Transcript NATIONAL ANNUAL TITLE III - University of the Virgin Islands

Effective Title III Program
Administration
Dr. Haywood L. Strickland, President and CEO
Wiley College * Marshall, Texas
June 3-5, 2008
It’s All About Stewardship
Excellence
• Fiscal Accountability
• Program Administration
• Monitoring
• Demonstrating Results
Did you do what you
said you were going to
do? At what cost?
PART I: FISCAL
ACCOUNTABILITY
ORDER OF PRECEDENCE WHEN
DECIDING ALLOWABILITY OF COST
• Legislation
• Program Regulations
• EDGAR (Incorporates OMB A-21 Cost
Principles for Educational Institutions)
• Approved Application
ALLOWABLE COSTS
(USE OF FUNDS)
• Legislation – Section 323 of Higher
Education Act of 1965 as amended U.S. Code
1060
• Part B, Historically Black Colleges &
Universities
ALLOWABLE COSTS
• Section 323 (a) General Authorization: Use of
funds
– Purchase, rental, or lease of scientific or
laboratory equipment for educational purposes,
including instruction and research purposes.
– Construction, maintenance, renovation, and
improvement in classroom, library, laboratory,
and other instructional facilities including
purchase or rental of telecommunications
technology equipment or services.
Allowable Costs (Sec. 323 continued)
– Support faculty exchanges, and faculty development
and faculty fellowships to assist in attaining
advanced degrees in their field of instruction.
– Academic instruction in disciplines in which African
Americans are underrepresented.
– Purchase of library books, periodicals, microfilm,
and other educational materials, including
telecommunications program materials.
– Tutoring, counseling, and student service programs
designed to improve academic success.
Allowable Costs (Sec. 323 continued)
– Funds and administrative management, and
acquisition of equipment for use in strengthening
funds management.
– Joint use of facilities, such as laboratories and
libraries.
– Establishing or improving a development office to
strengthen or improve contributions from alumni and
the private sector.
– Establishing or enhancing a program of teacher
education designed to qualify students to teach in a
public elementary or secondary school that shall
include, as part of such program, preparation for
teacher certification.
Allowable Costs (Sec. 323 continued)
–
–
–
Establishing community outreach programs which will
encourage elementary and secondary students to
develop the academic skills and the interest to pursue
postsecondary education.
Establishing or improving an endowment fund.
OTHER ACTIVITIES submitted pursuant to section
323 that:
1. contribute to carrying out the purpose of this
part; and
2. are approved by the Secretary as part of the
review and acceptance of such application
EDGAR REQUIREMENTS
• EDUCATION GENERAL ADMINISTRATIVE
REGULATIONS (EDGAR)
• SECTION 72.27 ALLOWABLE COST
– Incorporates OMB Circular A-21, Major Cost
Principles for Educational Institutions
ALLOWABLE & UNALLOWABLE COSTS
• OMB Circular A-21
Objective
Provides clear cut guidance on all
expenditures: allowable, allocable,
reasonable, and prudent.
OMB A-21 COST PRINCIPLES
• Purpose
– Establishing principles for
determining costs applicable to grants,
contracts, and other agreements with
educational institutions.
OMB A-21 COST PRINCIPLES
• Applicability
– All federal agencies that sponsor research
and development and other work at
educational institutions shall apply the
provisions of this Circular in determining
costs incurred for such work.
OMB A-21 COST PRINCIPLES
• TABLE OF CONTENTS
A.
B.
C.
D.
E.
F.
Purpose and Scope
Definition of Terms
Basic Considerations
Direct Costs
Indirect Costs
Identification and assignment of indirect
costs
OMB A-21 COST PRINCIPLES
• TABLE OF CONTENTS (Continued)
G. Determination & Application of Indirect
Cost Rate or Rates
H. Simplified Method for Small Institutions
I. Reserved
J. General Provisions for Selected Items of
Costs
K. Certification of Changes
FIRST LEVEL DETERMINATION OF
ALLOWABLE COST IN OMB A-21
• ALLOCABLE TO THE GRANT
– Benefits received
• REASONABLE
– Necessary for the operation
• ALLOWABLE
– Circular, law, local regulation
• PRUDENT
– Comparability with use of institutional funds
UNALLOWABLE COSTS
• OMB Circular A-21, Section J
– Alcoholic Beverages
– Communications (i.e. line charges, unit
charges)
– Donations & Contributions
– Entertainment (i.e. anything remotely related)
– Executive Lobbying (i.e. attempting to
improperly influence the decisions of officers
or employees of the Federal Government)
UNALLOWABLE COSTS (Continued)
– Exclusive Memberships, Subscriptions
& Professional Activity (i.e. Country
Clubs)
– Pre-agreement Costs (Unallowable
unless pre-approved)
– Scholarships & Student Aid
INDIRECT COSTS
INDIRECT COSTS
ARE NOT ALLOWABLE
IN THE TITLE III PROGRAM
THINGS TO REMEMBER
• TO DETERMINE IF A COST IS
ALLOWABLE OR
UNALLOWABLE,
CHECK THE FOLLOWING
SOURCES:
• The Law
• Program Regulations
• EDGAR, 34 CFR 74.27 Allowable Costs
• OMB Circular 21
• Approved Application
ACCOUNTABILITY
• GPRA – 1993
– Government Performance
and Results Act
– Ties federal funding to results
– Greater accountability
» GPRA indicators reflected in objectives
and activities
» Include milestones in objectives to
determine success accurately
DRAWDOWN POLICY
• Request funds for immediate needs
• Minimize time between requests &
expenditures (72 HOURS)
• Rate of draw downs commensurate with
approved scope & milestones
DOE CONCERNS
• Large amounts of
unobligated funds
• Excessive or infrequent requests
• Project goals/objectives not met – DOE
monitors
– Student population is not being served
as proposal objectives indicates
– Maybe, HBCU’s DON’T NEED THE
MONEY
GAPS MONITORING
OF AVAILABLE BALANCES
• Within 90 days, “flags” grants with 70%
or more of funds remaining
• Verifies financial data reported on
annual performance report
PART II: TITLE III PROGRAM
ADMINISTRATION AND
MANAGEMENT
ELEMENTS OF AN EXEMPLARY
TITLE III
PROJECT ADMINISTRATION PROGRAM
•
RESPONSIBILITIES OF A TITLE III
PROJECT DIRECTOR
A. Provide leadership and coordination
B. Facilitate integration of Title III
activities
RESPONSIBILITIES (Cont.)
C. Support an ongoing process of institutional
effectiveness
D. Develop and update a project handbook to
include policies and procedures
E. Monitor expenditures and reconcile monthly
F. Ensure conduct of an annual external evaluation
RESPONSIBILITIES (Cont.)
G. Ensure that Title III funds are disbursed in
keeping with:
•
Education Departments General and
Administrative Regulations (EDGAR) (Revised
June 23, 2005);
•
A-110 (Revised April 25, 2007);
•
OMB Circular A-21 (revised May 10, 2004);
and
•
A-133 (revised June 27, 2003).
Roles and Responsibilities of
Title III Activity Directors
The Title III Activity Director is responsible
for….
1.
2.
3.
4.
5.
6.
7.
8.
Activity management and oversight
Implementation of objectives
Supervision and monitoring of activity staff
Reporting activity status/progress
Approval and processing of requisition
Keeping abreast of grant regs & information
Maintaining up-to-date activity files
Maintaining up-to-date equipment inventory
Roles and Responsibilities of Title III Activity
Director (Cont.)
1.
2.
3.
4.
Budget Monitoring and Oversight
Staff meeting attendance
Approval of travel requests
Preparation and submission of annual plan of
operation
5. Documentation of objective implementation
6. Preparation for and participation in internal and
external Title III activity evaluation, site
review, etc.
MAJOR COMPLIANCE PROVISIONS
A. EDGAR
1. Property Controls
2. Prior Approval Requirements
3. Notification of Change in Key Personnel
4. Annual Evaluations of Performance
B. OMB Circular A-110
1. Available over the Internet at
http://www.whitehouse.gov/omb/circulars/a110_co
mpliance/06/pt3.pdf
2. An institution cannot hold excess cash on
hand. (Funds to be spent in 72 HOURS)
3. A-110 also describes “Davis-Bacon”
compliance requirements.
C. OMB CIRCULAR A-21
The Cost Principles
• As a reminder, follow
four guidelines
ALLOWABLE
ALLOCABLE
REASONABLE
PRUDENT
OMB CIRCULAR A-133/THE
SINGLE AUDIT REQUIREMENT
A-133 single audit requirement
pertains to all federal grants
which exceed $500,000. A133 auditing defines
institutions as:
Low-Risk or High Risk
D. OMB CIRCULAR A-133/The Single
Audit Requirements
1. A system of checks and balances
2. Proof of written policies and
procedures
3. Property Control Management
OMB CIRCULAR A-133/The Single Audit
Requirements (cont.)
4. A review of all reports filed
• The Financial Transactions (the 269s; 272s);
• Performance Reports;
• Annual Audit must be filed with the Federal
Audit Clearinghouse (which must include any
corrective action plans prepared by the
institution)
OMB CIRCULAR A-133/The Single
Audit Requirements (cont.)
5. Proof of compliance with the Davis-Bacon
Act.
6. Proof that all Expenditures Constitute
Allowable Costs.
PART III
MONITORING
BEGINS WITH
MEASURABLE
OBJECTIVES
Writing Measurable Objectives
• There are many formats for writing
objectives. During this workshop we will
use the National Laboratory for Higher
Education (NLHE) format and content.
A well written objective should take the form of a
single statement that contains the following:
1. QUANTIFIED OUTCOME
–
State the projected end result in measurable terms
A well written objective should also
include….
2. Time
–
Specify the date that the objective will be
completed.
The following are optional parts of
an objective:
A. Responsibility:
State what person(s) or unit is/are responsible
for implementing the objective.
B. Conditions:
Specify special conditions (if any) that will or
may impact that outcome of the objective.
Many grants, such as the Title III Grant, require each
objective to have an anticipated result.
The anticipated result statement should include…
• Performance Level and Baseline Data
• Evaluation Method(s) Date(s)
• Type and Location of Documentation
MONITORING
The Ongoing Review of Activities
to Manage Performance
•Title III Activity Timetable
•Internal Monitoring of Progress
•Monthly Time and Effort Reports
•Updated Equipment Inventory Records
FISCAL MONITORING
• Monthly Expenditure Reports by Activity
• Reconciled Monthly to Capture
Discounts, Cost-Savings, and Consistency with Drawdown
Reports
• Required for A- 133 Audit & Timely Submission to the
Audit Clearinghouse
• Facilitate Title III E-Reporting
GRANTEE’S RESPONSIBILITIES
• Project success & financial
accountability
• Submit annual & final performance
reports
• Valid & reliable data
• Report of GPRA standards & indicators
GRANTEE’S RESPONSIBILITIES
• ON SITE:
– Funded application & grant award
– Previous audits & site visit reports
– Annual Performance Reports
– Project revision(s) documentation
– Current budget & personnel list
COMMON AUDIT EXCEPTIONS
• Things that should NEVER happen:
– Poor recordkeeping
– Unallowable costs or activities
– Missing time & effort reports
– Failure to follow procurement standards
– Lack of internal controls
– Failure to obtain prior approval if required
– Poor cash management (excessive draws)
AUDIT REQUIREMENTS
• Non-Federal audit IF expending
$500,000 or more annually in Federal
awards
• Mail to Federal Audit Clearinghouse
OMB CIRCULAR A-133
EXPANDED AUTHORITIES
• GOALS: (Promote Successful Project Outcomes)
– Increase flexibility
– Increase accountability
– Reduce paperwork burden
– Develop partnerships
EXPANDED AUTHORITIES (Cont.)
• PRE-AWARD COSTS:
• May be incurred up to 90 days before
budget period begins
• NO PRIOR APPROVAL REQUIRED
EXPANDED AUTHORITIES (Cont.)
• PRE-AWARD COSTS OVERVIEW:
– Reasonable expectation of receiving a
grant
– Incurred at own risk
– ED funds are not available for draw down
until the budget period begins
– NOT for cost over-runs
EXPANDED AUTHORITIES
• CARRYOVER:
– Unexpended funds carried over without
prior approval
– May be used for allowable costs within the
approved scope
• Complete unfinished objectives
• “Other” activities within scope
EXPANDED AUTHORITIES (Cont.)
• CARRYOVER (continued):
– Program Officer may require
• Written statement to include:
–How will unexpended funds be used?
–When will unexpended funds be used?
–In rare cases, new funds may be reduced
PERFORMANCE MONITORING:
The Routine Tracking of:
Activity Inputs and Outputs
Adequacy of Project Management
Extent of Compliance
Level of Effort
Adequacy of Property Controls
MONITORING
Continuous Internal Review of Data to Manage
the Implementation Process
EVALUATION
Periodic External Review of Information to
Describe Short and Long Term Outcomes
and Benefits
PART IV
DEMONSTRATING RESULTS
EXTERNAL EVALUATION
ENCOMPASSES BOTH
FORMATIVE & SUMMATIVE
METHODOLOGIES
KINDS OF EVALUATIONS
• FORMATIVE
for improvement purposes
• SUMMATIVE
to describe program impacts
TYPICAL FORMATIVE
EVALUATION ACTIVITIES
Include Review of:
•
•
•
•
•
•
Time and Effort Reports
Property Control Procedures
Monthly and Quarterly Progress Reports
Fund Accounting Procedures
Internal Monitoring Strategies
General Grant Management Procedures (Checks
and Balances)
TYPICAL SUMMATIVE EVALUATION ACTIVITIES
Include Review of :
• Annual E-Performance Reports
• A-133 Audit Report Findings & Follow-Up
• Assessment Instruments and Results, and
• Level of Institutional Commitment
PURPOSES OF EVALUATION
• Document Accomplishments
• Provide Data on Cost-Effectiveness
• Describe Program Effectiveness
PURPOSES (Cont.)
• Document Compliances with Program
Regulations
• Ensure Agency (Donor) that Funds were
used as Approved
THE EVALUATION PROCESS
ENTAILS
•Verification of Relevant Documentation
Monthly Progress Report
Assessment Surveys and Results
Annual E-Performance
Report
Equipment Inventory Records
Minutes of Meetings
Title III Policies and
Procedures Manual
EVALUATION PROCESS FOCUS
1. What are the Actual Outcomes?
2. What were the Intended Outcomes?
3. Relationship of Actual Outcomes to CDP
Priorities.
4. Relationship of Resources Used to Actual
Outcomes.
5. Were there Unexpected Outcomes?
THE EXTERNAL EVALUATION
PROCESS ULTIMATELY
DOCUMENTS
INSTITUTIONAL
Accountability
AND
Performance
AND
Achievement
Thank you for your participation in this workshop
Haywood L. Strickland
[email protected]
June 3-5, 2008