Year 5 Coordinator's Financial Guide: From Reporting to Compliance

1. GEAR UP Year 5Coordinator/Assistant Meeting FISCAL UPDATE: Year 5 Financial Reporting & Cost Share

2. OUTLINE Background: Who Does What? Great News About Years 1, 2, 3 and 4 Still True & Important In Year 5 Year 5 Points of Emphasis Next Steps For New Coordinators / Assistants

3. BACKGROUND: WHO DOES WHAT? ► NAU is the Fiscal Agent for Arizona GEAR UP • Primary responsibility for fiscal reporting to USDOE • Assist with compliance (of all partners) with federal cost principles • Ensure match obligation is satisfied • Store all records to ensure audit readiness up to 5 years after project ends ► Arizona GEAR UP School Partners (Statewide) • Formal agreement with NAU • Superintendent designates “fiscal liaison” • Fiscal liaison prepares/submits monthly financial packets (federal funds and match) ► GEAR UP Coordinators and Assistants • Follow district policies and procedures when purchasing items • Assist fiscal liaisons with monthly financial reporting and documentation of cost share

4. BACKGROUND: WHO DOES WHAT? ► School Partners are reimbursed after expenditures (bothfederal and match) are reported accordingto Agreement guidelines& approved for payment ► Reported federal and match expenditures are governedby federal cost principles (now called Uniform Guidance), and subject to audit review, and thus financial reporting and documentation standards on accuracy, thoroughness, and timeliness are very high

5. GREAT NEWS ABOUT YRS 1-4

6. STILL TRUE AND IMPORTANT IN YR 5 ► The Allowability Test Is the expense: • Necessary to implement the program? • Allocable to program objectives? • Compliant with administrative regulations? • Consistently treated?

7. STILL TRUE AND IMPORTANT IN YR 5 ► The Allowability Test (continued) Is the expense: • In the work plan and budget? • Compliant with district procedures? • Justifiable to taxpayers?

8. STILL TRUE AND IMPORTANT IN YR 5 ► Monthly Financial Packets • Include both GEAR UP (Reimbursement) & Match • Require supporting documentation, including: • Time & Effort Forms • Cost Share Contribution Forms

9. STILL TRUE AND IMPORTANT IN YR 5 ► Working With Your Fiscal Office • Familiarize yourself with your Year 5 work plan and budget • Follow district fiscal operations procedures • Continue assisting with financial packets • Continue submitting T&E forms (for yourself and others) • Continue capturing & documenting match

10. YR 5 POINTS OF EMPHASIS ► Scrutiny on Event-Related Costs (especially food) “…there is a very high burden of proof to show that paying for food and beverages with Federal funds is necessary to meet the goals and objectives of a Federal grant…there may be some circumstances where the cost would be permissible…” From “Using Federal Grant Funds to Host A Meeting or Conference” [May 2013]http://www2.ed.gov/policy/fund/guid/eposbul/gposbul.html

11. YR 5 POINTS OF EMPHASIS ► Scrutiny on Event-Related Costs (especially food)(continued) Before incurring any event-related costs, GEAR UP Coordinators must have submitted an Event Notification Form (two weeks in advance)

12. YR 5 POINTS OF EMPHASIS ► Workplan and Budget Changes From Arizona GEAR UP Year 5 Guidelines and Instructions, page 5: If applicable, GEAR UP Partners shall submit written requests to modify workplans and budgets to their designated GEAR UP Site Support Specialist. These written workplan and budget modification requests must include a clear explanation and justification of the reason(s) why original workplan activities are not feasible and include proposed change(s) to the budget. Such requests must be made at the time a change to the workplan / budget is apparent. Written requests for the workplan / budget modifications relative to the fourth quarter of the performance period (April 1, 2017 – June 30, 2017) must be received by NAU GEAR UP on or before April 30, 2017. NAU GEAR UP will review and approve / disapprove budget modification requests accordingly, and initiate any administrative actions necessary to formalize such approval.

13. YR 5 POINTS OF EMPHASIS ► Our Best Sources of Match Are: • Facilities => value of space allocated to house Coordinators and Assistants • School Personnel => value of time spent on GEAR UP tasks contributed by key people in your District (besides teachers) • Value of volunteer time contributed at major events => when in doubt, use $22.83 per hour per www.independentsector.org, individually certified

14. NEXT STEPS FOR NEW GU STAFF • Introduce yourself to your district’s GEAR UP fiscal liaison, offer your assistance with fiscal operations (but understand that completing monthly financial packets is not your job) • Familiarize yourself with your work plan and budget, as well as your organization’s purchasing policies procedures • Establish systems for completing /submitting Time & Effort forms monthly (both your own and others) • Begin capturing and documenting match (frequently / intentionally)

15. QUESTIONS?

16. BONUS CONTENT: SPECIAL TOPICS Teacher Time Volunteers Discounts Facilities Pro-Rating Travel

17. SPECIAL TOPIC: TEACHER TIME • Generally, teacher salaries and benefits cannot count as match because they are not directly related to the GEAR UP grant • If, however, teachers are being paid by the school district or are volunteering their time to conduct activities outside their normal duties that are specifically related to the GEAR UP grant, the portion of their salary and benefits related to those activities may count as match • Teacher match must be work that: (1) is during unpaid school hours, and (2) is in addition to expected paid tasks

18. SPECIAL TOPIC: VOLUNTEERS • Professional services provided to GEAR UP at no cost can be valued at that professional’s rate of pay and benefits; EX: attorney speaking at a career fair • Options when individuals do unpaid work for GEAR UP outside of their profession: ● Value it at what is normally paid for that work by your organization, or the value of that type of work in the local area ● Use the value of volunteer time for Arizona (currently $22.83 per hr) per www.independentsector.org/volunteer_time ● EX: attorney speaking at a career fair www.independentsector.org/volunteer_time

19. SPECIAL TOPIC: DISCOUNTS • Discounts and/or waived fees can count as match, with proper attention to detail • Must be properly documented: ask vendors, in their quotes and/or invoices, to specify the exact amount of the discount they are providing, and indicate that it is specifically for GEAR UP • If the valuation is not that clear from vendor documentation, supplement it with a cost share contribution form

20. SPECIAL TOPIC: FACILITIES • Facility use (and donated space) on either an ongoing or single- event basis may be reported as cost share if the space used by GEAR UP would otherwise be made available to outside entities for rent or lease based on a pre- determined rate • The value associated with use of space must be arrived at using that documented rate • Must be properly documented – use a “Cost Share Contribution Form”

21. SPECIAL TOPIC: PRO-RATING • The “allocable” test: GEAR UP costs / cost share must be incurred to support / advance the work of GEAR UP (i.e. a work plan task) • If the benefits of a good or service extend beyond the GEAR UP cohort, pro-rate the associated costs / costshare (apply it in proportion to relative benefits, approximated through reasonable methods) • The “room on the bus” caveat: it is not necessary to pro-rate if the primary reason a good or service is procured is to satisfy a GEAR UP objective, and the benefits spill over to others

22. SPECIAL TOPIC: TRAVEL • When traveling, follow your district’s policies and procedures; typical travel costs include:● Registration (register early!) ● Air Fare (coach class ticket, lowest possible fare) ● Hotel (approved conference rate) ● Meals & Incidental Expenses (meals during travel status not provided by conference host) ● Other (mileage, airport parking/shuttles, etc.) • Travel costs not in the approved work plan and budget will not be reimbursed; they may be contributed as cost share if specifically approved, in writing and in advance, by the Arizona GEAR UP Executive Director