Federal Grants Management: Navigating the Super Circular

1. Federal Programs Directors’ Workshop March 13, 2014 WVDE Office of Federal Programs Federal Grant Management

2. LOOKING TO THE HORIZON

3. OMB Super Circular • Combines multiple Federal regulations that currently govern the way grants are administered into a single, comprehensive and streamlined uniform policy guide

4. Objectives • To strengthen accountability for Federal dollars by improving policies that protect against waste, fraud, and abuse. • To increase the impact and accessibility of programs by minimizing time spent complying with unnecessarily burdensome administrative requirement and focus on program objectives.

5. How Does This Impact Us? • The Super Circular consolidates eight OMB Circulars. Those having a direct impact on SEAs and LEAs are: • Circular A-102 Administrative Regulations • Circular A-87 Cost Principles • Circular A-133 Audit Requirements • The Circular did not entirely change the eight regulations but there are notable differences.

6. Important Changes • Cost Principles • Time and Effort • Audit Rules • Pass-Through Entities

7. Cost Principles • Can extend indirect cost rates for up to four years • Allows an flat indirect cost of rate 10% • Requires pass-through entities to either negotiate an indirect cost rate or provide the minimum flat rate

8. Time and Effort • Now called “Documentation of Personnel Expenses” • Documentation is still dependent on the number of costs objectives worked on • Eliminates the reference to PARs (now “Certified Reports”) • Reports may be electronic • Certification periods cannot exceed 12 months

9. Audit Rules • Increases the single audit threshold from $500,000 in Federal expenditures to $750,000 • This will reduce costs by reducing the number of single audits • Changes the determination of which programs to include in the single audit • This may impact how many programs are selected for audit

10. Audit Rules • The number of compliance areas required to be audited has been reduced • Should reduce audit time and cost • Shifts the burden from auditor to pass-through entity

11. Pass-through Entities SEA’s Responsibility: • Sub-recipient risk assessments/monitoring • Must give sub-recipients the option of either a negotiated or flat 10% indirect cost rate

12. Sub-recipient Monitoring • Risk Based Assessment Focused on: • Results of previous audits • Personnel Turnover • Financial Stability • History of Program Performance

13. Our Monitoring Requirements: • Analyze financial and program data • Ensure timely and appropriate corrective action is taken regarding any single audit program findings or prior monitoring findings

14. What Now? • The Super Circular is effective Dec. 26, 2013 at the Federal level • Federal Agencies have one year to implement their policies and procedures • Existing Federal awards will continue to be governed by the old circulars • Administrative requirements and cost principles will apply to new awards and additional funding made after Dec. 26, 2014

15. Resources • The Super Circular in its entirety can be found at: • http://www.gpo.gov/fdsys/pkg/FR-2013-12-26/pdf/2013-30465.pdf • Consolidated Monitoring Information • http://wvde.state.wv.us/federal-programs/esea/monitoring-procedures.html