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????