), known as the SF-269.

36 Federal Financial Report (SF-425) Financial information reported on the SF-425 is similar to the SF-269. The SF-425 quarterly report must be submitted no later than 30 days after the end of each calendar quarter.

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46 SF-425 HELPFUL TIPS Report actual expenditures not disbursements from Federal Government Report from the lowest level in Section 10 Report correct indirect cost type, rate, and base

47 Federal Financial Report (SF-425) SF-425 due Quarterly Reporting Period Delinquent After Oct 1 - Dec 31 January 30 Jan 1 - Mar 31 April 30 Apr 1 - Jun 30 July 30 Jul 1 - Sept 30 October 30 Funds will be frozen if report is not submitted within 30 days

48 Federal Financial Report (SF-425) Problems with SF-425? Contact: OCFO Customer Service Center 1-(800) or (202) Fax#: (202)

49 Reporting Requirements The Grant Management System (GMS) allows grantees to report on their grant progress through an online Categorical Assistance Progress Report or online Performance Report. Features include: Data for form is filled in with information already in GMS Grantees can attach documents as part of their report notifications occur to remind grantees to submit report OJP grant managers can review and send back incomplete reports to grantees

50 Reporting Requirements Check the special conditions on your Award Document or the Solicitation, to determine due dates for Progress Reports. If Progress Reports are delinquent, drawdowns will not be processed. If Progress Reports are delinquent, future awards and grant adjustment notices may not be processed. Progress reports should be submitted online utilizing GMS.

51 Reporting Requirements Questions concerning GMS may be addressed to the GMS Help Desk at 1-(888) Contact program manager for questions regarding Reporting Requirements

52 FINANCIAL MANAGEMENT SEMINAR OMB A-133 Audit Requirements State, Local Governments, & Non-Profit Organizations

53 AUDIT REQUIREMENTS A-133 Gov't, Education and Non-Profit Thresholds $500K or more expended during the FY - Single Audit required Audit Report - due nine (9) months after end of FY Submit online to Federal Audit Clearinghouse (FAC) $10,000 or more in questioned costs must be included in the Single Audit report

54 SINGLE AUDIT Commercial Organizations and Individuals Submit one copy to the Office of Justice Programs, Office of the Chief Financial Officer. If audit report is delinquent, funds may be withheld.

55 SINGLE AUDIT The Federal Audit Clearinghouse requires all grant recipients to submit form SF-SAC and the Single Audit Report package online utilizing the Internet Data Entry System (IDES). If audit report is delinquent, funds may be withheld.

56 SINGLE AUDIT To use the online system: Questions about submission can be addressed to: Phone #: If audit report is delinquent, funds may be withheld.

57 SINGLE AUDIT A statement that the examination was made in accordance with generally accepted government auditing standards. Report on the study and evaluation of internal accounting controls.

58 RESOLUTION OF AUDIT REPORTS Office of Audit, Assessment, and Management Establish working file for the audit report. Review and analyze the audit report. If there are any findings, a letter must be generated to the audited recipient. This letter should include a request for a Corrective Action Plan (CAP).

59 RESOLUTION OF AUDIT REPORTS The CAP should include: Description of each finding. Specific steps to be taken to implement the recommendation. Timetable for performance of each corrective action. Description of monitoring to be performed to ensure implementation of CAP.

60 RESOLUTION OF AUDIT REPORTS Recipient must generate response to the CAP letter within the specified time frame, usually within 30 calendar days from the letter. Analyze response and follow up on action taken. A special condition will be placed on new awards if report is delinquent.

61 TOP TEN AUDIT FINDINGS (FY2011) 1. Procedures not documented or need improvement - Accounting. 2. Procedures not documented or need improvement Internal Controls. 3. Procedures not documented or need improvement - Payroll. 4. Subgrantee monitoring not being conducted. 5. Accounting system inadequate or not effectively utilized to account for grant funds.

62 TOP TEN AUDIT FINDINGS (FY2011) 6. Procedures not documented or need improvement Inventory/Fixed Assets. 7. Progress Report not submitted timely. 8. Excess cash-on-hand identified. 9. Suspension and Debarment verification not performed or not properly documented. 10. Federal Financial Report not accurate (addition/carry-forward, reporting errors, etc.).

63 Monitoring Discussion Grants Financial Management Division s Mission Ensure stewardship over Federal funds awarded by: On-Site financial reviews OCFO-Based financial reviews Technical assistance to grantees

64 Monitoring Discussion How are grants selected for on site-review? Dollar amount of grant New grant or grantee Inherent risk of program Program Office Request Grantee s request for technical assistance Problems identified through OCFO Based review Random sample

65 Monitoring Discussion What will be reviewed during the on-site visit? Internal Controls Accounting System Accounting procedures including cash management procedures Federal Financial Reports (SF-425s) Compliance with Recovery Act Reporting Requirements and Special Conditions (if applicable) Test and Analyze expenditures Provide technical assistance

66 Monitoring Discussion Compare your actual expenditures with your grant objectives and approved budget APPROVED BUDGET ACTUAL EXPENDITURES Are you spending the money according to the purpose of the award?

67 Monitoring Discussion If there are deficiencies in your objectives and/or you have deviated from the budget without prior approval from the program office.. DEVELOP CORRECTIVE ACTION PLAN OCFO will help you get back on track

68 Monitoring Discussion What are the objectives of the OCFO based review? Conduct an analysis of grant activity to date Analyze Federal Financial Reports (SF-425s) Determine compliance with audit report submission requirements Determine compliance with Section 1512 reporting requirements (if applicable) Evaluate payments -- determine excess cash Identify grantees who need on-site financial review

69 Primary Grantee s Responsibility The primary grant recipient is responsible for monitoring the subrecipient and ascertaining that all fiscal and programmatic responsibilities are fulfilled, including compliance with Federal rules and regulations (e.g., OMB Circular A-133 compliance, EEO compliance).

70 TEN TOP MONITORING FINDINGS (FY 2011) 1. Expenditures were questioned for 143 grants. (28%) 2. Budget category expenditures were not properly tracked for 88 grants. (18%) 3. Subgrantee monitoring procedures not documented or needed improvement for 72 grants. (14%) 4. Program/interest income and related expenditures not accurately reported on SF-425 for 59 grants. (12%) 5. Payroll procedures not documented or needed improvement for 53 grants. (10%)

71 TEN TOP MONITORING FINDINGS (FY 2011) 6. Budget modification exceeded 10% limit or resulted in potential scope change for 48 grants. (9%) 7. Consultant service charges exceeded rate limit (i.e., daily threshold) for 46 grants. (8.9%) 8. Award special condition not met by grantee for 46 grants. (8.9%) 9. Subgrantee monitoring not being conducted for 45 grants. (8.8%) 10. Accounting procedures not documented or needed improvement for 44 grants. (8.5%)

72 Questions & Answers (Q&A)

73 THE END THE END THE THE END END THE END

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