grant management & documentation - in.gov · grant management & documentation ... •...

Grant Management & Documentation

Gabrielle Owens, Director of Regulatory Affairs & Deputy General Counsel

[email protected] Palin, Director, Victims Services Division

[email protected] Spicer, Regulatory Compliance Monitor

[email protected]

mailto:[email protected]



Laws Governing ICJI Administered Grants

CODE of FEDERAL REGULATIONS(2 CFR/Part – 200)

Uniform Administrative Requirements, Cost Principles and Audit Requirements

for Federal Awards

www.eCFR.gov

http://www.ecfr.gov/

Laws Governing ICJI Administered Grants

2015 Department of Justice Grants Financial Guide

https://ojp.gov/financialguide/DOJ/index.htm

https://ojp.gov/financialguide/DOJ/index.htm

Supporting Documentation

How do I get reimbursed?

Step 1 – Identify the line items that were approved on your grant. Step 2- Complete the Expense Summary Form for those approved items for expenditures made during the reporting period.Step 3 – Include all documentation supporting the expenditures listed on the Expense Summary Form.

General RuleEvery dollar that a subgrantee has requested reimbursement for must be supported by adequate documentation showing the expense occurred, is allowable, reasonable, and the subgrantee has proof of payment.

Expense Summary FormPage 1

Expense Summary Form Page 2


Personnel & Employee Benefits

Payroll Documentation

Pay stubs are required, we will not accept a report or spreadsheet. The pay stub must show:

name of the employee gross wages earned total hours worked during the period hourly rate of pay pay period begin and end dates pay date all deductions for taxes/benefits/etc.

Pay Stub ExampleEmployee Name

Timesheets

• Timesheets can be of a variety of styles but must: Show daily work activity (i.e. 8 hours or 9-5) Be signed by the employee and an

Approving Official who has firsthand knowledge of the work performed

• Timesheets are REQUIRED for every employee listed on the approved grant

Electronic Timekeeping• Electronic time and attendance systems can be

used, but the system must require the employee and Approving Official to prove who they are to be allowed to enter or approve time. A User ID/Password to log in to the timekeeping system is a good example.

• The time and attendance reports sent to ICJI must: Show daily work activity (i.e. 8 hours or 9-5) Must include every employee listed on the

approved grant.

Electronic TimekeepingTo be authorized by ICJI to submit time and attendance reports from an electronic timekeeping system, the subgrantee must:Submit a copy of the instructions from the

timekeeping system manual that outline the requirements for an individual identification method to the ICJI Grant Manager for approval. Screen shots showing the actual login and approval pages of the system are good to submit in addition to the instructions.

Timesheet Example


Travel/Training(Employees Only)

Receipts• Conference registration • Conference agenda• Hotel receipts• Airline receipts• Taxi receipts• Rental car receipts• Meals – ICJI follows the State per diem rules• Employee mileage reimbursement forms

(ICJI can only reimburse at the current State of Indiana mileage rate)


Equipment


• Receipts• Copies of three bids from vendors if any

piece of equipment is $500 or more• Equipment purchased with grant funds

and a value of $500 or more require property tags

• You will need to maintain a “Property Record” for all equipment purchased through grant funds (2 CFR Part 200.313)


Supplies & Operating Expenses

(Client expenses for training would go in here)

Supplies & Operating Expenses

• Receipts, receipts, receipts• Vendor Invoices (utility bills, invoices,

proof of payment)• Rent receipts (or copy of lease and proof

of payment)• Receipts/invoices must show the vendor

name, date of service/purchase, amount due, and list what services were performed or what was purchased

ReceiptsThere are 3 methods to divide up expenses from receipts between different grants.

1.Make separate purchases for each grant and get separate receipts, one for each grant.

* Did you notice the unallowable item?(The Wild Turkey – it’s alcohol)

Receipts2. Make a combined purchase and attach documentation explaining what items were purchased for each grant. Submit copies of the documentation with all grant reimbursement claims.

Grant # xyz1 Grant # xyz2Antifreeze 12.86 All the rest of theEdge 1Q 5W30 7.97 items purchasedEdge 1Q 5W30 7.97Edge 1Q 5W30 7.97

36.77sales tax 7% 2.57

Total 39.34

Vendor Invoice Example

Bed Nights

• Must substantiate the number of nights claimed. Redacted sign in/out sheets – no names

please Spreadsheet that show what nights are being

claimed per client (do not just claim a total number of nights, i.e. 120 bed nights)

Bed Nights Example(No Names Please)


Consultants / Contractors

Consultant/Contractor• Should have a signed agreement stating what

work is to be done and the costs associated with that work.

• Invoices from the consultant/contractor must clearly show the vendor name, date(s) of services, hours worked, payment amount due for the services, and a list of what service(s) the contractor/consultant performed.

• Consultant/contractor reimbursement rates are capped at $81.25 per hour, not to exceed $650 per day.

Consultant/Contractor• Examples of Consultants/ContractorsPlumbersSoftware/hardware computer engineersTherapistsLawyersGrounds maintenance staff

• Improper Examples of Consultants/ContractorsVolunteersBoard MembersEmployees

Match

• Expenditures that could be paid with grant funds can also be used as match: Salaries/Benefits Travel Equipment Supplies and Operating Expenses Consultants/Contractors

• If you do not achieve your stated match goals, you may be required to refund a portion of the grant funds

Match

Items utilized for match are subject to the same supporting documentation rules previously reviewed for expenditures made with grant funds.

Law Governing Match2 C.F.R. Part 200.306

(b) Match criteria:(1) Are verifiable from the subgrantee’s records;(2) Are not included as contributions for any other

Federal grant;(3) Are necessary and reasonable for

accomplishment of project or program objectives;(4) Are allowable costs;(5) Are not Federal funds from another grant or award;(6) Are approved in the grant budget; and (7) Conform to the requirements of 2 C.F.R. Part 200.

Match

Cash versus In-Kind

Examples of In-Kind Match

Volunteer hours. Requires time and attendance records similar to

employees to show daily hours worked and thevolunteer and an Approving Official must sign the timesheet. The timesheet must also include a short description of the work performed

Hourly rate must be reasonable and similar to others performing the same job function.

Donation of space, equipment, clothing, or items to be utilized to further the grant’s goals and objectives.

Must use fair market value to determine the allowable value of donated items.

Match Calculation Example 1

Award Amount = Adjusted% of Federal share Project Cost

Adjusted x Recipient’s = RequiredProject Cost Share Match

For Example: Federal Award Amount = $80,00080/20 Match

$80,000 = $100,000 Adjusted Project Cost 80%

$100,000 X 20% = $20,000 Required match

2015 DOJ Grants Financial Guide, paragraph 3.3, Matching or Cost Sharing Requirements

Award Amount = Adjusted% of Federal share Project Cost

Adjusted x Recipient’s = RequiredProject Cost Share Match

For Example: Federal Award Amount = $60,00080/20 Match

$60,000 = $75,000 Adjusted Project Cost 80%

$75,000 X 20% = $15,000 Required match

Match Calculation Example 2

Reporting & Late Reporting

Late Reporting

• Timely reporting is critical to Indiana’s continued funding.

• ICJI needs the subgrantees’ report to complete its own reports to the Federal awarding agencies in an accurate and timely fashion.

• Sanctions will be imposed on subgrantees who fail to report timely.

Fiscal Report Due Dates VOCA

Quarterly Fiscal Reports are due in the Grants Management System (Egrants/Intelligrants) no later than 15 calendar days after the quarter end, with the exception of the final Fiscal Report, which is due 30 calendar days after the expiration date of the grant:

Quarter Quarter Ends Quarterly Fiscal Reports Due

1 December 31 January 15

2 March 31 April 15

3 June 30 July 15

4 September 30 October 30

Fiscal Report Due Dates STOP





3 March 31 April 15

4 June 30 July 30

Fiscal Report Due Dates SASP



1 October 31 November 15

2 January 31 February 15

3 April 30 May 15

4 July 31 August 30

Fiscal Report Due DatesDVPT





3 March 31 April 15

4 June 30 July 30

Fiscal Report Due Dates FVPSA




2 March 31 April 15

3 June 30 July 15


Fiscal Report Due DatesSSBG




2 March 31 April 15

3 June 30 July 15


Fiscal Report Due Dates SAVAF





3 March 31 April 15

4 June 30 July 30



Programmatic Report Due Dates - VOCA

Quarterly Programmatic Reports are due in the PMT System no later than 45 calendar days after the quarter end:

Quarter Quarter Ends Quarterly Programmatic Reports Due

1 December 31 February 15

2 March 31 May 15

3 June 30 August 15

4 September 30 November 15

Programmatic Report Due Dates -STOP

Quarterly Programmatic Reports are due in the Grants Management System (Egrants/Intelligrants) no later than 15 calendar days after the quarter end:




3 March 31 April 15

4 June 30 July 15

Programmatic Report Due Dates - SASP



1 October 31 November 15

2 January 31 February 15

3 April 30 May 15

4 July 31 August 15

Programmatic Report Due Dates – STOP &

SASPMuskie Reports are due no later than January 20 of each year. The PDF file is emailed with instructions to each subgrantee and is returned completed via email to ICJI.

Programmatic Report Due Dates - DVPT

Quarterly Programmatic Reports are due in the Grants Management System (Egrants/Intelligrants) no later than 15 calendar days after the quarter end. This programmatic report captures data for all domestic violence grants (DVPT, FVPSA, and SSBG):




3 March 31 April 15

4 June 30 July 15

Programmatic Report Due Dates – FVPSA &

SSBG

Programmatic data for these grants are reported into the DVPT

programmatic report. See the DVPT due dates.

Programmatic Report Due Dates - SAVAF





3 March 31 April 15

4 June 30 July 15

Budget Modifications and the 10%

Rule

Applicability

This rule/policy shall apply to all federal and state grants administered by ICJI with the exception of grants administered by ICJI’s Traffic Safety Division and grant awards totaling less than $10,000.

Subgrantees must initiate a Project Modification Request

(“PMR”) if the budget modification proposes to:

• Change the scope of the project;• Add a new category that did not previously

exist on the grant (for example, adding Travel as a budget category that did not previously exist.);

• Move grant funds from one category to another (for example, move funds from Personnel to Supplies and Operating); or

• Increase the amount of any existing line item.

Submitting a Budget Modification/PMR

If the subgrantee meets any of the criteria, a budget modification must be submitted via ICJI’s electronic grant management system in the form of a PMR.

The Budget Modification/PMR will be denied if:

• Exceeds 10% of the grant award;• Inconsistent with the grant purpose;• Unallowable;• Failure to support/further the program;• Supplanting;• Within 30 days of the end of the grant; and• Name Change with no salary difference.

Exceeds 10% of the Grant Award

PMRs/Budget modifications are capped at 10% of the grant award for the life of the grant. The desire to re-purpose match requires a PMR but does not count toward the 10%. There is no limit to the number of PMR’s that can be submitted to ICJI. Once the subgrantee has been allowed to move 10% of the grant award, subsequent PMRs will be denied. If additional grant funds are added to the grant via addendum or amendment, the budget modification cap raises by 10% of the additional monies.

Inconsistent with the Grant Purpose

If the budget modification would change the purpose of the grant award.

Unallowable

The proposed budget modification is for an unallowable item or activity.

Failure to Support/Further the Program

If the budget modification does not enhance the program, the budget

modification will be denied (for example, a subgrantee cannot give

everyone listed in Personnel raises).

Within 30 Calendar Days of the End of the Grant

Budget modifications submitted within 30 calendar days of the end of the

grant will be denied.

Name Change with no Salary Difference

There is no need to submit a budget modification if the only change is a

name change. If one employee leaves and a new employee is hired for the

same salary/pay rate, the subgranteeshall send an email to its assigned grant manger indicating the name

change within 10 working days of the new hire’s start date.

New HiresHow? E-mail your ICJI Grant

Manager.When? Within 10 working days of the

new hire’s start date. Why? ICJI is required to ensure that

only authorized grant funded employees are approved for reimbursement.

What? New hire’s name, start date, salary, and benefits.

Departed HiresHow? E-mail your ICJI Grant Manager.When? Within 10 working days of the

employee’s departure date. Why? ICJI is required to ensure that

(1) only authorized grant funded employees are approved for reimbursement and (2) that services are being provided.

What? Employee’s name, start date, salary, and benefits.

Exercise – Fact Pattern

Subgrantee A receives a VOCA grant of $60,000 from ICJI to provide therapy services to crime victims. Sally Employee resigned from Subgrantee A. It took Subgrantee A three months to fill Sally’s position, thereby leaving $5,000 unencumbered. Subgrantee A wants to submit a Budget Modification to re-purpose the $5,000. Which of the following budget modifications would ICJI consider approving?

Exercise

☐ Redistribute the money to give other grant-funded employees bonuses

Exercise

☐ Create a new budget category for travel to send a grant-funded employee to a conference that would enhance his/her ability to serve victims

Exercise

☐ Move $12,000 to create a new budget category

Exercise

☐ Use the $5,000 to buy food and drinks for individuals who attend therapy at Subgrantee A

Exercise

☐ Utilize the funds to pay for bed nights

Exercise

☐ Add two budgetary line items for two temporary employees who are completing Sally Employee’s duties.

Exercise

☐ Use the $5,000 to start a new program, which would create a day care for victims of crime.

Exercise

☐ Move the $5,000 from the Personnel budget category to the Supplies and Operating budget category to buy group therapy curriculum for grant-funded employees.

Exercise

☐ Order hats, t-shirts, and travel mugs with Subgrantee A’s logo and hotline number to be distributed

Exercise

☐ Host a training for the community concerning domestic violence

Exercise

☐ Move the $5,000 to the Benefits budget category to pay Betty Employee’s benefits. Betty Employee is hired to fill Sally Employee’s vacancy. Sally Employee did not take health care benefits from Subgrantee A, but Betty Employee needs health care benefits.

Exercise

☐ Increase the percentage of grant funds used on each of Subgrantee A’s utilities

Exercise

☐ Take the children of the victims to the bowling alley for bowling and pizza

Exercise

☐ Purchase 500 books concerning surviving domestic violence (one copy for each victim utilizing grant funded services)

Exercise

☐ Subgrant the $5,000 to Subgrantee B, who is a fellow member of the Sexual Assault Multi-Disciplinary Team to buy a forensic camera

Compliance Monitoring Visitations

How are grants selected for on-site monitoring?Risk assessment; New subgrant or subgrantee;Request from another ICJI Division; Grantee’s request for technical

assistance; andRandom sample.

Compliance Monitoring

What will be examined during the on-site visit?

Supporting Documentation;Actual expenditures versus approved

budget;Internal Control Protocols; andAccounting System.


What are the objectives of the ICJI review?

Conduct an analysis of grant activity to date;Determine compliance with audit report

submission requirements;Evaluate documentation;Provide technical assistance;Offer grant management best practices; and Arm subgrantees with the tools to successfully

manage ICJI administered grants.


Common ICJI Compliance Monitoring Team findings:

Inadequately maintained timesheets; Unsigned timesheets (by employee and/or

approving official); Issues/overstatement involving match; Expenditures outside the grant period; Lack of internal grant management protocols; Lack of source documentation

(invoices/receipts); and Distribution of gift cards without documentation.


Indirect Costs and the De Minimis Rate

Indirect Cost - Costs incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives of the grant. The law regarding allocation of indirect costs and determination of indirect cost rates can be found at 2 C.F.R. Part 200, Appendix IV (non-profits) and Appendix V (state/local government).


De mininis Rate – If a subgrantee has not negotiated an indirect cost rate, it may elect to utilize a de minimis rate of 10% of modified total direct costs.


Modified Total Direct Costs (“MTDC”) – The base includes all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and subawards up to the first $25,000 of each subaward (regardless of the period of performance of the subawrads under the award). MTDC excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs, and the portion of each subaward in excess of $25,000.

New E-grants System

• Awarded the project;• Currently in development; and• Anticipated deployment date is late

2017.

E-contracting

• ICJI is in discussion with IDOA; and• Information will be disseminated as it

becomes available.

Questions?

grant management & documentation - in.gov · grant management & documentation ... •...

Documents