Welcome to Washington, DC
Seminar on Financial Management Office of Justice Programs Office of the Chief Financial Officer
APPLICATION
CLOSEOUT
FINANCIAL LIFE CYCLE OF GRANTS
GRANT ADMINISTRATION
BUDGET REVIEW
AWARD
Financial Management Systems
Financial Management Systems
All recipients are required to: Establish/maintain auditable accounting records; Accurately account for funds awarded; and Funds for each award must be accounted for separately from other grants and other funding sources. Records shall include Federal, matching, and program income.
Financial Management Systems
ďƒ˜States and locals shall expend/account for grant funds per Federal or State laws & procedures for their funds. (whichever are more restrictive)
Financial Management Systems
Accounting and Internal Controls: ďƒ˜Proper stewardship of Federal resources is an essential responsibility of the grantee organization. ďƒ˜Grantees must ensure that Federal programs and resources are used efficiently and effectively to achieve desired objectives.
Financial Management Systems
Adequate Accounting System: ďƒ˜Grantee must maintain an adequate system of accounting and internal controls and ensure that an adequate system exists for each of its subrecipients.
Financial Management Systems
An adequate accounting system: ďƒ˜Meets requirements for periodic reporting. ďƒ˜Provides financial data for planning, control, measurement, and evaluation of direct and indirect costs.
Financial Management Systems
In summary, a Financial Management System must be able to record and report on the: Receipt; Obligation; and Expenditures of grant funds
MATCH
MATCH
CASH versus IN-KIND
MATCH
To calculate match: Award Amount
=
% of Federal share
Adjusted x Project Cost
Recipient’s Share
Adjusted Project Cost
=
Required Match
Ex:
Federal Amount = $80,000 80/20 Match $80,000 = $100,000 Adjusted Project Cost 80% $100,000 X 20% = $20,000 Required match
FINANCIAL MANAGEMENT SEMINAR
CONFERENCE PLANNING, COSTS, & REPORTING
Conference Planning • Effective October 21, 2011 the Department of Justice (DOJ) implemented new guidelines and policies for conference planning, costs, and reporting. • The new guidance supersedes the previous guidance in the OJP Financial Guide and Food & Beverage Policy. • Grant recipients should minimize the costs of each conference to ensure prudent spending of Federal funds.
Conference Planning • Conference costs should be free from the fact or appearance of extravagant spending. • Whenever possible, grant recipients should seek alternative means to conduct training such as: Webinars; Acquiring the lowest cost locations and venues; Minimizing travel costs; and Ensuring all conference costs are necessary business expenses.
Conference Costs (Food & Beverages) New awards, contracts, and agreements:
• No OJP funding can be used to purchase food and/or beverages for any meeting, conference, training, or other event. • This restriction applies to any and all refreshments regardless of the size or nature of the meeting, but does not apply to water provided at no cost. • Additionally, this restriction does not impact direct payment of per diem amounts to individuals in a travel status under your organization’s travel policy.
Conference Costs Prior Approval • Grantees funded through cooperative agreements may not conduct a conference, meeting, or training without the prior consent and approval of the OJP bureau or program office. • An event may not proceed unless formal approval is received from OJP. • In absence of approval from OJP, grantees must cancel the event.
Conference Reporting • All awards, cooperative agreements, and contracts that include holding a conference as part of the recipient’s responsibility must submit the required report. • For cooperative agreements – the report must be submitted 45 days after the end of any event that meets the following criteria: total cost of the event exceeds $20,000 in award funds, or more than 50% of attendees were DOJ employees
Conference Reporting • If the “Other Costs” category exceeds 20%of the total conference, the recipient must submit a breakdown of those costs. • If any item(s) is paid for with registration fees, or any other non-award funding, then that portion of the expenses does not need to be reported. • All OJP cooperative agreement recipients with qualifying expenditures must utilize the tool in GMS (Wed-based Conference Cost Reporting) to submit their report.
FINANCIAL MANAGEMENT SEMINAR
HIGH RISK GRANTEES
FINANCIAL MANAGEMENT SEMINAR
High Risk Grantees Have a history of unsatisfactory performance Are not financially stable Have a management system which does not meet the management standards set forth in 28 C.F.R., Section 66.20 (Standards of Financial Management Systems)
FINANCIAL MANAGEMENT SEMINAR
High Risk Grantees Have not conformed to the terms and conditions of previous awards Have open Single Audit or Office of Inspector General (OIG) audit report recommendations Have significant non-compliance issues Are otherwise not responsible (e.g., open site visit, requests for information from DOJ program manager, etc.)
FINANCIAL MANAGEMENT SEMINAR
Reporting Requirements
Reporting Requirements
REPORT Section 1512(c)
SYSTEM FederalReporting.gov
Cumulative reporting for Recovery Act Awards
FFR/SF-425
Grants Management System (GMS)
Federal Financial Report (Formerly SF-269)
Progress Reports
Grants Management System (GMS)
Program/Project Activity Reports
Performance Measures
Performance Measurement Tool (PMT) Grants Management System (GMS)
Other Reports (Conference cost reporting, etc.)
Grants Management System (GMS)
Federal Financial Report (SF-425)
Federal Financial Report (SF-425)
ďƒ˜Quarterly Federal Financial Reports are submitted through the Grants Management System (GMS) at https://grants.ojp.usdoj.gov. ďƒ˜Grant recipients will be required to report grant expenditures utilizing the Federal Financial Report Form (SF-425). This form replaced the Financial Status Report (FSR), known as the SF-269.
Federal Financial Report (SF-425)
ďƒ˜ Financial information reported on the SF-425 is similar to the SF-269. ďƒ˜ The SF-425 quarterly report must be submitted no later than 30 days after the end of each calendar quarter.
Federal Financial Report (SF-425)
SF-425 – due Quarterly Reporting Period
Delinquent After
Oct 1 - Dec 31
January 30
Jan 1 - Mar 31
April 30
Apr 1 - Jun 30
July 30
Jul 1 - Sept 30
October 30
Funds will be frozen if report is not submitted within 30 days
Federal Financial Report (SF-425)
Problems with SF-425? Contact: OCFO Customer Service Center 1-(800)-458-0786 or (202) 305-9988 Email: ask.ocfo@usdoj.gov Fax#: (202) 353-9279
FINANCIAL MANAGEMENT SEMINAR
OMB A-133 Audit Requirements State, Local Governments, & Non-Profit Organizations
AUDIT REQUIREMENTS
A-133 Gov't, Education and Non-Profit Thresholds $500K or more expended during the FY - Single Audit required Audit Report - due nine (9) months after end of FY Submit online to Federal Audit Clearinghouse (FAC)
$10,000 or more in questioned costs must be included in the Single Audit report
RESOLUTION OF AUDIT REPORTS
Office of Audit, Assessment, and Management
Establish working file for the audit report. Review and analyze the audit report. If there are any findings, a letter must be generated to the audited recipient. This letter should include a request for a Corrective Action Plan (CAP).
RESOLUTION OF AUDIT REPORTS
The corrective action plan (CAP) should include: Description of each finding. Specific steps to be taken to implement the recommendation. Timetable for performance of each corrective action. Description of monitoring to be performed to ensure implementation of CAP.
RESOLUTION OF AUDIT REPORTS
Recipient must generate response to the CAP letter within the specified time frame, usually within 30 calendar days from the letter. Analyze response and follow up on action taken. A special condition will be placed on new awards if report is delinquent.
FINANCIAL MANAGEMENT SEMINAR
MONITORING DISCUSSION
Monitoring Discussion
Grants Financial Management Division’s Mission Ensure stewardship over Federal funds awarded by: On-Site financial reviews OCFO-Based financial reviews Technical assistance to grantees
Monitoring Discussion
How are grants selected for on site-review? Dollar amount of grant New grant or grantee Inherent risk of program Program Office Request Grantee’s request for technical assistance Problems identified through OCFO Based review Random sample
Monitoring Discussion
What will be reviewed during the on-site visit? Internal Controls Accounting System Accounting procedures including cash management procedures Federal Financial Reports (SF-425s) Compliance with Recovery Act Reporting Requirements and Special Conditions (if applicable) Test and Analyze expenditures Provide technical assistance
Monitoring Discussion
Compare your actual expenditures with your grant objectives and approved budget APPROVED BUDGET
ACTUAL EXPENDITURES
Are you spending the money according to the purpose of the award?
Monitoring Discussion
If there are deficiencies in your objectives and/or you have deviated from the budget without prior approval from the program office ‌..
CORRECTIVE DEVELOP
ACTION PLAN
OCFO will help you get back on track
Monitoring Discussion
What are the objectives of the OCFO based review? Conduct an analysis of grant activity to date Analyze Federal Financial Reports (SF-425s) Determine compliance with audit report submission requirements Determine compliance with Section 1512 reporting requirements (if applicable) Evaluate payments -- determine excess cash Identify grantees who need on-site financial review
Primary Grantee’s Responsibility
ďƒ˜The primary grant recipient is responsible for monitoring the subrecipient and ascertaining that all fiscal and programmatic responsibilities are fulfilled, including compliance with Federal rules and regulations (e.g., OMB Circular A-133 compliance, EEO compliance).
FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT OF 2006 (FFATA)
Subaward and Executive Compensation Reporting • Requires prime recipients to report on first-tier subawards of $25K or more. • Requires prime recipients to report executive compensation for prime or subawards if: The organization received 80% or more of its annual gross revenues in Federal awards and those revenues are greater than $25 million; and The public does not have access to information about executive compensation through periodic reporting.
Subaward and Executive Compensation Reporting • Prime recipients must report FFATA requirements in the (FFATA) Subaward Reporting System (FSRS) www.fsrs.gov. • Subaward information required for reporting: Name of entity receiving award Amount of award (obligated amount) Funding agency CFDA program number/NAICS code for contracts
Subaward and Executive Compensation Reporting • Subaward information required for reporting: Program source Award description Location of the entity (including congressional district) Place of performance (including congressional district) Unique identifier of the entity and its parent; and Total compensation and names of top five executives (prime and subrecipient)
When to Reporting • For Federal awards of $25K or more made on or after October 1, 2010, the prime recipient must report first-tier and executive compensation data. • Data must be reported in FSRS the following month after the obligation is made. Example: Awards made during October 2010 will have until November 30, 2010 to report.
Other Related Requirements for FFATA • CCR registration for prime recipients • DUNS number required for prime and first-tier subawards • If required, prime must report executive compensation for prime through CCR
CLOSEOUTS
CLOSEOUTS
Award recipients have 90 days after the end date of the award to close out the award. Cash Reconciliation Request reimbursement of funds to cover expenditures. The Federal expenditures must be equal to or greater than the cash disbursements from the awarding agency. Drawdown of Funds Request final payment Funds will be frozen after 90 days
CLOSEOUTS
CLOSEOUT REQUIREMENTS: Final Federal Financial Report (SF-425) Final Progress Report
Refund Excess Cash
CLOSEOUTS Refund excess cash Make check payable to DOJ/Office of Justice Programs Cover letter or voucher containing the grant number for the refund, itemization of funds and the unobligated balance. Printout of the final SF-425 report which supports the amount of the refund
Failure to remit payment to OJP will be referred to the U.S. Department of the Treasury for collection.
OJP Financial Guide The United States Department of Justice Office of Justice Programs Office if the Comptroller
Financial Guide
Electronic Access for the OJP Financial Guide via Internet
http://www.ojp.usdoj.gov/financialguide
OJP Financial Guide
Part I - General Information Part II -- Pre-award Requirements GuidePost Award Requirements PartFinancial III -Part IV -- Organization Structure
Electronic Access for the OJP Financial Guide via Internet
http://www.ojp.usdoj.gov/financialguide
FINANCIAL MANAGEMENT SEMINAR
Resources
OCFO Financial Questions via Telephone/Internet OCFO Customer Service Center Monday through Friday 8:30 a.m. - 6:00 p.m. est. 1-(800) 458-0786 or (202) 305-9988 FAX (202) 353-9279
OCFO e-mail Address: ask.ocfo@usdoj.gov
COPS Financial Questions via Telephone
Department of Justice Response Center Monday through Friday 9:00 a.m. - 5:00 p.m. est. 1 (800) 421-6770
HOW TO ACCESS GRANT $$
Catalogue of Federal Domestic Assistance (CFDA)
Over 1,999 Programs Represents $400b 52 Agencies Search by Keyword http://www.cfda.gov
HOW TO ACCESS GRANT $$
For more information Call the Federal Service Desk: 1-866-606-8220 FEDERAL DOMESTIC ASSISTANCE CATALOG STAFF 307 - 7th Street, S.W. Room #101 WASHINGTON, D.C. 20407
Electronic Access to Circulars & Common Rules via Internet OMB Home Page: www.whitehouse.gov/omb/ http://ecfr.gpoaccess.gov Click “Code of Federal Regulations”
DOJ Grants Financial Management Online Training • 24 Modules
• Topics similar to 2-day Regional Financial Management Training • Direct award recipients w/active grants/cooperative agreements • https://gfm.webfirst.com/
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