Financial ManagementFinancial ManagementFor Project AdministratorsFor Project Administrators

How Feds View ThemselvesHow Feds View Themselves

How Grantees View FedsHow Grantees View Feds

The NEW DOL GranteeThe NEW DOL Grantee

Our Expectations of You:Our Expectations of You: A program that is designed to focus on A program that is designed to focus on

customer needs and to address those needs customer needs and to address those needs A program that meets the requirements of A program that meets the requirements of

Federal law and regulationFederal law and regulation A program in compliance with WIA A program in compliance with WIA

requirements, OMB Requirements and requirements, OMB Requirements and Generally Accepted Accounting Principles.Generally Accepted Accounting Principles.

A high quality program that is backed up by a A high quality program that is backed up by a high quality proposalhigh quality proposal

The NEW DOL GranteeThe NEW DOL Grantee

What you can expect from us:What you can expect from us: Assistance with WIA regulationsAssistance with WIA regulations Assistance with proposal design and Assistance with proposal design and

developmentdevelopment On site technical assistance and monitoringOn site technical assistance and monitoring Assistance with fiscal and programmatic Assistance with fiscal and programmatic

issuesissues

The Fiscal Program DivideThe Fiscal Program Divide

There is a need for program operators to There is a need for program operators to be aware of financial requirementsbe aware of financial requirements

There is a need for fiscal people to be There is a need for fiscal people to be aware of program requirementsaware of program requirements

No one gets to opt outNo one gets to opt out

Why know this stuff?Why know this stuff?

Financial requirements impact program Financial requirements impact program designdesign

Need for financial information is critical to Need for financial information is critical to achieving program successachieving program success

Failure to comply may result in sanctionsFailure to comply may result in sanctions

It’s All Very SimpleIt’s All Very Simple

Written Policies and Sound Business Practices,Written Policies and Sound Business Practices, Followed Consistently Over Time,Followed Consistently Over Time, With Each Funding Stream Treated Equally,With Each Funding Stream Treated Equally, With All Costs Being Necessary and With All Costs Being Necessary and

Reasonable,Reasonable, Would be done similarly by a Prudent Person,Would be done similarly by a Prudent Person, Ensuring Proportional Share and Benefits Ensuring Proportional Share and Benefits

ReceivedReceived

Rules affecting programsRules affecting programs

Enabling legislation – Subtitle D of Title IEnabling legislation – Subtitle D of Title I Uniform administrative requirementsUniform administrative requirements

Grant management rulesGrant management rules Cost principlesCost principles

Determination of allowable costsDetermination of allowable costs WIA regulationsWIA regulations

Program activitiesProgram activities Both allowable and unallowableBoth allowable and unallowable

Cost category restrictionsCost category restrictions

Cost principlesCost principles

Set of government wide rulesSet of government wide rules Cost principlesCost principles

Define conditions for charging costsDefine conditions for charging costs

Types of Allowable costsTypes of Allowable costs AllowableAllowable UnallowableUnallowable Allowable with conditionsAllowable with conditions

OMB CircularsOMB Circulars

A-87A-87 Governments (State, Local, Indian Tribal)Governments (State, Local, Indian Tribal)

A-122A-122 Non-profit organizationsNon-profit organizations

A-21A-21 Institutions of Higher EducationInstitutions of Higher Education

48 CFR Part 3148 CFR Part 31 Commercial organizationsCommercial organizations

Required?Required?

Incorporated by referenceIncorporated by reference Uniform Administrative StandardsUniform Administrative Standards

29 CFR 97.2229 CFR 97.22 29 CFR 95.2729 CFR 95.27

WIA RegulationsWIA Regulations 20 CFR 667.20020 CFR 667.200

Additional GuidanceAdditional Guidance

ASMB C-10ASMB C-10 Implementation Guide for A-87Implementation Guide for A-87

Developed by DHHSDeveloped by DHHS At request of OMBAt request of OMB Available at DHHS websiteAvailable at DHHS website

StandardsStandards

Necessary and reasonableNecessary and reasonable Sound business practicesSound business practices Prudent person principlePrudent person principle

AllocableAllocable Only charge costs that clearly BENEFIT grantOnly charge costs that clearly BENEFIT grant Proper allocation methodsProper allocation methods

Authorized or not prohibitedAuthorized or not prohibited Federal, State, or local lawsFederal, State, or local laws

More StandardsMore Standards

Consistent treatmentConsistent treatment Across all programs Across all programs Year to yearYear to year Both indirect and directBoth indirect and direct

Not used for matching requirementsNot used for matching requirements Unless specifically authorizedUnless specifically authorized

And more…..And more…..

Adequately documentedAdequately documented Traceable to source documentationTraceable to source documentation Consistent with GAAPConsistent with GAAP

Conform to ETA grant exclusions & Conform to ETA grant exclusions & limitationslimitations Specific unallowable costsSpecific unallowable costs Administrative cost limitationAdministrative cost limitation

Items of CostItems of Cost

TravelTravel AllowableAllowable Reasonable and in support of grant activityReasonable and in support of grant activity

Pre-Award costsPre-Award costs Not allowable unless specifically authorizedNot allowable unless specifically authorized

InterestInterest Costs of borrowingCosts of borrowing Payments for equipment over timePayments for equipment over time

Items of cost, #2 Items of cost, #2

Capital assets or equipmentCapital assets or equipment $ threshold$ threshold Prior approval of GO BEFORE purchasePrior approval of GO BEFORE purchase

Advertising & public relationsAdvertising & public relations Recruitment of staffRecruitment of staff Related to grantRelated to grant Outreach is allowableOutreach is allowable

WIA RequirementsWIA Requirements

Legal expensesLegal expenses Unallowable for prosecution of claims against Unallowable for prosecution of claims against

the governmentthe government Audit appealsAudit appeals

Real propertyReal property UnallowableUnallowable Exception for ADA complianceException for ADA compliance

WIA Unallowable ActivitiesWIA Unallowable Activities

Employment generating activitiesEmployment generating activities Public service employmentPublic service employment Business relocationBusiness relocation Sectarian activitiesSectarian activities

Faith-based and CommunityFaith-based and CommunityOrganizationsOrganizations

Federal Register - March 9, 2004Federal Register - March 9, 2004

Equal Treatment in DOL Programs for Faith-based and Equal Treatment in DOL Programs for Faith-based and

Community Organizations Community Organizations Proposed ruleProposed rule http://www.gpoaccess.gov/fr/index.htmlhttp://www.gpoaccess.gov/fr/index.html

Includes proposed changes related to sectarian Includes proposed changes related to sectarian activities activities

Cost CategoriesCost Categories

Only Only 22 Cost Categories Cost Categories AdministrationAdministration Program ActivitiesProgram Activities

Reporting categoriesReporting categories Vary by grantVary by grant Classify within books of accountClassify within books of account Classify through linking spreadsheetsClassify through linking spreadsheets

Budget line itemsBudget line items

Reporting CategoriesReporting Categories

Program IncomeProgram Income

Non-federal costs {Sec. 185 (f)(2)}Non-federal costs {Sec. 185 (f)(2)} ““Stand-in” costsStand-in” costs

Earmark Grants Earmark Grants Administrative LimitsAdministrative Limits

Contained in Grant AgreementContained in Grant Agreement Not to exceed 10% of grant awardNot to exceed 10% of grant award

Unless negotiated to max of 15%Unless negotiated to max of 15% Documentation of need requiredDocumentation of need required Subject to Grant Officer approvalSubject to Grant Officer approval

Measured at conclusion of grant periodMeasured at conclusion of grant period Tracked, accounted for & reportedTracked, accounted for & reported

WIA DefinitionWIA Definition

20 CFR 667.220(a)20 CFR 667.220(a) Not related to direct servicesNot related to direct services

Either to clients or employersEither to clients or employers

List of specific functionsList of specific functions Unlike traditional definitionsUnlike traditional definitions

Applies to all Title I programsApplies to all Title I programs Including Earmark grantsIncluding Earmark grants

Administrative FunctionsAdministrative Functions

Overall general administrative functionsOverall general administrative functions Accounting, financial & cash managementAccounting, financial & cash management ProcurementProcurement Property managementProperty management Personnel managementPersonnel management PayrollPayroll Coordinating resolution of findingsCoordinating resolution of findings

Audit, monitoring, investigationsAudit, monitoring, investigations

Administrative FunctionsAdministrative Functions

General administrative functionsGeneral administrative functions Audit functionsAudit functions General legal servicesGeneral legal services Developing systems and proceduresDeveloping systems and procedures

Includes information systemsIncludes information systems Required for administrative functionsRequired for administrative functions

Monitoring of administrative functionsMonitoring of administrative functions

Information TechnologyInformation Technology

AdministrationAdministration Costs of information systemsCosts of information systems

Related to administrative functionsRelated to administrative functions Accounting & payroll systemsAccounting & payroll systems Procurement & purchasing systemsProcurement & purchasing systems

Costs includeCosts include Purchase, development & operationPurchase, development & operation

Program CostsProgram Costs Tracking/monitoring participant & performance informationTracking/monitoring participant & performance information Employment statisticsEmployment statistics Performance & cost informationPerformance & cost information

Eligible providers of training servicesEligible providers of training services Youth & education activitiesYouth & education activities

Required Notices Required Notices

Is the notice prominently posted? Where?Is the notice prominently posted? Where? Is the notice in languages other than English?Is the notice in languages other than English? Does the notice contain contact informationDoes the notice contain contact information Does the notice describe the complaint process?Does the notice describe the complaint process?

QUESTIONS????QUESTIONS????