Grant Management and Compliance

1. Grant Management and Compliance Claire D. Cornell, Program Officer, FIPSE Office of Postsecondary Education U.S. Department of Education

2. Simplify Grants Management 1. The approved/negotiated proposal is your plan. 2. The approved grant budget is your spending plan. 3. The project specifies goals and measurable outcomes. 4. You have many, many, many rules, regulations, statutes that govern your grant. 5. Make this manageable.

3. How? • Don’t manage the grant by yourself. • Form a grant management team. • Include a grants manager, a financial manager, and/or someone from your sponsored programs office. • Meet regularly with your team. • Make certain that one of you reads all of the attachments to the Grant Award Notification (GAN).

4. Your Team • The Project Director • A staff member who understands EDGAR, OMB circulars, federal rules and regulations and who will read all of the GAN Attachments. • A financial manager—who will track all of your expenditures. • The person who has “drawdown” authority.

5. What to do when you meet. • Outline the basic project outcomes for each year. • Establish a communication stream among your team members. • The PD learns about spending and drawdown rules. Basically—drawdown as you spend—at least quarterly. Don’t draw until you spend; don’t wait too long to draw. • The financial management person must be knowledgeable about drawdowns and outcomes. • The drawdown person must be knowledgeable about Department’s rules.

6. Comprehensive or B Grants • You are in your third (if you are a 2010 B grant) or your second (if you are a 2009 B grant) year of funding. • You are recording: • Learning outcomes • Projected results—curriculum, programming, student services • Tally the number of “targeted learners”

7. Your financial records reflect: • Expenditures for FY Year 1 and FY Year 2 • Any deviations from your original approved spending plan (budget). • That you have reviewed the correct OMB Circular –either A-21 or A-122 - to make certain that all of your costs are allowable.

8. You should be spending according to plan. • In the Department’s eyes, drawing down—means spending and spending means drawing down. • Your drawdowns should match your internal records. • At the end of your FY, you should have drawn down what you expended on project efforts. • This includes salaries, supplies, travel, etc.

9. Questions or Changes?? If your plan changes, and/or your spending plans change, contact your FIPSE Program Officer. • E-mail us. • Call us. • Find your FIPSE Program Officer’s contact information: http://www2.ed.gov/about/offices/list/ope/fipse/staff.html

10. W Grants are Special Focus Grants • If you have a grant that begins with the letter W, you were funded under the: • “Innovative Strategies in Community College for Working Adults and Displaced Workers” Invitational Priority. • You are in your third year of funding. • Your grant is a “high profile,” politically interesting project.

11. You are recording: • Learning outcomes • Projected results—curriculum, programming, student services • Tally the number of “targeted learners” • MOST CRITICALLY: • You should be tabulating the number of jobs that your target students have secured and/or are pursuing.

12. Comprehensive Grants and Special Focus Grants • You must report results • Quantifiable results • Results that allow FIPSE to pass your information to others in the Department and in the Higher Education Community • Results that justify your funding—or that are instructive to others. • They should highlight effective or ineffective strategies.

13. Timeframe • Follow the timeline from your grant application. • Keep on track. • Or, if you revise it; request approval from your Program Officer.

14. Record Time and Money:Time = Your Efforts • Personnel Records • Develop and Keep time and effort records for all project personnel. • Use your institution’s accepted format or create a unique tracking document.

15. SAMPLE Time and Effort Record This is not something that you need for FIPSE. Do not submit this document to FIPSE. This will help you to be ready in the event of an audit. It’s for your internal use—this documents personnel assignments and it will be useful, if your staff members work on multiple grants or have institutional responsibilities in addition to their FIPSE duties.)

16. Personnel Record Time Period: October 1, 2009 – December 31, 2009 NameProject NameRoleProject Number%Time/Hours or Assignment J. Smith Project Z, FIPSE PD P116B090863 20% @ 2080 hours/year Q Lab X College Mgr Institution 60%   NSF Project A PI NSF 091234 20% Y. Jones Project Z FIPSE Webmaster P116B090863 100% @ 2080 hours/year

17. Record federal $ expenditures and record cost- share $ (recorded on the 524 B Budget form). Track and document all outlay of Federal and non-federal funds.I prefer to use those forms for financial reports—but, this is not required.

18. Review the SF 524 forms Submitted with Your ApplicationHow did you plan to spend grant funds??

20. Need help? Use the Department’s resources. • Use Department of Education resources that distinguish allowable activities and allowable costs • Primary resource for all grantees: • Education Department General Administrative Regulations (EDGAR) • http://www2.ed.gov/policy/fund/reg/edgarReg/edgar.html

21. Resources for Non-profit Corporations and State Government Agencies • OMB Circular A-133 http://www.whitehouse.gov/omb/rewrite/circulars/a133/a133.html

22. Resources for Institutions of Higher Education • OMB Circular A-21 http://www.whitehouse.gov/omb/rewrite/circulars/a021/a21_2004.html

23. Changes???? Contact Your FIPSE Program Officer. • If you make changes in personnel, activities, project objectives, or if you make other substantive changes—e-mail your Program Officer. Get permission to make a change. • Get permission in writing. • If you change key personnel, the project director, your institution’s certifying official—notify FIPSE—provide all new contact information.

24. Changes in your budget?? • If your change does not exceed 10% of your total budget, you need not secure approval. However, you should e-mail a notification and explanation to your Program Officer. • If your proposed change does exceed 10% of your total budget, you must secure approval—in writing—contact your Program Officer.

25. 4. Compliance • Review EDGAR—familiarize yourself with EDGAR. • Follow the rules and regulations presented in the FIPSE Program Guidelines (e.g., budget for the annual Project Directors’ Meeting). • Consult with the appropriate OMB Circular. • If you have doubts or concerns about the appropriateness of a project effort or expenditure, contact your FIPSE Program Officer. • Keep accurate records. • Don’t be afraid to tell us that your project isn’t working as you’d planned—you learn; we learn.

26. Questions??

27. We’ve Finished!