More Than You Ever Wanted to Know About Financial Management

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More Than You Ever Wanted to Know About Financial Management Powered By Docstoc
					Financial Compliance Issues
                         More Than You Ever Wanted to
                             Administrative Costs
                             Leveraged Resources
                            Accrued Expenditures &
                           Unliquidated Obligations

MoHealthWINs TAACCCT Grant
    Prepared by the OTC Finance Office
            October 26, 2012

   Grant Detail and Contact Info
          Total Award: $19,982,296.00 CFDA #17.282
             Period of Performance: 10/1/11 to 9/30/14

  Fiscal Lead: Ozarks Technical Community College Finance Office
             Vice Chancellor of Finance – Marla Moody
              Senior Staff Accountant – Chasity Daniels
Grants Accountant – Betty Denson: 417-447-4831,

                 Program Director – Dawn Busick
              housed at MCCA Office: 573-634-8787

    Information Resources on MCCA Website:
      New Reimbursement Report
• MHW Reimbursement Report updated:
• Lines for Accrued Expenditures and Unliquidated
• Funds expended to date (actual requests) and
  committed to date (includes accrued expenditures
  and unliquidated obligations)
• Additional field to show percentage of administrative
  funds spent to date
           Administrative Costs
• 8% administrative cap applied across total budget
• Consortium members with ICR may want to claim all
  administrative costs as indirect
• Consortium members without indirect costs may
  claim administrative costs in direct line items
• Must report total administrative costs claimed on
  each reimbursement report
           Administrative Costs
• Not related to direct provision of workforce
  investment services, including services to
  participants and employers
• Can be personnel or non-personnel
• Can be direct or indirect
   Administrative Costs - Examples
• Accounting, budgeting, auditing
• General legal services functions
• Information system development (unless related
  to program delivery)
• Support personnel, travel costs, other goods and
  services related to administrative functions
               Program Costs
• Directly related to provision of workforce
  investment services, including services to
  participants and employers
• Can be personnel or non-personnel
• Can be direct or indirect
       Program Costs - Examples
• Vendor contracts (unless solely for administrative
• Case management
• Information system development for tracking
  participant and performance information
• Support personnel, travel costs and other goods
  and services related to program functions
    Administrative vs. Program Costs
• Not to be confused with direct or indirect costs
• Reasonable and based on benefit received
• Some costs may need to be prorated
• Allocate based on actual costs involved or duties
  performed - not job titles or general categories -
  be prepared to defend
• Program guidance found at 20 CFR 667.220
The MHW Grant & Leveraged Resources
• MHW Grant does not require match – requires
  leveraged resources reporting
• Leveraged resources not defined in federal
  regulations or related administrative requirements
• 29 CFR 95.23 provides limited guidance
• Leveraged resources could be described as:
  •“all resources used by the grantee to support grant
 activity and outcomes, whether or not those resources
         meet the standards required for match”*
       •DOL Training Handout: Background for Match and Leveraged Resources
    What are Leveraged Resources?
• May be paid for with federal or non-federal funds.
• Includes both cash and in-kind contributions.
• Must be allowable under the OMB cost principles.
• No administrative cost limitation on LR.
• Consortium committed to report over $11 million in
  leveraged resources over the life of the grant.
• Federal Project Officer will decide what actions to
  take if consortium not able to meet commitment.
    Reporting Leveraged Resources
• Reported each quarter - 9130 Report (OTC Finance
  Office) and Program Narrative (Program Director)
• Colleges report at least quarterly
• Totals listed on Reimbursement Report Form
• Summary sheet attached - for reporting and
• Keep backup documentation for
  on-site monitoring
   Leveraged Resources - Examples
• Unclaimed indirect costs
• Direct costs that could have been charged to the
  grant, but were not: donated space, staff salaries,
  supplies, outreach, web costs, travel costs in support
  of the grant, etc.
• Equipment used for grant – purchased with
  institutional funds, other federal funds, or donated
• Curriculum costs not charged to grant
• Documented third party donations of space,
  personnel, or other resources
    Leveraged Resources Valuation
• Guidance available at 29 CFR part 95.23
• Not used for contributions on other federal
• Necessary, reasonable, verifiable
• Allocate to show amount of benefit to grant
• Document and be prepared
  to defend valuation
          Accruals and Obligations
•   DOL requires accrual reporting
•   Better reflection of true program costs
•   Colleges report totals on Reimbursement Report
•   Retain documentation for on-site monitoring
•   OTC Finance Office reports on Form 9130
•   Failure to report on accrual basis could lead to
    loss of funds
        Accrued Expenditure or
        Unliquidated Obligation?
• An obligation is a commitment of funds
• All accrued expenditures are obligations, but not
  all obligations are accrued expenditures

                 Questions to Ask:
• Has performance been completed?
• What is our obligation to pay if the program
         Details of the Obligation
• Unpaid delivered goods - accrued expenditure
• Contracted goods - unpaid, but not yet delivered –
  unliquidated obligation
• Payroll - accrual if work performed, not yet paid
• Travel expenses or utilities - may be accrual
• Contracts - may be accrual or obligation
• Contract - work performed, not paid - accrual
• Contract with legal commitment - may be obligation
• Review contract terms
       This PowerPoint and Other Informational Resources are
       Available on the MCCA Website at

This workforce solution was funded by a grant awarded by the U.S.
Department of Labor's Employment and Training Administration. The solution
was created by the grantee and does not necessarily reflect the official position
of the U.S. Department of Labor. The Department of Labor makes no
guarantees, warranties, or assurances of any kind, express or implied, with
respect to such information, including any information on linked sites and
including, but not limited to, accuracy of the information or its completeness,
timeliness, usefulness, adequacy, continued availability, or ownership.

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