Title I, Part A and The Grants Accounting Approval Process

Title I, Part A and The Grants Accounting Approval Process 2016 Georgia Federal Programs Conference Georgia International Convention Center & Atlanta Airport Marriott Gateway Hotel Atlanta, Georgia June 21 23, 2016 1

Title I, Part A and The Grants Accounting Approval Process Presented by Anthony L. Threat Title I Education Program Specialist Regina Hailey Grants Accountant Manager 2

SCHOOL IMPROVEMENT & DISTRICT EFFECTIVENESS 3

Agenda Findings and Grants Management Overview of Grants Accounting Process Importance of communication between LEA s, Program Managers and Grants Accounting Inventory Monitoring Monitoring Preparations Monitoring Findings and Grants Management Corrective Action Information Question and answers 4

Purpose of Presentation Title I, Part A Guidance concerning Grant Management Overview of the FY17 Consolidated Application Checklist and Grants Management Overview of Consolidated Application Approval Process and Grants Management Monitoring Findings and Grants Management Overview of Grants Accounting Process Importance of communication between LEA s, Program Managers and Grants Accounting 5

FY17 Consolidated Application Provisioning Properly provisioned in the LEA Monitoring Application LEAs Charter Schools District Security Officer Superintendent Title I Coordinator Chief Financial Officer 6

LEA Monitoring of Schools and Programs CITATION: (a) ASSURANCES- A State educational agency, in consultation with the Governor of the State, that submits a consolidated State plan or consolidated State application under this Act, whether separately or under section 9302, shall have on file with the Secretary a single set of assurances, applicable to each program for which the plan or application is submitted, that provides that (1) each such program will be administered in accordance with all applicable statutes, regulations, program plans, and applications; 7

LEA Monitoring of Schools and Programs 2 C.F. R. 200.328 states: (a) Monitoring by the non-federal [Section 9304(a)(1), ESEA] entity. The non-federal entity is responsible for oversight of the operations of the Federal award supported activities. The non-federal entity must monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved. Monitoring by the non-federal entity must cover each program, function or activity. 8

LEA Monitoring of Schools and Programs Written Procedures and or Policies for monitoring all ESSA Requirements Timeline Monitoring schedule for monitoring schools Consolidated Plans (SWP, TA, PI, FLP, SI, Students served, rank List, Pre-K services if applicable Checklists Training PowerPoints, meeting agendas, sign in sheets 9

Comprehensive LEA Improvement Plan (CLIP) Written Procedures for review and approval process For all Federal Programs Approved/unapproved plans Guidance provided to schools and other departments Timelines Consolidated Plans(SWP, TA, PI, FLP, SI, Students served, MOE) 10

Maintenance of Effort MOE Written Procedures and method for determining MOE MOE Source Data and process for excluding funds for MOE calculations MOE Waiver Request if applicable US ED approval of MOE Waiver MOE Waiver New State Charter Schools and signed MOE Waiver if the inability to calculate MOE due to non existent funds 11

Comparability Consolidated Application Program Information Page Portal Information Staff Adjustments Staff hires Staff readjustments Comparability Deadline date and repayment of Funds 12

Cost Principals Reasonable Necessary Allocable Allowable Accounting records Purchase Orders Travel Policy LEA Chart of Accounts 13

Supplement Not Supplant Questions Inquires LEA Staff Schools Documentation, Meeting Agendas, Sign-In Sheets, Emails, Memos Expenditures, Allocation of Funds, Class Size Reduction, Class Schedules 14

Supplement Not Supplant Written allowabiltiy procedures for detailing approval and budgeting process Accounting records Purchase orders Staff payroll and approved application Cost Principals Reasonable; Necessary; Allocable; Allowable 15

Internal Controls Allocable Allowable Written procurement procedures Staff Payroll Contracts Travel Policy LEA Chart of Accounts and narrative Information Function Codes/Object Codes and Allowable expenditures 16

Internal Control Written Procedures Time Logs Fixed Schedule Periodic Certification Accounting Records Source Documentation Invoices Periodic Certification 17

Internal Controls Time logs Fixed Schedule Inventory Required Elements Physical Inventory with Signatures Disposition Policy Single Audit Reports (two years) 18

Cash Management Written Cash Management Procedures Internal Control Procedures Segregation of Duties Monitoring of Cash Management Activities Reconciliation Reimbursement Drawdowns and Supporting Documentation Payment and Immediate Cash Needs 19

Cash Management 20

Complaints Complaint Procedures for All Programs Addresses Complaints from Parents, Students, Staff, Private Schools, General Public Filing a Complaint Tracking Reporting Resolution of Complaint Dissemination to Schools in the District 21

Waste, Fraud, Abuse and Corruption Fraudulent Activity Policy Standards of Conducts Conflicts of Interest Policy Dated Agendas, Sign in Sheets, Meeting Minutes Ethics and Fraud Waste and Abuse and Corruption Dissemination of Policy 22

Assessment Communication to Local Educators Test Security Written Procedures/Policy Consequences of Violation Dissemination of Policy 23

Within District Allocation Procedures LEA Selection and Allocation Requirement Determination of Attendance SFN Direct Certified Report(CEP) Written Procedures for Determining Rank Order Written Procedures for Identifying Eligible Students Charter Schools New Charter Schools Reservation of Funds 24

Services to Eligible Private Schools DE1111 Form Required Consultation Letters of Initial Consultation Evidence of Consultation Written Affirmation Program Evaluation Affirmation of Services for Private Schools 25

Findings Cash Management Findings/Cash Management Sub recipients' requests for federal funds are evaluated, and drawdowns of federal cash are only for immediate needs. Evidence that LEAs do not draw funds before actual need. Excess cash balances are funds maintained at the recipient/sub recipient s level in excess of immediate (usually 3 days) needs. Finding/Current Condition The School District did not provide evidence of any drawdowns made from Title I, Part A. The District did not start posting/ applying expenditures to the general ledger for this fiscal year until October 1, 2013. Details (PO's, invoices, payroll registers, etc.) that support the drawdowns were not available for review during the monitoring visit. It could not be determined by the spreadsheet provided that the expenditures were paid within the two day requirement. 26

Findings Corrective Action: The School District must submit to the (Department) written procedures that provide the necessary internal controls that the District will implement to ensure effective and efficient operations associated with cash management, monitoring of cash management activities (including the process for drawing down funds) in compliance with laws and regulations, and Department guidelines specific to Title I, Part A. The procedures must also include how the District will monitor the implementation of the procedures, as well as, the person(s) responsible for monitoring the implementation of the procedures. 27

Grants Accounting Manager, Grants Accounting Agenda Regina Hailey Consolidated Application GAORS Invoice Application Completion Reports Georgia Department of Educaiton 31

New Grantee Startup Grantee must ensure that all banking information is made available to Grants Accounting Vendor Banking Form (Non-LEAs only) Grantee must assign roles for applications (Con AP, GAORS, Invoice Application, Completion Reports) Security Officer for LEA s Georgia Department of Educaiton 32

Consolidated Application Budgets Budget allocations by function and object codes Coordinate submitting budgets within the system Monitor Budgets(communication between LEA, Program and Grants Accounting) Georgia Department of Educaiton 33

How will you know if grant is approved? The grant goes through a sign-off process Coordinator sign-off Superintendent sign-off Program Manager sign-off Grants Accounting Approval Georgia Department of Educaiton 34

When can an Amendment be created? An amendment can ONLY be created (by Coordinator or Grants Accounting) once a grant is in approved status. Why would an amendment be created? When carryover/additional allocation is added to original allocation by Grants Accounting. When the system needs to revise how the funds were budgeted. Follow same steps as doing an original budget Georgia Department of Educaiton 35

When can an Amendment be created? Outside of function code variance Most federal grants have a 25-percent variance Change in the scope of the program Post audit purposes Georgia Department of Educaiton 36

GAORS GAORS (Grants Accounting On-line Reporting System) Approved Budgets 15 payment request per grant (one per month) Reimbursement Request-Payments to grantee Payments request created each Thursday and payments deposited in Bank account the subsequent Thursday Georgia Department of Educaiton 37

List of DE147 (Payment Requests) Georgia Department of Educaiton 38

Invoice Application Log into the Portal Click on Grants Application then Invoices then Manage Invoices Select Grant Select month that you are requesting funds Add line item information with attachment Submit to Program Manager for approval Grants accounting approves and payment is made Georgia Department of Educaiton 39

Invoice Application Approved budget amount Total amount of funds paid to date List of invoices to be paid Georgia Department of Educaiton 40

Completion Reports Log into the Portal Click on Grants Application then Completion reports Select Fiscal Year and Grant Must load last approved budget from Con AP Complete sub-grant (if applicable) Input all expenses based on grant period Submitting to GaDOE closes the grant Georgia Department of Educaiton 41

Completion Report Georgia Department of Educaiton 42

Completion Report Georgia Department of Educaiton 43

Completion Report Georgia Department of Educaiton 44

Grant Expenditures Georgia Department of Educaiton 45

Subgrant Georgia Department of Educaiton 46

Completion Report Grant Period-07/01/XX 09/30/XX Due 10/31/XX Expenditures as of September 30 th Report expenditures by function and object Refunds/Cash Shortages Request to reopen Completion Reports Georgia Department of Educaiton 47

Questions and Answers Georgia Department of Educaiton 50

Helpful Resources Title I Handbook Current Edition NCLB Act of 2001 (Blue Book) Department Web site http://public.doe.k12.ga.us US ED Web site www.ed.gov FY17 LEA Monitoring Form Education Support Services Operations Manual 46

Helpful Resources 2 C.F.R. Part 200, Uniform Guidance (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards) Education Department General Administrative Regulations (EDGAR) 47

GRANTS ACCOUNTING TEAM DELLA KILPATRICK ACCOUNTING MANAGER (404-656-4668) dkilpatr@doe.k12.ga.us REGINA HAILEY MANAGER, GRANTS ACCOUNTING (404-656-4676) rhailey@doe.k12.ga.us Georgia Department of Educaiton 48

GRANTS ACCOUNTING TEAM PHYLLIS RAINES GRANTS ACCOUNTANT (404-656-5553) praines@doe.k12.ga.us GEORGINA HAMILTON GRANTS ACCOUNTANT (404-463-0703) ghamilton@doe.k12.ga.us Georgia Department of Educaiton 49

Title I Education Program Specialists Contact Information Area Name Phone Number Email 1 Robyn Planchard (404) 985-3808 rplanchard@doe.k12.ga.us 2 Sherri Minshew (770) 324-1965 sminshew@doe.k12.ga.us 3 Anthony Threat (706) 615-0367 Anthony.threat@doe.k12.ga.us 4 Evelyn Maddox (404) 656-2045 emaddox@doe.k12.ga.us 5 Judy Alger (229) 838-6037 julager@doe.k12.ga.us 6 Grace McElveen (912) 334-0802 gmcelveen@doe.k12.ga.us 7 JaBra Harden Fuller (229) 563-6269 jharden@doe.k12.ga.us 8 Marijo Pitts-Sheffield (912) 269-1216 mpitts@doe.k12.ga.us 9 Kathy Pruett (706) 540-8959 kpruett@doe.k12.ga.us 10 Elaine Dawsey (478) 971-0114 edawsey@doe.k12.ga.us 11 Olufunke Osunkoya (678) 704-3557 oosunkoya@doe.k12.ga.us 12 Bobby Trawick (229) 246-1976 btrawick@doe.k12.ga.us 13 Ken Banter (478) 960-2255 kbanter@doe.k12.ga.us 14 Tammy Wilkes (478) 237-2873 twilkes@doe.k12.ga.us 50