21st Community Learning Centers (21CCLC) Funding Overview

21st Community Learning Centers (21CCLC) Funding Overview • Primary purpose of today’s presentation is to address fiscal issues related to 21st Century Community Learning Centers: FISCAL Webinar David Lyon September 20, 2007 – Ensure that grantees understand the fiscal responsibilities in receiving a federal grant; and – Prepare grantees for fiscal reviews. 21st Community Learning Centers (21CCLC) Funding Overview • Grants are awarded for a period of 3 to 5 years – subject to annual appropriation by the U.S. Department of Education. Colorado is allowing 5 year projects. • Grantees are given a minimum annual grant award of $50,000. Referring to Correct OMB Circulars • State and Local Governments A-87, Cost Principals A-133, Audits of States, Local Governments, and Non-Profit Organizations. • Non-Profit Organizations A-122, Cost Principals A-133, Audits of States, Local Governments, and Non-Profit Organizations. State Statutes and Regulations (FISCAL) • The Local Government Audit Law (CRS 29-1601) requires Colorado local governments to have an annual audit (Single Audit if Applicable) of their financial statements. • The law states that the audit must be performed by an independent CPA and be in accordance with generally accepted auditing standards. OMB Circular A-133, States, Local Governments & Non-Profit Organizations • The A-133 Compliance Supplement provides information on the areas of the various federal grant programs that are being focused on by the independent auditors. • Required for use by auditors for Single Audit Act audits. http://www.whitehouse.gov/omb/circulars/a133_compliance/04/04toc.html 1 The Single Audit Act • Establishes standards for obtaining consistency and uniformity for audits of states, local governments, and nonprofit organizations expending federal funds. • Governments (including School Districts) are required to complete a Single Audit if they have expenditures of federal funds in excess of $500,000. • Cost Principals OMB Circular A-87, State and Local Governments Purpose – Establishes principals and standards for determining costs for Federal awards carried out through grants. OMB Circular A-122, Non-Profit Organizations Purpose – Establishes principals and standards for determining costs for Federal awards carried out through grants. • OMB Circular A-87 – Basic Guidelines • To be allowable under Federal awards, costs must meet the following general criteria: OMB Circular A-87 – Basic Guidelines (continued) e) Be consistent with policies, regulations, and procedures that apply uniformly to both Federal awards and other activities. f) Be accorded consistent treatment. g) Be determined in accordance with GAAP. h) Not be included or used to meet cost sharing or matching requirements. i) Be the net of all applicable credits. j) Be adequately documented. http://www.whitehouse.gov/omb/circulars/a087/a87_2004.html a) Be necessary and reasonable. b) Be allocable to Federal awards. c) Be authorized or not prohibited under State or local laws or regulations. d) Conform to any limitations or exclusions as to types or amounts of cost items, as set forth in the Circular. Unallowable Costs • Under NCLB, distributing materials or operating programs that promote or encourage sexual activity; distributing legally obscene materials to minors on school grounds; providing sex education or HIV prevention education unless such instruction is ageappropriate and includes the health benefits of abstinence; or operating a program of contraceptive distribution in schools is unallowable. Unallowable Costs Under OMB Circular A-87: • Costs of alcoholic beverages are unallowable. • Donated services may not be reimbursed. • Contributions or donations made by the governmental unit, regardless of the recipient, are unallowable. • Costs of entertainment are unallowable. • Refer to the appropriate circular for others. 2 Unallowable Costs • Programs that operate, or for teaching that occurs during the regular school day. • Capital construction. • Vehicle purchases. • Land acquisition. • Supplanting federal, state, or local funds. • Any costs not allowable for federal programs per EDGAR. • Expenditures made outside of budget. Nutritious Meals/Snacks • Nutritious meals or snacks must meet the requirements of the USDA National School Breakfast/Lunch Program (NSLP). – The USDA website is: http://www.fns.usda.gov/cnd/ • The CDE Nutrition Unit can be reached... – By phone: (303) 866-6661 or toll-free within Colorado at (888) 245-6092 – By e-mail: nutrition@cde.state.co.us Nutritious Meals/Snacks Items that should not be purchased: • Food, snacks for staff (including coffee, creamer, filters, etc.). • Candy • Brownies • Soda • Chips • Any other ‘Junk Food’ • • Employee Time and Effort Time spent in workday must correlate to employee’s funding. Refer to OMB Circular A-87 (state and local governments), and OMB Circular A-122 (non-profit organizations) for specific requirements. http://www.cde.state.co.us/cdefinance/download/Em ployeeTimeandEffort3-13-07.doc • Note: CDE has summarized Employee Time & Effort under OMB-87. OMB-122 has similar requirements. Employee Time and Effort – Sample Timesheet http://www.cde.state.co.us/cdefinance/download/spreadsheet/CopyofEmployee TimeSheet3-13-07.xls Sustainability • Evidence of sustainability will be required on annual budgets and annual financial reports. • We will be comparing actual progress to the plan set forth by grantee in their RFP. • Ultimate goal of grantee should be to maintain the program without assistance from the 21st CCLC program. 3 Supplement not Supplant • For all programs, federal funds can be used only to supplement and, to the extent practical, increase the level of funds that would, in the absence of federal funds, be made available from nonfederal sources. In no case may an LEA use federal program funds to supplant funds from nonfederal sources. • • • Supplement not Supplant (continued) Generally, an LEA is presumed to fund statemandated programs with local and/or state funds. The use of federal funds for these programs would be considered supplanting. In certain instances, an LEA may overcome this supplanting presumption (given the proper written documentation), that it does not have the funds necessary to implement the program or activity and that the program or activity would not be carried out in the absence of federal funds. • Supplement not Supplant (continued) • Examples from OMB Circular A-133 Compliance Supplement elaborates on instances when it is presumed that supplanting has occurred: – Uses federal funds to provide services that were required to be made available under other federal, state, or local laws. Uses federal funds to provide services that were provided with nonfederal funds in the prior year. Period of Availability • Grantees may begin to obligate funds on the later of the following dates: – – The beginning of the project period (July 1), or The date that the application and budget is approved. • – If the grantee incurs financial obligations before or after the grant period, they will be the responsibility of the grantee. Period of Availability • Annual 12 month Fiscal Year Budget (July 1st – June 30th) (may be extended to September 30th). • Grantee must be able to report expenditures as of June 30th to the district for annual filings to CDE even if an extension is granted. Budget Revisions • Revisions: After original Budget Approval. • You should revise budgets for the following reasons: – Make changes that involve changing activities or staffing within the program, or – Making corrections, cleaning up. • Ex: Benefits are higher/lower than anticipated 4 Request for Funds • Pursuant to EDGAR 34 CRF, Part 80.20 (b)(7), CDE is required to monitor grantees’ to ensure that procedures for minimizing the time elapsing between the transfer of funds from the US Treasury and the disbursement by the grantee is being upheld. Cash on hand by LEA/Grantees – at any time, the Feds may require LEA/Grantees (through CDE) to report the amount of cash advances in excess of three days needs, EDGAR 34 CRF, Part 80.41 (c)(3). Request for Funds • Must have an approved budget to request funds. • Forms are personalized and emailed to you; Not available on the CDE website. • Due no later than the 15th of the month for payment in the following month. • Request for Funds • Preparing Forms: – – – – – – – Read the Instructions page. Confirm your award. Enter “Expenditures to Date.” Enter “Anticipated Expenditures.” Enter previously requested funds Line D. Line B + C minus Line D = Line E (amount of current request). Make sure request is signed by the Authorized Representative and complete the contact information. Request for Funds, Common Errors • Entering only the current month’s expenditures. • Entering Anticipated expenditures for more than 1 month. • Not including funds requested but not yet received on Line D. • Not signing the form. • Not including contact information, i.e. the phone number. Request for Funds • Funds MUST be requested from CDE by October 15th for funds that expired on September 30th (the end of the funding period). CDE must have time to close up its books with the Federal government. Distribution Reports • Historical transactions are available on the CDE website: http://www.cde.state.co.us/cdefisgrant/Grant_ Distribution_Reports.htm • 5 Annual Financial Reports • Provide actual expenditure activity for the fiscal year being requested, due on November 15, 2007. • Budget Fiscal Year Period runs from July 1st – June 30th (may be extended to September 30th). • • Records Retention Availability for Audit by CDE and/or Fed’s. Subject to your Record Retention policy, generally CDE is looking at 5 years, plus the current year as the rule of thumb. Visit the State Archivist Website at: www.colorado.gov/dpa/doit/archives/rm/schools • Fiscal Review – What should I expect? • An account of all expenditures from 21st CCLC for a given fiscal year(s) will be requested. • After reviewing those expenditures, supporting documentation will be requested for selected transactions. – Items such as purchase orders, cancelled checks, timecards, etc. may be requested. Fiscal Review – What should I expect? • We are looking for compliance with all aforementioned topics such as: – – – – – – – – A-133, A-87, A-122, EDGAR. Adherence to approved budgets. Unallowable activity. Nutritious Snacks. Time and Effort. Supplanting. Filing of Annual Financial Reports. Minimization of cash on hand. Fiscal Review • Our intention is to educate and inform grantees as well as build stronger 21st CCLC programs for our youths. This review is to strengthen our programs and insure that the State of Colorado continues to be a model for other states. Federal Statutes and Regulations (FISCAL) • NCLB Act of 2001 • http://www.ed.gov/policy/elsec/leg/esea02/index.html • 21st Century Community Learning Centers • http://www.ed.gov/policy/elsec/leg/esea02/pg55.html 6 Federal Statutes and Regulations • EDGAR – Education Department General Administrative Regulations • http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html For more information contact: Grants Fiscal: David Lyon (303) 866-6836 lyon_d@cde.state.co.us Program: Valerie Bass (303) 866-6791 bass_v@cde.state.co.us Kim Burnham (303) 866-6916 burnham_k@cde.state.co.us Extra Slides EDGAR – Education Department General Administrative Regulations • Applicable Regulations: Parts 74, 76, 77, 80, 82, and 85. Part 74 – Administration of Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-profit Organizations. Part 76 – State Administered Programs. Regulations that apply to state administered programs. EDGAR – Education Department General Administrative Regulations Part 77 – Definitions. Part 80 – Uniform Administrative Requirements for Grants & Cooperative Agreements to State and Local Governments. Part 82 – New Restrictions on Lobbying. Part 85 – Requirements for Drug-Free Workplace. Request for Funds Form 7 21st CENTURY COMMUNITY LEARNING CENTERS FREQUENTLY ASKED BUDGET QUESTIONS AND ANSWERS 1. How do I request funds? Funds are disbursed on a monthly basis. A Request for Funds form is sent electronically with the approval letter or under separate cover by the Grants Fiscal Management Services Unit, David Lyon. Submit one copy of the Request for Funds form by the 15th of the month prior to the month the funds are needed. (For example: request funds by June 15th to receive funds in July.) Remember, funds cannot be obligated or expended until your application and budget have been approved by CDE. The request for funds form must be signed by the authorized representative of your school district. This person is usually someone in the budget office of the district. For non-profits, this is the director/executive director of the program. 2. How do I make revisions to my budget? Budget revisions are only required if it becomes necessary for you to make changes to activities or staffing within the program. If this occurs, a revised budget narrative and revised budget form must be sent to CDE for approval prior to making any spending changes. You should clearly state the reason for the revision, the dollar amount of each activity/purchase and if applicable where the funds are coming from. For questions about budget revisions contact David Lyon at lyon_d@cde.state.co.us / 303-866-6836 or Kim Burnham at burnham_k@cde.state.co.us / 303-866-6916. 3. Is there a deadline for submitting budget revisions? Yes. Budget revisions will be accepted and reviewed. Refer to the timeline for dates. The last day to request revisions of your current year funds is August 15, 2007. You should be reasonable in your timing when submitting budget revisions. It is important to periodically review your spending on an ongoing basis. 4. What if we don’t spend 100% of our funds by June, 30 2007? For schools that do not spend 100% of their funds by June, 30 2007, carryover may be available through September 30, 2007. 5. Will we be funded for year 2, 3, 4 or 5? Future years are contingent upon the availability of future congressional appropriations and approval of a yearly adequate progress report. 6. Is an annual financial report required? Yes, annual financial reports will be sent at the same time as the progress report and due by November 15, 2007. 7. Are “rewards/incentives” for both staff and students allowed? No. OMB Circular A-87, Cost Principals for State, Local and Indian Tribal Governments specifically addresses this issue under the general principles for determining allowable costs (Item 12(a) and Item 20). 8. What are indirect costs? Indirect costs are those that are incurred for a common or joint purpose benefiting more than one cost objective and not readily assignable to the cost objectives specifically benefited. Indirect costs applies to costs originating in the grantee department, as well as those incurred by other departments in supplying goods, services and facilities. Non-profits must have an approved indirect cost rate approved by their cognizant agency in order to claim costs. These are not additional dollars, but are part of your total funding received. The Public School Finance Unit at CDE approves and assigns rates to school districts on an annual basis. 9. What specific documentation requirements must be met to support employee time and effort charges for specific requirements? The requirements for time and effort reporting come from the Federal Cost Principles: OMB Circular A-87 for State, Local and Indian Tribal Governments; and OMB Circular A-122 for Nonprofit Organizations. Refer to the following document for useful information: http://www.cde.state.co.us/cdefinance/download/EmployeeTimeandEffort3-13-07.doc 10. How do I know what costs are allowable under my grant? The 21st Century Community Learning Centers federal statute and non-regulatory guidance contain specific information related to this grant. In addition, EDGAR (Education Department General Administrative Regulations) must be followed. Under OMB Circular A-87 Cost Principals, the basic guidelines state: To be allowable under Federal awards, costs must meet the following general criteria: a. Be necessary and reasonable. b. Be allocable to Federal awards. c. Be authorized or not prohibited under State or local laws or regulations. d. Conform to any limitation or exclusions as to types or amounts of cost items, as set forth in the Circular. e. Be consistent with policies, regulations, and procedures that apply uniformly to both Federal awards and other activities. f. Be accorded consistent treatment. g. Be determined in accordance with GAAP. h. Not be included or used to meet cost sharing or matching requirements. i. Be the net of all applicable credits. j. Be adequately documented. For nonprofits, OMB Circular A-122 contains similar guidelines. 11. How long do I have to keep my records for this grant? Generally, CDE is looking at 5 years plus the current year as the rule of thumb. Records must also be available for audit by CDE and/or Feds. 12. May breakfast, lunch, and after-school snacks be claimed under the National School Lunch Program on days when school is not normally in session, but the 21st CCLC program is operational? No, when school nutrition programs are provided on non-school days, funding for food and labor must come from other sources. One source of funding on non school days is the USDA's Child and Adult Care Food (CACF) program. The CACF program contains a provision that allows breakfast, lunch and snacks to be claimed on non-school days for children up to the age of 12. While the reimbursement rates for CACF are the same as the School Lunch program, different agreements and claim forms must be submitted. After-school programs that are operating during the summer may apply for reimbursement under the USDA's Summer Food Services program. The program is open to both elementary and secondary school age students. 21st Century Community Learning Centers Timeline for SY 2007-08 DATE September 11, 2007 September 20, 2007 September 28, 2007 September 30, 2007 October 15, 2007 EVENT 21 CCLC Fiscal Session at NCLB Directors Meeting 10 AM Fiscal Webinar contact burnham_k@cde.state.co.us to register Deadline for submitting CSAP data into PPICS, Certify that APR information is correct Final expenditure date for carry-over of July 1, 2006 - June 30, 2007 dollars Deadline for requesting funds expended from July 1, 2006September 30, 2007 Budget Revisions due for SY 2007-08 (all grantees) Meeting for new 21st CCLC Staff (responsible for grant administration) Required Networking Day Final CDE expenditure sheet for 2006-07 due (July 1, 2006 - June 30, 2007; plus any carry-over expenditures through September 30, 2007) Budget Narrative of expenditures must be provided MQI self-assessments due Professional Development opportunities in data analysis, reading (fluency) and ELL strategies Budget Revisions due for May- September 2008 (if needed) MQI Plan (for grantees that did not receive site visits) and PPICS (all grantees) due Grantees receive request for funds forms for 2007-08 contingent upon receipt of federal dollars and a successfully completed progress report checklist Budget Revisions due for September 2008 carryover (if needed) st November TBA November TBA November 15, 2007 December 14, 2007 January- May TBA April 15, 2008 June 27, 2008 July-August 2008 August 15, 2008