n e hsa fiscal systems

8/13/2019 N E HSA Fiscal Systems

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Belinda Rinker, JD

Senior Advisor to the Office of Head [email protected]

The Elements OfAn Effective Fiscal System
mailto:[email protected]:[email protected]


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HumanResource

s

ProgramGovernan

ce

ERSEA

Child andFamily

Outcomes

Self-Assessme

nt

Child andFamily

Outcomes

Communication

Records &Reporting

Facilities,Materials &Equipment

Planning

OngoingMonitoring

Head Start

Performance Standards

1301, 1304.50,1304.511304.52, 1304.53, 1305

Fiscal Regulations

45 CFR 74 or 92;2 CFR 220,225 or 230


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Families

Community

Children


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Head Start

Early Head

Start

Grantee

Organization


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Governance

FiscalProgram


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Governance

FiscalProgram


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Governance

FiscalProgram


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Fiscal System Elements

Financial

Management Systems

Recordkeeping and

Reporting

Procurement

Compensatio

n

CostPrinciple

s

Facilitiesand

Property

Non-federalShare

Cost Allocation


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Systems

45 CFR 74.21 or 45 CFR 92.20

Accurate, current and complete disclosure of programfinances.

Records that adequately identify the source andapplication of funds.

Effective control over and accountability for funds,

property and program assets. Separation of fiscal duties

Board member with fiscal management or accountingexpertise

Annual Financial Audit

Comparison of actual outlays (amounts spent) withbudgeted costs.

Written procedures to minimize the time betweendrawdown and expenditure (payment) of costs and

expenses.


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Recordkeeping and Reporting Personnel files.

Volunteer files. Food service and menu records.

USDA Nutrition Assistance Programs

Facilities and equipment records. Property inventory and facilities records

Valid licenses and registrations required by Federal, State orlocal law

Insurance records. General liability, property, student accident, title insurance

(facilities) Fiscal records.

Status of grant funds (budget, projected and actual)

Cost are reasonable, allocable and allowable (cost principles)

Fiscal reports. Internal: Board, Policy Council (monthly), budgets, aged


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Procurement45 CFR 74.42, 74.44 or 45 CFR 92.36

Written procurement procedure applicable to goodsand services purchased.

Complies with all Federal, State and local regulations: bidprocess, Davis-Bacon Act compliance

Includes written code of conduct for employees engagedin awarding or administering contracts: related parties,conflicts of interest

Contracts are accurate, complete, signed and up to

date. Purchases of goods: supplies, equipment, vehicles

Personal service contracts: nutrition consultant, mentalhealth professional

Delegate agency agreements


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Compensation Compensation for all employees meets the cost

principle requirements: necessary, allocable and

reasonable. Wages, benefits, bonus and incentives

Executive Level II limitation is met ($179,700)

Adequate records are available to supportcompensation.

Time records for all non-exempt employees

Payroll records for all employees

Personnel activity reports Compensation costs for employees whose services

benefit more than one program are property allocated.

Compensation reporting (external) is timely, complete

and accurate: IRS, state taxes, workers compensation,


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Cost Principles2 CFR Part 220, 2 CFR Part 225 or 2 CFR Part 230

Written procurement procedures to determine that all

expenses are allowable, necessary and allocable.Adequate documentation supports expenditure.

Allowable: Reasonable for performance of the award (see below)

Consistent with policies and procedures and treated consistently Not charged to another program

Adequately documented

Cost limitations and exclusions are followed

Reasonable: does not exceed what a prudent person

would pay under similar circumstances at the time thedecision was made. Generally recognized as ordinary and necessary

Complies with sound business practices: arms length transactions

Prudence was exercised in light of responsibilities Follows established ractices and does not un ustifiabl increase


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Cost Principles (Continued)2 CFR Part 220, 2 CFR Part 225 or 2 CFR Part 230

Allocable: A cost is allocable (can be charged) to aparticular grant if it is charged in accordance with thebenefit to the grant:

The cost is incurred specifically (100%) for the chargedgrant, or

The cost benefits both the award and grant(s) and can bedistributed between or among programs in reasonableproportion to the benefits received, or

The expense is necessary to the overall operation of the

organization, although a direct relationship to anyparticular grant cannot be shown.

Costs may not be shifted from one grant to another tocover deficiencies in funding or avoid restrictions.

The cost principles also apply to costs and expenses


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Non-federal Share

The grantee agency must provide 20 percent of the

total costs of the Head Start program unless a waiverhas been granted.

For every federal Head Start dollar received the granteemust provide twenty-five cents (absent a waiver)

Criteria for application for waiver (written) are lack ofcommunity resources, initial costs, unanticipated costincreases, major disaster and community impact (See

ACF-PI-HS-12-02)

Allowable non-federal share costs meet applicable costprinciples: necessary, reasonable and prudent.

Adequate documentation is required to support non-federal share costs.

Except where specifically authorized by statute, other-


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Cost Allocation

Cost allocation is required when costs are shared by

two or more programs. Includes costs shared between Head Start and Early

Head Start

Includes costs shared between either Head Start or EarlyHead Start and programs or services from anotherfunding source

Exception is either Head Start or Early Head Start and itsassociated USDA Nutrition Assistance Program

Shared costs must be fairly allocated between oramong the programs that benefit from those costs inaccordance with a cost allocation plan.

Grantees have the option to apply for a negotiated

indirect cost rate or allocate indirect costs.


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Facilities and Property45 CFR Part 1309, 45 CFR Part 74 or 45 CFR Part 92

Special requirements apply to all facilities which are

purchased (initially or through mortgage payments),constructed or undergo major renovations using Head Startfunds (in whole or in part).

Special notices must be filed in the official (real property)records to protect federal funds used for facilities activities.

Personal property (worth at least $5,000) must be includedon a detailed inventory prepared every two years.

Permission is required before a program can use anyproperty purchased in whole or in part with Head Start funds

as collateral for a loan, including lines of credit. Permission is required before any property worth $5,000 or

more purchased in whole or in part with Head Start funds issold or transferred.

Detailed facilities and property records are required,including proof of insurance.


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Questions and Comments

n e hsa fiscal systems

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