grants monitoring and oversight
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Gilbert Tran Executive Office of the President
Office of Management and Budget
Governor’s Grants Conference 2011
Agenda
• The Big Grant Picture• Grant Basics• Grant Monitoring
and Oversight
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0
100
200
300
400
500
600
1960 1970 1978 1986 1994 2002 2010
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$7B $24B $91B $200B
$600B
CFDA lists more than 2,000 Federal grant programs
In Billion of $
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In 1950, Federal grants to states totaled $2.5 billion
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Distribution of Federal Grants
4%
1%
80%
8%
7%
States
Locals
Universities
Non-Profits
Tribes, For-Profit, Others
2012 US BUDGET - $3.7 TRILLION GRANTS- $600 BILLION
In 2012, Federal grants to states will total $480 billion
Patty, Will you marry me?
Patty, Will you marry me?
And pay my mortgage
My student loan
My child support
“Grants can’t be taken from granted”
Suspension Debarment Regulations
Drug Free Workplace Regulations
Lobbying
Act
Guidance Policy Manuals
Davis
Bacon Act
Terms and Conditions
Program Regulations
Statutes
OMB Circulars
Program Statutes
Appropriations
Govt.-Wide
Agency & Programs
Govt.-Wide
A&A
Grant Agreements, Terms and Conditions
Statutes
Authorizations: establish program, define purpose, prescribe eligibility standards and application process, set grant terms and conditions Appropriations: make fund available
OMB Circulars – Government-wide guidance adopted by agencies in their regulationsPublic Policy Requirements (e.g., lobbying, drug-free workplace)Agency Program and Administrative RegulationsOther Agency Guidance: policy manuals, award document T&C
OOH My head hurts!!
Cost Principles (Gilbert Tran)A-21- Colleges & UniversitiesA-87- GovernmentsA-122- Non-Profits
Administrative Requirements (Marguerite Pridgen)
A-102- GovernmentsA-110- Everyone Else
Audit Requirements (Gilbert Tran)A-133- Everyone
Compliance Supplement
What’s the LAW ?
$600 B
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Relation to Other CircularsRelation to Other CircularsRelation to Other CircularsRelation to Other CircularsType of Institution Cost Principles
Administrative Requirements
Audit
State/Local Government
A-87"Common Rule"
A-102A-133
Colleges & Universities
s
A-21 A-110 A-133
Hospitals & Care Facilities
Various, 45 CFR 74
Various, A-110 Various, A-133
Other Non-Profits A-122 A-110 A-133
For Profit (commercial)
48CFRPart 31 FAR FAR
Objectives of the Cost CircularsObjectives of the Cost CircularsObjectives of the Cost CircularsObjectives of the Cost Circulars
Provide guidelines for reimbursement requirementsProvide uniform standards of allowabilityProvide uniform standards of allocationDoes not supersede limitations imposed by lawSimplify intergovernmental relationsEncourage consistency in treatment of costs
Circular Basic PrinciplesCircular Basic PrinciplesProvide guidelines on cost reimbursements of Federal awards
Cost Allowability Direct and indirect costsAllocation of indirect costsProvisions on specific items of costs
RAA!!
RReasonableeasonable: “incurred by a prudent person”, “necessary for the operation”AAlllocablelocable: “benefits received”AAllowablellowable: Circular, law, T&C, local reg.
I just can’t wait to be …KING !!
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A-133 Single Audit - What is Audited?
Financial Statement audit Major Program
– Compliance with laws and regulations
– Internal control over compliance
Major Programs are based on auditor judgment Major Program Selection
– Size of Program
– Prior Audit Experience
– Federal Guidance
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Purpose of the Compliance Supplement
Identifies important compliance requirements that the Federal Government expects to be reviewed if it has a direct & material impact on program
CS is required to be used by auditors
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14 Types of Compliance Requirements
A. Activities allowed or unallowed
B. Allowable costs/cost principles
C. Cash management
D. Davis-Bacon Act
E. Eligibility
F. Equipment & real property management
G. Matching, level of effort, earmarking
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14 Types of Compliance Requirements
H. Period of availability of Federal fundsI. Procurement & suspension & debarmentJ. Program incomeK. Real property acquisition & relocation
assistanceL. ReportingM. Subrecipient monitoringN. Special tests and provisions
“Spending Stimulus take Money” - $787 Billion
“We’re going to operate in a transparent fashion so that taxpayers know this money is not being wasted on a bunch of boondoggles”
President Obama, Washington Post, June 12, 2009
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OMB Guidance -- 02/18/09, 04/03/09, 04/07/09, 05/11/09, 06/22/09, 09/11/09, 09/30/09,10/13/09, 11/30/09, 12/18/09, 3/22/10, 05/04/10, 09/24/10 Agency use SA for program risk assessment Agency use SA for program monitor
Separate ARRA CFDA, separate reporting on SEFA and DCF (including subrecipients)
Federal Audit Clearinghouse to display summary of all single audits
Review of Single Audits
Presidential Executive Memorandum 4/26/10 Combating Noncompliance with ARRA reporting requirement
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ARRAEffect of ARRA awards on major program determinationSEFA & SF-SAC presentation of ARRA awardsSeparate reporting of audit findingARRA programs –covered and not covered
Non-ARRAGranting of extensions suspendedLow-risk auditee criteria clarifiedLoan program safe harbor
If new ARRA CFDA added to cluster in 2011 Supplement and new ARRA CFDA has current year expenditures then cluster not qualify as low-risk
Cluster with new ARRA CFDA considered new programTherefore cannot qualify as low-risk Type A program as not pass the two-year look-back criteria
SFA & R&D ExcludedARRA portion of Pell Grant Program and Work-Study not identified to Grantee - SFA see Part 5-3, Section IVR&D, e.g., CFDA numbers not listed in Supplement
SFA and R&D ExcludedRule – If ARRA expenditures then not low-risk
Inherent risk associated with transparency and accountability requirements for ARRA funds preclude being low-risk
Exception if ALL of the following met:Had ARRA expenditures in 2010Audited as major program in 2010ARRA expenditures in current audit period less than 20% of total expenditures for program or clusterOtherwise determined low-risk under §___.520(c) and §___.525
SFA and R&D Excluded
Programs with ARRA expenditures considered programs of higher risk inherent risk ( §___.525(d))
When Type B programs are required to be selected as major under §___.520(e)(2), presumption is the programs with ARRA expenditures would be selected first.
However, auditor is not precluded from selecting an especially risky Type B program that does not have ARRA expenditures.
A, “Activities Allowed or Unallowed” to include limitations on activities funded with ARRA funds. D, “Davis-Bacon Act,” for coverage under ARRA.I, “Procurement and Suspension and Debarment,” to add ARRA Buy American requirements.L, Reporting
Added testing 1512 ReportingAward NumberAward AmountTotal Federal Amount ARRA Funds Received/InvoicedTotal Federal Amount of ARRA Expenditures
“Best Available Data” Clarification
M, Subrecipient Monitoring updatesRequirement for use Central Contractor Registry (CCR)
Clarification for timing
N, “Special Tests and Provisions,” for ARRA-funded expenditures.
Separate accountability for ARRA FundingPresentation on SEFA and Data Collection FormSubrecipient Monitoring
IPERA 2010 – Recapture AuditsS.303 – FFAMIA of 2009ARRA Internal Control Project Part 3 ARRA Single Audit Findings SypnosesARRA Single Audit MetricsPresidential Memorandum on State Flexibility – February 28, 2011
IPERA, July 22, 2010
Fall is here…Grants and Recovery Continue…
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