# Presentation: 370365

## Tracking the money

- A primer for Rural Development Employees

- Karen Savoie Murray, OCD
- Alden Turner, RD/ME

## The Rules

**OMB Circulars****	****	**
- _[http://](http://www.whitehouse.gov/OMB/circulars/index.html#numerical)__[www.whitehouse.gov/OMB/circulars/index.html#numerical](http://www.whitehouse.gov/OMB/circulars/index.html#numerical)_
**A-21** Cost Principles for Educational Institutions
**A-87** Cost Principles for State, Local and Indian Tribal Governments
**A-102** Grants and Cooperative Agreements with State and Local Governments
**A-110** Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non‐Profit Organizations
**A-122** Cost Principles for Non‐Profit Organizations
**A-133 **Audits of States, Local Governments, and Non‐Profit Organizations

## The Rules

**USDA Regulations**_** **_
- _[http://www.access.gpo.gov/nara/cfr/waisidx/7cfrv15_99.html#3010](http://www.access.gpo.gov/nara/cfr/waisidx/7cfrv15_99.html#3010)_
**7 CFR Part 3015**	Uniform Federal assistance regulations
**7 CFR Part 3016**	Uniform administrative requirements for grants and cooperative agreements to State and local governments
**7 CFR Part 3017**	Governmentwide debarment and suspension (nonprocurement) drug‐free workplace (grants)
**7 CFR Part 3018**	New restrictions on lobbying
**7 CFR Part 3019**	Uniform administrative requirements for grants and agreements with institutions of higher education, hospitals, and other non‐profit organizations
**7 CFR Part 3052**	Audits of States, local governments, and non‐profit organizations

## 7 CFR PART 3016

- UNIFORM ADMINISTRATIVE REQUIREMENTS FOR GRANTS AND COOPERATIVE AGREEMENTS TO STATE AND LOCAL GOVERNMENTS

## 7 PART 3019

- UNIFORM ADMINISTRATIVE REQUIREMENTS FOR GRANTS AND AGREEMENTS WITH INSTITUTIONS OF HIGHER EDUCATION, HOSPITALS, AND OTHER NON-PROFIT ORGANIZATIONS

## Sec. 3016.20, 3019.21  Standards for financial management systems.

- Grantees responsible for:
- accurate, current, and complete disclosure of the grant financial activities
- records which adequately identify the source and application of funds provided for financially-assisted activities.
- grant or subgrant awards and authorizations, obligations and income.

## Sec. 3016.20, 3019.21  Standards for financial management systems

- Source documentation:
- cancelled checks,
- paid bills,
- payrolls, time and attendance records,
- contract and subgrant award documents, etc.

## Sec. 3016.20, 3019.21  Standards for financial management systems

- Cash management:
- minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by grantees and subgrantees
- must be followed whenever advance payment procedures are used.

## Sec. 3016.21, 3019.22  Payment 

- minimize the time elapsing between the transfer of funds and disbursement by the grantee or subgrantee, in accordance with Treasury regulations at 31 CFR part 205.
- Grantees and subgrantees shall disburse repayments to and interest earned on a revolving fund before requesting additional cash payments for the same activity.

## Sec. 3016.22, 3019.27  Allowable costs.

- Reasonable fees or profit to cost-type contractors
- No fee or profit (or other increment above allowable costs) to the grantee or subgrantee.
- Applicable cost principles.
- 	OMB Circular A-87
- 	OMB Circular A-122

## Sec. 3016.24, 3019.23  Matching or cost sharing

- Federal grants cannot be used as a match for another Federal Grant (statuory exceptions).
- Program income, as defined in Sec. 3016.25 and 3019.24, may not be used for cost sharing or matching.
- Does not apply to income earned by a grantee or subgrantee from a contract awarded under another Federal grant.
- In-kind contributions have special restrictions.

## Sec. 3016.26, 3019.26 Non-Federal audit

- Grantees and subgrantees are responsible for obtaining audits -- Single Audit Act Amendments of 1996 (31 U.S.C. 7501-7507) and revised OMB Circular A-133, ``Audits of States, Local Governments, and Non-Profit Organizations.''
- In USDA, revised OMB Circular A-133 is implemented in 7 CFR part 3052, ``Audits of States, Local Governments, and Non-Profit Organizations.''

## Sec. 3016.30, 3019.25  Changes and Revisions

- Funds can be moved within the approved budget categories
-  unanticipated requirements
-  limited program changes
- May require the prior written approval of the awarding agency.

## Purchases

- Sec. 3016.**31, **3019**.32**  Real property
- Sec. 3016.**32, **3019**.34**  Equipment
- Sec. 3016.**33, **3019**.35**  Supplies
- Agency must be compensated for residual inventory of unused supplies exceeding $5,000

## Sec. 3016.36, 3019.41-.48  Procurement

- Grantees and subgrantees will use their own procurement procedures
- reflect applicable State and local laws and regulations,
- conforms to applicable Federal law and standards identified in this section.

## Sec. 3016.40, 3019.51  Monitoring and reporting program performance. 

- Grantees are responsible for
- managing grant and subgrant supported programs, functions and activities.
- compliance with applicable Federal reporting requirements
- achievement of performance goals
- Performance reports must be submitted on schedule required by agency

## Sec. 3016.41, 3019.51-.52  Financial reporting

- Standard Form 269 or 269A, Financial Status Report (some exceptions for construction grants)
- Accounting basis -- cash or accrual basis as prescribed by the awarding agency.
- Frequency -- No more than quarterly (30 days), no less than annually (90 days if annual).
- Request for advance or reimbursement--Standard Form 270, Request for Advance or Reimbursement.
- Standard Form 271, Outlay Report and Request for reimbursement for Construction Programs.

## Sec. 3016.42, 3019.53  Retention and access requirements

- applies to all financial and programmatic records, supporting documents, statistical records, and other records of grantees or subgrantees
- does not apply to records maintained by contractors or subcontractors.
- records must be retained for three years after (unless litigation pending)

## Sec. 3016.43, 3019.61-.62  Enforcement

- If Grantee fails to comply with statute or regulation
- agency may:
- Temporarily withhold cash payments
- Suspend or terminate the current award for the grantee's or subgrantee's program,
- Withhold further awards for the program (tax benefits, earmarks)
- The agency will provide the grantee or subgrantee
- an opportunity for hearing, appeal, or
- Other administrative proceeding

## 7 CFR 25

- Regulation changes for employees

- Karen Savoie Murray, OCD
- Alden Turner, ME

## Highlights of the changes

- Implementation
- Lead entity requirements
- Board composition
- Grants management regulations
- USDA regulations adopted
- Project eligibility criteria established
- Environmental regulations adopted

## Subpart E --

- Post-Designation Requirements

## § 25.404 Validation of designation

- § 25.404(a) Maintaining the principles of the program
-        Continuous improvement
-      Participation

## § 25.404(b) Administration of the strategic plan

- The strategic plan must be administered in a manner consistent with the principles of the program contained in § 25.202(a).

## Administration of the strategic plan

- Lead entity
- legal status and authority to receive and administer Federal funds
- legal capacity to implement the plan
- Board membership
- representative of entire socio-economic spectrum
- 55% elected
- one member from each census tract
-  elected and representative of the low income residents

## Administration of the strategic plan

- Partnerships are critical to success !
- local governments/institutions
- regional organization
- community organizations
- Public information –
- keep citizens and partners informed
- must have written PR procedures

## Subpart G -- 

- Round II and Round IIS Grants

## § 25.620   Eligible grant purposes

- services directed at the goals of --
- economic self-sufficiency
- preventing or remedying neglect, abuse, or exploitation of children and adults unable to protect their own interests, or preserving, rehabilitating or reuniting families;
- projects and activities identified in the strategic plan for the area; and
- activities that benefit residents of the area for which the grant is made.

## § 25.621   Ineligible grant purposes

- local match required for other federal grants;
- duplication or replacement of current services or financial support provided from other sources.  Expanded service OK.
- assisting a private business with less than 51 percent ownership by US citizens or legal permanent residents;
- relocation of businesses from other communities;

## § 25.621   Ineligible grant purposes

- support or promotion of gambling;
- political activities;
- preparation of EZ/EC program application package;
- costs incurred prior to the execution date of the MOA;
- judgments or debts owed to the United States;
- political lobbying.

## § 25.604   Disbursement of grant funds

- 7 CFR 3015, 3016 and 3019 of this title govern disbursements
- “request for advance or reimbursement,” in form and substance satisfactory to USDA, must be completed by the grantee on behalf of itself and all applicable subrecipients and submitted to the funding official.

## § 25.604   Disbursement of grant funds

- Requests for funds must include for each benchmark activity :
- $ amount requested;
- cumulative $ amount received;
- total obligated $ for each;
- total approved budget for the project (all sources);
- % of the benchmark completed;
- certification that the lead managing entity are in compliance with all applicable laws and regulatory requirements; and
- other information as the funding official may require.

**www.access.gpo.gov/nara/cfr/waisidx_02/7cfrv15_02.html#3000**

- OTHER  USDA  REGULATIONS

**7 CFR part 3015**, *“Uniform Federal Assistance Regulations”*
**7 CFR part 3016**, *“Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments”;*
**7 CFR part 3017**, *“Governmentwide Debarment and Suspension (Nonprocurement) and Governmentwide Requirements for Drug-Free Workplace (Grants)”;*
**7 CFR part 3018**, *“New Restrictions on Lobbying”;*
**7 CFR part 3019**, *“Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and other Non-Profit Organizations; and*
**7 CFR part 3052**, *“Audits of States, Local Governments, and Non-Profit Organizations.”*

## What Next?

- For more information:
- OCD Website – Grants Management site
- Slideshows will be posted on conference web site
- Call your desk officer, or
- Email _[ocd@ocdx.usda.gov](mailto:ocd@ocdx.usda.gov)__ with questions_