raúl soto ph.d., associate director cte 1 cte funding & omni circular

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Raúl Soto Ph.D., Associate Director CTE 1 CTE Funding & OMNI Circular

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Ral Soto Ph.D., Associate Director CTE 1 CTE Funding & OMNI Circular Slide 2 Agenda 1.Review Perkins Funding Requirements 2.Overview of new Omni Circular Disclaimer: Information adapted from Michael Brusteins January 21, 2014 presentation in Columbus Ohio Slide 3 What are the allowable uses of Perkins funds? 1.Perkins Act 2.EDGAR 3.OMB Omni Circular Basic Roadmap Slide 4 Perkins Act 1.Serve only CTE students 2.Meet the Local Plan requirements on Section 134 (Budgets) 3.Satisfy the Section 135 requirements on uses of funds 4.Accountability Section 113 5.Local Improvement Plans Section 123 Slide 5 Perkins Act Section 135 a)Improve b)Mandatory uses c)Permissive uses d)Administrative costs Slide 6 Five-Step roadmap in developing your Perkins Budget 1)Is the item allowable under a)Perkins b)State Plan c)State / Local Policies d)Omni Circular Slide 7 2)Is the item necessary? 3)Is the cost reasonable? 4)Is the cost allocable to Perkins? 5)Is the cost adequately documented? Slide 8 OMB Revised Administrative, Cost, and Audit Rules Governing All Federal Grants The Super Circular Omni Circular The One-Stop Shop for Federal Assistance Slide 9 Date of Applicability of Revised Rules All Drawdowns, after December 26, 2014 at State Level July 1, 2015 at Local Level Slide 10 What is covered? A-102 Administrative Rules State / Local Part 80 EDGAR A-110 Administrative Rules Postsecondary Part 74 EDGAR A-87 Cost Rules State / Local A-21 Cost Rules Rules Postsecondary A-122 Cost Rules Nonprofit A-133 Audit Rules (>$750,000) Slide 11 Education Department General Administrative Rules (EDGAR) Part 76 State Administrative Rules Part 80 General Administrative Rules Slide 12 EDGAR Part 80 1.Standards for Financial Management* 2.Payments* 3.Allowable Costs* 4.Period of Availability of Funds* 5.Program Income* 6.Non Federal Audit* * Omni Circular Changes Slide 13 EDGAR Part 80 (cont.) 7.Changes* 8.Equipment* 9.Supplies* 10.Procurement* 11.Monitoring* 12.Retention of Records *Omni Circular Changes Slide 14 Who is covered? All nonfederal entities expending federal awards Slide 15 Reasons for the Change? 1.Simplicity 2.Consistency 3.Obama Administration Executive Order on Regulatory Review Increase Efficiency Strengthen Oversight Slide 16 Most Significant Change Shift from focus on Compliance to focus on PERFORMANCE!!! Slide 17 Flexibility The Omni Circular adds significant flexibility to way grantee / subgrantee can adopt their own processes Example: Time and Effort Slide 18 Personnel Activity Report 1.After the fact 2.At least monthly 3.100% of effort 4.Certified by employee Slide 19 New OMNI: (200.430) Charges to federal awards must be based on records 1.Supported by a system of internal controls 2.Incorporated into official records of grantee 3.Reasonably reflect total activity for which employee is compensated Slide 20 200.430 New requirements are less prescriptive Grantees encouraged to adopt substitute systems Slide 21 200.430 Acceptable now to allocate sampled employees supervisors, clerical and support staffs, based on results of sampled employees *Note: Guidance forthcoming Slide 22 Employees assigned to administrative functions Salaries of administrative and clerical staff should be treated as indirect unless all of following are met: 1.Such services are integral to the activity 2.Individuals can be specifically identified with the activity 3.Such costs are explicitly included in the budget 4.Costs not also recovered as indirect Slide 23 New Emphasis on Risk 200.205 ODE must have in place a framework for evaluating risks before applicant receives funding Slide 24 Risk Factors: 1.Financial Stability 2.Quality of Management System 3.History of Performance 4.Audit Reports 5.Applicants Ability to Effectively Implement Program Slide 25 Fiscal Accountability 200.415 Major emphasis on strengthening accountability by improving policies that protect against waste, fraud and abuse (200.415) Slide 26 Conflict of Interest 200.112 All non federal entities must establish conflict of interest policies, and disclose in writing any potential conflict to federal awarding agency Slide 27 Mandatory Disclosures 200.113 Non federal entity must disclose in writing in timely manner to federal agency or pass- through all violations of federal criminal law involving fraud, bribery or gratuity violations potentially affecting federal award Slide 28 Significant Changes to Core Financial Management Standards 200.302 Written Procedures on, Cash Management Allowability of Costs Slide 29 Cash Management Subgrantee must be able to account for the receipt, obligation and expenditure Interest amounts up to $500 may be retained for administrative expense Slide 30 Meals / Conferences / Travel 200.432 Allowable conference costs include rental of facilities, costs of meals and refreshments, transportation, unless restricted by the federal award Conference hosts must exercise discretion in ensuring costs are appropriate, necessary and managed in manner than minimizes costs to federal award Slide 31 200.474 - Travel Travel costs may be charged on actual, per diem, or mileage basis Travel charges must be consistent with entitys written travel reimbursement policies Slide 32 200.474 - Travel Grantee must retain documentation that participation of individual in conference is necessary for the project Slide 33 200.474 - Travel Travel costs must be reasonable and consistent with written travel policy /or follow General Services Administration 48, Code of Federal Regulations 31.205-46(a) Slide 34 Computing Devices 200.20 Definition: Machines used to acquire, store, analyze, process, and publish data electronically Slide 35 Supplies 200.314 Now includes computing devices Residual inventory of unused supplies exceeding $5,000 in total aggregate value must compensate federal government Slide 36 Changes to Equipment Rules 200.313 Subgrantee cannot encumber the property without approval of pass-through Can shared use, if such use will not interfere 1 st preference projects supported by federal awarding agency 2 nd preference project funded by other federal agencies 3 rd preference use for non federally funded programs Slide 37 User Fees User fees on equipment should be considered if appropriate But user fees should not be less than private companies charge for equivalent services Slide 38 Trade-In on Equipment Allowed When grantee acquiring replacement equipment, the equipment to be replaced may be used as a trade-in without recourse to federal agency Slide 39 Disposition of Equipment Upon disposition federal agency may permit grantee to retain $500 or 10% of proceeds, whichever is less, for handling expenses Slide 40 Internal Controls on Equipment, Supplies, Computing Devices 200.302(b)(4) Regardless of cost, grantee must maintain effective control and safeguard all assets and assure that they are used solely for authorized purposes. Slide 41 Micro-Purchases 200.320 Acquisitions of supplies or services which do not exceed $3,000 may be solicited without competitive quotations if the non federal entity considers the price to be reasonable Slide 42 Insurance Coverage 200.310 At a minimum, grantee must provide equivalent insurance coverage on equipment purchased with federal funds as provided to equipment purchased with nonfederal funds Slide 43 Audit Resolution 200.501 Federal Compliance requirements do not pass through to contractors Auditee is responsible for ensuring compliance for procurement transactions Slide 44 Supplanting Perkins funds must supplement, not supplant, state and local funds for CTE Slide 45 Non-Supplant Tests 1.Perkins funds used for same activity that was paid for in prior year with state / local funds? 2.Perkins funds paid for activity mandated by state / local law? Slide 46 But what if activity would be discontinued in absence of Perkins federal funds? You need to maintain a)Documentation on reduction b)Documentation that activity would have been eliminated without Perkins funds Slide 47 Slide 48 Career-Technical Education Administrative Field Services 614-446-4835 education.ohio.gov Slide 49