Transcript COOPERATIVE FUNDING AGREEMENTS

COOPERATIVE AGREEMENT
FINANCIAL PROCEDURES
SUBJECTS
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Obligation of Agreements
Cost Principles
Payment Procedures
Reconciliation
Final Close Out
OBLIGATION OF AGREEMENTS
DOD FMR Volume 3 Chapter 8
ARMY – NGR 5-1/ANGI 63-101,
Chapter 12, and DFAS IN 37-1, Chapter 8
AIR – NGR 5-1/ANGI 63-101, Chapter 32
FULL VS INCREMENTAL
FUNDING
AIR - Fully Funded
ARMY – Fully Funded
(Preferred)
OBLIGATION OF AGREEMENTS
• Under a Continuing Resolution
Authority (CRA)
• Under a Separate State and Federal
Fiscal Years
COOPERATIVE AGREEMENT FUNDING
FUNDING
Federal Share (100%)
Federal Share (75%)
Federal Share (50%)
Federal Total
State Share (50%)
State Share (25%)
“CASH”
Quarterly Authority
Allotment
Maximum Funding Limitation
Annual Budget Authority
Annual Funding Program
Estimated Cost
$ 5,000,000.00
$_______________________
$_______________________
$ 5,000,000.00
$_______________________
$_______________________
$_______________________
$______________________
$________________________
$________________________
$_______________________
$_______________________
Program Income
$_______________________
State Total
$________________________
$_______________________
Grand Total
$________________________
$_______________________
In-Kind Assistance.
FLOWCHART SHOWING OBLIGATIONS OF
COOPERATIVE AGREEMENTS
Program Manager/Air Comptroller
Submits request to setup initial or modify CA
GOR
Reviews request/Prepares CA or modification
USPFO and TAG Signature
Federal PM/RA sets up
informal ledger.
Army PM
enters reservation
in AFCOS
GOR makes distribution
State Comptroller
set up data in State
Accounting System
Federal Accounting
ensures obligation
is posted in accounting
system
COST PRINCIPLES
GENERAL POLICY
ALL COSTS FOR WHICH REIMBURSEMENT
IS SOUGHT MUST BE SUPPORTED
AND DOCUMENTED.
COST REIMBURSEMENT RULES
INDIRECT COSTS
DIRECT COSTS
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ALLOCABLE COSTS
ALLOWABLE COSTS
REASONABLE COSTS
AVAILABILITY OF FUNDS
INDIRECT COSTS
 Incurred for a common or joint purpose benefiting
more than one cost objective
 Cost not readily assignable to the cost objectives
specifically benefited
National Guard appropriated funds are prohibited
from being used to reimburse indirect costs, except
for fringe benefits, under a Grant or Cooperative
Agreement.
DIRECT COSTS
Costs that can be identified directly with the
performance of a Cooperative Agreement
 Must meet the “consistent treatment rule”
 Must meet the cost reimbursement rules
ALLOCABLE
Cost must be allocable to the Cooperative
Agreement supported program, project or
facility.
The cost of goods or services purchased by
the state must be used to support the
Cooperative Agreement supported program.
ALLOWABLE
The cost must be allowable under applicable laws,
regulations and policy.
This includes Federal, DoD, Army, Air Force and
National Guard policies concerning the use and
management of federal funds.
REASONABLE
Cost must “not exceed that which would be incurred
by a prudent person under the circumstances
prevailing at the time the decision was made to incur
the cost.” OMB Circular A-87, Appendix A
AVAILABILITY OF FUNDS
Even of the State Military Department incurs costs that
are authorized, these costs cannot be reimbursed unless
sufficient funds have been obligated to the Cooperative
Agreement.
BURDEN OF PROOF
The “burden of proof” as to the
allocability, allowability and reasonableness
of costs for eligibility for reimbursement
rests with the State
FINAL AUTHORITY
The final authority in determine whether a particular costs
meets the costs principle rest with the USPFO/GRANTS
Officer.
COST PRINCIPLES
EXAMPLES
EXAMPLE #1
The State’s Military Department is billed for remote
connectivity to the Department of Administration.
This service is needed to have access to the State
Accounting system and the internet.
DIRECT OR INDIRECT?
EXAMPLE #2
Payment of a license fee to certify a
plumber who is employed under a
Cooperative Agreement Appendix.
DIRECT OR INDIRECT?
EXAMPLE #3
All State Agencies, to include the Military
Department, will be charged for each funding
line of any activity the State Treasurer
processes.
DIRECT OR INDIRECT?
EXAMPLE #4
The State Military Department is charged for
background checks on new State hires under
a Cooperative Agreement.
DIRECT OR INDIRECT?
EXAMPLE #5
Under the Single Audit Act” the State Military
Department contracted with a local CPA firm
to conduct an audit of the Cooperative
Agreements. The State wishes to pass this
cost on a pro rata basis to each Cooperative
Agreement.
DIRECT OR INDIRECT?
EXAMPLE #6
The State Military Department is assessed a yearly
charge on the Department’s per cent of mail
activity. This reimbursement helps offset the
operation of the State’s Central Mail Unit.
DIRECT OR INDIRECT?
EXAMPLE #7
Overtime pay for security
guards.
DIRECT OR INDIRECT?
EXAMPLE #8
Payment to State employees who are covered under
a Cooperative Agreement for making a suggestion
that saves funding for the Military Department.
DIRECT OR INDIRECT?
EXAMPLE #9
Provide training to State employees who are
authorized and employed under a Cooperative
Agreement.
DIRECT OR INDIRECT?
Travel of State Employees
• State Employees Must Travel on State
Orders
• Feds Reimburse the State up to the JFTR
Allowances
• The Use of Reimbursable Individual Travel
Orders is Prohibited
PAYMENT OPTIONS
• Reimbursement
• Advance Payment
PAYMENT REFERENCES
ARMY: NGR 5-1/ANGI 63-101,
Chapter 12
AIR: NGR 5-1/ANGI 63-101,
Chapter 32
REIMBURSEMENT PROCEDURE
• State funds expended
• State submits for reimbursement
• Federal Program Manager/Resource Advisor
must:
 Verify documentation for accuracy
 Certify charges are valid and are authorized
for payment
• Forward to ARNG(Pay/Exam)ANG-FM
REIMBURSEMENT FLOWCHART
Federal PM/RA request supplies, etc
State Military Department
Contracts with Vendor
Pays Vendor
Prepares request for
Reimbursement and submits to
Federal PM/RA
Federal PM/RA reviews request and
certifies
Forward request to Federal comptroller
Federal comptroller ensures funds
are obligated to cover reimbursement
Reimbursement processed through
CAPS as EFT Payment
DFAS processes EFT payment
to
State Military Department
ADVANCE PAYMENT
• DOD FMR Volume 12 Chapter 5
• DOD FMR Volume 10 Chapter 19
• NGR 5-1/ANGI 63-101 Chapter 12 (Army)
• NGR 5-1/ANGI 63-101 Chapter 32 (Air)
ADVANCE PAYMENT
• State Comptroller may request an
advance
• Advance may be required by
State statute
• Advance is based on cash flow and
reimbursement cycle time
HANDOUT
ADVANCE PAYMENT
• USPFO APPROVE/DISAPPROVE
• ARMY - Copy furnished to ARNGRC NGBARC
• At year end outstanding Advances must
be returned
• At anytime the Advance cannot exceed the
unpaid Federal portion of the
Cooperative Agreement
Advance and Reimbursement Payments
Payment to be made within 7
days if EDI & EFT used
DOD FMR Volume 10 Chapter 19, 190106
DOD FMR Volume 10 Chapter 7, 070102 G
CASH MANAGEMENT IMPROVEMENT
ACT (CMIA) 31 CFR 205
• Federal agencies must make timely fund
disbursements and grant awards to States.
• States and Federal agencies must
minimize the time between the advance of
Federal funds to States and the State
presenting settlement documentation or
check to close advance.
CASH MANAGEMENT IMPROVEMENT
ACT (CMIA) 31 CFR 205
• States are entitled to interest from the Federal
Government for the time State funds are expended for
program purposes pending Federal disbursement. The
Federal Government is entitled to interest from the
States for the time Federal funds are in State accounts
(advance) pending the State presenting settlement
documentation or check to close advance.
Treasury may charge responsible Federal agencies if
they are found to be flagrant or repeatedly incur Federal
interest liabilities.
RECONCILIATION
ARMY: DFAS IN 37-1, CHAPTER 27
AIR/ARMY: DoD FMR 7000-14R Vol 3
Chap 8
Tri-annual reviews
RECOMMENDED RECONCILIATION
• Monthly
 Status letter from State Comptroller
 Federal Program Manager reconcile to
include outstanding items
 Accounting Branch reconcile obligations
and reimbursements
RECOMMENDED RECONCILIATION
• End of Year
 State Comptroller, Federal Program
Manager, Federal Accounting
Branch meet
 Identify shortage/excess funds
FINAL SETTLEMENT/CLOSE
OUT OF COOPERATIVE
AGREEMENTS
REFERENCES
ARMY - NGR 5-1/ANGI 63-101
CHAPTER 12
AIR - NGR 5-1/ANGI 63-101
CHAPTER 32
MY CONCERN IS NOT
NECESSARILY HOW LONG AN
AGREEMENT IS OPEN, BUT
RATHER WE DON’T KNOW
WHY THE AGREEMENT IS
OPEN
CLOSE OUT DEFINED
When the state has submitted
their FINAL request for
reimbursement the Appendix is
closed
THE USPFO IS REQUIRED TO
CLOSE OUT THE AGREEMENTS
NLT 90 DAYS AFTER THE END OF
THE FEDERAL FISCAL YEAR
QUESTION?
FROM THE STATES PERSPECTIVE,
WHAT IS REQUIRED IF THERE ARE
PURCHASES THAT REMAIN
UNLIQUIDATED AND A REQUEST FOR REIMBURSEMENT TO THE GRANTS OFFICER
IS REQUIRED?
The State Resource Manager
must submit a request for
extension.
• Federal Program Managers must have all
requests for services, supplies, etc to the
State Comptroller by established cutoff.
• NLT 30 Sep State Comptroller awards
contracts.
REQUESTS FOR EXTENSION
MUST CONTAIN THE
FOLLOWING ELEMENTS
• Detailed listing of unliquidated
obligations.
• Anticipated date of liquidation.
GRANTS OFFICER
APPROVES OR
DISAPPROVES REQUEST
(If approved, Cooperative Agreement
remains open until the last item is
liquidated or until further extensions
are granted)
State continues to submit
Request for Extensions until
all outstanding obligations
are liquidated.
FINAL CLOSEOUT
• Final Request for Reimbursement
received from the State.
• Request from Federal Program
Manager to modify agreement to actual
amount of reimbursement.
• Final Modification completed by GOR.
COST NOT DISCLOSED
• State Comptroller submits separate
request for reimbursement to Grants Officer.
• Grants Officer validates request and
determines source of funding if approved.
MANAGEMENT CONTROLS
• Are the CA’s incrementally or fully funded and
have appropriate obligations been made?
• Have the Program Manager, Federal Accounting
and State Comptroller reconciled financial data
quarterly?
• Have prior year cooperative agreements been
closed out within the 90 day period, or request
for extension granted?
• Ensure advance to State does not exceed the
amount of the agreement and is based on a cash
flow cycle.
MANAGEMENT CONTROLS
• Has advance been collected in a timely manner?
• Do requests for reimbursements meet the cost
reimbursement rules of allowable, allocable,
reasonable and availability of funds?
• Has the federal Program Manager or Assistant
USPFO’s certified request for reimbursement
prior to submitting to the Finance Office for
payment?
QUESTIONS