MATCH PANELIST => PREPARATION NOTES Stephen R. Hart, Ed.D. Director -Fiscal / Office Operations, Arizona GEAR UP Northern Arizona University 5451 N. 28 th Ave. #216 Phoenix, AZ 85053 (602) 776-4614 direct (602) 751-4839 cell (602) 776-4619 fax www.nau.edu/gearup DISCLAIMER The information provided by staff working for Arizona GEAR UP (also known as NAU GEAR UP ) in this packet and also verbally during the NCCEP CBW 2017 Documenting Match workshop is offered in the spirit of helpful collaboration --best-practice advice / counsel / suggestions / reflections / recommendations / lessons learned among peers nationwide. It is informed from the experiences and perspective of Arizona GEAR UP, a State grant providing services in a cohort model to thousands of GEAR UP students statewide in Arizona since 2001. IT IS NOT LEGAL ADVICE! The NCCEP CBW 2017 match panelist from Arizona GEAR UP (Stephen Hart) is providing insight (as requested) based on his experiences and perspective as the fiscal operations manager for Arizona GEAR UP since May 2004(portions of three grant cycles). All GEAR UP grantees, regardless of grant size and/or type, are strongly encouraged to collaborate closely with their designated fiscal agent and/or USDOE / GEAR UP Program Officer on all grant-specific fiscal operations / audit readiness questions and concerns, including those matters that relate to matching contributions. USDOE / GEAR UP Program Officers are generally the best and final authority on such matters. Arizona GEAR UP Match Panelist Notes 1
U.S. DEPARTMENT OF EDUCATION GEAR UP OVERVIEW See excellent pre-cbw webinar presentation 01/31/17 by Alex Chough of NCCEP -- https://www.youtube.com/watch?v=bs-p4lzd0bi&feature =youtu.be&mc_cid=6cc677c046&mc_eid=90de4d8f2d If you e-mail Alex_Chough@edpartnerships.org and ask nicely, he will gladly send you a copy of the PPT slides he used during this presentation. ARIZONA GEAR UP OVERVIEW with Northern Arizona University as governor-designated grantee/fiscal agent Successfully administered: State Grant 2000-2006 $12M federal 1:1 Match, 3,000+ students served statewide Partnership Grant 2000-2006 $10M federal 1:1 Match, 2,500+ students served statewide State Grant 2006-2012 $17M federal 1:1 Match, 2,500+ students served statewide Currently administering: State Grant 2012-2019 $30M federal 1:1 Match, 4,000+ students served statewide See www.nau.edu/gearup for more detailed info Arizona GEAR UP Match Panelist Notes 2
PORTFOLIO OF MATCHING CONTRIBUTIONS (2012-19) PORTFOLIO OF MATCHING CONTRIBUTIONS (2012-19) (continued) When planned match contributions don t pan out PANIC!!!...then RE-GROUP!!!! Assess impact on overall ability to meet match obligation, in light of current overall progress (total actual + projected vs. total obligated). If needed identify/recruit replacement partner(s), in careful collaboration with stakeholders / USDOE Program Officer. Document new commitment(s) secured with completed / signed Partner ID Form(s) (submit to USDOE Program Officer). https://www2.ed.gov/programs/gearup/ applicant.html Each year, document all changes to collaborating partners in the current year s Annual Performance Report. Arizona GEAR UP Match Panelist Notes 3
EASING THE BURDEN OF DOCUMENTING MATCH First and foremost Get over it! Match is a reality for all GU programs. Make the 1:1 Match Obligation a mantra and a common and embraced concept with everyone you interact with. Be up-front and honest with all of your partners: documenting match properly (to ensure audit readiness) is rigorous (by design); encourage match partners to consider this carefully before they decide to partner with you (news flash: it s totally worth it!) When writing your GEAR UP grant proposal consider having fewer very committed partners with greater match commitments rather than many less-engaged partners with relatively small match commitments. Use GEAR UP (federal money) to attract non-federal money [ Leverage ]. Go after the low-hanging fruit first (which means you may have to let some actual valid match contributions go because they take too much time to properly document). www.nau.edu/gearup/ click Grant Management scroll down to Fiscal Operations click on Fiscal Operations Documents click on Financial Packet Cost Share Contribution Form EASING THE BURDEN OF DOCUMENTING MATCH (continued) As you implement Designate one person on your team to be the match guru, and make it a performance expectation for that person to provide cost share tech assistance and to record, track, beg, borrow, steal, nag and hound. www.nau.edu/gearup/ click Grant Management, scroll down to Fiscal Operations click on Fiscal Operations Documents, click on Financial Packet Template Sample Establish a fiscal rep (single point of contact) with all of your partners with whom you are reimbursing / documenting match, communicate regularly with that rep. Have all of your cost share partners / collaborators / vendors report on match contributions regularly (immediately / monthly / quarterly) and require them to submit all supporting documentation on every match contribution every time they request reimbursement. Don t worry about being absolutely perfect with your match documentation but do worry about being audit-ready at all times. www.nau.edu/gearup/ click Grant Management scroll down to Fiscal Operations click on Fiscal Operations Documents click on Financial Packet Cost Share Contribution Form Arizona GEAR UP Match Panelist Notes 4
PERSONNEL IN-KIND CONTRIBUTION EXAMPLES DISCLAIMER ALERT! YOU MAY HATE THESE EXAMPLES OR DISAGREE WITH THEM AND TAKE A DIFFERENT APPROACH! Examples from NAU GEAR UP valuing EMPLOYEES time contributions A VERY SMALL % of our NAU Principal Investigator (who is the university provost and oversees our grant implementation) Reasonable portions of carefully documented time spent implementing work plan tasks tied to grant objectives, from K-12 school partners assistant superintendents, principals, administrators (also counselors, if they are on the correct type of contract) NOTE: Stay away from counting teacher time as match Reasonable portions of carefully documented time spent implementing work plan tasks tied to grant objectives, from our non-profit (non-school) partners. These are valued at the employees pay rate (salary + benefits) Examples from NAU GEAR UP valuing VOLUNTEERS time contributions Reasonable portions of carefully documented time mainly for speaking to parents / students at career exploration events. These are generally valued at the Arizona hourly rate (currently $22.83) established by www.independentsector.org. http://www.independentsector.org/resource/thevalue-of-volunteer-time/ PERSONNEL IN-KIND CONTRIBUTION EXAMPLES (continued) WET BLANKET ALERT Ultimately, the documentation of Personnel costs (both those reimbursed with GEAR UP funds and those contributed as Match) is governed by Uniform Guidance 2 CFR Title 2 SubTtle A Chapter II Part 200 200.430 Compensation Personal Services). Therefore, Arizona GEAR UP requires all personnel costs (reimbursement and match) for each staff member whose personnel costs are being requested for reimbursement or contributed as match in a given time period to be certified by Time & Effort forms and further supported by payroll registers, calculation sheets, transaction reports, accounting reports, e-mail correspondence, and other types of documentation. Partners may substitute copies of their own such Time and Effort forms if they meet standards of Uniform Guidance 2 CFR Title 2 SubTtle A Chapter II Part 200 200.430 Compensation Personal Services. Arizona GEAR UP Match Panelist Notes 5
FACILITIES MATCH EXAMPLE DISCLAIMER ALERT! YOU MAY HATE THIS EXAMPLE OR DISAGREE WITH IT AND TAKE A DIFFERENT APPROACH! THE ARIZONA GEAR UP EXPERIENCE In prior grant cycles, NAU GEAR UP steered clear of counting facilities costs as match because of federal cost principles emphasis on using use allowance as the approach for valuing donated space (which posed some insurmountable logistical hurdles). However, Uniform Guidance essentially does away with use allowance as an approach to valuing facilities. Therefore, in the current grant cycle (2012-19), Arizona GEAR UP has counted facilities match from GEAR UP K-12 school partners (i.e. our subawardees ), using fair market value of the space (generally determined by using each school s Board-approved facilities rental schedule) that our full-time GEAR UP Coordinators occupy during the school day / school year. Use of this source of match has been affirmed as valid by USDOE Program Officer James Davis (in separate communications specifically with us) and also based on recent presentations I have attended at national GEAR UP training events by USDOE. Like all of our match contributions, this cost share is carefully documented and meets all the regulatory tests of allowabilitypromulgated by all of the various sources of federal cost principles that govern GEAR UP grants (funded grant proposal, GEAR UP implementing legislation and negotiated rules, EDGAR, Uniform Guidance, etc.). FACILITIES MATCH EXAMPLE (continued) THE ARIZONA GEAR UP EXPERIENCE (continued) CFR 200.465 is the UG citation of most relevance here 200.306 and 200.420 also weigh in on this. For places where an established value for donated space simply does not exist (i.e., a very small, rural school district that has not yet established a school board-approved facilities rental schedule), an independent appraisal may be required to count donated space as match, per CFR 200.306(h)(3). There may be other instances where an independent appraisal is required to establish fair market value proceed with extreme caution and maximum documentation! NAU GEAR UP does not count as match the value of space occupied by the university s GEAR UP staff (our Director, Assistant Directors, Site Support Specialists, Evaluator, etc.) at NAU s North Valley campus because NAU is the GEAR UP grantee (not a subawardee, like our K-12 school partners) and these rental costs are considered part of the grantee s indirect costs (proceeds generated by applying the USDOE-capped rate of 8% of MTDC). Arizona GEAR UP Match Panelist Notes 6
MATERIALS & SUPPLIES, CONTRACTED SVCS EXAMPLE DISCLAIMER ALERT! YOU MAY HATE THIS EXAMPLE OR DISAGREE WITH IT AND TAKE A DIFFERENT APPROACH! DISCOUNTED (OR DONATED) MATERIALS & SUPPLIES, CONTRACTED SERVICES Arizona GEAR UP never receives donated equipment (items that meet the federal definition of a single item costing $5K+) and we generally do not receive donated materials & supplies (for a variety of reasons). However, we regularly receive discounts and waived/reduced costs (sometimes very significant in value) on certain GEAR UP-specific purchases (both goods and services). SHOUT-OUT: Some of the best vendors to work with on this front have been GEAR UP motivational speakers (most of the recognizable names that are on the circuit Arel Moodie, Seeds Training, etc.); Xcalibur SCRIBE (and probably other NAU GEAR UP database providers); Signal Vine; NAU Summer Camps / Conferencing In these instances, we work with the vendors involved to have the exact amount of the discount identified on the associated paperwork (purchase agreements, proposals, purchase orders, invoices, payment request forms, etc.). In the grand scheme, these contributions are not huge, but they are a significant part of establishing a culture of shared awareness around the GEAR UP 1:1 match obligation and so therefore, we conscientiously record and count these discounted materials & supply costs as match contributions toward our overall obligation. SCHOLARSHIP MATCH DISCLAIMER ALERT! YOU MAY HATE THIS ADVICE OR DISAGREE WITH IT AND TAKE A DIFFERENT APPROACH! PROCEED WITH EXTREME CAUTION AND DOCUMENT CAREFULLY Make every scholarship cost share contribution you count GEAR UP student-specific and be ready to kill a lot of trees with your scholarship cost share documentation. Carefully review / study the scholarship web sites of partnering organizations so you fully understand the fund sources, amounts, terms and conditions of all scholarships that you intend to count as match. Most schools provide a formal financial aid package to their admitted students; nowadays, they seem to mostly exist online, in a web portal of some kind; consider this a starting place for documenting scholarship match value but not full documentation. The best documentation is copies of personalized scholarship offer letters supplemented by detailed information from scholarship organizations websites that state the exact purpose(s), amount(s) and year(s) of scholarship(s). Don t count any sources of federal financial aid as match (EX: Pell Grant, work-study) and don t count any loan eligibility amounts as match. Only count non-federal aid offers from one school; that is, don t duplicate scholarship match by counting all of the aid offers a GU student receives, focus on the school that the student is confirmed as definitely / most likely attending. Never blanketlycount as GEAR UP match the scholarship amounts that high school counseling offices proclaim were awarded to their graduating seniors; while this number is fantastic and should be celebrated, it is for PR purposes and would not withstand audit for GEAR UP match purposes if carefully scrutinized. Arizona GEAR UP Match Panelist Notes 7
INDIRECT COST MATCH DISCLAIMER ALERT! YOU MAY HATE THIS ADVICE OR DISAGREE WITH IT AND TAKE A DIFFERENT APPROACH! PROCEED WITH EXTREME CAUTION AND DOCUMENT CAREFULLY First, some quick background info / definitions from Uniform Guidance 200.56: If you are the applicant (fiscal agent) and have a negotiated indirect cost rate on file with a cognizant federal agency: Apply direct costs to all documented match at the USDOE-capped 8% of Modified Total Direct Costs (MTDC); MTDC Basis is shorthand for, back out Scholarships, Equipment, Participant Support Costs, and amounts of subcontracts > $25K from your base before multiplying it by 8%. Don t like this interpretation of MTDC? Take it up with Uniform Guidance 200.68: INDIRECT COST MATCH (continued) PROCEED WITH EXTREME CAUTION AND DOCUMENT CAREFULLY If your negotiated indirect cost rate is less than the USDOE-capped 8%, use the lower % (this happens, it is rare, tends to apply to LEAs more than IHEs). BUMMER ALERT: GEAR UP grantees are NOTpermitted to count, as match, Unrecovered Indirect Costs : the difference between the actual indirect amount (using the USDOE-capped 8% rate) and the what the indirect amount would have been if calculated under the recipient's approved [higher] negotiated indirect cost rate (which is typically higher than 8% for IHEs) see UG 200.306(c). If you are NOTthe applicant (fiscal agent) and you receive / expend GEAR UP funds and/or report match, follow the guidance of the applicant (fiscal agent) with respect to counting / reporting indirect costs as match (or not). You may want to be aware of the following: Under Uniform Guidance 200.331 and 200.414, pass-through entities (aka subrecipients aka subawardees ) may include indirect costs in their (reimbursement and match) budgets that they negotiate with the prime (lead) GU grantee; they may also waive all or a portion of these indirect costs. This is true even for entities that have never had a negotiated indirect cost rate on file with a cognizant federal agency; entities in this situation can use the de minimus rate of 10%, which USDOE has capped at 8% (as long as the entity does not then move forward with negotiating a rate with a cognizant federal agency). Arizona GEAR UP Match Panelist Notes 8
DOCUMENTS YOU SHOULD READ CAREFULLY IF YOU DEAL WITH MATCH ON A REGULAR BASIS GEAR UP Program Statute and Regulations - https://www2.ed.gov/programs/gearup The full text of Uniform Guidance (2 CFR 200), https://www2.ed.gov/policy/fund/guid/uniformguidance/index.html, especially as it pertains to match, which is 200.306 Cost Sharing or Matching and also all of the items 200.420 through 200.475 General Provisions For Selected Items of Cost Relevant portions of EDGAR Education Department General Administrative Regulations (full disclosure: I don t look at EDGAR very often but I don t feel particularly good about that, I should review it more often) - https://www2.ed.gov/policy/fund/reg/edgarreg/edgar.html. Your funded grant proposal, including (especially) the budget narrative, the Matching Funds Provided By Non- Federal Sources chart, the Applicant Organization Identification Form and Cost Share Worksheet, and all of the signed / submitted Partner ID Form and Cost Share Worksheet documents. Today s presentation from USDOE -http://www.edpartnerships.org/materials; scroll down to Tuesday February 7 and click on Seminar #11: Documenting the Match and Cost-Share (ED) (Powerpoint) NCCEP s webinar recorded 01/31/17 - Connecting To The Big Picture: An Orientation To GEAR UP - http://www.edpartnerships.org/materials; scroll down to Pre-Conference and click on Recorded Webinar DOCUMENTS YOU SHOULD READ CAREFULLY IF YOU DEAL WITH MATCH ON A REGULAR BASIS (continued) All formal agreements and supplemental written guidance / technical assistance provided by your specific grant s lead grantee / fiscal agent. If you want to look at some of the forms that are used by Arizona GEAR UP to see an example of how one GEAR UP grantee approaches match, go to www.nau.ed/gearup, click on Grant Management, scroll down to Fiscal Operations, click on Fiscal Operations Documents, and click on the form(s) / document(s) you want to review. You can also review other GEAR UP grantees match guidance / templates / forms / other documents online, most are just a simple Google search away. MATCH PANELIST => PREPARATION NOTES Stephen R. Hart, Ed.D. Director -Fiscal / Office Operations, Arizona GEAR UP Northern Arizona University 5451 N. 28 th Ave. #216 Phoenix, AZ 85053 (602) 776-4614 direct (602) 751-4839 cell (602) 776-4619 fax www.nau.edu/gearup Arizona GEAR UP Match Panelist Notes 9