Uniform Grant Guidance/Green Book Changes and Implementation June, 2015 www.FLDOE.org © 2014, Florida Department of Education.
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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. www.FLDOE.org © 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) www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 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 www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. Slide 5 EDGAR – Old Friend, New Look www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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 www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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 www.FLDOE.org © 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. www.FLDOE.org © 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. Slide 11 Training Overview Pre-Award Post-Award Procurement Cost Principles Indirect Costs www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. Slide 12 www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. Slide 13 Pre-Award www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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 www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 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. www.FLDOE.org © 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. www.FLDOE.org © 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 www.FLDOE.org © 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 www.FLDOE.org © 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 www.FLDOE.org © 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 www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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 www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 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 www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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 www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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 www.FLDOE.org © 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 www.FLDOE.org © 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. www.FLDOE.org © 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. www.FLDOE.org © 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 www.FLDOE.org © 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 . www.FLDOE.org © 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. Slide 37 Post Award www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. Slide 38 Award Letter Received, Now What? www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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 www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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 www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. Slide 41 Performance Expectations and Results/ Deliverables • Program Goals • Scope of Work • Tasks www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. Slide 42 Performance Expectations and Results – Performance Measures Expectations • • • • Specific Quantities Milestones or Frequency Level of Completion Materials Provided www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. Slide 43 Financial Consequences Monetary adjustments for non-performance www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 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. www.FLDOE.org © 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. Slide 47 Cost Principles www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. Slide 49 Cost Principles (cont.) State restrictions may further limit expenditures of federal awards. See “Reference Guide for State Expenditures.” www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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) www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. Slide 52 Cost Principles (cont.) Basic standards remain the same: • Necessary • Reasonable • Allocable • Allowable Note: All must be documented www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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? www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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%. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. Slide 64 Time and Effort Documentation Due to lack of clear directive from federal government – no change recommended at this point. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 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 www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. Slide 69 Indirect Costs www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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). www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. Slide 72 TIMELINE www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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 © 2014, Florida Department of Education. All Rights Reserved. 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 www.FLDOE.org © 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. www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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 www.FLDOE.org © 2014, Florida Department of Education. All Rights Reserved. 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 www.FLDOE.org © 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. www.FLDOE.org © 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