Title I, Part A: Allowable Use of Funds Office of School Improvement, Accountability & Compliance
Sources Electronic Code of Federal Regulations Unallowable Costs by Class/Object Code Title I, Part A Allowable & Unallowable Costs TEA Guidelines Related to Specific Costs Title I, Part A Allowability of Costs ACET Spring Conference 2015 The New EDGAR
Required Components Comprehensive Needs Assessment (CNA) Campus Improvement Plan (CIP) Allowable Costs
The school district must have written procedures for determining the allowability of costs in accordance with EDGAR Describe planning process, budget process, how to determine program allowability, and how to closeout project
Allowability of Costs Procedures 200.302 Procedures to include determining allowable costs from the planning process, procurements, time and effort and expenditure of funds
Factors Affecting Allowability of Costs 200.403 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 Federal award and be allocable thereto under these principles
In regards to accomplishing the objectives of the program and for implementing activities as described in the funding application 1. Is the cost necessary? In other words, are the costs necessary for the operation or proper and efficient performance of the federal award? 2. Is the cost reasonable? In other words, is the cost more than what a prudent person would spend under the circumstances at the time the decision was made to incur the cost?
Necessary Costs Consider This Is this identified in the plan? Do I have the capacity to use what I am purchasing? If I were asked to defend this purchase, would I be able to? Would it just be nice to have?
Reasonable Costs Consider This. Whether cost is a type generally recognized as ordinary and necessary for the operation of the non-federal entity or the proper and efficient performance of the federal award Is it in line with federal, state and local laws and the terms of the grant award Market prices for comparable goods or services in the geographic area Whether the individuals acted with prudence under the circumstances considering their responsibilities No significant deviation from established procedures and policies
Reasonable Costs Other Practical Questions/Considerations. Do I really need this? Is the expense targeted to valid programmatic/administrative need? Is this the minimum amount I need to spend to meet my need? Did I pay a fair rate? Again, If I were asked to defend this purchase, would I be able to?
Allowable Costs Must meet the following criteria: Be reasonable for the performance of the grant and be allocable under the applicable cost principles Conform to limitations or exclusions set forth in applicable cost principles to the grant agreement as to types of amount of costs Be consistent with policies and procedures that apply uniformly to federally or state-funded activities and activities funded from other sources Be accorded consistent treatment among all grant programs, regardless of funding sources Be in accordance with Generally Accepted Accounting Principles (GAAP) Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally or state-funded program in the current or a prior period Not be used for lease-purchases (i.e, debt service) if for discretionary grants
Allocable Costs Benefits both award and other work and can be distributed in proportions that may be approximated using reasonable methods; and Necessary to the overall operation of the entity and assignable to that Federal award or cost objective in accordance with relative benefits received Can only charge in proportion to the value received by the program Eg. Agency purchases a computer to use 50% on the Federal grant program and 50% on a state program can only charge half of the cost to the federal grant
Beginning Date of Project End Date of Project Duration of the Grant All goods must be received and all services must be rendered between beginning and end of the project
Duration of the Grant An obligation occurs depending on the expenditure, as follows: Services by an employee: When the services are performed by an employee
Duration of the Grant An obligation occurs depending on the expenditure, as follows: Services by a contractor: The date of a binding written commitment, such as a contract or other written agreement, to obtain services from the contractor
Duration of the Grant An obligation occurs depending on the expenditure, as follows: Travel: When the travel is taken
Duration of the Grant An obligation occurs depending on the expenditure, as follows: Approved Pre-Agreement Cost: On the first day of the grant or subgrant performance period
Duration of the Grant An obligation occurs depending on the expenditure, as follows: Acquisition of Property: Date of binding written commitment
Is it reasonable and necessary to carry out the intent and purpose of the program? What need in our CNA does this address? From the CIP, can you describe program, activity, or strategy addressed by this expenditure? I would like to buy. As we are a schoolwide campus, how will this upgrade the entire educational program? How is the expenditure supplemental to other nonfederal programs? How will the expenditure be evaluated to measure a positive impact on student achievement?
Ok, forget it. Have a great day!
Reasonable Properly Documented Necessary Asset Safeguards Allocable Assets used only for authorized purposes
Controls over and accountability for all funds, property, and assets Must adequately safeguard all assets and assure solely used for authorized purposes Supplies and computing devices technically not on inventory, but must be safeguarded and tracked
Comprehensive Needs Assessments and Improvement Plans Title I, Part A funds must be expended for programs, activities, and strategies that are scientifically based on research and meet needs identified through the CNA process. The CNA must be completed prior to applying for the funding because the application for funding must address the needs identified through the CNA process. These expenditures must also be tied to the LEA or campus improvement plan, depending on how the expenditure will be used and coded (e.g., at the LEA or campus level). Must be addressed in the improvement plan prior to obligations, expenditures and encumbrances being made.
Payroll Costs (6100) The following employee payroll costs are not allowed: Personal liability insurance Employer contributions to voluntary retirement plans such as 403(b) or 401(k) Substitute pay for private nonprofit school teachers Payroll costs that exceed local policy
Professional and Contracted Services (6200) A consultant shall not be used in the conduct of this application if the services to be rendered by such consultant could have been rendered by the grantee s employees. Grant funds may not be used for the following: Training or technical assistance on grant writing or obtaining grant funds Fundraising activities or training on fundraising Multicolor printing costs that are not reasonable and necessary to accomplish the objectives of the grant program (applies to printing costs incurred under 6200 and 6400) Legal retainer fees Tuition and fees for courses not directly related to the grant program New building construction or renovating or remodeling of buildings Conducting required annual audit and report of financial activities Audit fees and expenses for state-funded grants Audit fees
Supplies and Materials (6300) Grant funds may not be used for the following: Supplies and materials, including electronic devices, for personal use. Must be used only for grant-related activities. Costs associated with awards banquets, ceremonies, celebrations, and social events Cell phones for personal use Gifts or items that could be construed as a gift Souvenirs, memorabilia, or promotional items (such as T- shirts, caps, tote bags, key chains, or imprinted pens) NOTE: Refer to the Budgeting Costs Guidance Handbook.
Other Operating Costs (6400) Grant funds may not be used for the following: Out-of-state training when the same type and quality of training is available in state (for upcoming grant, this will require pre-approval) Gifts or items that can be construed as a gift Souvenirs, memorabilia, or promotional items (such as T-shirts, caps, tote bags, key chains, or imprinted pens) Door prizes (movie tickets, gift certificates, amusement park passes, and other similar items may be donated by others, but not purchased with grant funds) NOTE: Refer to the TEA Guidelines Related to Specific Costs for information on incentives to participate and awards for recognition. Food, meals, snacks, beverages, and refreshments as awards Multicolor printing costs that are not reasonable and necessary to accomplish the objectives of the grant program Membership dues in organizations substantially engaged in lobbying or in social organizations Memberships in social organizations Memberships in civic or community organizations (for colleges and universities) Professional or personal liability insurance for individual employees Tuition and fees for courses not directly related to the grant program
Other Operating Costs (6400) Travel costs that are not allowed are the following: Alcoholic beverages Tips or gratuities Entertainment, recreation, or social events Travel allowances, where per diem is paid to the employee regardless of the amount actually expended First-class airfare Any expense for other persons Meals and lodging for persons who live in the same city or town where the meeting, conference, or workshop is held Costs that are not reasonable and necessary to meet the objectives of the grant Costs related to training or technical assistance on grant writing or obtaining funds Field trips (under new EDGAR only allowed with pre-approval in grant application by Department of Education; TEA awaiting guidance on whether they can pre-approve)
Capital Outlay (6600) Unless specifically permitted in the authorizing statute and approved by TEA in the grant application, the following costs are unallowable: Land purchase and improvements to land Construction, renovation, or remodeling Ground leveling, site preparation, foundation, plumbing, wiring, and sidewalk for a portable building are considered construction costs. Therefore, these costs are not allowable to be charged to the grant.