Fiscal Requirements for Federal Programs. NEW FEDERAL PROGRAMS DIRECTORS TRAINING November 15, 2011. Session Topics & Group Assignments. Overview of Fiscal Information Related to: Legal Structures for Fiscal Accountability Allowable Costs and Procurement Procedures Inventory
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NEW FEDERAL PROGRAMS DIRECTORS TRAININGNovember 15, 2011
Overview of Fiscal Information Related to:
1. From what government documents are the basic fiscal requirements derived?
2. Which OMB Circular identifies allowable expenditures under general cost cutting principles?
3. Which OMB Circular provides the guidelines for fiscal audits?
4. Which OMB Circular provides the guidelines for the submission and approval of plans?
1. List several questions that should be asked before approving expenditures.
2. Describe some components of procurement procedures.
3. What information should be included at a minimum in all contracts?
4. What information should be provided on all invoices for contracted services?
Invoices submitted for payment on contract
1. What information is required on an inventory form for federal programs?
2. What two parts of a property management system (inventory) are required, but most neglected within district procedures?
3. How often is a physical inventory and reconciliation required?
Inventory items purchased with federal funds
are divided into three categories:
Under Section 80.32(c) of EDGAR, grantees and subgrantees must maintain specific property records that include:
ED determined that an adequate internal control system must include a process for labeling and locating property purchased with federal funds
(e.g., Title I FY 12 or Title I ARRA FY10)
Subgrantees must take a physical inventory of equipment at least every two years and must reconcile the results. The person conducting the physical inventory should sign and date the inventory form.
If any equipment is missing, the grantee or subgrantee must indicate on an inventory form.
1. What employees are required to maintain time and effort documentation?
2. Describe the two types of time and effort documentation and describe the use for each.
3. How often must the amount of payment from each cost objective be adjusted for a staff member who is funded by more than one cost objective?
If an employee works on multiple cost objectives:
1. Do federal programs utilize the restricted or unrestricted indirect cost rate?
2. Why are most indirect charges expensed at the end of the year?
3. Which indirect cost rate must be applied to carryover funds-the grant year or the current fiscal year’s cost rate?
1. Define Maintenance of Effort.
2. What percentage of the combined fiscal effort per student or the aggregate expenditure of the LEA from state and local funds for free public education in the LEA must the LEA maintain from the preceding year?
3. If a LEA fails to maintain this percentage, what are the consequences?
WAIVER – The USED Secretary may waive the requirements of maintenance of effort if it is determined that a waiver would be equitable due to exceptional or uncontrollable circumstances. Such exceptions may include a natural disaster or a precipitous decline in the financial resources of the LEA.
1. Discuss the supplement not supplant regulation as it applies to federal programs.
2. Provide a key question one should ask when trying to determine a supplant situation.
3. List three situations where an auditor will presume use of federal funds will violate the “supplement, not supplant” requirement.
1. When may a district obligate funds from a current grant?
2. What are some key parts of the grant award of which one should make note?
3. Why is important to track the entire grant award as well as individual school allocations?
4. What WVEIS reports are most helpful and what resources are available on the WVDE website?
1. From which NCLB programs may funds be transferred?
2. Which NCLB program may accept funds, but may not have funds transferred to another program?
3. What restrictions exist for districts which are identified for improvement?
4. What restrictions exist for districts which are identified for corrective action?
5. What effect do the fiscal year and the period of obligation have on transferred funds?
*Applies only to portion of funds subgranted on a formula basis.
1. Who authorizes the availability of federal funds and why is a time limit placed on the funds?
2. What is the obligation period of the federal grants?
3. Define the “tydings period” and of what benefit is this provision?
1. What percentage of the fiscal year’s allocation may a LEA carry into the “tydings period” for the Title I and Title II programs?
2. What procedures must a LEA follow if it is determined that the LEA exceeds the permissible amount of carry over?
3. If a waiver cannot be granted, what action must the state take?
4. Name the three ways that Title I carryover funds may be utilized when planning the proceeding year’s budget.
Title I and Title II are subject to a cap on amount that be carried forward into the “Tydings Period” which provides another 12 months for the use of funds.
* The requirement for equitable services to private schools also applies to carryover funds.
The LEA is not permitted to use Title I carryover funds in a school that is not eligible for Title I funding.
1. Define comparability of services.
2. How often must a district demonstrate comparability?
3. How would you determine if a district does not have to demonstrate comparability?
4. What is the purpose of excluding “all federally funded” staff when determining comparability calculations?
Section VII of the LEA monitoring document
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