Grants Management Updates Division of Finance and Operations 1
Presenters Mari Presley, Assistant Deputy Commissioner Finance and Operations Janice Brown, Chief Bureau of Contracts, Grants & Procurement Felicia Williams-Taylor, Program Specialist IV Bureau of Contracts, Grants & Procurement 2
TOPICS Applications and Budgets Allowability Project Close Out Supplement Not Supplant FDOE Grants Management Updates 3
Grants Management Update 4
Office of Grants Management (OGM) Update The fiscal year for federal entitlement funds is July 1 through on June 30. RFAs/RFPs received after the July 1 st start date will begin on the date of receipt in OGM. Generally, the effective date indicates all the Conditions for Acceptance are received in the Office of Grants Management. 5
Request for Application/Proposal RFA Refers to a Request for Application that is generally used in non-competitive programs. RFP Refers to a Request for Proposal that is generally used in seeking applications that are competitive. Florida Department of Education (2015). Green Book. 6
Conditions for Acceptance Meet the timelines indicated in the RFA/RFP The minimal requirements below must be met for applications to be considered for review. Consideration for review does not equal an approved application. Unless otherwise indicated by the Florida Department of Education (FDOE), applications should be received by the Office of Grants Management on/before the start date of the program by the deadline stated in the RFA/RFP. 7
Conditions for Acceptance (cont.) DOE 100A (Project Application Form) must include the signature of the current agency head/president DOE 101 or DOE 101S (Budget Narrative Form) All required forms must have the TAPS Number assigned by the Office of Grants Management. 8
Announcement The local and state educational agencies will receive an announcement from the Florida Department of Education (FDOE) through paperless communication or directly from a bureau when an RFA/RFP is available. LEAs should complete all requirements and mail the information to the Office of Grants Management on/before the due date identified in the application/proposal. 9
Common RFA/RFP Requirements Project Application Form (100A) Narrative (900D/900E) Budget (DOE 101/DOE 101S) Any other content and/or deliverables to receive an award (DOE 200) 10
Who Do I Contact For Assistance? Review the RFA/RFP and search for the program and grants management contacts located in the 900D/900E form. Program Contact = person(s) responsible for making sure the activities are compliant with federal and/or state law. 11
Who Do I Contact For Assistance? (cont.) Grants Management = person(s) responsible for receiving and tracking the DOE 100A and other required forms and who is responsible for ensuring the budget is in accordance with federal and/or state law. 12
What Are All These (WAAT) Forms? DOE 900E = entitlement application DOE 900D = discretionary (noncompetitive) DOE 905 = discretionary (competitive) 13
WAAT Forms? (cont.) DOE 610 Risk Analysis for LEAS and other public entities. Is on file and not required to submit each year unless the agency head, finance officer or policy changes occur. 14
WAAT Forms? (cont.) DOE 620 Risk Analysis for non-public entities, e.g., community based organizations. Must be done each year prior to an award being issued. Recommend the entity includes this documentation with one project application which will cover all projects submitted to the FDOE for the entire fiscal year. (ONE PER AGENCY) Changes to the DOE 620 within a fiscal year: for an agency head or finance officer requires the renewal of the signature page. because of a new policy and/or procedure requires a new signature page. Please earmark the changes from the previous version to help us easily identify them. Please contact us at CGP@fldoe.org or 850-245-0496 if you need assistance. 15
WAAT Forms? (cont.) DOE 100A = Original intent to request funds and the legal binding document between agency heads and the FDOE. DOE 101S = Original budget (discretionary) 16
WAAT Forms? (cont.) DOE 150 = request to amend and approved project application and/or budget DOE 151 = accompanies the DOE 150 to reflect budgetary changes Change in scope, goals or objectives Change in project evaluation scope Change in deliverables Change in work task Change in key or types of personnel Disengagement of project director Budget Revision to implement program amendment Increase project amount Revise project period Change reporting dates (program or fiscal) Decrease allocation Terminate program A written request may be sent via email to OGM and the corresponding program office for approval. 17
Where are these forms located? The FDOE Grant Forms webpage. 18
WAAT Forms? (cont.) DOE 200 = award from FDOE to an agency, one per project. 19
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Timelines and Special Conditions 21
Preliminary Allocations Preliminary Allocations are estimated allocation schedules included with an RFA/RFP for subrecipients to use for planning purposes prior to the final grant award notification. 22
Conditional Release of Funds The FDOE Deputy Commissioner of Finance and Operations authorizes a percentage of entitlement funds to be available for a brief period of time pending the final approval of an application. 23
Back to Conditions of Acceptance The conditional release of entitlement funds are contingent upon the FDOE s receipt of the requirements identified in the RFA/RFP Conditions of Acceptance. Project Application DOE 100A Must include the signature of the authorized agency head. If signed by a designee, the authorization must be included with the project application. DOE 101 or DOE 101S (Budget Narrative Form) 24
Indirect Cost Rates Finance Officers negotiate Indirect Cost rates and plans annually with the FDOE Comptroller. They are effective July 1st June 30th of each fiscal year. The RFA/RFP will indicate whether there are Caps or not. The these rates are posted on the FDOE s Office of the Comptroller website. 25
Florida Grants System (FLAGS) 26
Florida Grants System (FLAGS) What is the status of my application/proposal? Has the FDOE received it yet? Here are your options Access FLAGS Contact your authorized agency head/finance officer Contact OGM at CGP@fldoe.org or 850-245-0496. 27
FLAGS (cont.) If you do not have access to FLAGS? Contact your authorized agency s head or finance officer to retrieve information and/or complete the registration procedures to gain access to a role that best fits your needs according to your agencies leadership. 28
CODIFYING CODES The CCs 29
Function Codes Function Codes refer to the objective or purpose (activities) of an expenditure as follows: Instruction; Student Instructional Support Services; General Support Services; Debt Services; and Capital Outlay. 30
Object Codes Object codes refer to the goods purchased or services obtained. There are seven major categories for expenditures. Salaries; Materials and Supplies; Employee Benefits; Capital Outlay; Purchased Services; Energy Services; and Other 31
Function and Object Codes The function and object codes are the by-product that drives the Account Title and Description provided on the DOE 101 (budget form) and DOE 151 (budget amendment form). It enables the FDOE to determine whether a line item is allocable, allowable, reasonable and necessary to support the activities identified on the DOE 900D/900E (Project Narrative). Codifying the function and object codes enables the FDOE to align the project narrative with the budget in groups of related activities and the goods and services to be obtained. Florida Department of Education (2017). Red Book. 32
Common Issues Incorrect budget amount on Line D Total Project Amount Currently Approved on DOE 151 No notation for currency (commas, decimals) on project applications and amendment budgets. Agency s claim for Indirect Costs exceeds maximum allowed Incorrect or missing program name, project & TAPS numbers on DOE 150 & DOE 151 Use of Function & Object Codes not found in the Red Book, Florida College Accounting Manual or Statewide Object Code list (FLAIR) Use of Cents pennies in Requested Amounts and Estimated Roll Forward in project applications Inconsistent classification of Costs in Title III projects Year 1 line item is Administrative or Indirect Cost, Year 2 Direct. Program reservations (e.g. Parent & Family Engagement, Private School) unspecified in budget Itemized benefits (200 series Object Codes) missing from employee salaries Vague, general language etc., to include but not limited to, other used in project narratives and budget descriptions Line items in FLDOE final Project Disbursement Report (DOE 399) not matching line items found in approved project application & amendments Project applications & amendments submitted on outdated grants forms (DOE 100A, DOE 101/101S, DOE 150 & DOE 151) Incorrect Dun & Broadstreet (DUNS) and Federal Employer Identification (FEIN) numbers submitted on DOE 100A. 33
The CC s TABLE ONE Function Object Account Title and Description FTE Amount 6300 100 Administrative Salary 0.02 $1,000.00 An administrative position with 0.02 FTE at $1,000.00 will support instruction and curriculum development services for the LEA. 34
The CCs (cont.) TABLE 2 Function Object Account Title and Description FTE Amount 6300 100 Administrative Salary Assistant 0.02 $1,000.00 Director salary for management of private schools equitable funding and services. This specifies the type of administrator group rather than general and provides more details about the type of services the position will serve in the LEA. The CC s enables the program office and grants management to effortlessly align the project narrative and budget. 35
Allowability 36
Allowability 2 CFR 200.403 All Costs Must Be: Necessary, Reasonable and Allocable Conform with federal law & grant terms Consistent with state & local policies Treated consistently In accordance with GAAP Not included in match Adequately documented 37
Allowability State Rules 216.3475, F.S. Reasonable Necessary Allowable by state law DFS Reference Guide for State Expenditures 38
Allowable Not Allowable Not Allowed: Food, meals, refreshments Entertainment Promotional or marketing Cell phones Convenience items for personal use 39
Allowable Not Allowable Allowed: Furniture or equipment Meeting room rental Travel Field trips 40
DOE 399 41
Project Close Out Entitlement vs. Discretionary No difference in close out procedures Watch for variance in presented budget vs. reported expenditures Cash draw must agree with final DOE399 Green Book, Section C Records retention Audit requirements 42
Charter School Funding Requirements 1002.33(17)(c) F.S. Charter School Funding requirements Charter schools must receive all eligible federal funds within 5 months of first opening and within 5 months of enrollment expansion Must have a funding plan with the District sponsor 43
Charter School Funding Requirements Reimbursement shall be on a monthly basis Includes Title I, Title II & IDEA Charters must have a Expenditures must comply with Federal regulation & State law 44
Supplement Not Supplant 45
SUPPLEMENT NOT SUPPLANT TRADITIONAL PRESUMPTIONS OF SUPPLANTING APPLY TO ALL ESEA ENTITLEMENT PROGRAMS, EXCEPT TITLE I DETERMINATION IS MADE ON EACH INDIVIDUAL COST OR SERVICE CAN BE REBUTTED 46
TRADITIONAL PRESUMPTIONS OF SUPPLANTING 1. Required to be made available under other federal, state, or local laws. 2. Provided with Non-federal funds in the prior year. 3. Same services were provided to other students using non-federal funds. 47
TITLE I SNS under ESSA ESSA Sec. 1118(b) Title I, Part A funds must be used to supplement, not supplant state and local resources No presumptions To demonstrate compliance, the LEA shall demonstrate that the methodology used to allocate state and local funds to each school receiving assistance under this part ensures that the school receives all the State and local funds it would otherwise receive if it were not receiving Title I funds. 48
Title I - SNS ESSA Sec. 1118(b)(3) No LEA shall be required to Identify individual costs or services as supplemental Provide services through a particular instructional method or in a particular instructional setting to demonstrate compliance. 49
TITLE I SNS under ESSA CAUTION ED will apply a specific cost test to DISTRICT-WIDE costs Is there a state-mandated requirement? Same services provided to non- Title I students using other funds ED claims this would indicate violation of the methodology test in the statute. 50
Title I - SNS ESSA sec. 1118(b)(4): The Secretary may not prescribe the specific methodology a LEA uses to allocate State and local funds to Title I schools. 51
TITLE I SNS under ESSA Exclusion ESSA sec. 1118(d) SEA or LEA may exclude from a supplanting determination supplemental state or local funds expended for programs that meet the intent and purposes of Title I, Part A. 52
TITLE I SNS under ESSA Exclusion (cont.) 34 C.F.R. 200.79 a program meets intent and purposes, if it either Is implemented in a school with at least 40 % poverty; Is designed to promote schoolwide reform and upgrade the entire educational operation of the school; is designed to meet the educational needs of all students in the school, particularly those who are not meeting state standards; and Uses the state assessment system to review the effectiveness of the program; OR 53
TITLE I SNS under ESSA Exclusion (cont.) Serves only students who are failing, or most at risk of failing, to meet state standards; Provides supplementary services to participating students designed to improve their achievement; and Uses the state assessment system to review the effectiveness of the program. 54
Title I SNS Fla. implementation LEAs will be required to assure that they meet the SNS requirement and describe the methodology in its 2018-19 application LEA has flexibility, must show: Students living in poverty, ELLs, SWD, other subgroups generate additional funding for their school; and Each Title I school receives for its use all of the funds to which it is entitled 55
Title I SNS Fla. implementation Examples of Acceptable Methodologies (From 2015 ED guidance on schoolwide programs): Weighted per-pupil funding formula Staffing and Supplies, e.g.: 1 teacher per 22 students ($65,000/teacher) 1 principal per school ($120,000) 1 librarian per school ($65,000) 2 guidance counselors per school ($65,000/guidance counselor) $825/student for instructional materials and supplies 56
Title I SNS Fla. implementation Approval of application Approval of methodology Is methodology objective/measurable? Is methodology Title I neutral? 57
GRANTS MANAGEMENT UPDATES 58
APPLICATIONS & ALLOCATIONS RFAs for Entitlements & State projects Preliminary Allocations Level Funding for most Entitlements More for: Title IV and Adult Ed./English literacy 59
HURRICANE RELIEF Emergency Aid to RESTART operations Impact Aid Homeless/Displaced Students 60
Enterprise Grants Management Application (EGMA) 61
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Thank You Participating! Mari Presley, Assistant Deputy Commissioner Finance and Operations Mari.Presley@fldoe.org 850-245-9426 Janice Brown, Chief Bureau of Contracts, Grants & Procurement Janice.Brown@fldoe.org 850-245-0819 Felicia Williams-Taylor, Program Specialist IV Bureau of Contracts, Grants & Procurement Felicia.Williams-Taylor@fldoe.org 850-245-0717 63
References & Illustrations 64
References 2 CFR 200.414, Indirect (F&A) Costs Bureau of Contracts and Grants & Procurement Email Address - CGPmailbox@fldoe.org Brustein & Manasevit, PLLC 2018 DUNS Number Florida Grants System (FLAGS) Florida Accounting Information Resource (FLAIR) Grant Forms Green Book Indirect Cost Red Book Reference Guide for State Expenditures United States Department of Education 65
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Anatomy of a Project Number 71
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