Grants Administration 101 Capacity and Competitive Session 21 April 24, 2018 Presenter: Maggie Ewell Senior Policy Advisor, OGFM 1
Topics Overview of Grants Administration 7 Financial Standards in the Uniform Administrative Requirements Additional administrative requirements: Match Property Standards Records Management Subrecipient Monitoring and Oversight CFDA 10.500 change NIFA Attribution and Identifier 2
Federal Funding Vehicles Grant Agreement Cooperative Agreement Agreement Contract Legal contract Public purpose of support or stimulation --Public purpose --Substantial Government Involvement Provide supplies and/or services 3
Grant Award Phases Pre Award Post Award Closeout 4
Rules affecting grant financial management Authorizing legislation Uniform Guidance Uniform administrative requirements: Grant management rules Cost principles: Determination of allowable costs Program regulations Program activities allowable and unallowable Grant Agreement Terms and Conditions Statement/Plan of Work Description of grant activities and outcomes 5
The Pyramid of Grant Requirements Authorizations and Appropriations Government Wide Program Statutes & Appropriations OMB Uniform Guidance Government Wide Lobbying Drug Free Workplace Suspension Debarment Davis Bacon Act Agency & Programs Program Regulations NIFA Policy Guide; other guidance RFAs Terms and Conditions 6
The 7 Financial Standards Financial reporting Cash management Accounting records Budget controls Source documentation Allowable costs Internal Controls 7
Financial Systems must identify all Federal receipts and expenditures by: Program FAIN CFDA Federal Agency Pass through entity 8
Financial Generate data for preparation of financial reports Must report accruals if reporting on accrual basis Reporting 9
Accounting records Adequately identify grant funds (Awards, obligations, assets, liabilities, income and expenditures); Supported by source documentation; Must be maintained in accordance with GAAP 10
Source documentation Costs must trace to authorizing document Proof that costs are allowable and allocated If none, costs not allowable 11
Internal Controls What are they? System to protect integrity of funds Accountability for cash & property What is required? Establish adequate controls using sound management practices Green Book/COSO Key Reasonable precautions 12
Cash Management System to control cash assets that provides effective control over, and accountability for, all funds, property, and other assets Appropriate approvals, signatures, and source documents Adequately safeguard all assets and assure that they are used solely for authorized purposes. Written procedures required 13
Cash Management Procedures Authorized individuals and separation of duties Miscellaneous receipts and petty cash Control over cash and other cash-like assets Reconciliations Forecasting and daily cash balances Payment transfers and advances (internal and external) 14
Budget Controls Comparison of actual expenditures (outlays) to planned expenditures (budget); Prevents over and under-spending Minimize carry-over Ensure funds aren t returned to Treasury 15
Allowable costs Must ensure only allowable and allocable costs charged Who ensure costs are allowable? Follow written procedures Linked to Internal controls Follow Cost Principles Must ensure costs are authorized and allowable under authorizing statute 16
Additional Post Award requirements Cost Share/Match Property Standards Records Management Sub Recipient monitoring and management 17
Match 200.306 Matching funds, including cash and third party inkind contributions, must be (1) Verifiable from the non-federal entity's records; (2) Not included as contributions for any other Federal award; (3) Necessary and reasonable for accomplishment of project or program objectives; (4) Allowable under Subpart E Cost Principles 18
Match 200.306 (5) Are not paid by the Federal Government under another Federal award; (6) Are provided for in the approved budget, when required; (7) Conform to other provisions of this part (i.e. limitations, prior approvals, etc.) Valuation of third party in-kind covered in 306(d)-(j) 19
Matching funds Must be spent on authorized and allowable activities Authorized by Statute Allowable under Uniform Guidance Same uses and limitations as federal funds If you have a limitation on a cost for federal funds, cannot exceed that limitation by charged unrecovered costs to match 20
Matching funds cont d Only count towards match when expended (versus appropriated or transferred to University) Must be expended and reporting by award(vs. a revolving fund) E.g. FY 17 Smith-Lever, FY 16 Smith-Lever FY 16 Hatch, FY 15 Hatch; FY 17 1890 Research, FY 17 1890 Extension, etc. 21
Matching Funds cont d Expenditures must be supported by source documentation Examples: Time and Effort: Certification and approval documentation Equipment: Requisition/Purchase order with signatures; evidence of bids; NIFA prior approval (if required) 22
Property Standards 2 CFR 200.310-200.316 Facilities and Lease Agreements Use allowance not allowable Equipment Tangible property >$5000 Capacity grantees need prior approval Includes information technology systems Supplies Includes computing devices Intangible Property Trademarks, copyrights, patents and patent applications, and property 23
Equipment Prior Approval Capacity Awards Prior approval required for General Purpose equipment costing $5000 or more Prior approval waived for Special Purpose equipment for equipment costing less than $150,000 24
General Purpose Equipment Not limited to technical activities: Information technology systems Vehicles Office and laboratory furnishings (not scientific laboratory equipment) Reproduction and printing equipment Audio-visual equipment Used for research, medical, scientific, or other technical activities: Research equipment Laboratory equipment 20
Equipment Management Requirements ALL Recipients Property records Physical inventory 2 years Control system Maintenance and insurance Proper sales procedures 26
Records Management 2 CFR 200.333 Retention requirements for records Financial records: 3 years or until all matters are resolved Real property & equipment 3 years Indirect cost rate proposals/ cost allocation plans 3 years (note start date) 27
Records Management Federal agencies, OIGs, pass-through entities have right of access to records and personnel No Right of access expiration Cannot impose restrictions to limit access Excludes Personally Identifiable Information (PII) Follow policies on collection, transfer and storage of information (including safeguarding of PII) 28
Subrecipient Monitoring &Oversight Ensure subawards appropriately identified Specify required information for each award Include FAIN and DUNS numbers CFDA Number and dollar amount of each Evaluate risk of non-compliance Monitor subaward activities Verify audit coverage Honor ICRs or de minimis rate 29
CFDA 10.500 change 25
10.500 breakout Capacity and Competitive Contained 30-50 programs DATA Act Uniform Guidance 10 new CFDA numbers 31
Implementation Effective for 2019 grants FY 2019 RFAs FY 19 Awards and docs Memorandum issued to NIFA grantees and staff NIFA Update Gov Delivery Blast Resource Page NIFA Website Crosswalk 32
NIFA Actions Updated ezfedgrants and online systems Use new CFDAs in FY 2019 RFAs and opportunity listings Use new CFDAs in Notices of Award and other grant documentations 33
Grantee required actions Update systems to include new CFDA numbers Ensure accounting systems have new CFDA numbers linked to awards (2 CFR 200.302(b)(1) Provide crosswalk of new CFDA numbers to appropriate staff 34
Crosswalk Smith-Lever 3(b) and (c) Smith-Lever Special Needs, UDC 10.511 1890 Extension 10.512 1890 Facilities 10.513 35
Crosswalk EFNEP 10.514 RREA and RREA NNF 10.515 Rural Health and Safety 10.516 36
Crosswalk TCEP, TCEP-SE, FRTEP 10.517 FARAD Agricultural Risk Management Education Partnership 10.518 10.520 37
Crosswalk Children, Youth, and Families (CYFAR) including: Sustainable Community Projects (CYFAR-SCP) Professional Development Military Partnerships 10.521 38
The following list represents some of the current programs which are retaining CFDA # 10.500 for Cooperative Extension Services (CES). This list is not exhaustive: 39
Assistive Technology Program for Farmers with Disabilities: National AgrAbility Project (aka AgrAbility) Youth Farm Safety Education and Certification Reimbursable Agreements: e.g. Military Family Readiness System (aka MFRS); 4-H Military Partnership and Professional Development Delivery Modes for Department of Defense 40
NIFA Attribution 36
NIFA Acknowledgement 2 CFR Part 415 and award terms and conditions Grantees must use funding acknowledgment for all competitive or capacity grants or initiatives supported by NIFA 42
Acknowledgement "This work is supported by [Program Name] [grant no. XXXX-XXXXX- XXXXX/project accession no. XXXXXXX] from the USDA National Institute of Food and Agriculture." 43
NIFA Identifier Whenever practical, NIFA also expects that grantees use NIFA s official identifier in publications, posters, websites and presentations resulting from their award. This identifier can be found at http://nifa.usda.gov/resource/officialnifa-identifier. 44
Statement in publications In addition, all publications and other materials, except scientific articles or papers published in scientific journals, must contain the following statement: 45
Statement in publications "Any opinions, findings, conclusions, or recommendations expressed in this publication are those of the author(s) and do not necessarily reflect the view of the U.S. Department of Agriculture." 46
Questions? 47
THANK YOU!!!!! Maggie Ewell Margaret.ewell@nifa.usda.gov 202-401-0222 Capacity grant equipment prior approval requests: capacityequipment@nifa.usda.gov 48