Effective Title III Program Administration

1. Effective Title III Program Administration Dr. Haywood L. Strickland, President and CEO Wiley College * Marshall, Texas June 3-5, 2008

2. It’s All About Stewardship Excellence Fiscal Accountability Program Administration Monitoring Demonstrating Results

3. Did you do what you said you were going to do? At what cost?

5. PART I: FISCAL ACCOUNTABILITY

6. ORDER OF PRECEDENCE WHEN DECIDING ALLOWABILITY OF COST Legislation Program Regulations EDGAR (Incorporates OMB A-21 Cost Principles for Educational Institutions) Approved Application

7. ALLOWABLE COSTS(USE OF FUNDS) Legislation – Section 323 of Higher Education Act of 1965 as amended U.S. Code 1060 Part B, Historically Black Colleges & Universities

8. ALLOWABLE COSTS Section 323 (a) General Authorization: Use of funds Purchase, rental, or lease of scientific or laboratory equipment for educational purposes, including instruction and research purposes. Construction, maintenance, renovation, and improvement in classroom, library, laboratory, and other instructional facilities including purchase or rental of telecommunications technology equipment or services.

9. Allowable Costs (Sec. 323 continued) Support faculty exchanges, and faculty development and faculty fellowships to assist in attaining advanced degrees in their field of instruction. Academic instruction in disciplines in which African Americans are underrepresented. Purchase of library books, periodicals, microfilm, and other educational materials, including telecommunications program materials. Tutoring, counseling, and student service programs designed to improve academic success.

10. Allowable Costs (Sec. 323 continued) Funds and administrative management, and acquisition of equipment for use in strengthening funds management. Joint use of facilities, such as laboratories and libraries. Establishing or improving a development office to strengthen or improve contributions from alumni and the private sector. Establishing or enhancing a program of teacher education designed to qualify students to teach in a public elementary or secondary school that shall include, as part of such program, preparation for teacher certification.

11. Allowable Costs (Sec. 323 continued) Establishing community outreach programs which will encourage elementary and secondary students to develop the academic skills and the interest to pursue postsecondary education. Establishing or improving an endowment fund. OTHER ACTIVITIES submitted pursuant to section 323 that: contribute to carrying out the purpose of this part; and are approved by the Secretary as part of the review and acceptance of such application

12. EDGAR REQUIREMENTS EDUCATION GENERAL ADMINISTRATIVE REGULATIONS (EDGAR) SECTION 72.27 ALLOWABLE COST Incorporates OMB Circular A-21, Major Cost Principles for Educational Institutions

13. ALLOWABLE & UNALLOWABLE COSTS OMB Circular A-21 Objective Provides clear cut guidance on all expenditures: allowable, allocable, reasonable, and prudent.

14. OMB A-21 COST PRINCIPLES Purpose Establishing principles for determining costs applicable to grants, contracts, and other agreements with educational institutions.

15. OMB A-21 COST PRINCIPLES Applicability All federal agencies that sponsor research and development and other work at educational institutions shall apply the provisions of this Circular in determining costs incurred for such work.

16. OMB A-21 COST PRINCIPLES TABLE OF CONTENTS Purpose and Scope Definition of Terms Basic Considerations Direct Costs Indirect Costs Identification and assignment of indirect costs

17. OMB A-21 COST PRINCIPLES TABLE OF CONTENTS (Continued) Determination & Application of Indirect Cost Rate or Rates Simplified Method for Small Institutions Reserved General Provisions for Selected Items of Costs Certification of Changes

18. FIRST LEVEL DETERMINATION OF ALLOWABLE COST IN OMB A-21 ALLOCABLE TO THE GRANT Benefits received REASONABLE Necessary for the operation ALLOWABLE Circular, law, local regulation PRUDENT Comparability with use of institutional funds

19. UNALLOWABLE COSTS OMB Circular A-21, Section J Alcoholic Beverages Communications (i.e. line charges, unit charges) Donations & Contributions Entertainment (i.e. anything remotely related) Executive Lobbying (i.e. attempting to improperly influence the decisions of officers or employees of the Federal Government)

20. UNALLOWABLE COSTS (Continued) Exclusive Memberships, Subscriptions & Professional Activity (i.e. Country Clubs) Pre-agreement Costs (Unallowable unless pre-approved) Scholarships & Student Aid

21. INDIRECT COSTS INDIRECT COSTS ARE NOT ALLOWABLE IN THE TITLE III PROGRAM

22. THINGS TO REMEMBER TO DETERMINE IF A COST IS ALLOWABLE OR UNALLOWABLE, CHECK THE FOLLOWING SOURCES: The Law Program Regulations EDGAR, 34 CFR 74.27 Allowable Costs OMB Circular 21 Approved Application

23. ACCOUNTABILITY GPRA – 1993 Government Performance and Results Act Ties federal funding to results Greater accountability GPRA indicators reflected in objectives and activities Include milestones in objectives to determine success accurately

24. DRAWDOWN POLICY Request funds for immediate needs Minimize time between requests & expenditures (72 HOURS) Rate of draw downs commensurate with approved scope & milestones

25. DOE CONCERNS Large amounts of unobligated funds Excessive or infrequent requests Project goals/objectives not met – DOE monitors Student population is not being served as proposal objectives indicates Maybe, HBCU’s DON’T NEED THE MONEY

26. GAPS MONITORINGOF AVAILABLE BALANCES Within 90 days, “flags” grants with 70% or more of funds remaining Verifies financial data reported on annual performance report

27. PART II: TITLE III PROGRAM ADMINISTRATION AND MANAGEMENT

28. ELEMENTS OF AN EXEMPLARY TITLE IIIPROJECT ADMINISTRATION PROGRAM RESPONSIBILITIES OF A TITLE III PROJECT DIRECTOR Provide leadership and coordination Facilitate integration of Title III activities

29. Support an ongoing process of institutional effectiveness Develop and update a project handbook to include policies and procedures Monitor expenditures and reconcile monthly Ensure conduct of an annual external evaluation

30. Ensure that Title III funds are disbursed in keeping with: Education Departments General and Administrative Regulations (EDGAR) (Revised June 23, 2005); A-110 (Revised April 25, 2007); OMB Circular A-21 (revised May 10, 2004); and A-133 (revised June 27, 2003).

31. Roles and Responsibilities of Title III Activity Directors

32. The Title III Activity Director is responsible for…. Activity management and oversight Implementation of objectives Supervision and monitoring of activity staff Reporting activity status/progress Approval and processing of requisition Keeping abreast of grant regs & information Maintaining up-to-date activity files Maintaining up-to-date equipment inventory

33. Roles and Responsibilities of Title III Activity Director (Cont.) Budget Monitoring and Oversight Staff meeting attendance Approval of travel requests Preparation and submission of annual plan of operation Documentation of objective implementation Preparation for and participation in internal and external Title III activity evaluation, site review, etc.

34. MAJOR COMPLIANCE PROVISIONS EDGAR Property Controls Prior Approval Requirements Notification of Change in Key Personnel Annual Evaluations of Performance

35. OMB Circular A-110 Available over the Internet at http://www.whitehouse.gov/omb/circulars/a110_compliance/06/pt3.pdf An institution cannot hold excess cash on hand. (Funds to be spent in 72 HOURS) A-110 also describes “Davis-Bacon” compliance requirements.

36. OMB CIRCULAR A-21The Cost Principles As a reminder, follow four guidelines ALLOWABLE ALLOCABLE REASONABLE PRUDENT

37. OMB CIRCULAR A-133/THE SINGLE AUDIT REQUIREMENT A-133 single audit requirement pertains to all federal grants which exceed $500,000. A-133 auditing defines institutions as: Low-Risk or High Risk

38. OMB CIRCULAR A-133/The Single Audit Requirements A system of checks and balances Proof of written policies and procedures Property Control Management

39. OMB CIRCULAR A-133/The Single Audit Requirements (cont.) A review of all reports filed The Financial Transactions (the 269s; 272s); Performance Reports; Annual Audit must be filed with the Federal Audit Clearinghouse (which must include any corrective action plans prepared by the institution)

40. Proof of compliance with the Davis-Bacon Act. Proof that all Expenditures Constitute Allowable Costs. OMB CIRCULAR A-133/The Single Audit Requirements (cont.)

41. PART III MONITORING BEGINS WITH MEASURABLE OBJECTIVES

42. Writing Measurable Objectives There are many formats for writing objectives. During this workshop we will use the National Laboratory for Higher Education (NLHE) format and content.

43. A well written objective should take the form of a single statement that contains the following: QUANTIFIED OUTCOME State the projected end result in measurable terms

44. A well written objective should also include…. Time Specify the date that the objective will be completed.

45. The following are optional parts of an objective: Responsibility: State what person(s) or unit is/are responsible for implementing the objective. Conditions: Specify special conditions (if any) that will or may impact that outcome of the objective.

46. Many grants, such as the Title III Grant, require each objective to have an anticipated result. The anticipated result statement should include… Performance Level and Baseline Data Evaluation Method(s) Date(s) Type and Location of Documentation

47. MONITORING The Ongoing Review of Activities to Manage Performance

48. FISCAL MONITORING Monthly Expenditure Reports by Activity Reconciled Monthly to Capture Discounts, Cost-Savings, and Consistency with Drawdown Reports Required for A- 133 Audit & Timely Submission to the Audit Clearinghouse Facilitate Title III E-Reporting

49. GRANTEE’S RESPONSIBILITIES Project success & financial accountability Submit annual & final performance reports Valid & reliable data Report of GPRA standards & indicators

50. GRANTEE’S RESPONSIBILITIES ON SITE: Funded application & grant award Previous audits & site visit reports Annual Performance Reports Project revision(s) documentation Current budget & personnel list

51. COMMON AUDIT EXCEPTIONS Things that should NEVER happen: Poor recordkeeping Unallowable costs or activities Missing time & effort reports Failure to follow procurement standards Lack of internal controls Failure to obtain prior approval if required Poor cash management (excessive draws)

52. AUDIT REQUIREMENTS Non-Federal audit IF expending $500,000 or more annually in Federal awards Mail to Federal Audit Clearinghouse

53. EXPANDED AUTHORITIES GOALS: (Promote Successful Project Outcomes) Increase flexibility Increase accountability Reduce paperwork burden Develop partnerships

54. EXPANDED AUTHORITIES (Cont.) PRE-AWARD COSTS: May be incurred up to 90 days before budget period begins NO PRIOR APPROVAL REQUIRED

55. EXPANDED AUTHORITIES (Cont.) PRE-AWARD COSTS OVERVIEW: Reasonable expectation of receiving a grant Incurred at own risk ED funds are not available for draw down until the budget period begins NOT for cost over-runs

56. EXPANDED AUTHORITIES CARRYOVER: Unexpended funds carried over without prior approval May be used for allowable costs within the approved scope Complete unfinished objectives “Other” activities within scope

57. EXPANDED AUTHORITIES (Cont.) CARRYOVER (continued): Program Officer may require Written statement to include: How will unexpended funds be used? When will unexpended funds be used? In rare cases, new funds may be reduced

58. PERFORMANCE MONITORING: The Routine Tracking of:

59. MONITORING

60. PART IV DEMONSTRATING RESULTS 

61. EXTERNAL EVALUATION ENCOMPASSES BOTH FORMATIVE & SUMMATIVEMETHODOLOGIES

62. KINDS OF EVALUATIONS FORMATIVE for improvement purposes SUMMATIVE to describe program impacts

63. TYPICAL FORMATIVE EVALUATION ACTIVITIES Time and Effort Reports Property Control Procedures Monthly and Quarterly Progress Reports Fund Accounting Procedures Internal Monitoring Strategies General Grant Management Procedures (Checks and Balances)

64. TYPICAL SUMMATIVE EVALUATION ACTIVITIES Annual E-Performance Reports A-133 Audit Report Findings & Follow-Up Assessment Instruments and Results, and Level of Institutional Commitment

65. PURPOSES OF EVALUATION Document Accomplishments Provide Data on Cost-Effectiveness Describe Program Effectiveness

66. PURPOSES (Cont.) Document Compliances with Program Regulations Ensure Agency (Donor) that Funds were used as Approved

67. THE EVALUATION PROCESS ENTAILS Monthly Progress Report Annual E-Performance Report Minutes of Meetings Assessment Surveys and Results Equipment Inventory Records

68. EVALUATION PROCESS FOCUS What are the Actual Outcomes? What were the Intended Outcomes? Relationship of Actual Outcomes to CDP Priorities. Relationship of Resources Used to Actual Outcomes. Were there Unexpected Outcomes?

69. THE EXTERNAL EVALUATION PROCESS ULTIMATELY DOCUMENTS INSTITUTIONAL Accountability AND Performance AND Achievement

72. Thank you for your participation in this workshop