A Systems View of Fiscal Management - Virginia Head Start by hcj

VIEWS: 11 PAGES: 19

									A Fiscal Systems View of
 Program Management

Virginia Head Start Association
             June 20, 2012
         Belinda Rinker, JD
Senior Advisor to the Office of Head Start
       belinda.rinker@acf.hhs.org
 Families
Community
 Children
   Head Start
Early Head Start

   Grantee
 Organization
    Governance



Program    Fiscal
                          Eff
                          Ef fec
                              ec tv
                                 tiive
                                     ely
                                       ly C
                                          Coom
                                             mmmun
                                                 uniica
                                                     ca ted
                                                        ted
                                  Fiscal
Coordinated

              Governanc
                  e


                                 Program
                          D ata Info
                                     rmed
                          Eff
                          Ef fec
                              ec tv
                                 tiive
                                     ely
                                       ly C
                                          Coom
                                             mmmun
                                                 uniica
                                                     ca ted
                                                        ted
                                   Fiscal
Coordinated

              Governanc
                  e


                                 Program
                          D ata Info
                                     rmed
                        Fiscal System Elements
                                      Financial
                                     Management
                                      Systems

                    Facilities and                  Recordkeeping
                      Property                      and Reporting




Non-federal Share      Cost
  Cost Allocation                                   Procurement
                     Principles


                                     Compensation
       Financial Management Systems
                         45 CFR 74.21 or 45 CFR 92.20
 Accurate, current and complete disclosure of program finances.
 Records that adequately identify the source and application of funds.
 Effective control over and accountability for funds, property and
  program assets.
   Separation of fiscal duties
   Board member with fiscal management or accounting expertise
   Annual Financial Audit
 Comparison of actual outlays (amounts spent) with budgeted costs.
 Written procedures to minimize the time between drawdown and
  expenditure (payment) of costs and expenses.
 Written procedures for determining the reasonableness, allocability
  and allowability of costs (cost principles and the terms and conditions
  of the award).
 Accounting records supported by source documentation.
         Recordkeeping and Reporting
 Personnel files.
 Volunteer files.
 Food service and menu records.
   USDA Nutrition Assistance Programs
 Facilities and equipment records.
   Property inventory and facilities records
   Valid licenses and registrations required by Federal, State or local law
 Insurance records.
   General liability, property, student accident, title insurance (facilities)
 Fiscal records.
   Status of grant funds (budget, projected and actual)
   Cost are reasonable, allocable and allowable (cost principles)
 Fiscal reports.
   Internal: Board, Policy Council (monthly), budgets, aged payables
   External: Community, OHS, IRS, workers compensation, USDA
                         Procurement
                    45 CFR 74.42, 74.44 or 45 CFR 92.36

 Written procurement procedure applicable to goods and services
  purchased.
   Complies with all Federal, State and local regulations: bid process,
    Davis-Bacon Act compliance
   Includes written code of conduct for employees engaged in awarding or
    administering contracts: related parties, conflicts of interest
 Contracts are accurate, complete, signed and up to date.
   Purchases of goods: supplies, equipment, vehicles
   Personal service contracts: nutrition consultant, mental health
    professional
   Delegate agency agreements
                       Compensation
 Compensation for all employees meets the cost principle
  requirements: necessary, allocable and reasonable.
   Wages, benefits, bonus and incentives
   Executive Level II limitation is met ($179,700)
 Adequate records are available to support compensation.
   Time records for all non-exempt employees
   Payroll records for all employees
   Personnel activity reports
 Compensation costs for employees whose services benefit more
  than one program are property allocated.
 Compensation reporting (external) is timely, complete and
  accurate: IRS, state taxes, workers compensation, unemployment
  insurance.
 Future compensation benefit obligations are funded.
                              Cost Principles
                  2 CFR Part 220, 2 CFR Part 225 or 2 CFR Part 230
 Written procurement procedures to determine that all expenses are
  allowable, necessary and allocable.
 Adequate documentation supports expenditure.
   Allowable:
       Reasonable for performance of the award (see below)
       Consistent with policies and procedures and treated consistently
       Not charged to another program
       Adequately documented
       Cost limitations and exclusions are followed
   Reasonable: does not exceed what a prudent person would pay under
    similar circumstances at the time the decision was made.
       Generally recognized as ordinary and necessary
       Complies with sound business practices: arms length transactions
       Prudence was exercised in light of responsibilities
       Follows established practices and does not unjustifiably increase cost
              Cost Principles (Continued)
                2 CFR Part 220, 2 CFR Part 225 or 2 CFR Part 230

 Allocable: A cost is allocable (can be charged) to a particular grant if
  it is charged in accordance with the benefit to the grant:
   The cost is incurred specifically (100%) for the charged grant, or
   The cost benefits both the award and grant(s) and can be distributed
    between or among programs in reasonable proportion to the benefits
    received, or
   The expense is necessary to the overall operation of the organization,
    although a direct relationship to any particular grant cannot be shown.
 Costs may not be shifted from one grant to another to cover
  deficiencies in funding or avoid restrictions.
 The cost principles also apply to costs and expenses which are
  charged in accordance with a cost allocation plan (shared costs) and
  to costs which are claimed as non-federal share.
                   Non-federal Share
 The grantee agency must provide 20 percent of the total costs of the
  Head Start program unless a waiver has been granted.
   For every federal Head Start dollar received the grantee must provide
    twenty-five cents (absent a waiver)
   Criteria for application for waiver (written) are lack of community
    resources, initial costs, unanticipated cost increases, major disaster and
    community impact (See ACF-PI-HS-12-02)
 Allowable non-federal share costs meet applicable cost principles:
  necessary, reasonable and prudent.
 Adequate documentation is required to support non-federal share
  costs.
 Except where specifically authorized by statute, other federal funds
  cannot be used as non-federal share.
                       Cost Allocation
 Cost allocation is required when costs are shared by two or more
  programs.
   Includes costs shared between Head Start and Early Head Start
   Includes costs shared between either Head Start or Early Head Start
    and programs or services from another funding source
   Exception is either Head Start or Early Head Start and its associated
    USDA Nutrition Assistance Program
 Shared costs must be fairly allocated between or among the
  programs that benefit from those costs in accordance with a cost
  allocation plan.
 Grantees have the option to apply for a negotiated indirect cost rate
  or allocate indirect costs.
 Administrative costs (direct and/or indirect) cannot exceed 15% of
  the grantee’s overall Head Start grant.
                  Facilities and Property
              45 CFR Part 1309, 45 CFR Part 74 or 45 CFR Part 92

 Special requirements apply to all facilities which are purchased (initially
  or through mortgage payments), constructed or undergo major
  renovations using Head Start funds (in whole or in part).
 Special notices must be filed in the official (real property) records to
  protect federal funds used for facilities activities.
 Personal property (worth at least $5,000) must be included on a detailed
  inventory prepared every two years.
 Permission is required before a program can use any property purchased
  in whole or in part with Head Start funds as collateral for a loan,
  including lines of credit.
 Permission is required before any property worth $5,000 or more
  purchased in whole or in part with Head Start funds is sold or transferred.
 Detailed facilities and property records are required, including proof of
  insurance.
Virginia 2012 Monitoring Results
         No written procedures to determine
          reasonableness, allowability and allocability.
         Reporting to governing body and policy council.
           Credit card expenditures not included
           USDA meals and snacks not reported
         Training not provided to governing body and
          policy council for understanding and effective
          oversight.
         Inadequate equipment records.
         Repair, safety and security of materials,
          equipment and facilities.
         Failure to conduct criminal records checks.
Questions and Comments

								
To top