National Association of HBCU Title IIII Administrators 2015 Technical Assistance Workshop Samuel T....

National Association of HBCU Title IIII

Administrators 2015 Technical Assistance Workshop

Samuel T. Rhoades, J.D.Virginia Union UniversitySpecial Assistant to the President/Title III Administrator

NATIONAL ASSOCIATION OF HBCU/TITLE III ADMINISTRATORS, INC.

June 22-26, 2015Hyatt Regency River walkSan Antonio, TX

Title III Purpose

Title III funds provides financial assistance to establish or strengthen the physical plants, financial management, and academic resources and

endowments of undergraduate HBCUs. Funds may be used for the: (1) purchase, rental or lease of scientific or laboratory equipment for educational purposes—

instructional and research; (2) construction, maintenance, and renovation of instructional facilities; (3) faculty development and exchanges; (4) purchase

of educational material; and (5) funds and administrative management and acquisition of

equipment for use in strengthening management.

Activity Directors’ Responsibilities

• Overall Management of the Activity

• Fiscal and Programmatic Management• Activities Equipment Inventory• Requisitions and Compliance of University Policies

and Procedures• Internal/External Evaluation of Project Objectives• Maintain appropriate data• Submit Progress of Objective Attainment for Annual

Performance Report to be submitted to the Department of Education by the deadline.

BUT NOT LIMITED TO THE FOLLOWING:

HBCU Title III Phase I Formula Grant

• Number of Pell Grant recipients attending the applicant institution during the school year immediately preceding the beginning of the fiscal year in which the applicant applies for a grant.

• Number of graduates of the applicant institution during the school year immediately preceding the beginning of the fiscal year in which the applicant applies for a grant. (34 CFR Section 608.4 defines “graduates” as a student who has attended an institution for at least three semesters and fulfilled academic requirements for undergraduate studies in not more than five consecutive school years.)

• Enter the total from Column B, Years1-5.

• Enter the total from Column C. (Do not count a student attending graduate school for more than one reporting year.)

Allowable Activities• Support of faculty exchanges, faculty development and

faculty fellowships to assist these faculty members in attaining advanced degrees in their fields of instruction

• Academic instruction in disciplines in which Black Americans are underrepresented

• Purchase of library books, periodicals, microfilm, and other educational materials, including telecommunications program materials

• Purchase, rental, or lease of scientific or laboratory equipment for educational purposes, including instructional or research purposes

34CFR Section 608.10

Allowable Activities• Construction, maintenance, renovation, and

improvement in classroom, library, laboratory, and other instructional facilities, including purchase or rental of telecommunications, technology, equipment or services

• Tutoring, counseling, and student service programs designed to improve academic success

• Funds and administrative management, and acquisition of equipment for use in strengthening funds management

• Joint use of facilities, such as laboratories and libraries• Establishing or improving a development office to

strengthen or improve contributions from alumni and the private sector


Allowable Activities• Establishing or enhancing a program of teacher education

designed to qualify students to teach in a public elementary or secondary school in the State that shall include, as part of the program, preparation for teacher certification

• Establishing community outreach programs that will encourage elementary and secondary students to develop the academic skills and the interest to pursue postsecondary education

• Other activities that it proposes in its application that contribute to carrying out the purpose of this part and are approved by the Secretary as part of the review and acceptance of the application


HBCU Specific Title III Funding Declines Between FY 08-FY 15

Title III Top 20 FY 2014 Grantees HBCU ProgramGrantee Funding Grantee Funding

1. North Carolina A&T $5,983,060 11. Winston-Salem State University $4,029,365

2. Florida A&M University $5,722,787 12. Virginia State University $3,960,325

3. Morgan State University $5,224,766 13. Alabama State University $3,960,264

4. South University A & M College $4,977,153 14. Fayetteville State University $3,654,205

5. St. Phillip’s College $4,938,961 15. Norfolk State University $3,600,375

6. Jackson State University $4,862,359 16. Elizabeth City State University $3,560,283

7. North Carolina Central University $4,327,505 17. Albany State University $3,353,850

8. Prairie View A&M University $4,325,851 18. Grambling State University $3,274,746

9. Texas Southern University $4,314,257 19.Savannah State University $3,178,986

10. Tennessee State University $4,081,010 20. South Carolina State University $3,089,971

#

STATE

INSTITUTION NAME

FY 2014 AWARD

1 NC North Carolina A&T State University $5,983,060

2 FL Florida A&M University $5,722,787

3 MD Morgan State University $5,224,766 4

LA Southern University A&M College $4,977,153 5

TX St. Philip's College $4,938,961 6

MS Jackson State University $4,862,359 7

NC North Carolina Central University $4,327,505 8 TX Prairie View A&M University $4,325,851 9

TX Texas Southern University $4,314,257 10

TN Tennessee State University $4,081,010 11

NC Winston-Salem State University $4,029,365 12

VA Virginia State University $3,960,325 13 AL Alabama State University $3,960,264 14

NC Fayetteville State University $3,654,205 15

VA Norfolk State University $3,600,375 16

NC Elizabeth City State University $3,560,283 17

GA Albany State University $3,353,850 18

LA Grambling State University $3,274,746 19

GA Savannah State University $3,178,986 20

SC South Carolina State University $3,089,971 21

AL Alabama A&M University $3,077,055 22 GA Fort Valley State University $3,057,936 23

MD Bowie State University $3,039,537 24

LA Southern University - Shreveport $2,985,560 25

AR University of Arkansas - Pine Bluff $2,904,248

26 MS Alcorn State University $2,894,512

#

STATE

INSTITUTION NAME

FY 2014 AWARD

27 DC University of the District of Columbia $2,869,410

28 FL Bethune Cookman College $2,705,381

29 AL Lawson State Community College $2,699,915 30

SC Benedict College $2,630,384 31

MD Copping State University $2,574,762 32

MD University of Maryland - Eastern Shore $2,559,290 33

FL Florida Memorial University $2,548,030 34 KY Kentucky State University $2,500,812 35

GA Clark Atlanta University $2,475,192 36

SC Denmark Technical College $2,448,800 37

LA Xavier University (LA) $2,446,046 38

VA Hampton University $2,332,052 39 LA Southern University at New Orleans $2,310,798 40

TN Lane College $2,310,340 41

MS Mississippi Valley State University $2,309,929 42

MO Lincoln University (MO) $2,263,854 43

NC Shaw University $2,232,719 44

GA Morehouse College $2,211,380 45

DE Delaware State University $2,201,959 46

MS Tougaloo College $2,178,881 47

AL Tuskegee University $2,174,513 48 MS Coahoma Community College $2,150,100 49

GA Spelman College $2,081,987 50

OK Langston University $2,080,860 51

NC Livingstone College $2,039,357 52

DC University of the District of Columbia $2,869,410 53 FL Bethune Cookman College $2,705,381

HISTORICALLY BLACK COLLEGES AND UNIVERSITIES (HBCU) PROGRAM FY 2014 REGULAR AWARDS

#

STATE

INSTITUTION NAME

FY 2014 AWARD

54 OH Central State University $1,979,346 55 NC Johnson C. Smith University $1,965,586 56 AL Bishop State Community

College - Main $1,965,127 57

TX Huston-Tillotson University $1,924,095 58 PA Lincoln University (PA) $1,895,769 59 AL Miles College $1,812,036 60 WV West Virginia State

University $1,786,475 61

SC Clafin University $1,783,625 62 VA Virginia Union University $1,669,422 63 AR Philander Smith College $1,666,461 64 AL Oakwood College $1,660,387 65 GA Paine College $1,649,711 66 PA Cheyney University of

Pennsylvania $1,621,346 67

MS Rust College $1,611,943 68 LA Dillard University $1,609,699 69 VI University of the Virginia

Islands $1,593,256 70

SC Morris College $1,580,950 71 TX Wiley College $1,574,171 72 NC Saint Augustine's College $1,573,112 73 SC Voorhees College $1,567,978 74 WV Bluefield State College $1,567,683 75 MO Harris Stowe State University $1,493,594 76

NC Bennett College $1,485,198 77 MS Hinds Community College -

Utica $1,466,107 78

SC Allen University $1,421,202 79 TN Fisk University $1,414,071 80 OH Central State University $1,979,346

#

STATE

INSTITUTION NAME

FY 2014 AWARD

81 TX Jarvis Christian College $1,381,048

82 AL Talladega College $1,375,512

83 TN Lemoyne Owens College $1,274,364

84 FL Edward Waters College $1,233,708

85 AL Trenholm State Technical

College $1,199,027

86 AL J. F. Drake State Technical

College $1,178,351

87 AL Stillman College $1,169,221

88 AL Shelton State Community

College - Fredd $1,162,490

89 TN American Baptist College $1,137,978

90 TX Texas College $1,102,163

91 OH Wilberforce University $1,091,591

92 AR Arkansas Baptist College $1,084,533

93 TX Paul Quinn College $1,065,295

94 AL Concordia College $1,023,691

95 AL Bishop State Community

College - Carver $500,000

96 AL Gadsden State Community

College $500,000

97 VA Virginia University of

Lynchburg $500,000

98 AR Shorter College $250,000

99 SC Clinton Junior College $250,000

100 TX Southwestern Christian

College $250,000

Total Allocation

$223,783,000

HISTORICALLY BLACK COLLEGES AND UNIVERSITIES (HBCU) PROGRAM FY 2014 REGULAR AWARDS

STATE INSTITUTION NAME FY 2014 AWARD

NC North Carolina A&T State University $1,635,348

FL Florida A&M University $1,586,753

MD Morgan State University $1,493,914

LA Southern University A&M College $1,463,043

MS Jackson State University $1,421,445

TX St. Philip's College $1,411,106

NC North Carolina Central University $1,300,828

TX Prairie View A&M University $1,297,907

TX Texas Southern University $1,295,952

TN Tennessee State University $1,248,807

NC Winston-Salem State University $1,235,453

AL Alabama State University $1,229,847

VA Virginia State University $1,227,485

NC Elizabeth City State University $1,173,035

NC Fayetteville State University $1,159,709

VA Norfolk State University $1,151,596

GA Albany State University $1,108,659

LA Grambling State University $1,081,699

GA Savannah State University $1,066,336

SC South Carolina State University $1,046,584

AL Alabama A&M University $1,040,312

GA Fort Valley State University $1,038,751

MD Bowie State University $1,036,825

AR University of Arkansas – Pine Bluff $1,018,510

LA Southern University – Shreveport $1,013,785

MS Alcorn State University $1,010,281

DC University of the District of Columbia $992,171

FL Bethune Cookman College $962,566

AL Lawson State Community College $952,774

SC Benedict College $950,659

MD Copping State University $941,142

MD University of Maryland - Eastern Shore $934,545


KY Kentucky State University $927,252 LA Xavier University (LA) $922,946 GA Clark Atlanta University $917,297 SC Denmark Technical College $910,812 TN Lane College $892,470 MS Mississippi Valley State University $887,671 LA Southern University – New Orleans $886,668 VA Hampton University $882,621 MO Lincoln University (MO) $877,037 MS Tougaloo College $874,612 NC Shaw University $870,951 GA Morehouse College $867,450 AL Tuskegee University $857,612 DE Delaware State University $854,207 MS Coahoma Community College $844,145 OK Langston University $839,076 GA Spelman College $837,509 NC Livingstone College $828,464 TX Huston-Tillotson University $818,899 NC Johnson C. Smith University $816,427 OH Central State University $814,028 AL Bishop State Community College - Main $802,291 PA Lincoln University (PA) $800,337 AL Miles College $782,497 WV West Virginia State University $771,368 SC Clafin University $769,646 AR Philander Smith College $761,174 GA Paine College $755,240 VA Virginia Union University $754,181 AL Oakwood College $744,151 AL J. F. Drake State Technical College $500,000 AL Shelton State Community College - Fredd $500,000 AL Stillman College $500,000

HISTORICALLY BLACK COLLEGES AND UNIVERSITIES (HBCU) PROGRAM

FY 2014 MANDATORY AWARDS


AR Arkansas Baptist College $500,000 FL Edward Waters College $500,000 LA Dillard University $500,000 MO Harris Stowe State University $500,000 MS Hinds Community College - Utica $500,000 MS Rust College $500,000 NC Bennett College $500,000 NC Saint Augustine's College $500,000 OH Wilberforce University $500,000 PA Cheyney University of Pennsylvania $500,000 SC Allen University $500,000 SC Morris College $500,000 SC Voorhees College $500,000 TN American Baptist College $500,000 TN Fisk University $500,000 TN Lemoyne Owens College $500,000 TX Jarvis Christian College $500,000 TX Paul Quinn College $500,000 TX Texas College $500,000 TX Wiley College $500,000 VI University of Virgin Islands $500,000

WV Bluefield State College $500,000

AL Bishop State Community College - Carver

$250,000

AL Concordia College $250,000 AL Gadsden State Community College $250,000 AR Shorter College $250,000 SC Clinton Junior College $250,000 TX Southwestern Christian College $250,000 VA Virginia University of Lynchbury $250,000

Total Allocation $78,880,000

HISTORICALLY BLACK COLLEGES AND UNIVERSITIES (HBCU) PROGRAM

FY 2014 MANDATORY AWARDS

Title III Part B, Strengthening Historically Black Colleges And Universities Program

Conclusion• Strong financial systems are critical to properly administer

grants

• Internal controls are needed to assess the University’s strengths and weaknesses

• Ongoing training/technical assistance should be provided for Staff

• Policies and Procedures are updated as needed

• Develop and/or strengthen a continuation and sustainability strategy that leads to new revenue streams to support program activity viability.

CRAB MENTALITY

Crabs in a bucket can easily escape from the bucket one at a time, but instead of doing that they pull each other down whenever one rises to the top - thus insuring their collective demise.

This is analogous to the behavior of a person who diminishes or pulls down anyone else who achieves or is about to achieve success greater than their own.

Crab mentality: We all like to see our friends get ahead, but not too far ahead.

If I can't have it, no one can have it.

When All Else Fails!Contact

Government Accountability Office441 G. Street, NWMail Stop 4T21Washington, D.C. 20548(202) 512-3000

Office of Inspector GeneralDepartment of Health and Human ServicesAttn: HotlineP.O. Box 23489Washington, D.C. 20026

NATIONAL ASSOCIATION OF HBCU/ TITLE III ADMISTRATORS, INC.

Uniform Guidance Federal Register

Uniform GuidanceFederal Register

To deliver on the promise of a 21st-Century government that is more efficient, effective and transparent, the Office of Management and Budget (OMB) is streamlining the Federal government's guidance on Administrative Requirements, Cost Principles, and Audit Requirements for Federal awards. The modifications are a key component of a larger Federal effort to more effectively focus Federal resources on improving performance and outcomes while ensuring the financial integrity of taxpayer dollars in partnership with non-Federal stakeholders.

The guidance provides a government-wide framework for grants management, which will be complemented by additional efforts to strengthen program outcomes through innovative and effective use of grant-making models, performance metrics, and evaluation. The reform of OMB guidance will reduce administrative burden for non-Federal entities receiving Federal awards.

The final guidance supersedes and streamlines requirements from OMB Circulars A-21, A-87, A-110, and A-122 (which have been placed in OMB guidance); Circulars A-89, A-102, and A-133; and the guidance in Circular A-50 on Single Audit Act follow-up.

Uniform GuidanceFederal Register

The goal of this reform is to deliver on the President's directives to (1) streamline our guidance for Federal awards to ease administrative burden and (2) strengthen oversight over Federal funds to reduce risks of waste, fraud, and abuse.

Streamlining existing OMB guidance will increase the efficiency and effectiveness of Federal awards to ensure best use of the more than $500 billion expended annually.

Uniform GuidanceKey Issues for Universities

The single biggest regulatory change in the last 50-years of research administration. Final rule December 26, 2014.

Outline of Uniform GuidanceSubpart A – Acronyms and DefinitionsSubpart B - General ProvisionsSubpart C – Pre-Federal Award Requirements and Contents of Federal AwardsSubpart D – Post- Federal Award Requirements Subpart E – Cost PrinciplesSubpart F – Audit RequirementsAppendices I-XI

Uniform Guidance200.430 Compensation

Personal Services Section (h) is specific to Higher Education

– Identifies special conditions for: Allowable Activities, Incidental Activities, Extra Service Pay, Periods outside the academic year, etc.

Section (i) is Standards for Documentation of Personnel Expenses. Charges must reflect actual work performed and records must be supported by internal controls and officially recorded.

Uniform Guidance200.430 Next Steps

Effort Issues Where do we go from here?1. Evaluate your current process/system and potential new systems – (i) Standards for Documentation2. Review current system in light of Internal Control standards. How strong are your written policies?3. Evaluate options for change.

Uniform GuidanceWhat Should I (We) be Doing?

1. Council on Financial Assistance Reform: https://cfo.gov/cofar/

2. Follow the Federal Register and Agency implementation plans

3. Pay close attention to advice from your professional associations

4. By now, institutions should have a “Point of Contact” and Plan

5. Leverage many in the Institution Plan: Project Directors, all levels of Administration, IT, and your experts from Purchasing, Payroll, etc.

6. Start/Continue to develop your Institution via training.

https://cfo.gov/cofar/


Audit Readiness & Preparedness


When an organization receives Federal education funds, it assumes certain responsibilities along with those funds. “Audit Readiness” is a natural by product of the proper execution of these responsibilities.

A recipient of Federal education funds can expect to reduce instances of audits that result in findings of material noncompliance if the overall management assumed with the funds are carried out properly.

Thus audit readiness occurs when the recipient of Federal education funds is prepared to undergo an audit which will disclose that funds are used properly.


The Audit or Site Visit is an independent evaluation of:

• Internal Controls (Fiscal, Program)• Management Systems• Policies and Procedures (established by law,

regulations, and/or grantee)• Accountability• Compliance (law, regulations, approved application)

Audit Readiness & Preparedness What is the purpose of an Audit or Site Visit?

• To assure that federal funds are being expended within the provisions of all applicable laws and regulations

• To assess the progress that is being made in achieving stated project goals and objectives

• To provide technical assistance

• To identify exemplary practices (may not be considered during an audit)


Writing Measurable Objectives


Objectives describe the major ways the project is expected to impact your goals and the university’s needs. Objectives should be stated in measurable terms; note the SMART concept for writing objectives:

Specific

Measurable

Attainable

Realistic/Reasonable

Time-Bound


When establishing objectives, note the following:

• How are you going to accomplish the objectives of the program?

• What quantitative and qualitative methods will you have in place to monitor the success of your program?

• On-going monitoring of the program is required to determine that objectives are being achieved.

• Frequent self-evaluations enable timely corrections and adjustments if parts of the program are proving to be ineffective. Title III Directors’ should consider Activity Directors to submit quarterly progress reports as a method to help monitor activities and alleviate potential fiscal and programmatic problems.


Sample Objectives:

1)To ensure that a minimum of twenty (20)

undergraduate students in the College of Arts and

Sciences (Departments of Sociology, Social Work,

Criminal Justice and Psychology) will develop

research skills by collaborating with faculty

mentors to engage in community-based research,

each academic year (Baseline: 10).


Sample Objectives:

2) To strengthen the University’s one-year retention rate by

1% annually, yielding at least an 80% retention rate by

September 2012, through the implementation of

academic intervention services that reduce DFWs

(Baseline: 69%).

3) To increase sponsored programs productivity for the entire

University by increasing submissions by 5% annually

(Baseline: 25).


Record Keeping &

Documentation

Record Keeping & Documentation

The U.S. Department of Education requires the University to keep records that show the amount of funds under the grant, how the grant funds were used, the total cost of the project, share of cost provided from other sources, and other records to facilitate an effective audit.

34CFR Part 74 Section 74.50 Purpose of Reports and Records

Record Keeping & Documentation

Budget reporting forms Budget Revisions

Worksheets (including Departmental Transfers)

Quarterly reports of progress

Telephone conversation records

Emails Equipment inventory

forms Contracts Registration forms and

other documents from faculty development and training activities

Time & Effort Reports

Records to Retain for Audit Purposes and Internal/External Evaluations (Financial and Program)

Personnel Action Forms and other employment information (including vita, application forms, and affirmative action forms)

Consultant’s reportsPurchasing requisitionsTravel reportsReleased time reportsEvaluation reportsWorkshops/Workshop evaluationsDocuments showing progress

toward achieving objectives

Travel Policies & Procedures



Meals and Incidentals

Meals and incidental travel expenses are reimbursable only for overnight official business travel outside the traveler's official station. Reimbursement for expenses will be reimbursed on a per diem system. Per Diem rates are adjusted to accommodate for travel days and meals that are included in the conference registration cost.

Lodging

The University will reimburse actual expenses up to a daily maximum rate plus taxes and surcharges. If approved, rates can be no higher than the standard rate for your particular location.


Registration Fees

Travelers can cover registration costs by one of the following options: I) Pay in advance and seek reimbursement upon return with a paid receipt; or 2) Request a University check. When choosing the latter option, attach a copy of the original registration form to the travel request.

Other Business Expenses

Anticipated charges for business-related Internet charges, must be itemized on the travel request under “Other".


Mileage

Personal vehicle usage must be approved, in advance, by Facilities Management and the approval must be attached to the reimbursement voucher.

Car Rental

Title III will only approve rental care expenses. Title III will only approve rental car expenses when the traveler can demonstrate in writing that this mode of travel is more economical than utilizing other transportation. Car rental must be secured through an authorized vendor and the original receipt must be attached to the reimbursement voucher.


Foreign Travel

Title III restricts all out-of-the-country travel. All exceptions must be justified and approved by the U.S. Department of Education Program Officer.

Reimbursements for Approved Travel

After the travel has taken place prepare a Travel Reimbursement Voucher. To the voucher, attach receipts for taxi fares, hotel accommodations, fees, and other reimbursable expenses. Receipts are not required for meals. Submit package for approval. A copy of the conference itinerary and registration form must accompany the voucher as well.


Report on Travel with Title III Funds

Person(s) whose travel expenses are paid by the Title III grant are required to complete a "Report on Professional Meetings” form. This document should be maintained with the Activity’s office files.


Travel with Title III funds is allowable only for travel expenses identified in the approved grant application. Changes in approved travel must be justified. Travel that is not identified in the approved application requires approval by the Title III Office.

Approval for Travel Title III personnel who travel with grant funds must

submit a travel request to the Title III Office no less than thirty days prior to the actual travel date. Travel expenses must be limited to only those expenses that are necessary for providing essential services to the University.

E-CFR Section 200.474 Travel Costs

Spending Plan Using Federal Funds & Personal Overhead


Personnel Overhead All regular University hiring procedures will be followed in the hiring of

personnel for the Title III grant. The following procedures should be used to fill Title III positions:

Activity completes the appropriate personnel recruitment forms, as required by Human Resources, and forwards the completed form to the proper offices for approval. (Note: Federal regulations require that the Title III Office signs all documents.)

Human Resources should advertise position via requested media. Human Resources review all applications and refers to the

supervisor only those that meet the qualifications for the position advertised.

Activity Director interviews the prospective employees. (Note: No applicant should be interviewed before the first three steps have been taken.)

After a potential employee has been selected, Human Resources completes a Personnel Action form and forwards it to the proper offices for approval.

Personnel Overhead

The Title III Office must have all the credentials of all persons hired with Title III funds. A copy of the employee's employment vita or resume will serve this purpose. When employees leave or are replaced for any reason, the Title III Office must be informed immediately. Copies of correspondence, resignation letters and appropriate Human Resources forms will serve this purpose.

Time and Effort Reports

The U.S. Department of Education requires documentation of time spent working on Title III activities by all persons wholly or partially paid with Title III funds. Employees should, therefore, complete the monthly Time & Effort Report and submit it to the Title III Administrator. The Time & Effort Report must be signed by the Department Head/Dean, Activity Director, and the Title III Coordinator.

Personnel Overhead

For all Title III positions, there must be a search procedure to ensure that the hiring of persons supported by Federal funds is in compliance with all applicable Federal regulations and is within the framework of the Title III Plan of Operation and budget. Documentation for personnel management is essential and should be kept according to the guidelines that follow.

Hiring of Personnel

Personnel are to be hired in a nondiscriminatory manner according to the provisions of The Faculty and Staff Handbook. Also, maintain on-file a job description and copy of resumes of persons selected for Title III vacancies.

Personnel OverheadTime and Effort Reporting

The standards for documentation of personnel costs charged to the grant are set forth in the Education Division General Administrative Regulations (EDGAR) Part 74 Administration of Grants Subpart Q Cost Principles Section 74.174 Part IIB which provides that:

“The costs of such remuneration are allowable to the extent that the total compensation to individual

employees is reasonable for the services rendered and conform to the established policy of the institution

consistently applies and provided that the charges for work performed directly on Government Research

Agreements….are determined and supported as herein provided.” 45CFR 100, Appendix C. Section J.7d.

Spending Plan Using Federal Funds

Title III funds may be spent only on activities that are included in the approved application.

The application must give a description of the activities to be carried out; and it must show how grant funds will be used to supplement, and to the extent possible, increase the funds that would otherwise be made available for the activities to be carried out in the grant.

In no case may Title III funds take the place of funds that would otherwise be available.

For each proposed activity, applicants must prepare a separate, detailed itemized budget (in dollars) and a budget narrative for each year you are requesting grant funds. Demonstrate and justify that all costs are reasonable in today’s market and necessary to accomplish your activity objectives.

National Association of HBCU Title IIII Administrators 2015 Technical Assistance Workshop Samuel T....

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