21 st Century Community Learning Centers Program Reimbursements 101

Dr. John D. Barge, State School Superintendent“Making Education Work for All Georgians”www.gadoe.org

21st Century Community Learning Centers Program

Reimbursements 101

Andre’ HillBudget Analyst 2August 8, 2012


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

2


Cost Principles: Basic Guidelines

All Costs Must Be:

Necessary Reasonable Allocable

Legal under State and Local Law

3


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

4


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

5


OMB Circular A-87 Attachment B–

Selected Items of Costs

43 specific costs detailed

Listed in alphabetical order

6


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

7


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

8



• 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

9



• 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)

10



• 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

11



• 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

12


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

13


Unallowable Expenses (CONT.)

• Non-educational field tripsExamples: 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

14



• 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

15



• 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)

16



• 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 approvalApproval must be received from US ED

17


Verification Process

Entered Data

Monitoring Findings

Approval

18


Verification Process (CONT.)

• DataAll data must be entered into CAYEN Afteschool21 Data Management System

Objectives, Registration, Attendance (12 hours minimum weekly contact time), Grades, State Assessment, and Certification

19


Data Verification

20


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

21


Monitoring Verification

22


The Package

23


The Reimbursement Process

The AAA Effect

Accurate

Acceptable

Approvable

24


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’

25


26

a) Salary and benefitsLEAs1.Payroll system generated report (one or more of: earnings register detail, benefits distribution report, payroll summary) Non-LEAs1. 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) Contractors1. Detailed invoice with deliverables2. Program Director’s signed approval to pay on the invoice3. Proof of payment c) Field Trips1. Flyer (or copy of webpage) from location visited that indicates purpose of visit2. Invoice3. Program Director’s signed approval to pay on the invoice4. Proof of payment

21st CCLC FY13 Required Supporting Documents for Reimbursement Request Processing


27

d) Transportation 1. Invoice from Transportation Department/Transportation service provider2. Program Director’s signed approval to pay on the invoice3. Proof of payment4. Mileage log (Optional – if required by GaDOE)

e) Professional Development 1. Workshop/conference Agenda2. Travel Expense Statement (and receipts of travel expenses, if applicable)3. Purchase order4. Detailed invoice with deliverables 5. Program Director’s signed approval to pay on the invoice6. Proof of payment f) National Criminal Background Check (NCBC) 1. Purchase Order (PO)2. Invoice3. List of persons covered by the NCBC (preferably on both PO and Invoice)4. Program Director’s signed approval to pay on the invoice5. Proof of payment



28

g) Fidelity Bond and General Liability Insurance (Non-LEAs only) 1. Invoice2. 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/bill3. Proof of payment

j) Utilities1. Utility bill2. Program Director’s signed approval to pay on the invoice/bill3. Proof of payment i) Indirect Cost1. General ledger/expense statement that serves as the basis of the indirect cost2.Journal Entry/General Ledger that demonstrates that the indirect cost has been charged to the 21st CCLC subledger



29

j) General Expenses (such as purchase of goods, and other expense categories not mentioned above) 1. Purchase order2. Invoice3. Program Director’s signed approval to pay on the invoice4. 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 GaDOE3. Bank statements4. Receipts with credit/debit card verification To facilitate reimbursement request processing, GaDOE may require additional documentsnot listed in this document



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

30


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

31


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”

32


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.”

33


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

34


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?

35


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

36


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)

37



• 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

38


• 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’

3/28/2011 39



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)

40


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) 651-5006 [email protected]

• Budget Analysts Email with concerns listed Telephone call for clarification Technical assistance

41


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

42


Sample Packets

Grantee Participation

Review of Form, Resources,

& Sample Folders

43


Resources Cost Principles

• OMB Circular A-21

Educational Institutions

http://www.whitehouse.gov/omb/assets/omb/circulars/a021/a21_2004.pdf


State, Local, and Indian Tribal Governments

http://www.whitehouse.gov/omb/circulars_a087_2004/


Non-Profit Organizations

http://www.whitehouse.gov/omb/assets/omb/circulars/a122/a122_2004.pdf

44


Questions?

45

21 st Century Community Learning Centers Program Reimbursements 101

Documents

Transcript of 21 st Century Community Learning Centers Program Reimbursements 101