federal & state monitoring: the uniform guidance · 2016. 8. 1. · uniform guidance – no...
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Title Grants Division
Illinois State Board of Education
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Federal & State Monitoring: The Uniform Guidance
Technical Assistance Workshop 2016
Title Grants Division
Illinois State Board of Education
Topics of Interest • Overview of the Uniform Guidance (also
commonly referred to as the Omni Circular)
• Policies and Procedures Overview • Internal Controls Overview • Audit and Monitoring Expectations • Common Findings • Reminders
2 Federal and State Monitoring Division
Title Grants Division
Illinois State Board of Education
What is the Uniform Guidance? • In a nutshell: It’s a consolidation of 8 OMB
Circulars (2 CFR 200) • It’s called guidance, but it’s full of rules and
requirements, with some suggestions for “best practices”
• It’s not a dramatic departure from the previous requirements, but there are some new requirements and flexibilities
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Title Grants Division
Illinois State Board of Education
From Circulars to the Uniform Guidance
Prior to the Uniform Guidance After the Uniform Guidance
Circulars A-89, A-102, A-110 Uniform Guidance Subparts B, C, and D
Circulars A-21, A-87, A-122 Uniform Guidance Subpart E
Circulars A-133, A-50 Uniform Guidance Subpart F
EDGAR Parts 75 to 99 EDGAR Parts 75 – 79 and 81 – 99
EDGAR Parts 74 and 80 substance Became part of the Uniform Guidance
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Title Grants Division
Illinois State Board of Education
The Uniform Guidance • Enhanced Oversight Requirements of
Sub-recipients – Risk Assessment and Monitoring
• Greater Emphasis on Internal Controls and Written Policies
• Greater Focus on Performance Expectations and Results
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Federal and State Monitoring Division
Title Grants Division
Illinois State Board of Education
Uniform Guidance – Sub-recipient Risk Assessment
• Prior experience with same or similar awards • Results of previous audits • Is the LEA required to have a federal single audit • New personnel or substantially changed systems • Results of federal awarding agency monitoring • Written procedures and internal controls • Other factors as identified by federal government,
SEA, or other authoritative guidance
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Title Grants Division
Illinois State Board of Education
Uniform Guidance – Sub-recipient Risk-Based Monitoring
• Review of financial and performance reports and supporting documentation
• Assessment of written policies and internal controls
• Issuance of management decisions for audit findings
• Ensuring sub-recipient takes timely and appropriate action on noted deficiencies
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Title Grants Division
Illinois State Board of Education
Uniform Guidance – Risk-Based Monitoring
• Whether as part of the risk-based assessment or monitoring, SEA can impose conditions, including high risk conditions, on its sub-recipients (2 CFR 200.207 and 3474.10): – Increased reporting – Reimbursement plan – Additional monitoring – Mandatory technical assistance – Additional prior approvals – Other
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Title Grants Division
Illinois State Board of Education
Uniform Guidance – No Longer Only for Federal Awards
• Grant Accountability and Transparency Act (GATA) – 30 ILCS 708 (www.ilga.gov) – Directs the Governor’s Office of Management
and Budget (GOMB) to adopt rules which adopt the Uniform Guidance at 2 CFR 200.
– The rules shall apply to all State and federal pass-through awards effective on and after July 1, 2015. (30 ILCS 708/20)
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Title Grants Division
Illinois State Board of Education
Policies and Procedures Overview • At the heart of internal control environment • Polices and Procedures Must Be Specific to
Your District • The policy must state what you are going to do and
why • The procedures state
• What steps are required to be completed • Who is going to perform the steps • When the process will be completed • Who is responsible for review
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Federal and State Monitoring Division
Title Grants Division
Illinois State Board of Education
Policies and Procedures Overview • Specific functions/processes where written
policies/internal controls are most essential: – Payments/cash management – Compensation/personnel expenses – Procurement – Property management/inventory – Financial monitoring – Sub-recipient monitoring (contracts/grants) – Other, as needed
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Title Grants Division
Illinois State Board of Education
Internal Controls Overview • Per 2 CFR 200.303 internal controls are
elevated as an accountability measure – Grantees must:
• Establish and maintain effective internal control over federal awards • Evaluate and monitor compliance • Take prompt action in the event of noncompliance • Take reasonable measures to safeguard protected personally
identifiable information and other sensitive information – Resources
• Tool kit and PowerPoint Presentation – http://www2.ed.gov/policy/fund/guid/uniform-guidance/internal-controls.html
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Title Grants Division
Illinois State Board of Education
Internal Controls Overview • Internal controls give reasonable
assurance that the organization will achieve its objectives through: – Effective and efficient operations – Reliable reporting – Compliance with applicable laws and
regulations
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Title Grants Division
Illinois State Board of Education
Internal Controls: Crucial Accountability
• The elevated role of internal control – Creates a transparent system of accountability for
decision making around federal funds – The system of accountability applies equally to
federal agencies, grantees, and sub-recipients • Internal controls are not new to the financial
world – They may be new to people working on program
implementation
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Title Grants Division
Illinois State Board of Education
Internal Controls Overview • Strong Internal Controls include:
– Policies and procedures for individual functions – Adequate segregation of duties for all functions – Supervisory review of expenditures prior to
submission – Grant and Fiscal staff review of transactions to
ensure proper posting of expenditures to grants – Procedures to ensure grant objectives are being
met – Adequate, sufficient supporting documentation
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Title Grants Division
Illinois State Board of Education
Inventory Example Items to Consider
• Procedures must be in place to ensure the control of equipment and materials both in the LEA and those in private schools
• Equipment purchases must be approved in the grant budget • Inventory records must include the following components
• Description • Serial number or other identification number • Funding source for purchased property • Who holds title • Acquisition date • Cost • Location, use and condition • Disposition date, if applicable
• All equipment purchases must be physically located in the grant usage area and must support the intent of the program
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Title Grants Division
Illinois State Board of Education
Audit and Monitoring Expectations
• Monitoring Instrument – District responses should be consistent with their approved
application – Each comment box should contain specific details to document
that the district is in compliance for that specific portion of the grant
– Submission of the instrument by the required date
• Comparability • Submission of the instrument by the required date • Maintain supporting documentation
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Title Grants Division
Illinois State Board of Education
Audit and Monitoring Expectations
• Onsite and Desk Reviews – Supporting documentation for all programs to
be reviewed – Access to staff responsible for the programs
being reviewed – Audit and monitoring function is collaborative
but ultimately independent of program administration function
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Title Grants Division
Illinois State Board of Education
Common Programmatic Monitoring Findings – Title I
• Parental Involvement • Comparability of Services • Allocation of Funds • Private School Participation • Supporting Documentation for Programs • Compliance with Requirements for
Selection of Eligible Attendance Centers
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Federal and State Monitoring Division
Title Grants Division
Illinois State Board of Education
Common Fiscal Monitoring Findings – Title I
• Inaccurate/Untimely Expenditure Reports • Salaries paid were not approved or were
inaccurate • Inventory Issues • Expenditures paid were unallowable or did
not support the program intent • Expenditures were not within the grant
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Federal and State Monitoring Division
Title Grants Division
Illinois State Board of Education
• Was the cost included in application/budget? • Does the cost meet the requirements of the law? • Is the cost necessary, reasonable, allocable, and
documented? • Is the cost consistently applied? • Is the cost adequately documented?
– Examples: segregated accounts, invoices, payroll detail, cancelled checks, inventory records and other valid supporting documentation
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Basic Guidelines for Allowable Expenditures
Federal and State Monitoring Division
Title Grants Division
Illinois State Board of Education
References and Helpful Links • United States Department of Education: http://www.ed.gov • The Uniform Guidance (2 C.F.R. 200): http://www.ecfr.gov/ • Uniform Guidance Technical Assistance:
http://www2.ed.gov/policy/fund/guid/uniform-guidance/index.html
• Illinois Program Accounting Manual (IPAM): http://www.isbe.net/sfms/html/ipam.htm
• State and Federal Grant Administration Policy and Fiscal Requirements and Procedures: http://www.isbe.net/funding/pdf/fiscal_procedure_handbk.pdf
• http://www.isbe.net/e-bulletins/default.htm • http://isbe.net/grants/default.htm • http://isbe.net/ea/default.htm
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Title Grants Division
Illinois State Board of Education
Contact Information Illinois State Board of Education Federal and State Monitoring Division 100 North First Street Springfield, IL 62777 217-782-7970
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Title Grants Division
Illinois State Board of Education
Questions and Answers
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