Financial Compliance Issues

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Nov 10, 2013 (3 years and 8 months ago)

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www.mohealthwins.org

More Than You Ever Wanted to
Know


About

Administrative Costs

Leveraged Resources

Accrued Expenditures &


Unliquidated Obligations

MoHealthWINs TAACCCT Grant

Prepared by the OTC Finance Office

October 26, 2012


Financial Compliance Issues

Grant Detail and Contact Info

Total Award: $19,982,296.00 CFDA #17.282

Period of Performance: 10/1/11 to 9/30/14


Fiscal Lead: Ozarks Technical Community College Finance Office

Vice
Chancellor of
Finance


Marla Moody

Senior Staff Accountant


Chasity Daniels

Grants Accountant


Betty Denson: 417
-
447
-
4831, densonb@otc.edu



Program
Director


Dawn Busick

housed
at
MCCA Office:
573
-
634
-
8787





Information Resources on MCCA Website
:
www.mccatoday.org

New Reimbursement Report



MHW Reimbursement Report updated
:


Lines for Accrued Expenditures and Unliquidated
Obligations


Funds expended to date (actual requests) and
committed to date (includes accrued expenditures
and unliquidated obligations)


Additional field to show percentage of administrative
funds spent to date



www.mohealthwins.org

Administrative Costs


8% administrative cap applied across
total

budget


Consortium members with ICR may want to claim all
administrative costs as indirect


Consortium members without indirect costs may
claim administrative costs in direct line items


Must report total administrative costs claimed on
each reimbursement report

Administrative Costs


Not related to direct provision of workforce
investment services, including services to
participants and employers


Can be personnel or non
-
personnel


Can be direct or indirect





Administrative Costs
-

Examples


Accounting, budgeting, auditing


General legal services functions


Information system development (unless related
to program delivery)


Support personnel, travel costs, other goods and
services related to administrative functions


Program Costs


Directly related to provision of workforce
investment services, including services to
participants and employers


Can be personnel or non
-
personnel


Can be direct or indirect



Program Costs
-

Examples


Vendor contracts (unless solely for administrative
functions)


Case management


Information system development for tracking
participant and performance information


Support personnel, travel costs and other goods
and services related to program functions


Administrative vs. Program Costs


Not to be confused with direct or indirect costs


Reasonable and based on benefit received


Some costs may need to be prorated


Allocate based on actual costs involved or duties
performed
-

not job titles or general categories
-

be prepared to defend


Program guidance found at 20 CFR 667.220

The MHW Grant & Leveraged Resources


MHW Grant does not require match


requires
leveraged resources reporting


Leveraged resources not defined in federal
regulations or related administrative requirements


29 CFR 95.23 provides limited guidance



Leveraged resources could be described as:


“all resources used by the grantee to support grant
activity and outcomes, whether or not those resources
meet the standards required for match”*


DOL Training Handout: Background for Match and Leveraged Resources


What are Leveraged Resources?


May be paid for with federal or non
-
federal funds.


Includes both cash and in
-
kind contributions.


Must be allowable under the OMB cost principles.


No administrative cost limitation on LR.


Consortium committed
to report over $11 million in
leveraged resources over the life of the grant.


Federal Project Officer will decide what actions to
take if consortium not able to meet commitment.


Reporting Leveraged Resources


Reported each quarter
-

9130 Report (OTC Finance
Office) and Program Narrative (Program Director)


Colleges report at least quarterly


Totals listed on Reimbursement Report Form


Summary sheet attached
-

for reporting and
verification


Keep backup documentation for


on
-
site monitoring

Leveraged Resources
-

Examples


Unclaimed indirect costs


Direct costs that could have been charged to the
grant, but
were not
: donated space, staff salaries,
supplies, outreach, web costs, travel costs in support
of the grant, etc.


Equipment used for grant


purchased with
institutional funds, other federal funds, or donated


Curriculum costs not charged to grant


Documented third party donations of space,
personnel, or other resources



Leveraged Resources Valuation


Guidance available at 29 CFR part 95.23


Not used for contributions on other federal
projects


Necessary, reasonable, verifiable


Allocate to show amount of benefit to grant


Document and be prepared



to defend valuation




Accruals and Obligations


DOL requires accrual reporting


Better reflection of true
program costs


Colleges report totals on Reimbursement Report


Retain documentation for on
-
site monitoring


OTC Finance Office reports on Form 9130


Failure to report on accrual basis could lead to
loss of funds

Accrued Expenditure or


Unliquidated Obligation?


An obligation is a commitment of funds


All accrued expenditures are obligations, but not
all obligations are accrued expenditures


Questions to
Ask:


Has performance been completed?


What is our obligation to pay if the program
ends?



Details of the Obligation


Unpaid delivered goods
-

accrued expenditure


Contracted
goods
-

unpaid, but not
yet delivered


unliquidated obligation


Payroll
-

accrual if work performed, not yet paid


Travel
expenses
or utilities
-

may
be
accrual


Contracts
-

may
be accrual
or
obligation


Contract
-

work performed, not paid
-

accrual


Contract with legal commitment
-

may be obligation


Review contract terms


Questions?

This workforce solution was funded by a grant awarded by the U.S.
Department of Labor's Employment and Training Administration. The solution
was created by the grantee and does not necessarily reflect the official position
of the U.S. Department of Labor. The Department of Labor makes no
guarantees, warranties, or assurances of any kind, express or implied, with
respect to such information, including any information on linked sites and
including, but not limited to, accuracy of the information or its completeness,
timeliness, usefulness, adequacy, continued availability, or ownership.


This PowerPoint and Other Informational Resources are

Available on the MCCA Website at www.mccatoday.org