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National Association of Title IIII Administrators Technical Assistance Workshop June 24, 2010 PowerPoint Presentation
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National Association of Title IIII Administrators Technical Assistance Workshop June 24, 2010. STRATEGIES FOR EFFECTIVELY BALANCING YOUR TITLE III BUDGETS AND KEEPING YOUR INSTITUTION COMPLIANT IN THE MIDST OF BUDGET CUTS. Presenters: Ms. Mary Anne (Vicki)) Payne , Compliance Officer

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STRATEGIES FOR EFFECTIVELY BALANCING YOUR TITLE III BUDGETS AND KEEPING YOURINSTITUTION COMPLIANT IN THE MIDST OF BUDGET CUTS

Presenters:

Ms. Mary Anne (Vicki)) Payne, Compliance Officer

Morgan State University

Mrs. Katrina B. Miller, Title III Director

Norfolk State University

Ms. Deborah Newkirk, Independent Consultant

today s objectives
Today’s Objectives
  • Balancing your Title III Budget
  • Allowable and Unallowable Costs

associated with LAAs

  • Supplementing vs. Supplanting
  • Strategies for staying compliant
reference for legislative allowable activities laa
REFERENCE for LEGISLATIVE ALLOWABLE ACTIVITIES (LAA)
  • HBCU – Higher Education Act (HEA) of 1965 revised Sec. 323 (a); HEOA, Public Law 110-315 (Aug. 2008) Sec. 309 (12, 13, 14)
  • HBGI – Higher Education Act (HEA) of 1065 – revised Sec. 326 (c); HEOA, Public Law 110-315 (Aug. 2008), Sec. 311 (b)
  • CCRAA– HEOA, Sec. 302, Title IV, Part J
  • MANDATORY FUNDING (SAFRA) -HEOA
unallowable activities
UNALLOWABLE ACTIVITIES

Activities inconsistent with a State plan

for desegregation

Activities related to sectarian instruction

or religious worship

Activities provided by a school of

divinity

Cultural Activities for Students

unallowable and allowable costs
UNALLOWABLEand ALLOWABLE COSTS

APPROVED activities DOES NOT mean ALLOWABLE costs

public relation advetisemen t costs circular a 21 j 1 a b c d e f
PUBLIC RELATION/ADVETISEMEN T COSTS (Circular A-21 (J 1 a, b,,c,,d,,e,,& f)

Allowable

Recruitment of personnel

Procurement of goods and services

Disposal of surplus materials

Costs required by sponsored agreement

Communication costs

Unallowable

  • ALL costs related to advertisement and public relations except costs specified under

ALLOWABLE including promoting the institutions

  • Costs associated with

Convocations

  • Costs of meeting rooms, & other facilities associated with shows and other special events
  • Costs of promotional items
special purpose and general purpose equipment circular a 21 j 16
SPECIAL PURPOSE and GENERAL PURPOSE EQUIPMENT (Circular A-21 J 16)

ALLOWABLE

Research, medical, scientific , medical, or other technical activities

Laboratory, library, and classroom furniture

Furnishing and equipment for Title III office

UNALLOWABLE

  • General purpose equipment such as; office equipment and furnishings, air conditioning equipment, if not approved in the sponsored agreement
development office circular a21 j 22
DEVELOPMENT OFFICE(Circular A21 J 22)

Allowable

Establishing a development office

Physical custody and control of monies

Unallowable

  • Organized fundraising
  • Financial campaigns
  • Endowment drives
  • Solicitation of gifts and bequests
  • Any expenses incurred solely to raise capital or obtain contributions
  • Investment counsel and staff whose responsibility is solely to enhance income from investments
examples of other unallowable costs identified in circular a 21
EXAMPLES of OTHER UNALLOWABLE COSTS identified in CIRCULAR A-21
  • Alcoholic Beverages- J2
  • Alumni/a e activities- J3
  • Bad Debts- J4
  • Civil defense costs- J5
  • Commencement costs- J6
  • Entertainment costs- J15
  • Fines and penalties- J18
  • Housing and personal living expenses- J20
  • Lobbying costs- J24
examples of unallowable costs continued
EXAMPLES OF UNALLOWABLE COSTS (continued)
  • Membership, subscriptions, an d professional activity costs –J28 (d, c)
  • Student activity costs – J45
supplement not supplant
SUPPLEMENT not SUPPLANT
  • What is supplementing?

To increase funding of existing

institutional programs.

  • What is supplanting?

To use grant funds to replace the costs

associated with existing institutional

programs.

examples of
EXAMPLES OF……….

SUPPLANTING

Replacing salaries

paid by other sources

with grant funds

Using grant funds for existing programs or

activities

SUPPLEMENTING

  • Using grant funds to

increase personnel

  • Use grant funds to enhance or develop new programs
examples continued
EXAMPLES (continued)

SUPPLANTING

Using grant funds to replace Institution funds currently being used for furnishing a computer lab

Replace institution funds for travel, faculty training etc with grant funds

SUPPLEMENTING

  • Using grants funds to increase the furnishing for the computer lab
  • Use grant funds to increase the number of faculty being trained and the amount of travel to professional workshops
in short
IN SHORT…….
  • ANY COSTS PREVIOUSLY PAID BY THE INSTITUTION OR OTHER FUNDING SOURCES SHOULD NOT BE REPLACED WITH GRANT FUNDS
slide17

Strategies for Remaining

Compliant with Title III Funds

building and strengthening the title iii community through engagement principles
Building and Strengthening the Title III Community through Engagement Principles

Communicate a compelling message.

Build a guiding coalition.

3. Create principled-based versus compliance-based guidelines for decisions and behaviors.

Gravenkemper, S. (2007) Building Community in Organizations. Counseling Psychology Journal: Practice and Research.

4. Identify early engagement indicators.

5. Generate continuous opportunities for dialogue at al levels.

6. Plan assimilation strategies for new members and new leaders.

principle based versus compliance based guidelines for decisions and behaviors
Principle-Based versus Compliance Based Guidelines for Decisions and Behaviors

Compliance-Based Guidelines

Enforces Federal Regulations

Enforces State policies and procedures

Increases the “red tape” and decreases effective communication.

Principle-Based Guidelines

  • Promotes dialogue among campus community
  • Increases engagement/

collaboration

  • Promotes a sense of community
taking charge a plan for remaining compliant
Taking Charge: A Plan for Remaining Compliant

Survey Title III Community (Transparency)

Provide expectations and roles/responsibilities for those working with Title III (Accountability)

Build Trust through staff forums, activity directors information session and Start-Up meetings (Accountability).

  • Provide opportunities for growth through internal workshops (Accountability).
  • “Show and tell” budget progress/spending levels (Transparency).
  • Design new activity director support program (Accountability).

20

manage risk appropriately
Manage Risk Appropriately
  • Establish and enforce Internal Controls
  • Develop effective budget management practices
  • Maintain “healthy” working relationships with the fiscal office and internal auditor
  • Determine how to profit from uncertainty while limiting your risk
know what you re really going after
....Know What You’re Really Going After
  • Be Visionary
  • Reveal the “bottom line” for Title III at your institution.
        • Determine the ultimate goal for Title III at your institituion.
  • Leverage Title III Resources
        • Strengthen through entreprenureial iniaitives
title iii part b contacts
TITLE III, PART B CONTACTS

Dr. James E. Laws, Director

Institutional Development and Undergraduate Education Service

James.laws@ed.gov

Ms. Karen Johnson, Team Leader

HBCU/HBGI; MSEIP; PBI; CCRA

Karen.Johnson@ed.gov

1990 K St., NW

6th Floor

Washington, DC 20006

202/502-7777

IDUES WEBSITE: http://www.ed.gov/about/offices/list/ope/idues/index.html