Transcript Slide 1

1
CTE Funding & OMNI Circular
Raúl Soto Ph.D., Associate Director CTE
Agenda
1. Review Perkins Funding Requirements
2. Overview of new Omni Circular
Disclaimer: Information adapted from Michael Brustein’s January 21, 2014 presentation
in Columbus Ohio
What are the allowable uses of
Perkins funds?
1. Perkins Act
Basic Roadmap
2. EDGAR
3. OMB Omni Circular
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
Perkins Act
Section 135
a) Improve
b) Mandatory uses
c) Permissive uses
d) Administrative costs
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
2) Is the item necessary?
3) Is the cost reasonable?
4) Is the cost allocable to Perkins?
5) Is the cost adequately documented?
OMB Revised Administrative, Cost,
and Audit Rules Governing All
Federal Grants
The Super Circular –
“Omni Circular”
The One-Stop Shop for Federal
Assistance
Date of Applicability of Revised
Rules
All Drawdowns, after
December 26, 2014 at State Level
July 1, 2015 at Local Level
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)
Education Department General
Administrative Rules (EDGAR)
• Part 76 – State Administrative Rules
• Part 80 – General Administrative Rules
EDGAR Part 80
1.
2.
3.
4.
5.
6.
Standards for Financial Management*
Payments*
Allowable Costs*
Period of Availability of Funds*
Program Income*
Non Federal Audit*
* Omni Circular Changes
EDGAR Part 80 (cont.)
7. Changes*
8. Equipment*
9. Supplies*
10.Procurement*
11.Monitoring*
12.Retention of Records
*Omni Circular Changes
Who is covered?
• All “nonfederal entities” expending
federal awards
Reasons for the Change?
1. Simplicity
2. Consistency
3. Obama Administration Executive Order on
Regulatory Review
– Increase Efficiency
– Strengthen Oversight
Most Significant Change
• Shift from focus on Compliance to focus
on PERFORMANCE!!!
Flexibility
• The “Omni Circular” adds significant
flexibility to way grantee / subgrantee can
adopt their own processes
• Example: Time and Effort
Personnel Activity Report
1. After the fact
2. At least monthly
3. 100% of effort
4. Certified by employee
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
200.430
• New requirements are less prescriptive
• Grantees encouraged to adopt
“substitute systems”
200.430
• Acceptable now to allocate sampled
employee’s supervisors, clerical and
support staffs, based on results of
sampled employees
*Note: Guidance forthcoming
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
New Emphasis on Risk
200.205
• ODE must have in place a framework
for evaluating risks before applicant
receives funding
Risk Factors:
1.
2.
3.
4.
5.
Financial Stability
Quality of Management System
History of Performance
Audit Reports
Applicant’s Ability to Effectively Implement
Program
Fiscal Accountability
200.415
• Major emphasis on “strengthening
accountability” by improving policies that
protect against waste, fraud and abuse
(200.415)
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
Mandatory Disclosures
200.113
• Non federal entity must disclose in writing in
timely manner to federal agency or passthrough all violations of federal criminal law
involving fraud, bribery or gratuity violations
potentially affecting federal award
Significant Changes to Core
Financial Management Standards
200.302
• Written Procedures on,
Cash Management
Allowability of Costs
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
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
200.474 - Travel
• Travel costs may be charged on actual, per
diem, or mileage basis
• Travel charges must be consistent with
entity’s written travel reimbursement policies
200.474 - Travel
• Grantee must retain documentation
that participation of individual in
conference is necessary for the
project
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)
Computing Devices
200.20
Definition:
• Machines used to acquire, store,
analyze, process, and publish data
electronically
Supplies
200.314
• Now includes “computing devices”
• Residual inventory of unused supplies
exceeding $5,000 in total aggregate value –
must compensate federal government
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”
–1st preference – projects supported by federal
awarding agency
–2nd preference – project funded by other federal
agencies
–3rd preference – use for non federally funded
programs
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
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
Disposition of Equipment
• Upon disposition federal agency may
permit grantee to retain $500 or 10% of
proceeds, whichever is less, for
handling expenses
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.”
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
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
Audit Resolution
200.501
• Federal Compliance requirements do
not pass through to contractors
• Auditee is responsible for ensuring
compliance for procurement
transactions
Supplanting
• Perkins funds must supplement, not
supplant, state and local funds for CTE
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?
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
Career-Technical Education
Administrative Field Services
614-446-4835
education.ohio.gov
education.ohio.gov