WELCOME. Pre-Award Phase Training

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1 WELCOME Pre-Award Phase Training

2 Morning Session Welcome GATA and New Federal Guidance Overview Cost Principles - Basic Considerations 10:00 10:15 BREAK Cost Principles Basic Consideration Cost Principles Selected Items of Cost 12:00 1:00 LUNCH Afternoon Session Pre-Qualification and Risk Assessment Notice of Funding Opportunity Application/Merit Based Review/Notice of State Award 3:15 3:30 BREAK Budget Template/Indirect Cost Rates Grant Agreement Closing Comments 2

3 GATA & NEW FEDERAL UNIFORM GUIDANCE Highlights of Significant Changes Copying, distributing, re-creating or any other unauthorized use of the content in these slides without the express written consent of the Grant Accountability and Transparency Unit (GATU) is strictly prohibited.

4 New Federal Uniform Guidance and GATA What changed? How does it affect State agencies? How does it affect State funded awards? How does it affect Subawards? What do I do now? Answers and help are available! 4

5 Grant Accountability and Transparency Act 30 ILCS 708 GATA Objectives Assists State agencies and grantees in implementing the new federal guidance at 2 CFR 200 (Uniform Guidance) Increase accountability and transparency while reducing administrative burden Leverages the Federal Uniform Guidance for state grants Establishes uniform processes throughout grant life cycle Creates the Catalog of State Financial Assistance (CSFA) Provides training and technical assistance to State agencies and grantees 5

6 Grant Accountability and Transparency Act 30 ILCS 708 GATA Objectives Optimizes resources by eliminating duplicate efforts through centralization of common compliance requirements including: Pre-qualification Fiscal and Administrative Risk Assessment Audit Report Reviews Negotiation of Indirect Cost Rate Agreements Coordination of Fiscal and Administrative On-site Reviews 6

7 Grant Accountability and Transparency Act 30 ILCS 708 GATA Objectives Creates standardized processes and templates: Pre-Qualification Grant Application Process Budget and Financial Reporting template Fiscal, Administrative and Programmatic Internal Control Questionnaires Specific Conditions for high risk grantees Grant Agreements Year-end reporting template 7

8 GATA applies to: GATA: Applicability State agencies that receive federal funding State agencies that receive State funding to administer State grant programs. State agencies that make State awards Entities that receive State awards. Entities that receive Federal pass-through awards. Limited exceptions are noted in Section 45 of GATA. 8

9 New Federal Uniform Guidelines Overview 9

10 New Federal Guidance 2 CFR 200 Part 200 Eliminating Duplicative and Conflicting Guidance BEFORE: Awards Received A-102 & A-89 A-87 A-133 & A-50 Subawards to Nonprofits Subawards to Universities A-110 A-122 A-133 & A-50 AFTER: All OMB guidance streamlined in 2 CFR Part 200 A-110 A-21 A-133 & A-50 10

11 Uniform Guidance Overall Goals Eliminate Duplicative and Conflicting Guidance Focus on Performance and Outcomes Increase Efficiency and Effectiveness Make Best Use of Resources Strengthen Oversight Including Formalizing Internal Controls Target Audit Requirement of Risk of Waste, Fraud and Abuse 11

12 2 CFR Part 200 Organization by Subpart Subpart A Acronyms and Definitions ( ) Subpart B General Provisions ( ) Subpart C Pre-Award Requirements and Contents of Federal Awards ( ) Subpart D Post-Award Requirements ( ) Subpart E Cost Principles ( ) Subpart F Audit Requirements( ) 12

13 Appendices I. Notice of funding opportunity II. III. Contract provisions Indirect costs Higher Ed IV. Indirect costs Nonprofits V. State/local government central service cost allocation plans VI. Public assistance cost allocation plans VII. State/local government indirect cost proposals VIII. Nonprofits exempted from Federal cost principles IX. Hospital cost principles X. Data Collection Form (SF-SAC) XI. Compliance Supplement 13

14 The e-cfr at 14

15 Subpart C Highlights of Significant Changes Pre-Award Requirements Notices of Funding Opportunities Competitive awards General rule minimum of 60 days (State rule is 45 days) Some exceptions, but in no case shorter than 30 days Federal Awarding Agency Review of Merit Proposals Competitive awards Must design and perform a merit review process separate from the financial risk review 15

16 Highlights of Significant Changes Pre-Award Requirements Subpart C Federal Awarding Agency Review of Risk Posed by Applicants Federal agencies are required to use information available through any OMB-designated repositories: Single Audit reports, FAPIIS, D&B, Do Not Pay Must create a framework for reviewing risk Competitive awards Conditions of the award may be adjusted to match the assessed level of risk. 16

17 Highlights of Significant Changes Pre-Award Requirements Subpart C Specific Conditions Has been expanded to include a list of examples of specific conditions that may be applied to an award by either the Federal agency or pass-through entity Certain approvals, additional financial reporting, etc.; Must provide the nature of, reason for, action required, timeline allowed, and method for requesting reconsideration Information Contained in a Federal Award a(14) Identification of R&D awards 17

18 Subpart D Highlights of Significant Changes Post Award Requirements New sections added Mandatory disclosures Performance management Internal controls Subrecipient monitoring and management Significant changes from existing guidance Procurement (NFP s, IHE s) Financial and performance reporting Record retention and access 18

19 Highlights of Significant Changes Post Award Requirements Subpart D - Internal Controls Overview OMB Directive Mitigate the risk of fraud, waste and abuse Internal Control not previously mentioned use of term controls was used throughout Explicit mention now made in new section titled Internal Controls ( ) References several sources of Internal Control guidance with which the system of internal controls should be in compliance 19

20 Highlights of Significant Changes Post Award Requirements Subpart D - Internal Controls Overview Awardee Entity must: Establish and maintain effective internal controls over Federal awards Comply with terms and conditions applicable to the Federal award and other applicable laws and regulations Evaluate and monitor the awardee s compliance with Federal awards Take prompt action when issues of noncompliance are identified Take reasonable measures to ensure the protection of personally identifiable information 20

21 Highlights of Significant Changes Post Award Requirements Subpart D Subrecipient Monitoring Overview Subrecipient vs. Contractor determination Subaward agreement contract provisions Monitoring of subrecipients 21

22 Highlights of Significant Changes Post Award Requirements Subpart D Subrecipient Monitoring Overview All pass through entities must: Subaward agreement requirements including state and federal compliance requirements Evaluate subrecipient s risk Consider imposing specific subaward conditions [ ] Monitor the activities of the subrecipient 22

23 Highlights of Significant Changes Post Award Requirements Subpart D Subrecipient Monitoring Overview Depending on the subrecipient risk assessment, perform such other monitoring procedures (monitoring tools listed) Verify that every subrecipient is audited Review the results of the audit and corrective action plan Monitor the implementation of the correction action plan Consider results of subrecipient audits and monitoring on the pass through entity s records Consider taking enforcement action on subrecipient [ ] 23

24 Highlights of Significant Changes Post Award Requirements Subpart D Subrecipient Monitoring Overview Monitoring of the subrecipient must: Review financial and programmatic reports required by the pass through entity Ensure deficiencies identified through audits, on-site reviews and other means are followed up on timely Risk assessment is key in determining level of further monitoring [ (b)] Optional monitoring tools [ (e)]: Provide technical training and assistance On-site reviews Arrange Agreed Upon Procedure Engagements (allowable audit costs ) 24

25 Highlights of Significant Changes Post Award Requirements Subpart D Procurement [ ] State s must follow state procurement policies and procedures Non-Profit, Local Government and Higher Education must use one of the following procurement procedures: Procurements by micro-purchases Purchase <$3k Competitive quotations not necessary if price is determined to be reasonable Procurement by small purchase procedures Simplified Acquisition Threshold (currently $150k) Price or rate quotations must be obtained by an adequate # of qualified sources 25

26 Highlights of Significant Changes Post Award Requirements Subpart D - Procurement Procurement by sealed bid (formal advertising) construction contracts Bids are publicly solicited and a firm fixed price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. Procurement by competitive proposals Normally conducted with more than one source submitting an offer, and either a fixed price or cost-reimbursement type contract is awarded. Requests for proposals must be publicized and identify all evaluation factors and their relative importance. Any response to publicized requests for proposals must be considered to the maximum extent practical 26

27 Highlights of Significant Changes Post Award Requirements Subpart D Non-Competitive Procurements Existing requirements -requires documents to be available for review (if requested) for noncompetitive bids greater than small purchase threshold Noncompetitive procurements may only be used when one or more of the following circumstances apply: Item is available only from a single source Public exigency or emergency will not permit delay from competitive proposal process After solicitation of a number of sources, competition is determined inadequate Awarding agency expressly authorizes noncompetitive upon written prior approval 27

28 Effective Dates and Grace Period for Procurement Two year grace period after the effective date of the Uniform Requirements for Nonprofits and Universities For procurement policies and procedures, the non-federal entity must, in the two full fiscal years that begins on or after December 26, 2014: Document whether it is in compliance with the old or new standard, and must meet the documented standard; For example, a non-federal entity with a June 30 th year end would be the year ending June 30, 2017; The Single Audit Compliance Supplement will instruct auditors to review procurement policies and procedures based on the documented standard. For future years, all non-federal entities will be required to comply fully with the Uniform Requirements. 28

29 Highlights of Significant Changes Post Award Requirements Subpart D Financial and Performance Reporting Financial Reporting GOMB/OMB-approved data elements for collection of financial information No less frequently than annually nor more frequently than quarterly except under unusual circumstances Monitoring and Reporting Program Performance Expanded with increased focus on reporting of program performance Non-construction performance reports Construction performance reports 29

30 Highlights of Significant Changes Post Award Requirements Subpart E - Cost Principles Key Changes Language converged from existing cost principles (except for hospitals) Prior written approval Time and effort reporting Indirect cost recovery Other selected items of cost 30

31 Highlights of Significant Changes Post Award Requirements Subpart D Financial and Performance Reporting Subpart E - Cost Principles Prior written approval Consideration of advanced approval from cognizant Federal agency or Federal awarding agency Comprehensive list of selected items of cost where prior written approval is needed When in doubt obtain prior written approval 31

32 Highlights of Significant Changes Post Award Requirements Subpart E - Cost Principles Key Changes- Personnel Expense Documentation Requirements: System of internal control providing reasonable assurance charges are accurate, allowable and allocable Records incorporated into official records of entity Reasonably reflect total activity for which employee is compensated Encompass all activities Comply with entity s policies and procedures 32

33 Highlights of Significant Changes Post Award Requirements Subpart E - Cost Principles Indirect Costs, Federally Negotiated Negotiated rate must be accepted unless cap on indirect recovery required by statute or approved by Federal agency head or designee Federally agency approval, policies and general decision making criteria for lowered IDC recovery must be made publicly available Indirect cost reimbursement policy to be included in the Notice of Funding Opportunity May apply for an extension of previously negotiated rate for up to 4 years Impact on settlement of provisional and fixed carryforward rates 33

34 Highlights of Significant Changes Post Award Requirements Entities without a Federally Negotiated Indirect Cost Rate Agreement Options for indirect cost recovery Negotiate IDCR with pass through entity using guidelines of this Part Indefinite application of de minimis indirect cost rate of 10% of Modified Total Direct Costs (MTDC), ONLY if the entity has NEVER had a federally negotiated indirect cost rate Impact on pass through agencies Required use of existing Federal agency methods (DHHS, DOL) Centralized function under GATA negotiated once and all agencies will accept the rate, unless statutory cap 34

35 Highlights of Significant Changes Post Award Requirements Subpart F - Audit Requirements Single Audit Threshold changes Audit Requirements Threshold increased to $750k from $500k in federal expenditures during the awardee s fiscal year Major Program Determination Type A Program Determination Percentage of coverage rule Reduced to 20% from 40% From 25% to 50% 35

36 Highlights of Significant Changes Post Award Requirements Subpart F - Audit Requirements other significant changes Financial Statements New disclosure for whether or not the awardee entity elected to use the 10% de minimis cost rate ( ) Audit Findings Questioned costs threshold for reporting is $25k, increased from the current $10k Note this is both known and likely 36

37 Highlights of Significant Changes Post Award Requirements Audit Requirements for For Profit Entities For Profit entities will be required to have a program specific audit conducted if their funding meets the Single audit threshold of $750,000 or more Conducted in accordance with 2 CFR Must use the Program-specific audit guide when available If a Program-specific guide is not available, the auditee and auditor must have the same responsibilities for the Federal program as they would have for a major program in a single audit 37

38 Highlights of Significant Changes Post Award Requirements GATA Audit Requirements for Entities that do not meet the Single Audit Threshold: Recipients and subrecipients receiving $300,000 or more in total revenues, must have a financial statement audit conducted in accordance with Generally Accepted Auditing Standards (GAAS); (Attorney General audit requirements) Recipients and Subrecipients who expend between $300,000 and $500,000, must have the financial audit conducted in accordance with Generally Accepted Government Auditing Standards (GAGAS) and are deemed to be high risk are also required to undergo an Agreed Upon Procedures (AUP) audit, paid for and arranged by the pass-through entity in accordance with 2 CFR for up to 2 out of four of the applicable compliance areas 38

39 Highlights of Significant Changes Post Award Requirements GATA Audit Requirements for Entities that do not meet the Single Audit Threshold: Recipients and Subrecipients who expend between $500,000 and $749,999 in state and federal grant funding, must have a financial statement audit conducted in accordance with GAGAS (paid for arranged by the grantee) and are deemed to be high risk are required to undergo an AUP audit, arranged and paid for by the grantor and/or pass-through agency in accordance with 2 CFR for up to 4 of the compliance areas: 1) Activities Allowed or Unallowed 2) Allowable Costs/Cost Principles 3) Eligibility 4) Reporting 39

40 New Federal Guidance & GATA Highlights of Significant Changes Questions 40

41 COST PRINCIPLES FEDERAL & STATE GRANTS BASIC CONSIDERATIONS Carol A Kraus, CPA Grant Accountability and Transparency Unit Copying, distributing, re-creating or any other unauthorized use of the content in these slides without the express written consent of the Grant Accountability and Transparency Unit (GATU) is strictly prohibited.

42 Subpart E- Cost Principles General Provisions Basic Considerations Direct & Indirect (F&A) costs Negotiated Indirect Cost Rate Agreements (additional training module) Special Considerations for States, Local Governments and Indian Tribes Special Considerations for Institutions of Higher Education General Provisions for Selected Items of Cost (next training module) 42

43 Why are Cost Principles Important? What are the Federal and State requirements governing the funding received? What are Reasonable Costs? When do these cost principles apply? When do I need prior approval to charge costs? What are the fundamental premises? How does this impact my organization? 43

44 Policy guide The application of these cost principles is based on the fundamental premises that: a) The non-federal entity is responsible for the efficient and effective administration of the State, Federal and Federal pass-through award through the application of sound management practices. b) The non-federal entity assumes responsibility for administering State and Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the award. 44

45 Policy guide The application of these cost principles is based on the fundamental premises that: c) Where wide variations exist in the treatment of a given cost item by the non-federal entity, the reasonableness and equity of such treatments should be fully considered. d) In reviewing, negotiating and approving cost allocation plans or indirect cost proposals, the cognizant agency for indirect costs should generally assure that the non-federal entity is applying these cost accounting principles on a consistent basis during their review and negotiation of indirect cost proposals. 45

46 Policy guide The application of these cost principles is based on the fundamental premises that: e) The non-federal entity may not earn or keep any profit (increases in equity) resulting from State or Federal financial assistance, unless explicitly expressly authorized by the terms and conditions of the Federal award 46

47 Policy Guide This language sets the tone for revised cost principles and emphasizes the implementation of a framework to better mitigate the risk of waste, fraud and abuse 47

48 Application General. These principles must be used in determining the allowable costs of work performed by the non-federal entity entity under State, Federal and Federal pass-through awards. These principles also must be used by the non-federal entity as a guide in the pricing of fixed-price contracts and subcontracts where costs are used in determining the appropriate price. 48

49 Application The principles do not apply to: Arrangements under which State or Federal financing is in the form of loans, scholarships, fellowships, traineeships, or other fixed amounts based on such items as education allowance or published tuition rates and fees Fixed amount awards. See also Subpart A Acronyms and Definitions, Fixed amount awards and Use of grant agreements (including fixed amount awards), cooperative agreements, and contracts 49

50 Application The principles do not apply to: Federal Contracts. Where a Federal contract awarded to a non-federal entity is subject to the Cost Accounting Standards (CAS), it incorporates the applicable CAS clauses, Standards, and CAS administration requirements CAS applies directly to the CAS-covered contract and the Cost Accounting Standards at 48 CFR parts 9904 or 9905 takes precedence over the cost principles in this Subpart E Cost Principles of this part with respect to the allocation of costs. 50

51 Application The principles do not apply to: Exemptions. Some nonprofit organizations, because of their size and nature of operations, can be considered to be similar to forprofit entities for purpose of applicability of cost principles. Such nonprofit organizations must operate under Federal cost principles applicable to for-profit entities A listing of these organizations is contained in Appendix VIII to Part 200 Nonprofit Organizations Exempted From Subpart E Cost Principles 51

52 Basic Considerations Composition of Costs Total cost. The total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. (Direct + Indirect) - Credits = Total Cost 52

53 Factors affecting Allowability of Costs Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: a) Be necessary and reasonable for the performance of the award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both state and federally-financed and other activities of the nonfederal entity 53

54 Factors affecting Allowability of Costs Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: d) Be accorded consistent treatment. A cost may not be assigned to an award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except for state and local governments and Indian tribes, as otherwise provided for in this Part. 54

55 Factors affecting Allowability of Costs Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period g) Be adequately documented 55

56 Reasonable costs A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-federal entity is predominantly federallyfunded. 56

57 Reasonable costs In determining reasonableness of a given cost, consideration must be given to: a) Whether the cost is generally recognized as ordinary and necessary for the operation of the non-federal entity or the proper and efficient performance of the award. b) The restraints or requirements imposed by such factors as: sound business practices; arm s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the award. c) Market prices for comparable goods or services for the geographic area. 57

58 Reasonable costs In determining reasonableness of a given cost, consideration must be given to: d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-federal entity, its employees, where applicable its students or membership, the public at large, and the State and Federal government. e) Whether the non-federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the award s cost. 58

59 Allocable costs a) A cost is allocable to a particular award or other cost objective if the goods or services involved are chargeable or assignable to that award or cost objective in accordance with relative benefits received. This standard is met if the cost: Is incurred specifically for the award Benefits both the award and other work of the non-federal entity and can be distributed in proportions that may be approximated using reasonable methods Is necessary to the overall operation of the non-federal entity and is assignable in part to the award in accordance with the principles 59

60 Allocable costs b) All activities which benefit from the non-federal entity s indirect (F&A) cost, including unallowable activities and donated services by the non-federal entity or third parties, will receive an appropriate allocation of indirect costs. c) Any cost allocable to a particular Federal award under the principles provided for in this Part may not be charged to other Federal awards to overcome fund deficiencies, to avoid restrictions imposed by Federal statutes, regulations, or terms and conditions of the Federal awards, or for other reasons. However, this prohibition would not preclude the non-federal entity from shifting costs that are allowable under two or more Federal awards in accordance with existing Federal statutes, regulations, or the terms and conditions of the Federal awards. 60

61 Allocable costs d) Direct cost allocation principles. If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must should be allocated to the projects based on the proportional benefit. If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then, notwithstanding paragraph (c) of this section, the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Where the purchase of equipment or other capital asset is specifically authorized under an award, the costs are assignable to the award regardless of the use that may be made of the equipment or other capital asset involved when no longer needed for the purpose for which it was originally required 61

62 Allocable costs e) If the contract is subject to Cost Accounting Standards, costs must be allocated to the contract pursuant to the CAS. To the extent that CAS is applicable, the allocation of costs in accordance with CAS takes precedence over the allocation provisions in this Part. 62

63 Applicable credits a) Applicable credits refer to those receipts or reduction-ofexpenditure-type transactions that offset or reduce expense items allocable to the award as direct or indirect (F&A) costs. Examples of such transactions are: purchase discounts, rebates or allowances, recoveries or indemnities on losses, insurance refunds or rebates, and adjustments of overpayments or erroneous charges To the extent that such credits accruing to or received by the non-federal entity relate to allowable costs, they must be credited to the award either as a cost reduction or cash refund, as appropriate 63

64 Applicable credits b) In some instances, the amounts received from the State and Federal government to finance activities or service operations of the nonfederal entity must should be treated as applicable credits. Specifically, the concept of netting such credit items (including any amounts used to meet cost sharing or matching requirements) should be recognized in determining the rates or amounts to be charged to the award 64

65 Prior written approval Under any given Federal, Federal pass-through or state award, the reasonableness and allocability of certain items of costs may be difficult to determine. To avoid subsequent disallowance or dispute based on unreasonableness or nonallocability, the non-federal entity may seek the prior written approval of the cognizant agency for indirect costs or the State and/or Federal awarding agency in advance of the incurrence of special or unusual costs Prior written approval should include the timeframe or scope of the agreement and must include the name and title of the individual from the granting agency 65

66 Prior written approval The absence of prior written approval on any element of cost will not, in itself, affect the reasonableness or allocability of that element, unless prior approval is specifically required for allowability as described under certain circumstances in the following sections of this Part: (a) Use of grant agreements (including fixed amount awards), cooperative agreements, and contracts, paragraph (b)(5); (b) Cost sharing or matching; (c) Program income; (d) Revision of budget and program plans; (e) Real property; 66

67 Prior written approval (f) Equipment; (g) Fixed amount subawards; (h) Direct costs, paragraph (c); (i) Compensation personal services, paragraph (h); (j) Compensation fringe benefits; (k) Entertainment costs; (l) Equipment and other capital expenditures; (m) Exchange rates; (n) Fines, penalties, damages and other settlements; 67

68 Prior written approval (n) Fines, penalties, damages and other settlements; (o) Fund raising and investment management costs; (p) Goods or services for personal use; (q) Insurance and indemnification; (r) Memberships, subscriptions, and professional activity costs, paragraph (c); (s) Organization costs; 68

69 Prior written approval (t) Participant support costs; (u) Pre-award costs; (v) Rearrangement and reconversion costs; (w) Selling and marketing costs; and (x) Taxes (including Value Added Tax); and (y) Travel costs. 69

70 Limitation on allowance of costs The award may be subject to statutory requirements that limit the allowability of costs When the maximum amount allowable under a limitation is less than the total amount determined in accordance with the principles in this Part, the amount not recoverable under the award may not be charged to the award 70

71 Special Considerations In addition to the basic considerations regarding the allowability of costs highlighted in this subtitle, other subtitles in this Part describe special considerations and requirements applicable to states, local governments, Indian tribes, and Institutions of Higher Education. 71

72 Special Considerations Certain provisions among the items of cost in this subpart, are only applicable to certain types of non-federal entities, as specified in the following sections: (a) Direct and Indirect (F&A) Costs ( Classification of costs through Required certifications) of this subpart; (b) Special Considerations for States, Local Governments and Indian Tribes ( Cost allocation plans and indirect cost proposals and Interagency service) of this subpart; and (c) Special Considerations for Institutions of Higher Education ( Costs incurred by states and local governments and Cost accounting standards and disclosure statement) of this subpart. 72

73 Collection of Unallowable Costs Payments made for costs determined to be unallowable by either the Federal awarding agency, cognizant agency for indirect costs, or passthrough entity, either as direct or indirect costs, must be refunded (including interest) to the Federal government in accordance with instructions from the State or Federal agency that determined the costs are unallowable unless State or Federal statute or regulation directs otherwise. 73

74 Adjustment of Negotiated Indirect Cost Rate (containing unallowable costs) Negotiated indirect (F&A) cost rates based on a proposal later found to have included allowable costs must be appropriately readjusted by the cognizant agency These adjustments or refunds are designed to correct the proposals used to establish the rates and do not constitute a reopening of the rate negotiation. The adjustments or refunds will be made regardless of the type of rate negotiated 74

75 Direct & Indirect (F&A) Costs Classification of Costs There is no universal rule for classifying certain costs as either direct or indirect (F&A) under every accounting system A cost may be direct with respect to some specific service or function, but indirect with respect to the Federal award or other final cost objective Therefore, it is essential that each item of cost incurred for the same purpose be treated consistently in like circumstances either as a direct or an indirect (F&A) cost in order to avoid possible double-charging of Federal awards. Guidelines for determining direct and indirect (F&A) costs charged to Federal awards are provided in this subpart 75

76 Indirect (F&A) Costs Most organizations also incur costs for common or joint objectives that cannot be readily identified with an individual project or program Facilities operation and maintenance costs, depreciation, and administrative expenses are examples of costs that usually are treated as F&A costs The organization is responsible for the management and accounting of costs consistently and must not include costs associated with its F&A rate (Indirect Cost Rate) as direct costs 76

77 Indirect (F&A) Costs 2 CFR 200 explicitly requires pass-through entities (typically states and local governments receiving federal funding) and all federal agencies to reimburse the non-federal entity s indirect costs by applying the non-federal entity s federally negotiated indirect cost rate, if one already exists. If a negotiated rate does not yet exist, then the non-federal entity is empowered either to: Request negotiating a rate with the Pass-through agency (State of Illinois) Elect the de minimis rate of 10 % of their modified total direct costs (MTDC) 77

78 Required Certifications To assure that expenditures and reports are proper and in accordance with the terms and conditions of the Federal/State award a required certification signed by an official who is authorized to legally bind the non-federal entity is needed for: Approved and revised project budgets Annual and final fiscal reports Vouchers requesting payment under the agreements Indirect cost rate proposals Unallowable cost exclusion Lobbying 78

79 Questions 79

80 COST PRINCIPLES- GENERAL PROVISIONS SELECTED ITEMS OF COST Carol A Kraus, CPA & Sean Berberet Grant Accountability and Transparency Unit Copying, distributing, re-creating or any other unauthorized use of the content in these slides without the express written consent of the Grant Accountability and Transparency Unit (GATU) is strictly prohibited.

81 Subpart E- Cost Principles General Provisions Basic Considerations Direct & Indirect (F&A) costs General Provisions for Selected Items of Cost ( through ) 81

82 Objectives for Selected Items of Cost These sections ( through ) identify the allowability of certain items: Allowability applies to direct costs, indirect costs, and matching funds Allowability of any costs not included in the select items should based on the treatment provided for similar or related items of cost and the principles of allocability, reasonableness, and necessity ( ) 82

83 Introduction These principles apply whether a cost is treated as direct or indirect. Failure to mention a particular item of cost is not intended to imply that it is not allowable; rather, determination as to allowability in each case should be based on the treatment or principles provided for similar or related items of cost. 83

84 Advertising and Public Relations Allowable Advertising: Recruitment of personnel required for performance of Federal/State award Procurement of goods & services for the performance of the award Disposal of scrap or surplus acquired in the performance of award Program outreach and other specifics necessary to meet the requirements of the Federal/State award 84

85 Advertising and Public Relations The term public relations includes those activities dedicated to maintaining the image of the non-federal entity or maintaining or promoting understanding and favorable relations with the public The only allowable public relations costs are: 1. Costs specifically required by the State/Federal award 85

86 Advertising and Public Relations 2. Costs of necessary communications with the public and press pertaining to specific activities or accomplishments which result from performance of the Federal award; or 3. Costs of conducting general liaison with news media and government public relations officers, to the extent that such activities are limited to communication and liaison necessary to keep the public informed on matters of public concern, such as notices of funding opportunities, financial matters, etc. 86

87 Advertising and Public Relations Specifically unallowable advertising: 1. All advertising and public relations costs other than as specified on previous slides 2. Costs of meetings, conventions, convocations, or other events related to other activities of the entity (see also Conferences), including: Costs of displays, demonstrations, and exhibits 87

88 Advertising and Public Relations Specifically unallowable Advertising: 3. Costs of meeting rooms, hospitality suites, and other special facilities used in conjunction with shows and other special events; and 4. Salaries and wages of employees engaged in setting up and displaying exhibits, making demonstrations, and providing briefings 5. Costs of promotional items and memorabilia, including models, gifts, and souvenirs; 6. Costs of advertising and public relations designed solely to promote the non-federal entity. 88

89 Advisory councils Costs incurred by advisory councils or committees are unallowable unless: 1. Authorized by statute 2. Authorized by the Federal/State awarding agency 3. Authorized as an indirect cost where allocable to Federal/State awards 89

90 fsdfvsdfsdfsdfAlcoholic Beverages Alcoholic Beverages Costs of alcoholic beverages are unallowable! 90

91 Audit services A reasonably proportionate share of the costs of audits required by, and performed in accordance with, the Single Audit Act Amendments of 1996 are allowable Costs associated with the following types of audits are now specifically designated as unallowable: 1. Audits not conducted in accordance with Single Audit requirements 2. Audits that fall below the Single Audit threshold 91

92 Audit services Pass-through entities may also charge for the cost of agreed-upon procedures to monitor subrecipients exempt from the Single Audit Act as long as such procedures are: Conducted in accordance with Generally Accepted Government Auditing Standards (GAGAS); Paid for and arranged by the pass-through entity; and Limited in scope to one or more of the following types of compliance requirements: activities allowed or unallowed, allowable costs/cost principles, eligibility, and reporting 92

93 Bad Debts Bad debts, including losses (whether actual or estimated) arising from uncollectible accounts and other claims, related collection costs, and related legal costs, are unallowable 93

94 Collections of improper payments The costs incurred by a non-federal entity to recover improper payments are allowable as either direct or indirect costs, as appropriate. Amounts collected may be used by the non-federal entity in accordance with cash management standards set forth in Payment. 94

95 Compensation-Personal Services Includes all compensation paid currently or accrued by the organization during the period of the award. Compensation costs are allowable when: Reasonable and Necessary Consistent/Allocable Adequately documented 95

96 Compensation-Personal Services Charges for employee compensation still must be based on records accurately reflecting work performed. Records must meet the following standards: 1. Supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated 2. Incorporated into the non-federal entity s official records; 3. Reasonably reflect the total activity for which the employee is compensated 96

97 Compensation-Personal Services 4. Encompass 100% of activities those that are Federally and State assisted and those that are not; 5. Comply with the established accounting practices and policies of the non-federal entity; and 6. Support the distribution of the employee s salary or wages among specific activities or cost objectives. 97

98 Compensation-Fringe Benefits New Uniform Guidelines explains that the cost of fringe benefits is allowable provided the benefits are reasonable and required by law, employment agreement or an established policy. 98

99 Compensation-Fringe Benefits The following criteria must be met for leave benefits (e.g., annual, FMLA, sick, holidays, court, military, administrative, etc.) to be allowable: Benefits are provided for under established written leave polices; Costs are equitably allocated to all related activities including federal awards; and Accounting basis (cash or accrual) selected for costing each type is consistently followed 99

100 Compensation-Fringe Benefits Costs of pension plans and post-retirement health plans may be computed using a pay-as-you-go method or an acceptable actuarial cost method in accordance with established written policies. 100

101 Compensation-Fringe Benefits Pension plan costs are incurred in accordance with the established policies of the non-federal entity are allowable, provided that: 1. Such policies meet the test of reasonableness. 2. The methods of cost allocation are not discriminatory. 3. For entities using accrual based accounting, the cost assigned to each fiscal year is determined in accordance with GAAP 101

102 Compensation-Fringe Benefits 4. The costs assigned to a given fiscal year are funded for all plan participants within six months after the end of that year. However, increases to normal and past service pension costs caused by a delay in funding the actuarial liability beyond 30 calendar days after each quarter of the year to which such costs are assignable are unallowable. Non- Federal entity may elect to follow the Cost Accounting Standard for Composition and Measurement of Pension Costs (48 CFR ) 102

103 Conferences Allowable conference costs paid by the non-federal entity as a sponsor or host of the conference may include rental of facilities, speakers' fees, costs of meals and refreshments, local transportation, and other items incidental to such conferences unless further restricted by the terms and conditions of the Federal award. As needed, the costs of identifying, but not providing, locally available dependent-care resources are allowable. Conference hosts/sponsors must exercise discretion and judgment in ensuring that conference costs are appropriate, necessary and managed in a manner that minimizes costs to the Federal award. 103

104 Contributions and Donations Costs of contributions and donations, including cash, property, and services, from the non-federal entity to other entities, are unallowable The value of services and property donated to the non- Federal entity may not be charged to the Federal award either as a direct or indirect (F&A) cost. The value of donated services and property may be used to meet cost sharing or matching requirements (see Cost sharing or matching) 104

105 Contributions and Donations Services donated or volunteered to the non-federal entity may be furnished by professional and technical personnel, consultants, and other skilled and unskilled labor. The value of these services may not be charged to the Federal/State award either as a direct or indirect cost. However, the value of donated services may be used to meet cost sharing or matching requirements in accordance with the provisions of Cost sharing or matching Depreciation on donated assets is permitted as long as the donated property is not counted toward federal award cost sharing or matching requirements 105

106 Depreciation Depreciation on buildings or equipment furnished by the Federal/State government or purchased through Federal/State grants are unallowable expenses Depreciation on buildings or equipment furnished by the non-federal agency is an allowable indirect cost only The allocation for depreciation must be made in accordance with Appendices IV through VIII 106

107 Entertainment costs Costs of entertainment, including amusement, diversion, and social activities and any associated costs are unallowable 107

108 Equipment and Other Capital Expenditures Capital expenditures for general purpose equipment, buildings, and land are unallowable as direct charges, except with the prior written approval of the Federal awarding agency or pass-through entity Capital expenditures for special purpose equipment are allowable as direct costs, provided that items with a unit cost of $5,000 or more have the prior written approval of the Federal awarding agency or pass-through entity Equipment and other capital expenditures are unallowable as indirect costs 108

109 Fines, penalties, damages and other settlements Costs resulting from non-federal entity violations of, alleged violations of, or failure to comply with, Federal, state, tribal, local or foreign laws and regulations are unallowable Except when incurred as a result of compliance with specific provisions of the Federal award, or with prior written approval of the Federal awarding agency 109

110 Fundraising and Investment Management Costs Costs of organized fund raising, including financial campaigns, endowment drives, solicitation of gifts and bequests, and similar expenses incurred to raise capital or obtain contributions are unallowable Fund raising costs for the purposes of meeting the Federal program objectives are allowable with prior written approval from the Federal awarding agency. Proposal costs are covered in Proposal costs 110

111 Fundraising and Investment Management Costs Costs of investment counsel and staff and similar expenses incurred to enhance income from investments are unallowable except when associated with investments covering pension, self-insurance, or other funds which include Federal participation allowed Costs related to the physical custody and control of monies and securities are allowable Both allowable and unallowable fund raising and investment activities must be allocated as an appropriate share of indirect costs under the conditions described in Direct costs 111

112 Goods or Services for Personal Use Costs of goods or services for personal use of the non-federal entity's employees are unallowable regardless of whether the cost is reported as taxable income to the employees Costs of housing (e.g., depreciation, maintenance, utilities, furnishings, rent), housing allowances and personal living expenses are only allowable as direct costs regardless of whether reported as taxable income to the employees. In addition, to be allowable direct costs must be approved in advance by a Federal/State awarding agency 112

113 Idle Facilities and Idle Capacity Unallowable except to the extent that: They are necessary to meet fluctuations in workload Were necessary but due to unforeseen changes, are no longer necessary (under this exception, costs of idle facilities are allowable for a reasonable period of time, ordinarily not to exceed one year) MUST HAVE PRIOR APPROVAL 113

114 Insurance and Indemnification Key changes to the allowability of insurance costs mostly apply to nonprofits. Contributions to a reserve for some self insurance programs (including worker s compensation, unemployment compensation and severance pay) are now allowable if certain conditions are met. Also insurance refunds, if received, must be credited against such costs in the year the refund is received. 114

115 Interest Costs incurred for interest on borrowed capital, temporary use of endowment funds, or the use of the non-federal entity's own funds, however represented, are unallowable. Financing costs (including interest) to acquire, construct, or replace capital assets are allowable, subject to prior approval. 115

116 Lobbying Lobbying costs are generally unallowable, with narrow exceptions for non-profits 2 CFR 200 adds more detail to the treatment of lobbying costs 116

117 Losses on other awards or contracts Any excess of costs over income under any other award or contract of any nature is unallowable Any excess of costs over authorized funding levels transferred from any award or contract to another award or contract is unallowable 117

118 Maintenance and repair costs Costs incurred for utilities, insurance, security, necessary maintenance, janitorial services, repair, or upkeep of buildings and equipment (including Federal property unless otherwise provided for) which neither add to the permanent value of the property nor appreciably prolong its intended life, but keep it in an efficient operating condition, are allowable. Reminder: Improvements to building and equipment that add value should be treated as capital expenditures 118

119 Materials and Supplies costs, including costs of computing devices Costs incurred for materials, supplies, and fabricated parts necessary to carry out a Federal award are allowable. Computing devices are defined as machines used to acquire, store, analyze, process, and publish data and other information electronically, including accessories for printing, transmitting and receiving, or storing electronic information. Computing devices costing less than $5,000 that are essential and allocable, but not solely dedicated to the performance of a federal award, may be directly charged to an award 119

120 Memberships, Subscriptions and Professional Activity Costs The cost of membership in civic, business, technical, professional, and similar organizations is allowable. The cost of books, and subscriptions to civic, business, technical, professional, and like organization periodicals is allowable Costs of membership in any country club or social or dining club or organization are unallowable Costs of membership in organizations whose primary purpose is lobbying are unallowable. See also Lobbying 120

121 & Participant Support Costs Participant support costs are direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences or training projects. These costs must now be accepted by agencies as allowable costs, but still require prior agency approval In addition, these costs must be excluded when calculating the Modified Total Direct Costs (MTDC) to determine the overall project s F&A costs 121

122 Publication & Printing Costs Costs of publication and printing costs (electronic and print media) are allowable If publication costs are not identifiable with a particular cost objective they should be allocated as indirect costs. 122

123 Recruiting Costs The following recruiting costs are allowable: cost of "help wanted" advertising, operating costs of an employment office, costs of operating an educational testing program, and travel expenses including food and lodging of employees while engaged in recruiting personnel 123

124 Relocation Costs of Employees Costs incident to the permanent change of duty assignment (for an indefinite period or for a stated period not less than 12 months) of an employee. Relocation costs are allowable, subject to many limitations Limits (what was previously unlimited) amount of time for which a Federal award may be charged for costs of an employee s vacant home to a maximum of six months 124

125 Rental Costs of Real Property and Equipment Rental Costs including sale and lease back arrangements and less than arm s length leases are allowable provided certain criteria is met Rental costs under capital leases are allowable only up to the amount that would be allowed had the non-federal entity purchased the property on the date the lease agreement was executed. GAAP must be used to determine whether a lease is a capital lease The rental of any property owned by any individuals or entities affiliated with the non-federal entity for purposes such as home office workspace is unallowable 125

126 Training and Education The costs of training and education provided for employee development is now allowable for nonprofits 126

127 Travel Costs Travel costs may be charged on an actual cost basis, on a per diem basis, or a combination of the two Method(s) used for charging travel costs must be in accordance with an entity s written travel reimbursement policy. In order to charge travel costs (including lodging, meals and incidentals) of employees, documentation must justify that: 1. participation of the individual is necessary to the federal/state award; and 2. the costs are reasonable and consistent with the entity s established travel policy. 127

128 Questions 128

129 PRE-QUALIFICATION AND RISK ASSESSMENT Carol Kraus, CPA & Jennifer Butler, CMC Grant Accountability and Transparency Unit Copying, distributing, re-creating or any other unauthorized use of the content in these slides without the express written consent of the Grant Accountability and Transparency Unit (GATU) is strictly prohibited.

130 Pre-Qualification and Risk Assessment Objectives GATA Website Grantee Portal Grantee Registration and Pre-Qualification Financial and Administrative Risk Assessment Programmatic Risk Assessment Specific Conditions 130

131 GATA Website GATA will have a web presence through a state-hosted website From the website, the user will be able to access the following: Grantee Portal The Catalog of State Financial Assistance (CSFA) Notice of Funding Opportunities Listing of all executed grants State User Log in State Debarred and Suspended List Vendor Stop Pay List Report Interface Document Upload (NOFO, grant awards, etc.) 131

132 Pre-Qualification Background Pre-Qualification (30 ILCS 708/25 (6)) The prospective grantee must register on the Grantee Portal for prequalification prior to receiving a grant The prospective grantee may submit an application for a grant prior to completing the pre-qualification process but will not be awarded a grant until the prequalification process is completed The first year (FY17) the applicant is not prohibited from submitting a grant application prior to the Pre- Qualification. However, starting FY18 the prequalification must be completed prior to applying for a grant 132

133 Pre-Qualification Stage One To complete the information necessary for Pre-Qualification Stage One, the prospective grantee will need the following information: Organization name and address including Zip plus 4 Federal Employee Identification Number Organization type Local government, Nonprofit, For Profit, Educational Data Universal Numbering System (DUNS) number; SAM Cage Code number (if organization receives federal funding) Month, date and year organization was founded/incorporated Organization Affiliates (if yes, provide information above for each affiliate) Organization Contact information name, title, and phone number 133

134 Pre-Qualification Stage One Based on the information provided, pre-qualification verifies and validates if: DUNS number is current SAM Cage Code is current Fiscal condition of the organization is acceptable Applicant is in good standing with the Secretary of State (SoS) Applicant is not on Illinois Debarred and Suspended List or Stop Payment List Applicant is not on the Federal Excluded Parties List Applicant is not on the Sanctioned Party List maintained by the Illinois Department of Healthcare and Family Services 134

135 Grantee Notification and Remediation The Grantee will receive one of three notifications: 1. Notification of Non-Qualification - on State Debarred Suspended list or the Federal Excluded Parties list (no remedy available) 2. Notification of Non-Qualification with Remediation e.g. Stop Pay list, expired DUNS number, Not in Good Standing with SoS, the grantee will be provide with information to remedy 3. Qualified to receive a grant award and will be required to provide additional information in Stage Two of the registration process 135

136 Pre-Qualification Stage Two Grantee Experience: Based on the level of State or Federal grant administration experience: Less Than Two Years Grantee is considered high risk and the fiscal and administrative risk will not be conducted until notified they are a finalist in the grant application evaluation process More than two years Grantee will proceed to the fiscal and administrative risk stage More than 5 years Grantee will proceed to the fiscal and administrative review; if the grant programs meet the requirements for multi-year awards, the grantee is eligible to receive a multi-year award 136

137 Stage Two Small Grantee Provide total revenue in most Note: If total funding in Direct Federal, recent accounting period (Audit Federal Pass-through or State grants is or Tax return) from the following less than $20K No fiscal and sources: administrative risk assessment until notified Pass Through Federal Grants $7,000 State Grants $12,000 Direct Federal Funding $0 Other $175,000 Total $184,

138 Objectives Financial, Administrative and Programmatic Risk Assessment Requirements for Risk Posed by the Applicant 2 CFR Specific Conditions 2 CFR GATA Framework Fiscal and Administrative Risk Assessment Programmatic Risk Assessment 138

139 Financial, Administrative and Programmatic Risk Assessment The GATA Steering Committee elected to adopt the Federal Uniform Guidance with minor changes Federal awarding agency review of risk posed by applicants - 2 CFR (c) Financial stability Quality of management systems and ability to meet the management standards prescribed in 2 CFR 200 History of performance Reports and findings from audits performed under Subpart F Audit Requirement of this Part or the reports and findings of any other available audits The applicant s ability to effectively implement statutory, regulatory, or other requirements imposed on non-federal entities 139

140 Financial, Administrative and Programmatic Risk Assessment Specific conditions. The Federal awarding agency or pass-through entity must impose additional specific award conditions as needed, under the following circumstances: Based on the criteria set forth in Federal awarding agency review of risk posed by applicants When an applicant or recipient has a history of failure to comply with the general or specific terms and conditions of a Federal award When an applicant or recipient fails to meet expected performance goals as described in Information contained in a Federal award When an applicant or recipient is not otherwise responsible 140

141 Financial, Administrative and Programmatic Risk Assessment Specific conditions (Continued) These additional Federal award conditions must include items such as the following: Requiring additional project monitoring Requiring technical or management assistance Establishing additional prior approvals 141

142 Financial, Administrative and Programmatic Risk Assessment Specific conditions (Continued) These additional Federal award conditions must include items such as the following: Requiring additional, more detailed financial reports Requiring payments as reimbursements rather than advance payments Withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within a given period of performance 142

143 Financial, Administrative and Programmatic Risk Assessment Specific conditions (Continued) The Federal awarding agency or pass-through entity must notify the applicant or non-federal entity as to: The nature of the additional requirements The reason why the additional requirements are being imposed The nature of the action needed to remove the additional requirement, if applicable The time allowed for completing the actions if applicable, and The method for requesting reconsideration of the additional requirements impose 143

144 Financial, Administrative and Programmatic Risk Assessment Specific conditions (Continued) Any specific conditions must be promptly removed once the conditions that prompted them have been corrected Note: The specific conditions must be included in the Notice of State Award (NOSA) 144

145 GATA Framework for Risk Assessment Fiscal and Administrative Risk will be performed centrally and the grantee risk profile will be shared with state grant making agencies Programmatic Risk will be conducted in the application process in accordance with the framework Internal Control Questionnaires will collect risk profile data 145

146 Overview of Steps taken for the preparation of the Internal Control Questionnaire (ICQ) The Pre-Qualification and Programmatic Risk Subcommittees reviewed many documents for risk assessment and Internal Control and determined the guiding principles: 2 CFR Internal control over compliance requirements for Federal awards Audit requirements the end result Financial Audits performed in accordance with Government Auditing Standards Federal Compliance Supplement 146

147 Risk Assessment and Prior Performance State Grant Making Agencies will be required to provide information on grantee prior performance including: Programmatic and Fiscal results vs. goals and objectives Timely reporting financial, performance, close out, audit reports Prior audit report findings Timely implementation of audit report corrective action Resolution of on-site review issues 147

148 2 CFR Internal Control over Compliance Requirements for Federal awards Internal control over compliance requirements for State and Federal pass-through awards means a process implemented by an awardee entity designed to provide reasonable assurance regarding the achievement of the following objectives: The following items are marked either Fiscal and Administrative (F&A), Programmatic (P) or Both (B) which includes both Fiscal and Administrative and Programmatic Transactions are properly recorded and accounted for, in order to: Permit the preparation of reliable financial statements and State and Federal Pass-through reports (B) Maintain accountability over assets (F&A) 148

149 2 CFR Internal Control over Compliance Requirements for Federal awards Demonstrate compliance with Federal and State statutes, regulations, and the terms and conditions of the grant agreement (B) Transactions are executed in compliance with: State Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a grant program (B) Any other Federal statutes and regulations that are identified in the Compliance Supplement (B) Funds, property, and other assets are safeguarded against loss from unauthorized use or disposition (B) 149

150 Compliance Supplement - Types of Compliance Requirements Activities allowed or unallowed (P) Allowable costs/cost principles (B) Cash management - (F&A) Davis Bacon (P) Eligibility (P) 150

151 Compliance Supplement - Types of Compliance Requirements Equipment and real property management (B) Matching, level of effort, earmarking (B) Period of availability of federal funds (B) Program income (B) 151

152 Compliance Supplement - Types of Compliance Requirements Real property acquisition and relocation (moved to Special Tests and Provisions under Uniform Guidance) (P unique requirement of specific grant) Reporting (B) Subrecipient monitoring (B) Special Tests and Provisions (P additional requirements unique to specific grant; not covered under prior requirement) 152

153 Programmatic Risk Assessment Framework Limited program experience, protocols and internal controls governing program delivery increase an applicant s programmatic risk profile Programmatic risk assessment questions assess the applicant s ability to successfully execute the specified program The programmatic risk profile may require additional conditions within the grant award to develop the entity s capacity to deliver and/or administer the grant program 153

154 Risk Assessments Inform the Grant Making Process Risk assessments and subsequent risk profiles inform the agency and protect state assets Risk assessments are a mandatory up-front requirement for all grant awards Patterns and trends in risk assessment will influence GATA and agency-specific grantee training, technical assistance, and the scope of grantee monitoring plans 154

155 Risk Assessments Build Grantee Capacity Results of the risk assessments do not preclude entities from becoming grantees Risk profiles will proactively guide the grant monitoring requirements and specific conditions The risk profile establishes a blueprint for grantees to meet minimum compliance requirements and increase grant administration capacity Agencies will utilize risk profiles to control against fraud, waste and abuse Risk Assessments Educate the Agency and the Grantee for Proactive Grant Management and Monitoring 155

156 Questions and Answers 156

157 UNIFORM NOTICE OF FUNDING OPPORTUNITY Jennifer Butler, CMC Grant Accountability and Transparency Unit Copying, distributing, re-creating or any other unauthorized use of the content in these slides without the express written consent of the Grant Accountability and Transparency Unit (GATU) is strictly prohibited.

158 Notice of Funding Opportunity (NOFO) Official public notice of a grant opportunity offered by a state agency Associated with the funding record in the Catalog of State Financial Assistance (CSFA) Informs potential applicants so an educated decision can be made to apply for funding Prepared by the state agency and made publicly available through the agency protocol 158

159 Notice of Funding Opportunity (NOFO) Structured to comply with 2 CFR , and Appendix 1 Required as a public notice for all competitive grants and cooperative agreements Must be posted in accordance with uniform requirements and specific grant requirements For competitive grants, must be published at least 45 calendar days Should be posted at least 30 calendar days 159

160 Uniform NOFO Template Summary Information Agency-specific content including: Program description Funding Information Eligibility Information Application and Submission Information Application Review Information Award Administration Information State Awarding Agency Contacts Other Information Links to mandatory forms (Uniform Application) 160

161 Summary Information General information about the funding opportunity including: Awarding agency name; contact information CSFA and CFDA information Source of funding Indication if cost sharing or matching is requirements and if indirect costs are allowed Closing date for applications Details about a Technical Assistance session, if applicable 161

162 NOFO Agency-specific Content Narrative that details the grant program / project A. Program Description B. Funding Information C. Eligibility Information D. Application and Submission Information E. Application Review Information F. Award Administration Information G. State Awarding Agency Contact(s) H. Other Information, if applicable 162

163 A. Program Description Must include a full program description including purpose and program objectives Must describe how this grant supports the awarding agency s funding priorities Must include citations for authorizing statutes and regulations Must specify performance goals, indicators or milestones and timing of expected performance Must require the grantee to relate financial data to performance accomplishments 163

164 B. Funding Information Must specify the source of funds (e.g., federal or state) Must indicate that a grant will be awarded to successful applicants Must instruct the applicant to submit a project plan for executing the grant award ensure program delivery is well thought out May elaborate on available funding: Total amount of funding expected to be awarded Anticipated number of awards Anticipated start dates and periods of performance 164

165 C. Eligibility Information Specify considerations or factors to determine applicant or application eligibility Include references to documentation that must be submitted to support eligibility determination, if applicable Agencies should seek cultural inclusion among grantees Must state if cost sharing, matching or cost participation is required Must state if indirect cost rates are allowed and if there are restrictions Specify other eligibility criteria (if applicable) including a reference to the regulation of requirement An entity must complete pre-qualification through the Grantee Portal before a grant can be awarded 165

166 D. Application and Submission Information Must include instructions for obtaining the grant application and supporting materials (linked to the NOFO) Must specify required content of the application and the and forms/formats the applicant must submit including: Limitations on number of pages, font size, etc. Number of copies required, sequence / assembly details Original signature requirements Must specify information successful applicants must submit after notification of intent and before grant award Must require applicants to provide a DUNS number and a SAM Cage Code (pre-qualification requirements) 166

167 D. Application and Submission Information (Continued) Must identify due dates and times for all submissions Specify date and local time; account for weekends, federal or state holidays What the deadline means (receipt of application, post mark, etc.) Specify how the agency determines if deadlines have been met Note the effect of missing the deadline If applicable, state that the funding opportunity is open with no specific due dates for applications May indicate if an acknowledgement of receipt will be distributed by the agency Must include funding restrictions so applicants develop applications and budgets consistent with the program 167

168 D. Application and Submission Information (Continued) Must state if the funding opportunity is subject to Executive Order 12372, Intergovernmental Review of Federal Programs Must include funding restrictions so applicants develop applications and budgets consistent with program requirements Specify limitations on direct and indirect costs, pre-award costs Must address other submission requirements including format for submission (e.g., paper or electronic; only one format) Provide instructions for submitting applications and point of contact if applicant experiences technical difficulties 168

169 E. Application Review Information Must specify criteria to evaluate applications including merit and other review criteria, and statutory, regulatory or other preferences applied in the evaluation process Specify relative percentages, weights, or other means to distinguish criteria Provide detailed explanation for statutory, regulatory or other preferences with explicit indication of their effect (e.g., additional points) Must specify how cost sharing will be considered in the review process, if applicable Clarify restrictions on types of cost acceptable as cost sharing 169

170 E. Application Review Information (Continued) Must list Merit Based Review policy and other program policy or factors used in selecting applicants (e.g., geographic dispersion) Must specify if there is a multi-phase review process; may describe the phases Appeal process must be specified pursuant to the Merit Based Review Policy Agency may disclose the anticipated dates for announcing or notifying applicants of award decision(s) 170

171 F. Award Administration Information Addresses what a successful applicant can expect to receive following selection Emphasize that a notice provided prior to a state award is not authorization to begin performance Must identify the usual administrative requirements of the agency including parameters for indirect cost rates Introduces the Notice of State Award which specifies usual administrative requirements of the agency and special / general terms and conditions for the funding opportunity Must include type, frequency and means of post-award reporting requirements 171

172 G. State Awarding Agency Contacts Must provide agency point(s) of contact while the funding opportunity is open Specify multiple ways to reach the contact (e.g., , phone) Ensure multiple people can access the account or phone line As appropriate, identify different contacts for distinct kinds of help (e.g., administrative, programmatic) 172

173 H. Other Information, if Applicable May include additional information that will assist potential applicant such as: Indicate if this a new or one-time initiative List related programs or other upcoming agency funding for similar opportunities Provide internet addresses for the agency for reference May alert applicants to the need to identify proprietary information and inform of how the agency handles such information 173

174 Mandatory Forms Links from the NOFO are provided to: Uniform State Application Including agency-specific forms and application requirements Project narrative Completed budget and budget narrative 174

175 Notice of Funding Opportunity Agencies may begin using the NOFO template Or, agencies may conduct a gap analysis to determine the differences between the NOFO and the document currently used To be compliant, make sure your agency s public notice of grant opportunities includes all required fields from the NOFO 175

176 Notice of Funding Opportunity Questions 176

177 THE UNIFORM GRANT APPLICATION Jennifer Butler, CMC Grant Accountability and Transparency Unit Copying, distributing, re-creating or any other unauthorized use of the content in these slides without the express written consent of the Grant Accountability and Transparency Unit (GATU) is strictly prohibited.

178 Uniform Grant Application Based on the information provided in the Notice of Funding Opportunity (NOFO), an individual or entity may elect to submit a grant application Interested parties will access a grant application from the NOFO Grant applications will reside on the awarding agency s website The grant application will be submitted directly to the awarding agency pursuant to agency protocol Entities may apply for grant awards prior to completing the pre-qualification in FY17 Pre-Qualification is required to receive a grant award 178

179 Uniform Grant Application Template In compliance with 2 CFR 200, a uniform grant application template has been developed based on the framework of SF-424 The template includes two sections: Agency Completed Section Applicant Completed Section 179

180 Agency Completed Section General grant information Type of submission (pre-application, application, corrected application) Type of application (new, continuation, revision) Agency information CFSA information CFDA information Funding Opportunity Information, as assigned in the NOFO Competition Identification, if applicable 180

181 Applicant Completed Section Applicant Information Name Legal (used in DUNS registration) and Common (DBA) names EIN/TIN number Organizational DUNS number SAM Cage Code Contact Information for application program matters and application business/administrative matters Areas affected (e.g., counties, congressional and legislative districts) Applicant project detail Project title, proposed project term, estimated funding (all sources) Applicant certification including signature of authorized representative 181

182 Agency Requirements to Accompany the Application The application template is the transmittal for the applicant s response to the NOFO State and agency requirements that must be submitted with the application are specified in the NOFO In accordance with agency protocol, applicants will submit the requirements directly to the agency The agency will update the Date / Time Received field of the application upon receipt of the application 182

183 Use of the Grant Application Template Agencies may begin using the Uniform Application for Grant Assistance template Or, agencies may conduct a gap analysis to determine the differences between the template and their current grant application To be compliant, make sure your agency s grant application includes all required fields from the uniform grant application template 183

184 Uniform State Grant Application Questions 184

185 MERIT BASED REVIEW Trudy Ingalls, Ed.S, CPPO, PMP Grant Accountability and Transparency Unit Copying, distributing, re-creating or any other unauthorized use of the content in these slides without the express written consent of the Grant Accountability and Transparency Unit (GATU) is strictly prohibited.

186 Merit Based Review Applicability to Competitive Grants in Illinois Merit-Based Review for competitive grants in Illinois including fully or partially funded Federal, Federal-Pass Through and State funded grants shall comply with GATA Legislation 30 ILCS 708 and 2 CFR 200 Uniform Requirements. Grants funded solely by private funds are not subject to GATA legislation and 2 CFR 200 requirements. 186

187 Merit Based Review 2 CFR Authoritative Sources and IL Proposed Rule Change 2 CFR Federal awarding agency review of merit of proposals. For competitive grants unless prohibited by Federal statute, the Federal awarding agency must design and execute a merit review process for applications. This process must be described or incorporated by reference in the applicable funding opportunity (see Appendix I to this part, Full text of the Funding Opportunity.) See also Section Notices of funding opportunities. An appeals process must be described and incorporated with the merit based review process 187

188 Merit Based Review Process Overview A.Receipt of Grant Application Proposals shall be recorded including applicant, date and time B. State Agencies shall keep a file of the grant award process C. Competitive evaluation criteria must be tied to objective/purpose of grant and include at a minimum need, capacity and quality 188

189 Merit Based Review Process Overview D. Merit based review of the Competitive Grant Application shall be prepared in accordance with 2CFR Section and include the evaluation process description, criteria and importance stated in the grant application including: 1. Preferences, technical assistance options, and tie breakers 2. Identifying if there are multiple phased of evaluation 3. Review based solely on criteria identified in the grant 4. Cost sharing when applicable and specifically defined 189

190 Merit Based Review Process Overview D. The evaluation process shall include: (Continued) 5. Evaluation shall be conducted by a committee. a. Committee members must not have any conflicts of interest or apparent conflicts of interest. b. Grant applicants may not be evaluation committee members unless exceptions required by statute c. Committee members must sign Confidentiality and Conflict of Interest Disclosure d. Evaluation committee members may be removed 190

191 Merit Based Review Policy and Guidelines Evaluation Process Examples of Conflict of Interest: Financial interest, including ownership of stocks and bonds, in a firm which submits, or is expected to submit, an application in response to the funding opportunity Employment of any member of the immediate family by any applicant or potential applicant 191

192 Merit Based Review Policy and Guidelines Evaluation Process Examples of Conflict of Interest: A close personal relationship that may include a spouse, dependent child or member of the proposal evaluator's household that may compromise or impair the fairness and impartiality of the proposal evaluator or advisor and grants officer during the proposal evaluation and award selection process, and the management of an award 192

193 Merit Based Review Policy and Guidelines Evaluation Process D. The evaluation process shall include: (Continued) 6) Evaluation shall be based on numerical rating unless another scoring methodology is more appropriate based on the unique circumstances of the grant program and at a minimum a. Any scoring tool shall reflect the evaluation criteria b. Individual score sheet which is completed independently c. Summary score sheet d. Variances documented 193

194 Merit Based Review Merit Based Finalist Requirements D. The evaluation process shall include: (Continued) 7) Merit Based Finalist Requirements prior to Receiving an Award a. Agency will perform the programmatic risk assessment b. Agency will distribute the Notice of State Award Finalist which identifies outstanding requirements that must be completed prior to grant award: Grantee pre-qualification (via the Grantee Portal) Conflict of Interest and Mandatory Disclosures Fiscal and Administrative Risk Assessment NOTE: Requirements in D.7 apply to all grant awards 194

195 Merit Based Review Notice of State Award (NOSA) E. At the discretion of the awarding agency, finalists that satisfactorily complete all grant award requirements will be issued a Notice of State Award (NOSA) The NOSA will be prepared by the awarding agency and will include: Terms and conditions of the award Specific conditions assigned to the grantee based on the fiscal and administrative and programmatic risk assessments. Based on the NOSA, the applicant is positioned to make an informed decision to accept the grant award 195

196 Merit Based Review Appeal Process F. Merit-Based Evaluation Appeal Process: Only the evaluation process is subject to appeal. 1) An appeal must be submitted in writing and received within 14 calendar days, including the contact information of the appealing party, the grant and reason(s) for appeal 2) Acknowledgement of the appeal must be within 14 calendar days and responses within 60 calendar days 3) An appeal may stay the execution of the grant agreement and the resolution must include a written determination 4) Judicial Action may defer resolution of an appeal 196

197 Questions? 197

198 UNIFORM BUDGET TEMPLATE & INDIRECT COST RATES Carol A Kraus, CPA & Sean Berberet Grant Accountability and Transparency Unit Copying, distributing, re-creating or any other unauthorized use of the content in these slides without the express written consent of the Grant Accountability and Transparency Unit (GATU) is strictly prohibited.

199 Uniform Budget Template & Indirect Cost Rates This training module will focus on: Understanding the basic requirements and application of Indirect Cost Rates Getting familiar with the new Uniform Budget Template This is intended to be an introductory training on the basic concepts, more in depth training will be provided 199

200 What is a Indirect Cost Rate? A Negotiated Indirect Cost Rate Agreement (NICRA) is a tool used for determining the appropriate amount of indirect costs each program should bear. It is the ratio (expressed as a percentage) of an indirect cost pool and a particular direct cost base. Indirect Cost Pool Direct Cost Base = Indirect Cost Rate % The agreement is negotiated between the awardee and the state or federal government 200

201 Why does my organization need a Negotiated Indirect Cost Rate? In order to be reimbursed for indirect expenses associated with a project or program, an awardee must have: State or Federally NICRA or, if eligible, elect to use the new 10% de minimis rate of Modified Total Direct Costs (MTDC) NO INDIRECT COSTS WILL BE REIMBURSED WITHOUT AN APPROVED RATE 201

202 Negotiated Indirect Cost Rate Agreement (NICRA) Overview Lets review the basics to fully understand a Negotiated Indirect Cost Rate Agreement. A cost is allocable to a particular cost objective, such as a grant, contract, project, service, or other activity, in accordance with the relative benefits received Direct Costs Can be identified specifically with a particular final cost objective (i.e., a particular award, service or direct activity) Indirect Costs Incurred for common or joint objectives and cannot be readily identified with a particular final cost objective 202

203 Negotiated Indirect Cost Rate Agreement (NICRA) Overview After direct costs have been determined and assigned directly to awards or other work as appropriate, indirect costs are those remaining to be allocated to benefiting common cost objectives. NOTE: 2 CFR 200 emphasizes that it is essential that each item of cost incurred for the same purpose must be treated consistently in like circumstances either as a direct or indirect cost. 203

204 Negotiated Indirect Cost Rate Agreement (NICRA) Overview DIRECT COSTS Direct Costs are those costs that can be identified specifically with a particular final cost objective (i.e., a particular award, project, service, or other direct activity of an organization) Costs identified specifically with awards as direct costs of the awards and are assigned directly to the award Costs identified specifically with other final cost objectives of the organization not associated with the state or federal funded grants are direct costs of those cost objectives and are not to be assigned to other awards directly or indirectly 204

205 Negotiated Indirect Cost Rate Agreement (NICRA) Overview DIRECT COSTS Typical examples of direct costs for many organizations may include: Salaries and wages Fringe benefits Materials and supplies Travel expenses Communications expenses Equipment Rent and Occupancy for program 205

206 Negotiated Indirect Cost Rate Agreement (NICRA) Overview The Uniform Guidelines (UG) explains that salaries of administrative and clerical staff should normally be treated as indirect costs. However, such costs may be charged as a direct cost to a federal award if all of the following conditions are met: Administrative or clerical services are integral to the project or activity Individuals involved can be specifically identified with the project or activity The costs are explicitly included in the budget or have prior written approval of the awarding agency The costs are not also recovered as indirect costs 206

207 Negotiated Indirect Cost Rate Agreement (NICRA) Overview INDIRECT COSTS Indirect Costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective After direct costs have been determined and assigned directly to awards or other work as appropriate, indirect costs are those remaining to be allocated to benefiting cost objectives A cost may not be classified as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to an award as a direct cost 207

208 Negotiated Indirect Cost Rate Agreement (NICRA) Overview INDIRECT COSTS Typical examples of indirect costs for many organizations may include: Depreciation on buildings and equipment Costs of operating and maintaining facilities General administration and general expenses, such as the salaries and expenses of executive officers, personnel administration, and accounting Office supplies, Office Rent (common areas such as reception areas, break rooms, conference rooms), Utilities, Postage Administrative support such as clerical Property Insurance 208

209 Negotiated Indirect Cost Rate Agreement (NICRA) Overview INDIRECT COSTS Indirect Costs are typically classified within two broad categories: Facilities and Administration (F&A) Facilities includes: Depreciation on buildings, equipment and capital improvements Interest on debt associated with certain buildings, equipment and capital improvements, and Operations and maintenance expenses incurred for the administration, operation, maintenance, preservation, and protection of the organization s physical plant 209

210 Negotiated Indirect Cost Rate Agreement (NICRA) Overview Operations and maintenance expenses include: Janitorial and utility services Repairs and ordinary or normal alterations of buildings, furniture and equipment Care of grounds Maintenance and operation of buildings and other facilities Security Disaster preparedness Environmental safety Property, liability and other insurance relating to property Space and capital leasing Facility planning and management Central receiving 210

211 Negotiated Indirect Cost Rate Agreement (NICRA) Overview Administration includes: General administration and general expenses that have been incurred for the overall general executive and administrative offices of the organization and other expenses of a general nature which do not relate solely to any major function of the organization. Examples: Director s office Office of finance Business services Budget and planning Personnel Safety and risk management General counsel Management information systems Library costs and All other types of expenditures not listed specifically under one of the subcategories of Facilities (including cross allocations from other pools, as applicable) 211

212 Negotiated Indirect Cost Rate Agreement (NICRA) Overview INDIRECT COSTS Special care should be exercised in developing the Administration cost pool to ensure that costs incurred for the same purposes in like circumstances are treated consistently as either direct or indirect costs Organizations receiving more than $10 million in Federal funding in a fiscal year must breakout indirect costs between Facilities and Administration 212

213 Negotiated Indirect Cost Rate Agreement (NICRA) Overview What is an Indirect Cost Rate Proposal (ICRP)? Documentation prepared by an organization to substantiate its claim for the reimbursement of indirect costs. The proposal is the basis for establishing a Negotiated Indirect Cost Rate Agreement (NICRA) 213

214 Negotiated Indirect Cost Rate Agreement (NICRA) Overview The Centralized Indirect Cost Unit will review and negotiate rate proposals on behalf of State Agencies This Unit, in conjunction with the State Cognizant Agency, will negotiate with subrecipients who do not currently have a rate to use on State awards. 214

215 Negotiated Indirect Cost Rate Agreement (NICRA) Overview What is a Cognizant Agency? A Cognizant agency is the agency that provides the majority of funding to a recipient, or in cases involving the State of Illinois agencies, funding to a subrecipient. Indirect cost rate negotiations will be outsourced through a vendor beginning with grants issued in FY

216 Negotiated Indirect Cost Rate Agreement (NICRA) Overview Does every organization need to negotiate a rate through the State of Illinois in order to charge indirect costs on State awards? Not every organization will be required to negotiate a rate through the State of Illinois. There are other indirect cost rate options available to organizations. The next slides identify all options for indirect cost rates required for reimbursement 216

217 Negotiated Indirect Cost Rate Agreement (NICRA) Overview Every organization must Negotiate Indirect Cost Rate Agreement or use an available option for indirect cost in order to claim indirect cost reimbursement 1. Federal rate 2. State of Illinois rate 3. 10% de minimis (MTDC) rate READY TO MOVE ON 217

218 Negotiated Indirect Cost Rate Agreement (NICRA) Overview If the organization receives direct federal funding and has Federally approved NICRA, State agencies are required to accept and utilize the rate for indirect cost reimbursement The organization must provide a copy of the NICRA No verification of the computations is required 218

219 Negotiated Indirect Cost Rate Agreement (NICRA) Overview If the organization only receives federal pass-through or state funding, a State Indirect Cost rate or election of the de minimis rate is required to be negotiated State awarding agencies are required to accept and utilize the approved rate for indirect cost reimbursement The NICRA must be negotiated annually with the Centralized Indirect Cost Unit 219

220 Negotiated Indirect Cost Rate Agreement (NICRA) Overview If eligible, the organization may elect to use the 10% de minimis rate of Modified Total Direct Cost (MTDC) to calculate indirect cost reimbursement for a program provided: The organization has never negotiated an indirect cost rate with the Federal government ever, ever, ever Let s briefly discuss the 10% de minimis rate 220

221 De Minimis Rate 10% of MTDC Once elected it may be used indefinitely The calculation of the Modified Total Direct Cost must be verified by the State annually MTDC means all direct salaries and wages, applicable fringe benefits, materials and supplies, services and travel The first $25,000 of subawards and subcontracts Excludes equipment, capital expenditures, charges for patient care, rental costs, tuition reimbursement, scholarships and fellowships, participant support cost 221

222 Steps in calculating the MTDC Identify Direct and Indirect Costs Separate unallowable cost (both direct and indirect) Identify costs that must be excluded from the MTDC base Calculate the MTDC base 222

223 Example 10% de minimis calculation Program A Budget Salaries & Wages $100,000 Fringe Benefits $50,000 Travel $10,000 Materials & Supplies $20,000 Subcontract (1) $100,000 Equipment $10,000 Total Direct Costs $290,000 Less (Subcontract over $25,000) ($75,000) Less Equipment ($10,000) Modified Total Direct Cost (MTDC) $205,000 10% de minimis rate of (MTDC) $20,500 $20,500 is the maximum amount allowable for indirect costs for the program under the de minimis rule. Combined approved budget should be: Total Direct $290,000 + Indirect $20,500 $310,500 NOTE: The de minimis rate can only be applied to the MTDC 223

224 Negotiated Indirect Cost Rate Agreement (NICRA) Overview There are certain programs that will require organizations or subrecipients, by statute, to use what is called a restricted rate A restricted rate limits the indirect cost percentage to be used by any organization Please refer to the Notice of Funding Opportunity and grant application to determine if your program is subject to a restricted rate 224

225 Other Limitations Salary Caps Other limitations restrictions include Salary Caps Salary Caps limit total amount of salaries allowed to be charged to a grant The Salary Cap limitations apply to both Direct and Indirect Costs Grant funding may NOT be used to pay an individual working on a grant program at a rate in excess of the Federal Executive Level II Pay Scale This amount typically increases annually. Beginning January 10, 2016, the salary rate limitation has increased from $183,300 to $185,100. For individuals with salary in excess of the salary cap, payroll costs must be allocated by applying amount of effort committed to the salary cap Please refer to the Notice of Funding Opportunity and grant application to determine if your program is subject to a salary cap 225

226 Other Limitations Salary Caps Example A staff member whose base salary is $200,000 receives an award where he/she has proposed 25% of total time Payroll expense charged cannot exceed 25% of salary cap of $185,100 annually In this case, the person could not charge payroll expenses to the grant in excess of $46,275 annually (25% effort x $185,100). The excess salary costs must be paid from a non-grant source. Some grant programs do not allow any of the salary to be charged to the grant, if it exceeds the Salary Cap 226

227 Negotiated Indirect Cost Rate Agreement (NICRA) Overview Finally, certain organizations may not seek indirect cost reimbursement at all. For those organizations, it is imperative that direct budget costs cannot contain any indirect expenses. 227

228 Wait My organization needs an Indirect Cost Rate Agreement from the State of Illinois GATA will have the Centralized Indirect Cost Unit available for negotiating rates in early Spring 2016 Qualified applicants must submit its initial Indirect Cost Rate Proposal (ICRP): Immediately following execution of the grant agreement, or No later than three (3) months after the effective date of the State award Extensions are not allowed Indirect costs will not be reimbursed until the negotiation is finalized 228

229 Uniform Budget Template Please find your copy of the NEW Uniform Budget Template that was provided. The final portion of this training module will briefly cover the directions and sections that comprise the new template. 229

230 Uniform Budget Template Getting familiar with the new Uniform Budget Template within the Grant Application General Instructions Section A- State of Illinois Funds Indirect Cost Rate Information Section B- Non-State of Illinois Funds Section C- Budget Worksheet and Narrative 230

231 General Instructions Uniform Budget Template General Instructions guides the applicant through the 3 majors sections that consist of the Uniform Budget template Although the degree of specificity of any budget will vary depending on the nature of the project and State of Illinois agency requirements, a complete, well-thought-out budget serves to reinforce your accountability 231

232 Section A- Budget Summary State of Illinois Funds 1. Applicants will enter the total amount of State of Illinois grant funds requested for a particular program 2. Applicants will be required to provide a break-down by the applicable budget expenditure categories shown in lines Total amount of grant funds requested must equal the total amount of costs budgeted Items of Note State Agencies will have the ability to gray-out certain expense categories that may not apply to a particular award Only eligible applicants and grant programs will provide multiyear budgets for multi-year grant awards. All other applicants will be required to budget for one fiscal year 232

233 Section A- Budget Summary State of Illinois Funds Items of Note (cont.) Line 15 allows for a Grant Exclusive Line Item : Particular to a certain program and not included in the general expenditure categories The Grant Exclusive Line Item must include regulatory cite Line 17 requires Indirect Cost Rate information in order to calculate the indirect cost reimbursement for the program 233

234 Section A- Indirect Cost Rate Information Options available to applicants for indirect cost reimbursement: 1. Applicants must use a Federally approved indirect cost rate if established 2. If applicants do not have a Federally approved rate: Applicants may request a rate through the State of Illinois GATA has developed a centralized unit that will review and negotiate rates on behalf of all State of Illinois agencies Proposals are required immediately after the applicant has been advised that the award will be made and no later than 90 days after the effective date Eligible applicants may elect to use the de minimis of 10% modified total direct cost (MTDC) 234

235 Section A- Indirect Cost Rate Information Options available to applicants for indirect cost reimbursement (continued): 3. Applicants do not request indirect cost reimbursement 4. Applicants may be required to use a restrictive rate or salary cap (must be included in the NOFO, NOSA and grant agreement) Look and sound familiar? You guys are experts at this! 235

236 Section A- Indirect Cost Rate Information More in-depth training and information regarding Negotiated Indirect Cost Rate Agreements (NICRA) and the State of Illinois Indirect Cost Rate Unit will be: Coming soon to a training module near you! How do I receive a NICRA? Who should I contact? What information do I need? Where do I submit a proposal? When should I submit a proposal? How do I get approved? 236

237 Section B- Budget Summary Non-State of Illinois Funds (Matching Funds) 1. If applicants are required to provide or use volunteers to provide cost-sharing, matching funds or other non-state of Illinois resources to the project, the applicant must provide a revenue breakdown of all Non-State of Illinois funds 2. Applicants will be required to provide a break-down by the applicable budget categories shown in lines Total amount of grant funds requested must equal the total amount of costs budgeted NOTE: State Agencies can enter match requirement amounts under Program Revenues 237

238 Section C Budget Worksheet & Narrative All applicants are required to submit a budget narrative along with Section A and Section B. The budget narrative is sometimes referred to as the budget justification. The narrative serves two purposes: It explains how the costs were estimated It justifies the need for the cost The narrative may include tables for clarification purposes Applicants must use the State of Illinois Uniform Budget worksheet and narrative guide provided 238

239 Section C Budget Worksheet & Narrative The Budget Worksheet and Narrative is designed to follow the expenditure categories listed in Sections A & B. Each worksheet contains: Headings with basic expenditure references and additional instructions A work area section for computations A designated area for written narratives for non-state or federally funded expenditures (match) including the valuation method for in-kind contributions 239

240 Budget Training More in-depth training and information regarding the Budget Template will be: Coming soon to a training module near you! What information do I need? How do I complete a budget? How do I place a value on volunteer services? How do I place a value on donated items? Who reviews approves the budget? How do I apply the indirect cost rate? 240

241 Indirect Cost Rate and Budget Template Questions 241

242 UNIFORM GRANT AGREEMENT Grant Agreement Overview Jennifer Butler, CMC Grant Accountability and Transparency Unit

243 Uniform Grant Agreement Objectives Three Parts of the Uniform Grant Agreement (UGA) Agency Gap Analysis Description of the Exhibits Required Attachments 243

244 Uniform Grant Agreement Overview The UGA is divided into three parts along with exhibits Part One contains the uniform requirements applicable to all awards in the State of Illinois (state and federal requirements) Part Two may contain any additional agency-specific requirements an agency may have for grants Part Three should contain the grant (program or project) specific requirements 244

245 Grant Agreement Sections Overview Part one is considered core and common requirements (state and federal requirements) Agencies can add to the requirements that are listed in Part One by adding provisions to Part Two or Part Three Agencies may not subtract from Part One The overall goal is keep Part One as uniform as possible; subtractions to Part One should only occur if there is an exception to the state or federal general rule 245

246 Grant Agreement Sections Overview Parts Two and Three contain cross-references to Part One, therefore Parts Two and Three may add requirements to Part One These cross-references in the UGA template are instructional and should be removed Further, the UGA must identify all federal or state rules applicable to the program, likely in Part Three 246

247 Uniform Grant Agreement Overview All blanks in the UGA should be completed. Note that some blanks are of variable length. For example, Paragraph 1.3 lists the CFDA number, and the award may have multiple CFDA numbers Changes in these funding source(s) or an increase to the award amount requires an amendment, signed by both parties Notice of State Award and the final approved budget must be attached to the UGA 247

248 Agency Gap Analysis Agencies may wish to conduct a gap analysis to determine the differences between the UGA and the document currently used When the analysis reveals items not covered by Part One, those items can be contained in Part Two or Part Three 248

249 UGA Exhibit Descriptions Exhibit A Project Description Provide a comprehensive description of the core functions, activities, tasks or products associated with UGA Language should be clear and specific Do not simply reiterate the program objective or goal without providing further detail Include any federal award description 249

250 Exhibit A Examples The program area is defined as [geographic or county information] and will include the following services: Provide a full-day comprehensive Head Start Child Development program to eligible children ages 6 weeks to 6 years from migrant and seasonal farm worker families (program will run for 95 days from July 2, 20XX to October 31, 20XX, and June 8, 20XX to June 30, 20XX) Collect allowable non-federal share contributions (cash or in-kind donations) Maintain compliance with Illinois Migrant and Seasonal Head Start policies and procedures 250

251 Exhibit B Deliverables and Milestones Deliverables: All services, goods, products, work product, data, items, materials and property to be created, developed, produced, delivered, performed, or provided by or on behalf of, or made available through, the grantee (or any agent, subgrantee) in connection with the UGA Specific and targeted results expected from the activities outlined in the Exhibit A; serves as a checklist of what is to be accomplished throughout the term. Clear, objective and measureable to determine whether the Grantee has satisfied all obligations 251

252 Exhibit B Deliverables and Milestones Milestones: Important events that must occur at specific points throughout the term to effectively achieve goals Include timelines, dates or other measurements where appropriate 252

253 Exhibit B Deliverables and Milestones Examples Enroll 56 eligible children ages 6 weeks to 6 years from migrant and seasonal farm-workers families for 95 days from July 2, 20XX to October 31, 20XX, and reopening on June 8, 20XX and June 30, 20XX Collect $15,000 in allowable non-federal share contributions (cash or in-kind donations) each quarter Complete developmental assessments for all children enrolled more than 30 days within 60 days of enrollment 253

254 Exhibit B Deliverables and Milestones Examples Complete medical and dental assessments for all children enrolled more than 30 days within 60 days of enrollment Hold parent committee meetings on a monthly basis Hold policy committee meetings on a monthly basis Submit quarterly expenditure reports to grantor 254

255 Exhibit C Payment Details payment information, such as when or how payments will be made: Reimbursement Only Working Capital Advance 2 month advance with monthly reconciliation Based on completion of milestones 255

256 Exhibit D Contact Information Identifies and lists the contact information for the parties Grantees may have more than one contact listed including: Program Contact Fiscal Contract Administrative Contact 256

257 Exhibit E Performance Measures Outlines performance-related reporting requirements, describes the indicators or data points that the grantee must provide, includes method and timeframe for submitting data reports: What will be measured? What data points need to be reported? How often will data be reported? How will grantee submit the data (written reports, Excel, , E-Cornerstone, e-grants, CRV) 257

258 Exhibit E Performance Measures When appropriate, include outcomes (which represent the ultimate impact on the client) in addition to outputs (which measure the grantor s activities) For programs with a logic model, metric must be aligned to the outcomes State the frequency of reporting (daily, weekly, monthly, quarterly, and annually), the method of reporting (e.g., Excel, E-Cornerstone, DARTS) and the data fields to be reported 258

259 Exhibit E Performance Measures Examples Number of children enrolled with associated demographic information Number and percentage of children with disabilities who are enrolled and received services Number of developmental assessments completed Number and percentage of medical assessments completed Number and percentage of parents with partnership agreements Number and percentage of parents committee meetings held Number and percentage of policy committee meetings held 259

260 Exhibit F Performance Standards Minimum thresholds for acceptable performance If Performance Standards are available, they should correlate to Performance Measures Corrective action or termination of funding may be necessary if standards are not being met Specify which performance indicators will be used to trigger remedial action, if not all 260

261 Exhibit F Performance Standards Examples 100% of eligible children in the recruitment area are enrolled 100% of eligible children with disabilities are enrolled and received services 98% of developmental assessments are completed 95% of dental assessments are completed for children enrolled >30 days 90% of parents whose children are enrolled in the program completed partnership agreements 261

262 UGA Exhibits G-H Exhibit G State Agency Contracts Identifies other state agreements the Grantee is a party to Exhibit H Specific Conditions Lists specific conditions applicable to the award imposed after a risk assessment and merit review, if applicable, and the requirements to remove the conditions 262

263 UGA Attachments Final Approved Budget Notice of State Award (NOSA) 263

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