Welcome and Introductions

Transcription

1 Fiscal Matters: An Overview of Annual Head Start and Early Head Start Grant Requirements U.S. Department of Health and Human Services, Welcome and Introductions Staff Grantee Representatives 1

2 Goals for This Session Provide an Overview of Annual Head Start and Early Head Start Grant Requirements Increase Compliance Awareness Meet Your Fiscal Operations Specialist Federal Oversight of Five Year Grants The Office of Head Start is transitioning grants from indefinite project periods to five year project periods. Federal oversight involves the review and analysis of data, program services, and management systems to ensure organizations establish and implement: Program goals, including goals for school readiness; Effective management systems, including data management and analysis, ongoing monitoring, and fiscal oversight; and Methods to assess progress on anticipated outcomes for children, families, and the community throughout the five year project period. 2

3 Federal Oversight of Five Year Grants IMPORTANT INFORMATION: Please document all Program related questions about the five year project requirements on the forms provided. THE REFUNDING APPLICATION 3

4 Two Refunding Application Submission Requirements Indefinite Budget Period Five Year Project Period Funding Guidance Letter (FGL) contains the application submission requirements FGL is generally mailed at least seven months before the Head Start (HS) and/or Early Head Start (EHS) Program Year Begin Date Refunding Applications are due 90 days before the Head Start and/or Early Head Start Program Year Begin Date Refunding Applications must be submitted electronically using the Head Start Enterprise System (HSES) The Regional Office will no longer accept hard copies of Refunding Applications. Only the original SF 424s and certification pages will be accepted. must be submitted on behalf of the Authorized Official registered in HSES for your organization Board Chair Indefinite Budget Period (Three Year Cycle) Organizations not yet approved for funding under a five year project period in accordance with Information Memorandum ACYF IM HS 00 12, dated April 25, 2000 Indefinite Refunding (Continuation) application submission requirements are for a three year cycle Year 1 a comprehensive application Years 2 & 3 an abbreviated application SF 424 Submitted electronically on behalf of the registered Authorized Official SF 424A A breakout of amounts by object class categories for HS and EHS operations & T/TA SF 424B Assurances Non Construction Programs Electronic GABI Reports Budget Justification 4

5 Indefinite Budget Period (Three Year Cycle) cont. Long Range Goals and Objectives Program and Budget Narratives Risk Management (If applicable) Employee Compensation Cap o Effective January 2014, $181,500 is the Executive Level II rate Training and Technical Assistance Plan Results of Self Assessment and Improvement Plan Tax Certification form (signed) o Required for Federal awards of $5,000,000 or more, certifying that Federal taxes have been filed No convictions have occurred pursuant to Internal Revenue Code No notification of unpaid Federal taxes within the last 90 days Signed Governing Board and Policy Council Approval Statements and meeting minutes Five Year Project Period Organizations must submit either a baseline application or continuation application The FGL will contain a table outlying the criteria base on the type of grant and effective date of the project period. The following material must be uploaded to the HSES: Application and Budget Justification Governing Body and Policy Council Approvals Indirect Costs Rate Agreement, if applicable Results of Self assessment and Improvement Plan, and Training and Technical Assistance Plan Include the following evidence of Governing Body approval and Policy Council approval or disapproval: Signed statements of the Governing Body and Policy Council Chairs Governing Body and Policy Council minutes documenting each group s participation in the development and approval of the application, and If the Policy Council did not approve the application, submit the required letter from the Policy Council indicating its reasons for withholding approval. 5

6 Content of Application Applications for Federal financial assistance to operate a Head Start and/or Early Head Start program must provide a comprehensive description of the organization s plans to deliver quality Head Start and/or Early Head Start services and a detailed budget to support the planned delivery of services. Applications to obtain a grant for a five year project period or to continue operations during the five year project period contain two sections: Section I. Program Design and Approach to Service Delivery Section II. Budget and Budget Narrative Section I. Program Design and Approach to Service Delivery Program Design and Approach to Service Delivery, specifies the organization s plans to operate the Head Start and/or Early Head Start programs. Detailed information is requested for the criteria outlined in five sub sections: A. Long Range Goals, Objectives and Program Impacts; B. Service Delivery; C. Approach to School Readiness; D. Parent, Family and Community Engagement (PFCE); and E. Governance, Organizational and Management Structure, and Ongoing Oversight. 6

7 Section II: Budget and Budget Justification Instructions Requirements for All Applications (baseline and continuation) Submitted for each of the five year project period and individual budget period Comprehensive budget that aligns with the proposed program approach and identifies allowable, reasonable and allocable costs SF 424A Distribution of funds by object class categories in separate columns for HS and/or EHS program operations, training and technical assistance for the grant and for each delegate agency. Detailed budget narrative & justification that identifies the amount of funds and a description of the intended use of the funds. Describe the organization s financial management system and internal control environment. o Maintain effective control & accountability for grant funds, property and other assets. Budget and Budget Justification Instructions cont. Identify each source of non Federal share (NFS) match, including the estimated amount per source and the valuation methodology. Demonstrate in the narrative the allowability of the amounts and sources identified that will contribute to the required NFS match of the total project costs. If the application proposes a waiver of any portion of the non Federal share match requirement a detailed justification is required that conforms with the criteria under Section 640(b)(1) (5) of the Head Start Act. 7

8 Budget and Budget Justification Instructions cont. Demonstrate the ability to meet the 15 percent limitation on development and administrative costs A detailed justification is required if the application proposes waiver of the 15 percent limitation that meets the conditions for CFR (g). Provide the source and the amount of cash and other resources proposed to support the project including Child & and Adult Care Food Program (CACFP), Child Care and Development Block Grant (CCDBG), United Way, State and/or local funds. Etc. Demonstrate an appropriate cost allocation methodology for any proposed shared costs between programs and, when applicable, between or among multiple HS and/or EHS grants. Budget and Budget Justification Instructions cont. Provide a copy of the current or proposed indirect cost agreement. If applicable, provide a detailed narrative to accompany the proposed budget, including any one time costs, for any proposed conversion requests. If applicable, identify the amount of funds that will be reallocated by object class category to convert from either part day to full working day services or from HS to EHS services. Explain the changes in each object class category. Describe the proposed budget savings, if any, and planned use of the funds to support requests for enrollment reduction, as applicable. 8

9 Budget and Budget Justification Instructions cont. If applicable, detailed explanation of use of HS funds for the initial or ongoing purchase, construction and major renovation of facilities in accordance with 45 CFR 1309 for prior approval. Identify the sources of funding for each facility. No HS funds may be used toward the payment of one time expenses, principal and interest for the acquisition, construction or major renovation of a facility without the express written approval of the Regional Office. Upload and Submissions HSES will generate the following forms, and the application will be considered electronically signed when submitted: SF 424 SF 424A (Non Construction Programs) SF 424B Assurances (Non Construction Programs) Certification Regarding Compliance with Compensation Cap (Level II of the Executive Schedule) Tax Certification Form 9

10 REPORTING REQUIREMENTS Standard Form (SF) 425 AVAILABLE FOR DOWNLOAD: mb/assets/grants_forms/sf 425.pdf COMMON ERRORS: Numbers one through nine not completed to include all grantee and current reporting period information. Federal expenditures and unobligated balance not recorded correctly. Administrative costs, USDA funding and unobligated balance information missing from the remarks section (number 12) on final reports. Expenditures reported in dollars and cents as opposed to whole dollars. Signatures and dates missing. 10

11 Standard Form (SF) 425 Budget Period Begins: First Report Semi Annual Due: Reporting Cumulative Costs Through: Second Report Annual Due: Reporting Cumulative Costs Through: Third Report Final Due: JAN 1 JUL 30 JUN 30 JAN 30 DEC 31 APR 30 FEB 1 OCT 30 JUL 31 APR 30 JAN 31 APR 30 MAR 1 OCT 30 AUG 31 APR 30 FEB 28/29 JUL 30 APR 1 OCT 30 SEP 30 APR 30 MAR 31 JUL 30 MAY 1 JAN 30 OCT 31 JUL 30 APR 30 JUL 30 JUN 1 JAN 30 NOV 30 JUL 30 MAY 31 OCT 30 JUL 1 JAN 30 DEC 31 JUL 30 JUN 30 OCT 30 AUG 1 APR 30 JAN 31 OCT 30 JUL 31 OCT 30 SEP 1 APR 30 FEB 28/29 OCT 30 AUG 31 JAN 30 OCT 1 APR 30 MAR 31 OCT 30 SEP 30 JAN 30 NOV 1 JUL 30 APR 30 JAN 30 OCT 31 JAN 30 DEC 1 JUL 30 MAY 31 JAN 30 NOV 30 APR 30 Division of Payment Management Services SF 425 Federal Financial Report (FFR) / Federal Cash Transaction Report (FCTR) The Division of Payment Management has changed its name to Division of Payment Management Services (DPMS). FFR (FCTR) is submitted electronically to the DPMS via the Payment Management System (PMS). 11

12 Division of Payment Management Services QUARTER FFR/FCTR DUE DATES DISBURSEMENT ACTIVITY DUE DATE 1st OCT 1 DEC 31 JAN 30 2nd JAN 1 MAR 31 APR 30 3rd APR 1 JUN 30 JUL 30 4th JUL 1 SEP 30 OCT 30 Division of Payment Management Services Key Items of Payment Request Information: Cash on Hand Amount of Federal grant funds remaining in the organization s bank account. A Positive amount funds left from a previous draw. A Negative amount expended organizational funds for HS/EHS expenses and reimbursement is being requested. 12

13 Division of Payment Management Services The PMS Payment Request Formula Payment Request Amount = Expected Disbursement Amount Cash on Hand Cash Requests and Reporting Disbursements to Payment Management Services for grant closeout: Reasonable to request funds and report disbursements to PMS in whole dollars Round up ($0.50 cents or more) Round down ($0.49 cents or less) Reasonable to include any remaining cents in the last funds requests for the budget period Division of Payment Management Services Expired Grants DPMS has implemented a grant expiration process to assist organizations in the timely closeout of grants after their performance periods have expired. Federal grant management policy specifies that within 90 days of the performance period end date the grant recipient must submit its final financial report for the grant, unless the awarding agency extends the performance period or reporting period due dates. Payment Requests from Expired Grants The Regional Office is notified and asked to authorize or disapprove the payment request. DPMS may contact the organization s authorized representative for additional information. 13

14 Division of Payment Management Services IMPORTANT REMINDERS: FFRs/FCTRs are due to PMS 30 days after each quarter. DPMS normally restricts the release of funds if FFRs/FCTRs are delinquent. Funds are to be drawn down solely to accommodate immediate needs and must not be held in excess of three business days. Beginning Fiscal Year 2015, a pre closeout letter will be mailed to organizations 60 days prior to expiration date of award as notification that final reports are due within 90 days of the grant expiration date. Division of Payment Management Services IMPORTANT INFORMATION: FFR/FCTR questions and other PMS related questions/matters Point of Contacts: State and Local Governments (School Districts, County & City Governments) Ms. Linda Porter Phone Number: (301) Address: linda.porter@psc.hhs.gov Non Profit Organizations Ms. Maribelle Ramos Phone Number: (301) maribelle.ramos@psc.hhs.gov Universities Ms. Linda Johnson Phone Number: (301) linda.johnson@psc.hhs.gov 14

15 Standard Form (SF) 428 Tangible Personal Property Report AVAILABLE FOR DOWNLOAD: mb/grants/approved_forms/sf 428.pdf BEST PRACTICES: Submit the completed form annually with the Final SF 425. Inventory listing may be attached to the form in current formats as opposed to completing the supplemental form. Standard Form (SF) 428S Tangible Personal Property Report Supplemental Sheet AVAILABLE FOR DOWNLOAD: mb/grants/approved_forms/sf 428 s.pdf BEST PRACTICE: Submit the completed form annually with the Final SF

16 Standard Form (SF) 429 Real Property Status Report AVAILABLE FOR DOWNLOAD: mb/grants/approved_forms/sf 429.pdf BEST PRACTICES: Submit the completed form annually with the Final SF 425. This form should be submitted only if property and/or land has been acquired in whole or in part, or improved with Federal grants funds. Annual Audits IMPORTANT REMINDERS: Audits must be submitted electronically to the Federal Audit Clearinghouse and the Regional Office within nine months from end of the organization s fiscal year end. Expenditures reported on the final SF 425, FFR/FCTR and audit must reconcile. Report expenditures in whole dollars. Ask auditors to reconcile audited expenditures where grant year and audit year differ. Failure to submit audits on time or respond to requests for information could put future grant funding at risk. 16

17 Grant Cycle The Cycle Begins Here Grant Application submitted via HSES Awarding Agency reviews application for approval Awarding Agency processes the Notice of Award Notice of Award is certified by the Regional GMO Awarding Agency Closes award AUTH=DISB=ADVANCES Grant data is Transmitted to PMS overnight, provided there are no errors Regional Grants Office reviews semi annual and final FFR s for compliance PMS updates their database PMS records grantee quarterly disbursements Grantee reports disbursements data quarterly to PMS via FFR Grantee requests funds from PMS PMS issues payments to grantee the next business day PRIOR APPROVALS 17

18 Key Items That Require Prior Approval Budget Revisions Line item changes that equal or exceed $250,000 or 25% of the total approved budget (whichever is less). Completion and submission of a SF 424, revised SF 424A, program and budget narratives, and policy council approval. Submit the request at least 45 days prior to the end of the budget period. One Time Supplements Completion and submission of a SF 424, SF 424A, program and budget narratives, and policy council approval. Real Property Purchase/Construction, Incidental Alterations and Major Renovations Completion and submission of a 1309 Pre Award Checklist. Incidental alterations (or renovations) means facility improvements that do not meet the definition of major renovation. Major renovation means structural changes to the foundation, roof, floor, or exterior or load bearing walls of a facility, such as to significantly change its function and purpose. Additionally, a renovation of any kind which has a cost exceeding the lesser of $200,000 is considered a major renovation. Equipment Valued at $25,000+ (Post Award Requirement) An item of personal property, which costs $25,000 or more per unit, and which has a useful life of more than one year. Key Items That Require Prior Approval Non Federal Share Waivers Provide sufficient detailed information in the request submitted. Reminder The normally required 20% of the total grantee budget (Federal funds plus non Federal share) is the same as 25% of the federal funds. Carryover/Unobligated Balances Carryover of unobligated balances may be approved to complete work that was approved but not completed during the previous budget period. Funding may only be carried over for two subsequent budget periods. Vehicle Dispositions Current per unit fair market value of $5000 or more. Include the year, model, passenger size, vehicle identification number, and fair market value with the request. 18

19 Key Items That Require Prior Approval Modular Dispositions Current per unit fair market value of $5000 or more and/or classified as real property. Submit a written request for disposition of the modular unit to the Regional Office, including: A statement, including factual basis for the statement, that the modular unit is no longer needed for program purposes. The serial number or other identifying information. The date of acquisition. The acquisition price. The date of any major renovation(s). The total value of any major renovation(s). The completion date of any major renovation(s). The proposed method of disposal. Additional information regarding modular dispositions is provided in Information Memorandum ACF IM HS 12 08, dated November 30, 2012 available for download at: Contact assigned Fiscal Operations Specialist for guidance. Key Items That Require Prior Approval BEST PRACTICES: As soon as the need for prior approval has been identified, submit a request. Submit requests for prior approval on official letterhead. ed requests are not considered official. Be responsive to requests for additional information made by assigned Fiscal Operations and/or Program Specialist. Contact assigned Fiscal Operations and/or Program Specialist if it is not clear whether or not prior approval is necessary. 19

20 Formal Regional Office Approvals Notification of Regional Office decision regarding a request are made via: Notice of Award Letter Signed by the Grants Management Officer (GMO) and/or Regional Program Manager Conclusion It is important to be knowledgeable of grant requirements and regulations. Remember to consult for current information and grant resources. The Omni Super Circular will become effective December 26, New Office of Management and Budget (OMB) Uniform Guidance: Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Supersedes and streamlines the requirements from OMB circulars o Cost Principles A 21 (2 CFR Part 220), A 87 (2 CFR Part 225) and A 122 (2 CFR Part 230) o Administrative Requirements A 110/2 CFR Part 215 (45 CFR Parts 74 and 92) o Audit Requirements A 133 Remain deadline attentive. Ask assigned Fiscal Operations and/or Program Specialist for assistance when in doubt. 20

21 Thank You for Attending MEET AND GREET 21