Uniform Grant Guidance/Green Book Changes and Implementation June, 2015 www.FLDOE.org © 2014, Florida Department of Education.
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Transcript Uniform Grant Guidance/Green Book Changes and Implementation June, 2015 www.FLDOE.org © 2014, Florida Department of Education.
Uniform Grant Guidance/Green Book
Changes and Implementation
June, 2015
www.FLDOE.org
© 2014, Florida Department of Education. All Rights Reserved.
Slide 1
Purpose of Training
• Discuss the major changes resulting from the
Uniform Guidance.
• Identify changes that have been made to the Green
Book.
• Inform all participants of how DOE is implementing
these changes
• Solicit feedback.
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 2
What is this New Guidance?
The Office of Management and Budget (OMB)
released its final guidance on “Uniform
Administrative Requirements, Cost Principles and
Audit Requirements for Federal Awards”. This
new guidance, the Uniform Grant Guidance or
UGG, is a reform of previous OMB guidance and
serves as a one-stop shop for federal assistance
and provides a government-wide framework for
grants management.
(Previously known as Omni or Super Circular)
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Slide 3
Goals of the Uniform Grant Guidance
• Streamline guidance on federal awards;
• Reduce administrative burden for the government;
• Strengthen federal oversight of funding to reduce
potential for waste, fraud and/or abuse;
• Set standard requirements for financial award
management uniformly across all federal agencies;
• Consolidate eight OMB Circulars into Title 2 of the
CFR;
• Increase efficiency and effectiveness of Federal
award-making.
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 4
From Circulars to the Uniform Guidance
What Was. . .
Is Now. . .
Circulars A-89, A-102, A-110
Circulars A-21, A-87, A-122
Uniform Guidance Subparts B, C,
and D
Uniform Guidance Subpart E
Circulars A-133, A-50
Uniform Guidance Subpart F
EDGAR Parts 75 to 99
EDGAR Parts 75-79 and 81-99
EDGAR Parts 74 and 80
Became part of the Uniform
Guidance
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Slide 5
EDGAR – Old Friend, New Look
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Slide 6
Key Parts of the NEW EDGAR
• Title 34
• Part 75 – Direct Grant Programs
• Part 76 – State-Administered Programs
• Part 77 – Definitions
• Part 81 – Enforcement
• Title 2
• Part 200 – Cost/Administrative/Audit Rules
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Slide 7
Prior Rules
(Incorporated Into the NEW EDGAR)
•
•
•
•
A-21 – Cost Rules – Rules – IHEs
A-87 – Cost Rules – State / Local Gov’t
A-122 – Cost Rules – Nonprofit
A-102 – Administrative Rules State / Local Gov’t
• A-110 – Administrative Rules IHEs
• A-133 – Audit Rules
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 8
Relationship of UGG to Green Book
• Project Application and Amendment Procedures for
Federal and State Programs (Green Book) provides
guidance to internal staff, recipients and
subrecipients for management of state and federal
projects.
• Includes both federal and state requirements.
• To the extent appropriate, UGG changes have been
incorporated into this revision of the Green Book.
• There are elements of the Uniform Guidance that
may have impact that may not be reflected in the
Green Book so participants should continue to
familiar themselves with UGG.
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 9
Applicability
• Who does UGG apply to?
All non-Federal entities receiving federal funds
as a recipient or subrecipient.
• What is a non-Federal entity?
Any entity not part of the federal government
that receives federal funds as a recipient or
subrecipient.
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Slide 10
Grant vs. Project/Subgrant
• Be cautious of references to the term “Grant.”
• When used in UGG, the term “Grant” refers to the
award of funds from the federal government to
DOE (or direct funding from the federal
government to any eligible entity).
• In order to distinguish between the award of funds
to DOE, we use the term “Project” or “Subgrant” to
refer to DOE award of funds to other entities.
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Slide 11
Training Overview
Pre-Award
Post-Award
Procurement
Cost Principles
Indirect Costs
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Slide 12
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Slide 13
Pre-Award
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Slide 14
UGG’s Impact on Green Book
Many of the Green Book’s standard forms have been
amended as a result of the recent UGG:
DOE FORMS 100 A/B – Project Application Forms
DOE FORM 150 – Project Amendment Form
DOE FORM 200 – Project Award Form
DOE FORM 900s – RFA/RFP Templates
DOE FORM 610 & 620 – Risk Analyses
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Slide 15
New Certification Statement
• Updated required certification statement for the
project application, amendments, fiscal reporting
and General Assurances.
• Required on all annual and final fiscal reports for
payments.
Note: the language of the certification has been
modified for the application and amendment forms.
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 16
Certification Language
I, ______________________________________________, (Please Type Name) as
the official who is authorized to legally bind the agency/organization, do hereby
certify to the best of my knowledge and belief that all the information and
attachments submitted in this application are true, complete and accurate, for the
purposes, and objectives, set forth in the RFA or RFP and are consistent with the
statement of general assurances and specific programmatic assurances for this
project. I am aware that any false, fictitious or fraudulent information or the
omission of any material fact may subject me to criminal, or administrative
penalties for the false statement, false claims or otherwise. Furthermore, all
applicable statutes, regulations, and procedures; administrative and programmatic
requirements; and procedures for fiscal control and maintenance of records will be
implemented to ensure proper accountability for the expenditure of funds on this
project. All records necessary to substantiate these requirements will be available
for review by appropriate state and federal staff. I further certify that all
expenditures will be obligated on or after the effective date and prior to the
termination date of the project. Disbursements will be reported only as
appropriate to this project, and will not be used for matching funds on this or any
special project, where prohibited.
Further, I understand that it is the responsibility of the agency head to obtain from
its governing body the authorization for the submission of this application.
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 17
DOE 100 A – Project Application
• New category added to capture the Data Universal
Numbering System (DUNS) # & Employer
Identification Number (EIN) #
• Applicants must now include their DUNS # (Unique
Entity Identifier) used for the System for Award
Management (SAM) registration. The name used on the
actual Award must match the name attached to these
documents.
• EIN, according to IRS can be Taxpayer Identification
Number (TIN); Social Security Number (SSN) and
Individual Taxpayer Identification Number (ITIN)
• New Certification Statement required.
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 18
DOE 150 – Project Amendment Form
• Restructured to align with changes to Form 100A
• Certification statement required
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 19
DOE 200 – Project Award Form
• Adds details to satisfy Federal requirements
•
•
•
•
Federal award indicated – Title & Number
DUNS number indicated (Unique Entity Identifier)
FEID/FEIN number indicated
RFA/RFP incorporated into the terms and conditions
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 20
DOE 900s Forms – Application Templates
• Application templates have been updated
•
•
•
•
Revised General Assurances
New Uniform Guidance references
Revised Risk Analysis requirements
Revised guidance on equipment purchases
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 21
UGG Requires a
Risk Analysis
• Section A of DOE’s
Green Book amended
to require risk analysis
for ALL subrecipients.
Components of Risk
Analysis
• Subrecipient’s prior
experience with the
same or similar
subawards;
• Audit results;
• New staff and/or
changed systems;
• Results of any direct
Federal monitoring
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Slide 22
Risk Analysis Tool – DOE Form 610 (new)
School Districts, State Colleges, State Universities, and
Florida State Agencies
• Organizational charts and agency’s Board approved policies
and procedures.
• Changes in senior management and/or changed internal
systems
• Results of any direct Federal monitoring
• Written policies and procedures must be submitted.
• Single audit results
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Slide 23
Risk Analysis Tool – DOE Form 620
Governmental and Non-Governmental Agencies
(except Florida State Agencies)
• Organizational charts and list of agency’s Board of
Directors procedures.
• Subrecipient’s prior experience with subaward(s).
• Written policies and procedures must be
submitted.
• Results of any monitoring or program reviews.
• Single audit results must be submitted with
application packet.
• Financial stability will be determined.
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 24
Review of Risk Posed by Applicants
The pass-through entity (FDOE) must have a
framework for evaluating risks before any applicant
receives funding. The framework should evaluate:
• Financial Stability
• Quality of Management System
• History of Performance
• Audit Reports
• Applicant’s Ability to Effectively Implement
Program
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Slide 25
Special Conditions
Results of the Risk Assessment may be cause for
Special Conditions to be placed upon an award to
include, but not limited to the following:
• Require reimbursement;
• Withhold funds until evidence of acceptable
performance;
• More detailed reporting;
• Additional monitoring;
• Require subgrantee/subrecipient to obtain technical or
management assistance; or
• Establish additional prior approvals.
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Slide 26
Financial Management System
•
•
•
•
•
•
•
New: Identification of Federal Awards
Financial Reporting
Accounting Records
Internal Controls
Budget Controls
New: Written Procedures to Implement CMIA*
New: Written Procedures to Determine
Allowability
*CMIA = Cash Management Improvement Act
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Slide 27
Financial Management System
Management requirements - Written procedures for
determining the allowability of costs in accordance
with Subpart E—Cost Principles and the terms and
conditions of the Federal program.
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Slide 28
Internal Controls (Must Be Formalized in Writing)
The non-Federal entity must:
• Establish and maintain effective control over the federal
award.
• Evaluate and monitor the non-Federal entity’s
compliance statutes, regulations, and terms of the
federal award.
• Take prompt action when instances of noncompliance
are identified, including noncompliance identified in
audit findings.
• Take reasonable measures to safeguard protected
personally identifiable information as defined under 2
CFR §200.79
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 29
Equipment
Management Requirements. Managing procedures for
equipment acquired in whole or in part under a Federal
award shall, at a minimum, require:
(1) Description of the property
(2) Source of funding
(3) Acquisition date and cost
(4) Percentage of Federal participation
(5) Location
(6) Use and condition of the property
(7) Disposition data
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 30
Equipment (cont.)
• A physical inventory of the property must be taken and the
results reconciled with the property records at least once
every two years. However, the state requirement is that
inventory be reconciled annually.
• A control system must be developed to ensure adequate
safeguards to prevent loss, damage, or theft of the property.
Any loss, damage, or theft must be investigated.
• Adequate maintenance procedures must be developed to
keep the property in good condition.
• If the non-Federal entity is authorized or required to sell the
property, proper sales procedures must be established to
ensure the highest possible return.
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 31
Procurement
The non-Federal entity must have written procedures for procurement
transactions. These procedures must ensure that all solicitations:
(1) Clear and accurate description of the technical requirements for the
material, product, or service to be procured.
(2) Description must not, in competitive procurements, contain features
which unduly restrict competition.
(3) The description may include a statement of the qualitative nature of
the material, product or service to be procured and, when necessary,
must set forth those minimum essential characteristics and
standards.
(4) Avoid detailed product specifications.
(5) When it is impractical or uneconomical to make a clear and accurate
description of the technical requirements, a “brand name or
equivalent” description may be used as a means to define the
performance or other salient requirements of procurement.
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 32
Conflict of Interest
• Must maintain written standard of conduct, including conflict of
interest policy.
• A conflict of interest arises when any of the following has a
financial or other interest in the firm selected for award:
•
•
•
•
Employee, officer or agent
Any member of that person’s immediate family
That person’s partner
An organization which employs, or is about to employ, any of the above
or has a financial interest in the firm selected for award
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 33
Conflict of Interest
NEW: If the non-federal entity has a parent, affiliate, or
subsidiary organization that is not a state or local
government the entity must also maintain written standards
of conduct covering organization conflicts of interest .
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 34
Florida Guidelines
Procurement for school districts is governed by Rule 6A1.012, FAC, Purchasing Policies.
This rule requires that each district school board shall
establish purchasing rules which must include but not be
limited to the provisions contained in the Rule.
https://www.flrules.org/gateway/RuleNo.asp?title=FINANCE
AND ADMINISTRATION&ID=6A-1.012
Procurement for state agencies is governed by Chapter 287,
Laws of Florida.
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Slide 35
Florida Guidelines
All other entities must adhere to procedures specified in
UGG.
OMB is allowing other entities an additional year to come
into compliance with the revisions to the procurement
requirements; however the basic principles have not
changed.
Carefully review the requirements in UGG and develop
written procedures accordingly.
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 36
Cash Management
The non-Federal entity must have written procedures for cash
management activities. These procedures must ensure that
the following phases are addressed:
•
•
•
•
Payment Process
Obligation
Liquidation
Drawdown
• Cash Management Improvement Act (CMIA) requires no more than 72 Hours between draw down of
monies and payment of those monies, otherwise interest begins to accrue.
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Slide 37
Post Award
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Slide 38
Award Letter Received, Now What?
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Slide 39
Uniform Guidance & Performance
Uniform Guidance stresses utilizing performance
requirements
•
•
•
•
Program goals
Expected outcomes
Milestones (lessons learned, use of promising practices)
Continue using FL guidance
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Slide 40
Performance - Financial Reporting
Performance Metrics
1. Compare actual accomplishments to objectives.
(quantify to extent possible)
2. Reasons goals were not met if appropriate
3. Additional pertinent information (e.g. analysis and
explanation of cost overruns, high unit costs)
4. Significant developments
a. Problems, delays. Adverse conditions that
would impair ability to meet objective of the
award
b. Favorable developments. Finishing sooner or at
less cost
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Slide 41
Performance Expectations and Results/
Deliverables
• Program Goals
• Scope of Work
• Tasks
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Slide 42
Performance Expectations and Results –
Performance Measures
Expectations
•
•
•
•
Specific Quantities
Milestones or Frequency
Level of Completion
Materials Provided
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Slide 43
Financial Consequences
Monetary adjustments for non-performance
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Slide 44
Timeline for Effects of Changes
• US Department of Education has indicated that
changes in performance expectations will be
handled on a program by program basis. It may be
some time before the full effects of the changes are
felt.
• Expect to see more rigorous performance
requirements to be implemented with
programmatic reauthorization, and updated
regulations and/or non-regulatory guidance.
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 45
Final Expenditure Reports: DOE 399, 499,
and 599
New certification statement replaces previous
certification statement on these reporting forms.
By signing this report, I certify to the best of my knowledge
and belief that the report is true, complete, and accurate,
and the expenditures, disbursements and cash receipts are
for the purposes and objectives set forth in the terms and
conditions of the Federal award. I am aware that any false,
fictitious, or fraudulent information, or the omission of any
material fact, may subject me to criminal, civil or
administrative penalties for fraud, false statements, false
claims or otherwise.
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 46
Key Changes in Audit Requirements
• Single Audit Threshold has increased to $750,000.
• Questioned costs <$25,000 are no longer required
to be reported.
• Fewer audits and findings have monitoring
implications.
• Audits must be submitted electronically to the
Federal Audit Clearinghouse and made available to
all funding agencies.
• States will continue to resolve sub-recipient
audits.
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Slide 47
Cost Principles
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Slide 48
Cost Principles
Notable changes:
• Certification required for fiscal reports, payment
vouchers, and indirect cost proposals.
• Adds guidance about dependent care costs related to
conferences.
• Discusses direct charging of materials and supplies
(Computer equipment <$5,000 treated as a supply).
Florida requirements will not change. State law
prescribes a threshold of <$1,000.
• Small attractive items with a purchase value less than
$1,000, whether classified as equipment, technological
item, or supplies must be safeguarded and there must
be a written policy on tracking.
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Slide 49
Cost Principles (cont.)
State restrictions may further limit expenditures of
federal awards. See “Reference Guide for State
Expenditures.”
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Slide 50
Allowability of Costs Criteria
Except where otherwise authorized by statute, costs
must meet the following general criteria in order to
be allowable under Federal awards:
a) Be necessary, reasonable, and allocable;
b) Conform to limitations or exclusions set in the
principles or the Federal award;
c) Be consistent with policies and procedures
that apply to both federal and non-Federal
funds.
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Slide 51
Allowability of Costs Criteria (cont.)
d) Be applied with consistent treatment.
Example - A cost may not be assigned to a Federal award
as a direct cost if any other cost incurred for the same
purpose in like circumstances has been allocated to the
Federal award as an indirect cost.
e) Be determined in accordance with generally
accepted accounting principles (GAAP)
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Slide 52
Cost Principles (cont.)
Basic standards remain the same:
• Necessary
• Reasonable
• Allocable
• Allowable
Note: All must be documented
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Slide 53
Reasonable Costs
A cost is reasonable if, in its nature and 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 cost.
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Slide 54
Reasonable Costs (cont.)
• Consideration must be given to:
a. Whether cost is a type generally recognized as ordinary
and necessary for the operation of the non-Federal entity
or the proper and efficient performance of the Federal
award;
b. The restraints or requirements imposed such as:
• Arms length bargaining (hint: procurement processes);
• Federal, state and local laws; and
• Terms of the grant award.
c. Market Prices for comparable goods or services in the
geographical area;
d. Whether the individuals acted with prudence under the
circumstances considering their responsibilities; and
e. No significant deviation from established prices.
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Slide 55
Reasonable Costs (cont.)
• Practical Questions
• Do I really need this?
• Is the expense targeted to valid programmatic/ administrative
need?
• Is this the minimum amount I need to spend to meet my need?
• Do I have the capacity to use what I am purchasing?
• Did I pay a fair rate?
• If I were asked to defend this purchase, would I be able to?
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Slide 56
Allocable Costs
A cost is allocable to a particular Federal award
or other cost objective if the goods or services
involved are chargeable or assignable to that
Federal award or cost objective in accordance
with relative benefits received.
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Slide 57
Allocable Costs (cont.)
• A cost is allocable to a Federal award or cost objective if the
goods or services involved are chargeable or assignable in
accordance with relative benefits received.
• Incurred specifically for the award;
• Benefits both award and other work and can be distributed in proportions
that may be approximated using reasonable methods; and
• Necessary to the overall operation of the entity and assignable to the
award in accordance with this Part.
• Can only charge in proportion to the value received by the
program
• Example: Agency purchases a computer to use 50% on the Federal grant
program and 50% on a state program – can only charge half the cost to
the grant.
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Slide 58
Applicable Credits
Applicable credits refer to those receipts or
reduction-of-expenditure-type transactions that
offset or reduce expense items allocable to the
Federal award as direct or indirect (F&A) costs.
Examples: Purchase discounts, rebates or
allowances, recoveries or indemnities on losses,
insurance refunds or rebates, and adjustments of
overpayments or erroneous charges.
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Slide 59
Treatment of Applicable Credits
To the extent that such credits accruing to or
received by the non-Federal entity relate to
allowable costs, they must be credited to the Federal
award either as a cost reduction or cash refund, as
appropriate.
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Slide 60
Time and Effort Documentation
New Standards for Documentation of Personnel
Expenses. Charges for salaries:
• Must be based on records that accurately reflect
the work performed.
• Must be supported by a system of internal controls
which provides reasonable assurance charges are
accurate, allowable and properly allocated.
• Must be incorporated into official records.
• Not to exceed 100%.
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Slide 61
Time and Effort Documentation
Salary Charges:
• Must reasonably reflect total activity for which
employee is compensated.
• Must encompass all activities (federal and nonfederal).
• Must comply with established accounting
policies and practices.
• Must support distribution among specific
activities or cost objectives.
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Slide 62
Time and Effort Documentation (cont.)
• Budget estimates alone do not qualify as support
for charges to Federal awards
• Percentages may be used for distribution of total
activities.
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Slide 63
Substitute System(s)
• Florida currently has a substitute system which
was approved in 1996 and many districts have
implemented this system.
• Several years ago a “new” option was offered that
allows employees with schedules that do not
change from week to week to certify time and
effort on a semi-annual basis.
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Slide 64
Time and Effort Documentation
Due to lack of clear directive from federal
government – no change recommended
at this point.
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Slide 65
Travel Costs
Travel costs are the expenses for
transportation, lodging, subsistence, and
related items incurred by employees who
are in travel status on official business of
the non-Federal entity.
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Slide 66
Travel – Methods of Charging
Travel costs, as previously defined, may be
charged:
1. On an actual cost basis;
2. On a per diem or mileage basis in lieu of actual
costs incurred; or
3. On a combination of the two above
The method used must be applied to an entire trip
and not to selected days of the trip, and results in
charges consistent with those normally allowed in like
circumstances.
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Slide 67
Travel
Note: All subrecipients are required to adhere to
Section 112.061, Florida Statutes, and the DOE
Travel Manual, which cover per diem allowance and
travel expenses. These statutory provisions are
consistent with UGG cost principles.
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 68
Some Cost Items Have Not Changed!
The following are not allowable:
•
•
•
•
•
•
•
Alcohol
Entertainment
Fines and Penalties
Lobbying
Advertisement that promotes the organization
Religious worship, instruction, or proselytization
Construction, remodeling, repair, operation, or maintenance of
religious facility
• Unless specifically authorized, acquisition of real property or
construction
• Purchase of goods and services to be used after the end of the
project period
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Slide 69
Indirect Costs
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Slide 70
How is the Indirect Rate Determined?
• Approved by the cognizant agency.
• DOE is the cognizant agency for all LEAs.
• Two types of rates – restricted and unrestricted.
Most education grant funds are required to use
restricted rates.
• IF an entity has a restricted indirect cost rate
approved by an entity other than DOE, that is the
rate that will be used.
• IF there is not an approved restricted rate, the rate
will be 8% of the modified total direct cost (MTDC).
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Slide 71
Relationship Between Indirect and
Administrative Costs
• Indirect costs are considered a part of
administrative costs.
• IF there is a cap on administrative costs (and for
many education programs there is a cap), AND that
cap is lower than the indirect cost rate, the indirect
rate must be lowered to equal or be less than the
administrative costs cap.
• Example: Entity has an indirect rate of 8%.
Administrative costs cap for program is 5%.
Indirect rate cannot exceed 5% for the specific
program.
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Slide 72
TIMELINE
www.FLDOE.org
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Slide 73
When do these changes take place?
• UGG applies to all Federal grants awarded on or after
December 26, 2014. Since most education grants are
issued effective July 1, the Uniform Guidance becomes
applicable on July 1, 2015.
• Audit and indirect cost changes take effect the next
fiscal year after December 26, 2014, – July 1, 2015.
• As of October 1, 2015, the majority of grant funds will
be subject to the Uniform Guidance.
• Revisions to Green Book will take effect on July 1, 2015.
• Revised General Assurances and Risk Assessment
required prior to awards.
www.FLDOE.org
© 2014, Florida Department of Education. All Rights Reserved.
Slide 74
FAQ's
www.FLDOE.org
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Slide 75
Does Equipment Become “Supplies?”
No.
Object codes as specified in the Red Book will not
change:
• 600
•
•
•
•
641
642
643
644
Furniture, Fixtures and Equipment
Capitalized Furniture, Fixtures and Equipment
Noncapitalized Furniture, Fixtures and Equipment
Capitalized Computer Hardware
Noncapitalized Computer Hardware
Charts of Accounts for other sub-recipients should
clearly distinguish these categories
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 76
When Does a Subrecipient Need to Submit a
Formal Amendment (DOE 150/151) for Prior
Approval?
There are very limited changes to this section of the
Green Book. There is no specification of a 10% change in
budget lines requiring an amendment. Need for an
amendment is based on the types of changes rather than
the amount of the change. See Section B of the Green
Book.
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Slide 77
Prior Approval of Amendment Required
• New - Additional criterion: Disengagement of the
project director – if the position responsible for
managing/overseeing the project award is
disengaged from the project for more than three
months, or if there is a 25% reduction in time
devoted to the project.
• Changes in:
•
•
•
•
•
Scope, goals, or objectives
Project evaluation scope
Deliverables or work tasks
Key personnel
Contracted services
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Slide 78
When Are Obligations Made?
Type of Obligation
When Obligation Occurs
Acquisition of Property
Date of binding written commitment
Personal Services
by Employee
When services are performed
Personal Services
by Contractor
Date of binding written commitment
Travel
When travel is taken
Approved PreAgreement Cost
On the first day of the grant or subgrant
performance period
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 79
When is “Advertising” Allowable?
• Allowable for programmatic purposes including:
•
•
•
•
•
Recruitment
Procurement of goods
Disposal of materials
Program outreach
Public relations (in limited circumstances)
• Exercise care as “promotional items” are prohibited
under state law unless specifically authorized by
statute.
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© 2014, Florida Department of Education. All Rights Reserved.
Slide 80
Is Purchase of Food Allowable?
Food is not an allowable expenditure unless made
pursuant to s. 1001.43(2)(g) which provides that the
district school board may adopt policies which
permit
“The use of federal funds to purchase food when federal
program guidelines permit such use.”
www.FLDOE.org
© 2014, Florida Department of Education. All Rights Reserved.
Slide 81
When Can Equipment Purchased By One
Program Be Used in Another Program?
• Equipment must be used by the Non-Federal entity in the
program or project for which it was acquired as long as
needed, whether or not the project or program continues to
be supported by the Federal award.
• When no longer needed, may be used in other activities
with the following priority:
1. Projects supported by Federal awarding agency
2. Project funded by other Federal agencies
• When used it may be shared (according to the above
priorities) provided such use will not interfere with work on
the original projects/programs.
www.FLDOE.org
© 2014, Florida Department of Education. All Rights Reserved.
Slide 82
Resources
www.FLDOE.org
© 2014, Florida Department of Education. All Rights Reserved.
Slide 83
DOE Staff
Green Book Revision and UGG Training Team*
• Vickie Brown*
• Janice Brown*
• Teresa Nix*
• Alricky Smith*
• Levis Hughes*
• Sue Wilkinson
• Don Crumbliss
• Deborah Evans
• Lorraine Allen
• Chane Eplin
• Pat Faircloth
• Virginia Sasser
• Peggy Primicerio
• Wanda Young
• Harriett Abrams
www.FLDOE.org
© 2014, Florida Department of Education. All Rights Reserved.
Slide 84
Useful Websites
• U.S. Department of Education website devoted to
technical assistance for grantees (regulations, FAQs,
training resources)
http://www2.ed.gov/policy/fund/guid/uniformguidance/index.html.
• DOE Grants Management website (Green Book,
fiscal training)
http://www.fldoe.org/finance/contracts-grantsprocurement/grants-management.
www.FLDOE.org
© 2014, Florida Department of Education. All Rights Reserved.
Slide 85
www.FLDOE.org
www.FLDOE.org
© 2014, Florida Department of Education. All Rights Reserved.
Slide 86