Transcript Towards a National Funders Network for Workforce
SIF Sub-Grantees Subaward Agreement/ MOU Webinar
Prepared by Steve Adams, Deputy Director, NFWS
February 11, 2011
Agenda
Introduction Why The Language is There Reviewing Subaward Agreement Reviewing MOU Other Discussion 2
Introductions
Steve Adams (NFWS) Shannon Mason (NFWS) Jill Moriello (JFF Grants Management Analyst) Ruth French – auditor at JFF (fed funds experience) 3
We’re new at federal subgranting
Re-granting federal funds is fairly new to us. So we haven’t tested our subaward agreements much. Subaward could have been clearer and with fewer requirements.
We should have provided additional guidance along with fiscal webinar.
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Why the language is there
Our federal grant from CNCS/SIF requires that we notify subgrantees that the same rules apply to them We have to show we’re in compliance Again, could have been clearer with you 5
The Subaward agreement
Go to Subaward agreement Go to MOU 6
Cost Principals
Allowable/Unallowable Allocable Reasonable Consistent 7
Allowable Costs
Be included in the Approved Budget Be reasonable and allocable for the performance of the award Be given consistent treatment within the entire organization Be in accordance with GAAP Not included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program 8
Unallowable Costs
Examples Lobbying Fines and Penalties Expenses not necessary to meet program objectives Costs that would constitute waste, fraud and abuse Unreasonable costs from a “prudent person” perspective 9
Allocable Costs
A cost is allocable to the grant if: It is treated consistently with other costs incurred for the same purpose in like circumstances and if: It is incurred specifically for the award Benefits both the award and other work and can be distributed in reasonable proportion to the benefits received or Is necessary to the overall operation of the organization 10
Reasonable
A cost is reasonable if, in its nature or amount, it does 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 costs 11
Consistent
Grantees must be consistent in assigning costs Regardless of the source of funding, i.e. federally or non-federally sponsored activities, and Following written cost allocation plan, as applicable Charges must be consistent with those normally allowed in like circumstances in the organization’s non-federally sponsored activities 12
Proper Documentation is a Must
Document, Document, Document Allowable Allocable Reasonable Consistently Applied
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Tracking Federal Intermediary and Sub Grantee Revenues and Expenditures 14
Efficient Accounting System
Accounting system must be capable of: Distinguishing between grant vs. non grant related expenditures Identifying costs by Program Year Identifying costs by Budget Category Accounting for each award/grant separately Properly segregates fund sources Easily provide management with financial reports at both the detail and summary levels 15
Fiscal Responsibility Highlights
Effective Financial Management Written and followed policies and procedures Qualified and trained financial staff Effective communications Succession planning and cross-training Self-assessment and continuous improvement Active, knowledgeable and informed Board and finance committee 16
Fiscal Responsibility Highlights
(continued) Overall compliance with State and Federal regulations Accurate, timely and complete financial reporting Tracking of budget to actual expenses Ensure key staff understand roles, responsibility, understand each other’s priorities and work together 17
Criminal History Check
Statewide Criminal History Search www.NationalSexOffenderRegistry.gov
Differs by State FBI can be substituted for a statewide search Murder is the only disqualifier Required personnel: Anyone receiving a salary Prime or Sub-grantee level —all are required Refer to CNCS FAQ on website for further assistance 18
DISCUSSION
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