# Presentation: 680588

## Grant AdministrationFY06 ERCM Initial Grantee MeetingSan Antonio, TX December 7, 2006

**Rich Lucey**
**Education Program Specialist, ****U.S. Department of Education, Office of Safe and Drug-Free Schools**
**Bryan Williams**
**Program Analyst, ****U.S. Department of Education, **
**Office of Safe and Drug-Free Schools**

- Monitoring and Reporting Requirements
- Faith-Based Organizations
- Fiscal Management
- Audit Requirements
- Expanded Authorities
- Freedom of Information Act
- Useful Resources

***Agenda ***

## Monitoring & Reporting Requirements

- Notify Monitor of Changes
- Post-Award Performance Call
- Semiannual Monitoring Call
- Grant Performance Reports
- Interim and Final Reports

## Grant Performance Report (ED 524B) 

- ED's generic performance report for discretionary grants
- Used by ED's program offices as an *interim* and *final *performance report
- May be submitted electronically through       e-Reports

## Purpose of the ED 524B

- ED collects performance measures data from grantees to demonstrate program success to Congress (Government Performance and Results Act)
- Performance information:
- Guides ED's budget request for programs
- Ensures program implementation is focused on results
- Ensures success is measured by results achieved

## Purpose of the ED 524B

- Financial and performance monitoring tool for ED program offices for individual grants
_*Interim Reports*_:  Grantees provide data to demonstrate that they are making **substantial progress** toward meeting approved goals, objectives, and performance measures to receive continuation funding.
_*Final Reports*_:  Grantees provide data to demonstrate **overall project success and impact.**

## Highlights of the ED 524B

- _Project Objectives_: State what you hope to achieve with your funded grant project
- _Performance Measures_: Demonstrate whether you have met or are making progress toward meeting your project objectives, including GPRA measures

## Highlights of the ED 524B

- _ED 524B Cover Sheet (Item 7)_
**Interim Performance Reports:      **Reporting period is from start of current budget period through 30 days before due date of report.
- Interim performance reports are generally due 7 to 10 months after the start of each budget period.

## Highlights of the ED 524B

- _Budget Expenditures Data (Item 8)_** **
- All financial questions must be completed by your *Business Office*
**	**Submit actual budget expenditures for:
- 	1) Entire Previous Budget Period
- 	2) Current Reporting Period
- Break down expenditures between federal and non-federal funds

##  Highlights of the ED 524B

- Budget Information (Section B of the Project Status Chart) - must address
- Provide an explanation if funds *have not* been drawn down from GAPS to pay for budget expenditures reported in item 8 on Cover Sheet
- Describe significant budget changes resulting from modification of project activities

## Site Visits

- Site visits are a grant monitoring tool as provided for in EDGAR Part 74.51(g), "The Secretary may make site visits, as needed."
- Also called an on-site review
- A site visit may last multiple days

## Site Visits

- Reasons to conduct a site visit
- Program performance - Excellent
- Goals and objectives achieved in unique or innovative ways
- Development of effective strategies that may be replicable at other sites

## Site Visits

- Reasons to conduct a site visit
- Program performance - Problem
- Difficulty achieving goals and objectives
- Compliance issues
- Fiscal improprieties
- Technical assistance

## Site Visits

- What goes into site visit decision
- Review of materials
- Performance reports
- Financial reports
- Performance calls
- Correspondence
- Request for technical assistance

## Site Visits

- What to expect during the site visit
- Entrance and exit interviews
- Review of grant activities to date
- Review recent budget and expenditures with fiscal staff
- Review evaluation plan

## Site Visits

- What to expect after site visit
- Reviewer's written report
- Positive findings
- Exemplary practices
- Negative findings
- _Required Actions_: Compliance
- _Recommended Actions_: Non-binding suggestions

## Site Visits

- What to expect after site visit
- Grantee's response
- Required Actions
- Detail corrective actions that will bring grant into compliance with programmatic/fiscal guidelines
- Dispute findings and present supporting documents
- Recommended Actions
- Respond to recommended actions

## Site Visits

- What to expect after site visit
- Follow-up and closeout
- Grant monitor will follow up to ensure that all corrective actions have been accomplished
- Grant monitor will inform grantee in writing when review is closed

## Faith-Based Organizations

- White House Office of Faith-Based and Community Initiatives - January 2001
- Federal Agency Centers - January 2001
- Equal Protection of the Laws for Faith-Based and Community Organizations - December 2002

## Faith-Based Organizations

- Focus of the Initiative
- Identify and eliminate barriers that impede FBCOs in the federal grants process
- Increase accessibility to the federal grants process through training and technical assistance

## Faith-Based Organizations

- Core Principles
- Equal treatment for faith-based organizations applying for grants
- Preservation of religious liberty/character
- Protection of beneficiaries
- Federal funds may not be used for inherently religious activities

## Faith-Based Organizations

- The U.S. Department of Education amended its regulations (EDGAR) to reflect these principles.
- 74.44: Procurement procedures
- 75.52: Grant eligibility
- 75.532: Use of funds for religion prohibited

## Faith-Based Organizations

- Monitoring
- Faith-based organizations are subject to the same accounting and reporting requirements as all other grantees
- Federal funds may not be used for inherently religious activities

## Faith-Based Organizations

- Section 75.532: Use of funds for religion prohibited
- (a) No grantee may use its grant to pay for any of the following:
**(1) Religious worship, instruction, or proselytization**
**(2) Equipment or supplies to be used for any of those activities**

## Faith-Based Organizations

- Guidance to Faith-Based and Community Organizations on Partnering with the Federal Government
- www.fbci.gov
- U.S. Department of Education's Center for Faith-Based and Community Initiatives
- www.ed.gov/about/inits/list/fbci/index.html

## Fiscal Management

- Memo to discretionary grantees
- Draw down funds only as necessary
- Project director should continually monitor fiscal activity
- Excessive Drawdowns
- First Quarter: 50 percent or more
- Second Quarter: 80 percent or more
- Third Quarter: 100 percent

## Fiscal Management

- Large Available Balances
- 70 percent of the project's budget is available 90 days or less before the budget period ends
- Grant monitor works with grantee to reconcile situation

## Fiscal Management

- Indirect Cost Rates (ICR)
- Grantee must have a current ICR agreement to charge indirect costs
- Applicants without a current negotiated indirect cost rate that are selected for funding are subject to the terms and conditions included in Attachment D: Prohibition against Indirect Cost Recovery

## Fiscal Management

- Attachment D: Prohibition against Indirect Cost Recovery
**Grantee shall submit ICR proposal to cognizant agency (i.e., ED) within 90 days after award of the grant**
**Grantee may not charge its grant for indirect costs until negotiated ICR agreement is in place**
**Grantee must provide proof of its negotiated ICR agreement to grant monitor**

## Audit Requirements

- Two types of audits
- Grantee-Initiated Audit
- Independent Auditor
- Compliance with OMB Circular A-133
- Annually expend $500,000 or more in federal funds must have a single audit or program-specific audit performed for that year

## Audit Requirements

- Two types of audits
- OIG Audit
- Office of Inspector General
- Not every grantee is audited
- Office of Chief Financial Officer reviews A-133 audit reports
- OIG audit triggered by serious audit findings identified by OCFO
- Questions? Contact grant monitor

## Expanded Authorities

- Budget Transfers
- No-Cost Time Extensions

## Expanded AuthoritiesBudget Transfers

- Parts 74.25 and 75.264
- No prior approval required unless:
- Change in project scope or objectives
- Change in key personnel
- Notify grant monitor of transfer
- Amount of money
- Identify categories
- Purpose

## Expanded AuthoritiesNo-Cost Time Extensions

- Parts 74.25(e)(2) and 75.261
- One-time extension for up to 12 months without prior approval
- Written justification needed at least 10 days prior to extension
- Cannot be for the purpose of exhausting unexpended funds
- Cannot require additional funds nor change the project's scope or objectives

## Freedom of Information Act (FOIA)

- Any person has the right to request access to federal agency records or information
- All records must be made available, except:
- Privileged or confidential information
- Personal information

## Freedom of Information Act (FOIA)

- FOIA Process
- Project Director contacted
- 10 days to respond to ED
- Memo to FOIA Officer from ED
- Information sent to requestor
- Fee involved: research and personnel

## Useful Resources

- Web Sites
- Publications
- Telephone Numbers

## Useful Resources

- OSDFS Web Site
-  _[www.ed.gov/osdfs](http://www.ed.gov/osdfs)_

## Useful Resources

- What Works Clearinghouse
- Gathers studies on effectiveness of educational interventions
- www.w-w-c.org

## Useful Resources

- The Challenge Newsletter
-  OSDFS Publication
-  Provides information and resources to help create safe and healthy learning environments
-  www.thechallenge.org

## Useful Resources

- Training and Technical Assistance Centers
- Character Education and Civic Engagement
- Emergency Response/Crisis Management
- Higher Education
- Mentoring

## Useful Resources

- Character Education and Civic Engagement Technical Assistance Center
- Provides state program administrators, local educators, and the public with information on character education and civic engagement
- www.cetac.org
- Contact: Rita Foy Moss
- rita.foy@ed.gov

## Useful Resources

- Emergency Response and Crisis Management Technical Assistance Center
- Provides technical assistance and resources to grantees and non-grantee local educational agencies regarding crisis planning
- www.ercm.org

## Useful Resources

- Higher Education Center for Alcohol and Other Drug Abuse and Violence Prevention
- Provides training, technical assistance, and publications related to drug abuse and violence prevention on college campuses and in their surrounding communities
- _[www.higheredcenter.org](http://www.higheredcenter.org/)_
- Contact: Rich Lucey
- richard.lucey@ed.gov

## Useful Resources

- Mentoring Program Training and Technical Assistance Center
-  Ensure that programs funded under the Mentoring Program receive help in management and implementation of projects
-  Contact: Bryan Williams
- bryan.williams@ed.gov