21 st Century Community Learning Centers Program Reimbursements 101

1. 21st Century Community Learning Centers ProgramReimbursements 101 Andre’ Hill Budget Analyst 2 August 8, 2012

2. Why reimbursement? • Subgrantees are paid for program expenses on a reimbursement basis only • Georgia is the grantee, and program providers are considered subgrantees (similar to a sub-contractor) • Evidence of expenditure, purchase, or payment must be presented to receive reimbursement • 21st CCLC program funds must be used to supplement and not supplant (take the place) of other Federal, State, local, or non-Federal funds

3. Cost Principles: Basic Guidelines All Costs Must Be: Necessary Reasonable Allocable Legal under State and Local Law

4. Basic Guidelines (cont.) • Necessary and Reasonable • Must be necessary for the performance or administration of the grant • Must follow sound business practices: • Arms length bargaining (hint: competitive procurement processes) • Follow federal, state and local laws • Follow terms of the grant award • Fair market prices • Act with prudence under the circumstances • No significant deviation from established prices

5. Basic Guidelines (cont.) • Allocable • Can only charge in proportion to the value received by the program • Example: Organization purchases a computer to use 50% in the Title IV program and 50% in a state program – can only charge half the cost to Title IV • Legal Under State and Local Law • If an expense cannot be paid under state and local laws, it cannot paid with Federal funds

6. OMB Circular A-87 Attachment B– Selected Items of Costs 43 specific costs detailed Listed in alphabetical order

7. General Allowable Expenses • Salaries for 21st CCLC Project Director, Program Manager, and Site Coordinators (reasonable and in line with industry standard) • Tutors and paraprofessionals • Contractors • Independent evaluation • Supplies and materials required for the 21st CCLC program • Computer hardware and software required for the 21st CCLC program • Travel to required 21st CCLC trainings, conferences and workshops • Transporting students home following 21st CCLC activities • Cell phones Justification must be provided. Must be in accordance with organization policies

8. General Allowable Expenses (cont.) • Criminal Background Checks • Checks must be completed against a reputable criminal background check database on all 21st CCLC staff, teachers, contractors, sub-contractors, evaluators, etc. involved in the program, whether or not they are in direct contact with students, prior to start date • Annual (365 days) criminal background checks are required • Annual national background checks conducted by school systems are acceptable, and made available in resource folders • Fitness Determination Letter – official letter issued by school system stating the fitness of employee

9. General Allowable Expenses (cont.) • Criminal Background Check (cont.) • Prudent judgment must be used when hiring individuals; policies must be in place, and followed • It is the sub-grantee’s responsibility to ensure that all potential business partners are qualified to work in the program by also checking the company and individuals against EPLS (https://www.epls.gov/) and the debarment guidelines listed in EDGAR 34 CFR part 74 subpart C and part 85 subparts C and H Failure to comply may result in immediate forfeiture of funding

10. General Allowable Expenses (cont.) • Rent and Utilities • Allocable portion only (ensure supplanting does not take place) • For rent: agreement needed and must be reasonable and within industry standards • Light Snack (nutritional) • For parent involvement activities only • Cost must be reasonable (current GaDOE cap is $3.50 per person)

11. General Allowable Expenses (cont.) • T-ShirtsOnce a year, for field trip security/safety reasons only. 21st CCLC logo must be affixed. • Travel • Meetings and conferences - the primary purpose of which is the dissemination of technical information (agendas are required). Includes lodging, travel, meals associated with the meeting or conference. Must consult with GaDOE for approval and generally maximum of three program personnel per conference. • Regular travel costs (ex.: mileage costs for Program Director) • Tablet-type Computer Tools (e.g., iPad, iPod Touch with educational software) or Video Systems (e.g., Xbox, PS2, Wii) • May be allowable based on proper planning/implementation. Prior consultation and approval required from GaDOE

12. General Allowable Expenses (cont.) • Educational Field Trips Must have the ability to impact/improve students’ grades, CRCT scores, and/or bring awareness to college and careers. Lesson plans, sample student surveys, and sample student essays are required. Consult with your ERES/Budget Analyst prior to expense. Examples: Georgia Aquarium – Science; GSU – college awareness; CNN – career awareness • Advertising Only for the recruitment of personnel required for the performance of a Federal award and the procurement of goods and services

13. Unallowable Expenses OMB Circular A-87, Attachment B, #14 • Entertainment - Costs of entertainment, including amusement, diversion, and social activities and any costs directly associated with such costs (such as tickets to shows or sports events, meals, lodging, rentals, transportation, and gratuities) are unallowable

14. Unallowable Expenses (cont.) • Non-educational field trips Examples: skating, bowling, sporting events, amusement parks, etc. • Field trips during regular school day hours • Field trips out-of-state Exceptions may be given if 21st CCLC site is just outside destination state line • Payments of stipends to students or family members to participate

15. Unallowable Expenses (cont.) • The construction of new buildings or the renovation/remodeling of existing structures • Fundraising activities of any kind • Payment to students for receiving tutoring or mentoring services • Purchase of buildings • Purchase of vehicles • Personal Digital Assistants (PDAs), Data Plans • Incentives or anything that can be perceived as gifts Gifts in kind, gift cards, iPods, field trips, games, etc. • Funds to invest in the stock market, savings or bank accounts

16. Unallowable Expenses (cont.) • Food/Snacks Partnership with feeder schools is encouraged. USDA approved snacks can be supplied through your feeder schools. Schools will be reimbursed by the USDA for snacks served to your program. Partnerships with corporate food providers may also help you provide nutritious snacks. • Tips • Alcohol • Parties Including “blow-up” games and rides • Taxes (LEA)

17. Unallowable Expenses (cont.) • Advertising Advertisement of the program in advertising media: magazines, newspapers, radio and television, direct mail, exhibits, electronic or computer transmittals, and the like • Expenses incurred prior to grant approval Approval must be received from US ED

18. Verification Process Entered Data Monitoring Findings Approval

19. Verification Process (cont.) • Data All data must be entered into CAYEN Afteschool21 Data Management System Objectives, Registration, Attendance (12 hours minimum weekly contact time), Grades, State Assessment, and Certification

20. Data Verification

21. Verification Process (cont.) • Monitoring • Must be in compliance with all stat and federal statutory requirements and guidance • All findings received during the monitoring process must be corrected prior to continuing reimbursements

22. Monitoring Verification

23. The Package

24. The Reimbursement Process The AAA Effect Accurate Acceptable Approvable

25. Documentation for reimbursement requests Important: The difference between documentation for your records vs. documentation for reimbursement requests (in GAORS) Track expenses (and balances) by sub-grant in GAORS and also through your accounting system Three months’ working capital is needed to operate this program Link to GAORS login: https://portal.doe.k12.ga.us/login.aspx • Explanation of ‘Check Requests’

26. 21st CCLC FY13 Required Supporting Documents for Reimbursement Request Processing a) Salary and benefits LEAs 1.Payroll system generated report (one or more of: earnings register detail, benefits distribution report, payroll summary) Non-LEAs 1. Payroll system generated report or spreadsheet (if payroll system generated report is unavailable); ADP register; cancelled checks LEAs and Non-LEAs (Optional - if required by GaDOE) 1. Time and effort documentation (e.g. semi-annual certificates, Personnel Activity Reports (PARs), time-sheets, salary distribution records) 2. Proof of salary transfer/payment b) Contractors 1. Detailed invoice with deliverables 2. Program Director’s signed approval to pay on the invoice 3. Proof of payment c) Field Trips 1. Flyer (or copy of webpage) from location visited that indicates purpose of visit 2. Invoice 3. Program Director’s signed approval to pay on the invoice 4. Proof of payment

27. 21st CCLC FY13 Required Supporting Documents for Reimbursement Request Processing d) Transportation 1. Invoice from Transportation Department/Transportation service provider 2. Program Director’s signed approval to pay on the invoice 3. Proof of payment 4. Mileage log (Optional – if required by GaDOE) e) Professional Development 1. Workshop/conference Agenda 2. Travel Expense Statement (and receipts of travel expenses, if applicable) 3. Purchase order 4. Detailed invoice with deliverables 5. Program Director’s signed approval to pay on the invoice 6. Proof of payment f) National Criminal Background Check (NCBC) 1. Purchase Order (PO) 2. Invoice 3. List of persons covered by the NCBC (preferably on both PO and Invoice) 4. Program Director’s signed approval to pay on the invoice 5. Proof of payment

28. 21st CCLC FY13 Required Supporting Documents for Reimbursement Request Processing • g) Fidelity Bond and General Liability Insurance (Non-LEAs only) • 1. Invoice • 2. Program Director’s signed approval to pay on the invoice • 3. Proof of payment • h) Telephone  • 1. Phone bill reflecting 21st CCLC charges (and basis of proration, if applicable) • 2. Program Director’s signed approval to pay on the invoice/bill • 3. Proof of payment • j) Utilities • 1. Utility bill • 2. Program Director’s signed approval to pay on the invoice/bill • 3. Proof of payment • i) Indirect Cost • 1. General ledger/expense statement that serves as the basis of the indirect cost • Journal Entry/General Ledger that demonstrates that the indirect cost has been charged to • the 21st CCLC subledger

29. 21st CCLC FY13 Required Supporting Documents for Reimbursement Request Processing j) General Expenses (such as purchase of goods, and other expense categories not mentioned above) 1. Purchase order 2. Invoice 3. Program Director’s signed approval to pay on the invoice 4. Proof of payment Notes: Acceptable proof of payment (subgrantee’s choice of any one of the following. GaDOE may require more than one and/or additional documents from within this list) 1. Detailed general ledger/(21st CCLC sub ledger) reports (that includes date and check numbers) 2. Cancelled checks, if required by GaDOE 3. Bank statements 4. Receipts with credit/debit card verification To facilitate reimbursement request processing, GaDOE may require additional documents not listed in this document

30. Components of the Request (cont.) Notes: • NO social security numbers • On time sheets: clear and accurate calculation of date-wise (and total) hours worked • Calculations should be easily traced (adding machine tape, for example) • All contractors should be verified through the Secretary of State’s office

31. Preparing Invoice/reimbursement request • Portal Log-in • Select “Prepare Invoices” (whether a new request or resubmission) • Select Fiscal Year, Grant • Select month in “Request Funds for Period:” • Click “Add” button to create the new request • Fill in Invoice Entry information; click “Add” button • The entry is added to the Invoice List • Input the original (sub) grant award year in the ‘Year’ column

32. Preparing Invoice - Attachments • From the list of Invoice Entries, click on the Attachment Icon (piece of paper with red border) • EVERY Invoice entry MUST have at least one attachment • Click “Browse” button to locate the document to be attached • Select the document to be attached from your folders, click “Open” • Click on “Upload” button • Repeat process until all Invoice Entries have an attachment and full documentation to ensure timely processing of the Invoice • When complete and ready to submit, click “Send to Submitter”

33. Submitting an Invoice for Review • Subgrantee approver searches GAORS for invoice in status of “Ready for Submission by Submitter” • Select the Invoice Period to be submitted by clicking on the attachment icon (piece of paper icon) • After reviewing documentation and invoice, select the “Revise” button to send back to Preparer. • If documentation is approved to submit to GaDOE for reimbursement, select the “Submit” button. • Invoice reimbursement goes into status “Ready for Review by Program Manager.”

34. Invoice Status • “New Payment Request” – newly created invoice OR an invoice which was previously submitted but rejected by either the submitter or the Program Manager at GaDOE. • “Ready for Submission by Submitter” – Preparer is finished, awaiting approval by local submitter. • “Ready for Review by Program Manager” – Preparer is finished, submitter approved, awaiting review by GaDOE Budget Analyst (30-days to review). • “Ready for Grants Accounting Review” – Invoice was approved by the Budget Analyst, and is awaiting processing by Grants Accounting. • “Approved” – Invoice has been processed for payment by Grants Accounting; monies will arrive typically in 7 days • Note: There are 15 reimbursement request ‘slots’ in each FY in GAORS

35. Reimbursement Checklist • Were services rendered/goods received in FY13? • Exclude pre-award expenses (expense incurred prior to July 1, 2012) • Expense – budgeted? Aligned with program objectives? (If unbudgeted, but material – consult with GaDOE, even if budget amendment is not required) • Invoice - sufficiently detailed? • Service completed? In accordance with contract? • Describes service/goods in detail? Rate per hour? • Date-wise number of hours by site? • Is attendance data in Cayen up-to-date? Facilitate easy cross check with GAORS (activity/session name)? • If invoice contains both 21st CCLC and non-21st CCLC items, label/circle 21st CCLC items • Program Director’s signature of approval (check request)? • Description on Purchase Order indicates purpose of the purchase? • 21st CCLC/non-21st CCLC expenses have been prorated accurately and supported by documentation/calculations?

36. Reimbursement Checklist – Cont’d • Remember to update inventory list when purchasing inventory items and affix inventory tag on the item (see Resources folder for sample inventory list, tag) • Upload only Adobe Acrobat (PDF) files • Maintain documents of record (e.g. POs, contracts, lessons plans, hiring agreements, competitive quotes) even if not required for GAORS • Expenses that should not be charged if you are already charging Indirect Cost • Seek reimbursement for mileage (not fuel) • Do not implement multi-year contracts (that span multiple FYs) • Remember to disburse checks to vendors/suppliers right away. Follow-up with bank statement reconciliations • Field trip timing should not be in conflict with regular school hours

37. Reimbursement Checklist – Cont’d • GAORS: • Use unique invoice numbers • Use ‘Year’, ‘School Name’ and ‘Invoice No.’ suffix coding scheme to delineate multiple grants (Note: use your accounting system/Excel worksheet to track expenses and balances by grant) • Using the FY13 Chart of Accounts? (Copy of Chart of Accounts is Located on the CD)

38. Reimbursement Checklist – Cont’d • If using ‘standard’/projected/budgeted rates – remember to carry out analysis and adjustments on a quarterly basis • Refreshments: • Light and nutritional • For parent involvement activities only • Not allowed for professional development events • Current GaDOE cap: $3.50 per person/event • Prior approval required from GaDOE for program to charge fees • When nearing end of FY, check for ‘missing’ invoices from vendors

39. Reimbursement Checklist – Cont’d • Time and Effort • Time sheet hour calculations – accurate? Rounding up – as per your policy? • Employee and supervisor signatures on all time sheets? • Corrections on time sheets (and any document for that matter) being counter signed? • Payment to Program Director – authorized by someone of higher/appropriate authority? • Personnel Activity Reports (PARs) or Semi-Annual Certifications? • If someone has multiple cost objectives: PARs • If someone has single cost objectives: Semi-Annual Certification (Exception: time sheet already includes all essential elements of a Semi-Annual Certification. If in doubt, use Semi-Annual Certification) • Semi-Annual Certification must be signed after-the-fact • Use clear terms such as hours/minutes instead of non-standard terms such as ‘sessions’

40. FREQUENT REASONS FOR REJECTIONS IN GAORS • Essential supporting documents missing (e.g., invoice, proof of payment) • Tips/gratuities, gift cards, door prizes • Trip to amusement park/field trip not aligned with program objectives • Refreshment expense that does not meet criteria • Un-allocable expense (e.g., maintenance expense for an automobile used for 21st and non-21st CCLC, but expense proration basis is not clear/undocumented) • Installation of PABX telephone system/new landline telephone line, permanent fixtures (e.g. whiteboards), improvement-type ‘repairs’ • Program Director’s signature of approval (check request) missing • Prepaid expenses –advances and deposits (e.g., hotel , registration fees) • Background check carried out without Purchase Order (or equivalent authorization from Program Director)

41. Communication • GAORS Helpdesk • Automated notification email with brief description 1958 Twin Towers East205 Jesse Hill Jr. Drive SEAtlanta, GA 30334 (404) 651-9503 (800) 869-1011 (GA) (404) 651-5006dticket@doe.k12.ga.us • Budget Analysts • Email with concerns listed • Telephone call for clarification • Technical assistance

42. Timeline • Reimbursements must be submitted on a monthly basis • Must be submitted by the 15th calendar day of each month • If multiple requests are submitted, only the current month’s will be processed. The other request(s) will be considered late and processed only after reimbursement requests from all subgrantees for the current month have been processed • Assurances ensure consequences for continued late submissions; potential to be placed in High-Risk status • 21st CCLC has 30 days to review each submission • Credit to bank account via direct deposit on Thursdays • End of State fiscal year processing downtime (June 30th to mid-July) • Unforeseen circumstances – TBD

43. Sample Packets Grantee Participation Review of Form, Resources, & Sample Folders

44. Resources Cost Principles • OMB Circular A-21 Educational Institutions http://www.whitehouse.gov/omb/assets/omb/circulars/a021/a21_2004.pdf • OMB Circular A-87 State, Local, and Indian Tribal Governments http://www.whitehouse.gov/omb/circulars_a087_2004/ • OMB Circular A-122 Non-Profit Organizations http://www.whitehouse.gov/omb/assets/omb/circulars/a122/a122_2004.pdf

45. Questions?