OregonServes - Fiscal Grants Management
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1)
Regulations & Requirements (Terms &Conditions/ OMB Super Circular)
2)
Financial Management Principles
3)
Policies & Procedures
4)
Internal Controls
5)
Administrative Costs
6)
Documenting Expenses
7)
Match
8)
Reporting & Budgeting (Amendments)
9)
Site Visits
10)
Grant Closeout
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Distinguish
grant verses non-grant related expenses
Identify cost by
program year & budget category
Differentiate between
direct and indirect costs
Account for each
award/grant separately
Record
in-kind
contribution as both revenue & expense
Provide management with
financial reports
at both the summary or detailed levels
that will
compare outlay with budget
amounts
Correlate financial reports submitted to CNCS
directly to accounting information
and supporting documents
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It is required by federal regulations and your contract with the state.
Supports a value, cost, or performance criteria relative to the grant
To track incoming information
To validate information provided by staff, members and/or donors
To provide evidence of accomplishments
To assist during the monitoring activities, audits, or site visits
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By grant
By program year
By type of document
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Internal to the organization
External sources
Should reflect appropriate review, approval, sign-off
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“Financial management systems
must be capable of
distinguishing expenditures
attributable
to this grant from
expenditures not attributable to this grant. The systems must
be able to identify costs by
programmatic year
and by
budget
category
and to differentiate between
direct
and
indirect costs
or administrative costs.”
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Cash and in-kind contributions are accepted as part of the grantee’s cost sharing or
matching when contributions meet all of the following criteria:
Are
verifiable
from the grantee’s records and properly documented
Are
necessary and reasonable
for proper and efficient accomplishment of project
or program objectives
Are
allowable
under the applicable OMB cost principles
Are
not
paid by the Federal Government under another award, except where
authorized by the Federal statute to be used for cost sharing or matching
Are provided for in the
approved budget
(allowable under program guidelines)
Conform to other
grant provisions or OMB Circulars
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CNCS policy allows AmeriCorps State and National grantees to use
electronic timekeeping systems as the system of record when three
conditions are met:
1)
A written policy is in effect establishing the use of electronic
timekeeping system as your system of record; and,
2)
A secure, verifiable electronic signature system (a) identifies and
authenticates a particular person as the source of the electronic
signature; and (b) indicates such person’s approval of the information
contained in the electronic message.
3)
Once appropriate electronic signatures have been applied, no changes
may be made unless there is a clear, auditable record of the revision.
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Reimbursement is made based on actual expenses
Reimbursements may
not
be for estimated, unauthorized, or
unallowable expenses
Invoices must be for approved and budgeted expenditures that
programs have already incurred
No advances allowed
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1.
Member hours
2.
Expense Workbooks
3.
Federal Financial Reports
4.
Program Reports (performance-based)
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Invoices are due by the 21st of the month following
the invoice period
Effective immediately, all invoices are to be submitted
electronically via OnCorps reporting system
Invoices are submitted monthly
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Only complete and approved invoices are submitted for payment – we
send them back if there are errors
You can expect payment about 20 days after the day we receive an
error-free invoice
Proofread before submitting—small errors will delay payment
Common errors:
Selecting incorrect program year for the Budget Period
Don’t have enough match reported
Line Item Over Expended/Over Reporting of CNCS or Grantee Share
(
Red Numbers
in your Workbook = Something is Wrong)
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Budget changes of more than 10% of your total budget or to line items
previously allocated $0
must not
be implemented before OregonServes
approves the change (i.e. don’t purchase/pay for items that are not in an
approved budget at the time of purchase).
Adequate written justification must be provided with request—changes
need to be consistent with program design and activities.
Budget Modification Request Form must be completed in OnCorps.
Do not submit a major budget change at year-end. This indicates
inadequate monitoring of budget throughout the year. There is no
guarantee that a year-end change will be approved and you may not be
reimbursed for these expenses.
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Specific costs requiring approval under the cost principles, such as:
Overtime pay, rearrangement and alternation costs, and pre-award costs
Purchases of equipment over $5,000 using CNCS funds, unless specified in the
approved application and budget
Changes in the cumulative budget line items that amount to 10% or more of the total
budget, unless the CNCS share is $100,000 or less
The total budget includes both the CNCS and grantee shares
Grantees may transfer funds among approved direct costs categories when the cumulative
amount of such transfers do not exceed 10% of the total budget
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Plan may change as the program is implemented
Review budget monthly
Request budget amendments promptly
Do not wait until last month of year to request budget
modification
Budget is driven by program needs
F
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Prepare all financial reports with information from the organization’s
accounting system
Review and reconcile the information to ensure accuracy prior to report
submission
Submit all reports on time
Proofread before submitting
Submit by April 15
th
and October 15
th
Must be submitted via OnCorps
Required financial information includes:
Program Income
Submission of all invoices for reporting period
Reporting other federal grant sources
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1.
By e-mail, request an extension
2.
Provide reason why an extension is needed
3.
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Submit extension request to oregon.serves@hecc.oregon.gov
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System of internal controls should exist on timekeeping under Uniform
Grant Guidance
•
Timesheets cannot be based on budgeted amounts – actual work only
•
Suggestion 1 – periodically, conduct your own timesheet review audit
•
Suggestion 2 – provide mandatory training on how to accurately and
timely maintain timesheets
Organizations do not:
•
Separate accounting records for each Federal grant
•
Submit Federal Financial Reports (FFRs) on schedule
•
Make sure that the FFRs reconcile to internal accounting records
(general ledger)
•
Record match dollars in general leger, with same detail/documentation
as for grants expenditures
•
Contemporaneously and adequately document source of match
contributions
•
Substantiate market value of in-kind match contributions
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Learn about grant closeout regulations, financial management principles, administrative costs, and documentation basics for grant management. Understand how to differentiate between direct and indirect costs and provide financial reports to management.
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Presentation Transcript
OregonServes Fiscal Grants Management Madeline Seghers & Alma Plasencia AmeriCorps Oregon Program Officers
Grants Management Components 1) 2) 3) 4) 5) 6) 7) 8) 9) 10) Grant Closeout Regulations & Requirements (Terms &Conditions/ OMB Super Circular) Financial Management Principles Policies & Procedures Internal Controls Administrative Costs Documenting Expenses Match Reporting & Budgeting (Amendments) Site Visits
Administrative Accounting System Requirements Distinguish grant verses non-grant related expenses Identify cost by program year & budget category Differentiate between direct and indirect costs Account for each award/grant separately Record in-kind contribution as both revenue & expense Provide management with financial reports at both the summary or detailed levels that will compare outlay with budget amounts Correlate financial reports submitted to CNCS directly to accounting information and supporting documents
Documentation Basics Why Retain Documentation? It is required by federal regulations and your contract with the state. Supports a value, cost, or performance criteria relative to the grant To track incoming information To validate information provided by staff, members and/or donors To provide evidence of accomplishments To assist during the monitoring activities, audits, or site visits No documentation may mean no credit during a review.
Documentation Basics Keep Your Documents Organized (systematically) By grant By program year By type of document Physical information: Hard copy Soft copy: CD, flash drive, server, microfilm Source: Internal to the organization External sources Should reflect appropriate review, approval, sign-off Examples: Invoices, receipts, timesheets, contracts, in-kind contribution forms, checks deposited, travel claims
Fiscal Systems AmeriCorps Grant Provisions Financial management systems must be capable of distinguishing expenditures attributable to this grant from expenditures not attributable to this grant. The systems must be able to identify costs by programmatic year and by budget category and to differentiate between direct and indirect costs or administrative costs. Record in-kind contribution as both revenues and expenses
Acceptable Match is.. Cash and in-kind contributions are accepted as part of the grantee s cost sharing or matching when contributions meet all of the following criteria: Are verifiable from the grantee s records and properly documented Are necessary and reasonable for proper and efficient accomplishment of project or program objectives Are allowable under the applicable OMB cost principles Are not paid by the Federal Government under another award, except where authorized by the Federal statute to be used for cost sharing or matching Are provided for in the approved budget (allowable under program guidelines) Conform to other grant provisions or OMB Circulars
Personnel Electronic Timekeeping System Requirements CNCS policy allows AmeriCorps State and National grantees to use electronic timekeeping systems as the system of record when three conditions are met: 1) A written policy is in effect establishing the use of electronic timekeeping system as your system of record; and, 2) A secure, verifiable electronic signature system (a) identifies and authenticates a particular person as the source of the electronic signature; and (b) indicates such person s approval of the information contained in the electronic message. 3) Once appropriate electronic signatures have been applied, no changes may be made unless there is a clear, auditable record of the revision.
Invoices Reimbursement is made based on actual expenses Reimbursements may not be for estimated, unauthorized, or unallowable expenses Invoices must be for approved and budgeted expenditures that programs have already incurred No advances allowed
Invoices Must also have up-to-date and current: 1. Member hours 2. Expense Workbooks 3. Federal Financial Reports 4. Program Reports (performance-based) Must also demonstrate compliance with program operations, i.e., no outstanding corrective action
Invoice Due Dates Invoices are due by the 21st of the month following the invoice period Effective immediately, all invoices are to be submitted electronically via OnCorps reporting system Invoices are submitted monthly
Invoice Review Only complete and approved invoices are submitted for payment we send them back if there are errors You can expect payment about 20 days after the day we receive an error-free invoice Proofread before submitting small errors will delay payment Common errors: Selecting incorrect program year for the Budget Period Don t have enough match reported Line Item Over Expended/Over Reporting of CNCS or Grantee Share (Red Numbers in your Workbook = Something is Wrong)
Budget Amendment Guidelines Budget changes of more than 10% of your total budget or to line items previously allocated $0 must not be implemented before OregonServes approves the change (i.e. don t purchase/pay for items that are not in an approved budget at the time of purchase). Adequate written justification must be provided with request changes need to be consistent with program design and activities. Budget Modification Request Form must be completed in OnCorps. Do not submit a major budget change at year-end. This indicates inadequate monitoring of budget throughout the year. There is no guarantee that a year-end change will be approved and you may not be reimbursed for these expenses.
Budget Amendment Guidelines OSC must receive written approval from CNCS for these budgetary changes: Specific costs requiring approval under the cost principles, such as: Overtime pay, rearrangement and alternation costs, and pre-award costs Purchases of equipment over $5,000 using CNCS funds, unless specified in the approved application and budget Changes in the cumulative budget line items that amount to 10% or more of the total budget, unless the CNCS share is $100,000 or less The total budget includes both the CNCS and grantee shares Grantees may transfer funds among approved direct costs categories when the cumulative amount of such transfers do not exceed 10% of the total budget
Budget Amendment Pointers Your budget = plan of expected costs Plan may change as the program is implemented Review budget monthly Request budget amendments promptly Do not wait until last month of year to request budget modification Budget is driven by program needs
Federal Financial Reports Prepare all financial reports with information from the organization s accounting system Review and reconcile the information to ensure accuracy prior to report submission Submit all reports on time Proofread before submitting Submit by April 15thand October 15th Must be submitted via OnCorps Required financial information includes: Program Income Submission of all invoices for reporting period Reporting other federal grant sources
Late Reports? Prior to the due date 1. 2. 3. By e-mail, request an extension Provide reason why an extension is needed State expected date of completion Expense Reports and FFRs Submit extension request to oregon.serves@hecc.oregon.gov HECC Finance reconciles FFRs to Expense Reports. If they do not tie, expect a call or e-mail! FFR Due Dates for the Program Year Period Claiming Date FFR Due April 15th July-March October 15th April-September
Compliance Reviews Corporation for National & Community Service (CNCS) - Improper Payments Elimination and Recovery Improvement Act (IPERIA) OregonServes (OSC)- Fiscal Desk Review Office of Inspector General (OIG) - Audit
Common Accountability Problems System of internal controls should exist on timekeeping under Uniform Grant Guidance Timesheets cannot be based on budgeted amounts actual work only Suggestion 1 periodically, conduct your own timesheet review audit Suggestion 2 provide mandatory training on how to accurately and timely maintain timesheets Organizations do not: Separate accounting records for each Federal grant Submit Federal Financial Reports (FFRs) on schedule Make sure that the FFRs reconcile to internal accounting records (general ledger) Record match dollars in general leger, with same detail/documentation as for grants expenditures Contemporaneously and adequately document source of match contributions Substantiate market value of in-kind match contributions
Questions? Madeline Seghers, Program Officer: madeline.seghers@hecc.oregon.gov HECC Finance: hecc.finance@hecc.oregon.gov
