Don’t Take It For Granted!

Sarah Averill and Audrey HukariDivision of Grants AdministrationTexas Education Agency

Welcome and Introductions How Does TEA Calculate My Grant Funding? EDGAR Allowable Costs

◦Reasonable, Necessary, and Allocable

Supplement, Not Supplant Policies and Procedures Grant Resources

Topics

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SC5050 is a special collection used to determine eligibility and, if eligible, funding for the following programs:◦NCLB Programs

Title I, Part A Title II, Part A Title III, LEP Title III, Immigrant

◦Carl D. Perkins◦ IDEA-B (Newly opened charters only)

SC5050-Request for Federal Funding and Indirect Cost Rates for Charter Schools

SC5050 is also used:◦ If requested- to determine indirect cost rates for

charter schools

SC5050-Request for Federal Funding and Indirect Cost Rates for Charter Schools

SC5050 is also used to determine significant expansion If requested-NCLB Programs:

A minimum student enrollment of 300 Increase of at least 50% in the age 5 to 17 enrollment

If requested-IDEA-B: A minimum student enrollment of 50 Increase in enrollment must be at least 50%

SC5050-Request for Federal Funding and Indirect Cost Rates for Charter Schools

Circulars: A-87: State and Local Governments A-21: Educational Institutions A-122: Nonprofit Organizations

OMB’s website: http://www.whitehouse.gov/omb/circulars/index.html

Office of Management and Budget (OMB)

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Cost principles for LEAs, including charter schools

Allowable costs

◦Reasonable, necessary and allocable

Direct costs Indirect costs

OMB Circular A-87

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EDGAR Title 2 CFR Part 200

“Old” EDGAR “New” EDGAR after 12/26/14

OMB Circulars A-89, A-102, A-110 2 CFR Part 200, Subparts B, C, and D

OMB Circulars A-21, A-87, A-122 2 CFR Part 200, Subpart E

OMB Circulars A-133, A-50 2 CFR Part 200, Subpart F

EDGAR Parts 75 to 99 EDGAR Parts 75-79 and 81-99

EDGAR Parts 74 and 80 Incorporated into EDGAR

Auditors and Monitors:◦Outcomes vs. Process

Flexibility for Grantees Major emphasis on “strengthening

accountability”

A New Focus:Performance and Compliance

Costs must meet the following criteria:

◦Reasonable, Necessary & Allocable

◦Not prohibited by state/local laws & regulations

Request for Application (RFA)

◦Treated consistently

◦ In accordance with Generally Accepted Accounting Principles (GAAP)

Allowable Costs

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A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost.

What Does “Reasonable” Mean?

Could the costs be considered ordinary and necessary to carry out the grant program?

What are the market prices for comparable goods and services?

Did the individuals concerned act prudently?

Determining Reasonableness

A cost is necessary when it is vital or required in order to meet the objectives of the grant or for the grant to be successful.

It is not “nice to have”.

What Does “Necessary” Mean?

Costs must be allocated (or charged) to the grant program in accordance with the benefits received.

What are “Allocable” Costs?

Costs that can be identified specifically with a particular cost objective.

Examples:◦Salaries of employees that carry out program activities◦Supplies and materials◦Equipment◦Travel

Direct Costs

Costs incurred for a common or joint purpose benefiting more than one cost objective and not readily assignable to the cost objectives specifically benefited, without effort disproportionate to the results achieved.

Examples:◦Budget & Accounting◦ IT Support◦Human Resources◦Admin and clerical staff

Indirect Costs

An indirect cost rate that is approved by your cognizant agency, i.e. TEA.

Must submit the SC5050 on time each year and request an indirect cost rate.

What Do We Need To Claim Indirect Costs?

A cost may not be assigned to one source of funds as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to another source of funds as an indirect cost.

Consistent Treatment of Costs

Federal funds must supplement—add to, enhance, expand, increase, extend—the programs and services offered with state and local funds.

Federal funds are not permitted to be used to supplant—take the place of, replace—the state and local funds used to offer those programs and services.

In general both the funding & activities must be supplemental

Supplement, Not Supplant (SNS)

If I didn’t have federal funds available to conduct this activity/service, would I still conduct it with other funds anyway?

If yes, you are supplanting because it isn’t a supplementary activity

How Do I Know If I Am Supplanting?

All federal funds involved in a supplanting situation would most likely have to be returned to the federal government.

Is There A Penalty For Violating SNS?

Refer to the SNS section in the Program Guidelines

Refer to Schedule #2 in the SAS/application

How Do I Know If SNS Applies?

Draft them Approve them Know them Follow them Update them annually

Policies & Procedures

Accounting for property and supplies purchased with federal funds

Budgeting and accounting for federal grants Financial reporting and cash management for

federal grants Authorized uses for federal funds Maintenance and retention of records pertaining

to federal grants Monitoring and reporting program performance

for federal grants

What Policies & Procedures Do We Need?

Time and Effort reporting requirements Procurement of goods and services using

federal grants Program income generated from activities

supported by federal grants Support of salaries, wages and related costs

charged to federal grants Travel reimbursement requirements applicable

to federal grants Use of credit and debit cards

What Policies & Procedures Do We Need? (continued)

TEA Help Desk Applying for a Grant Administering a Grant Grants Awarded Data Training and Other Resources

TEA Grant Management Resources

Locate the TEA Grants Page

TEA Grants Page

Applying for a Grant TEA Help Desk Secure Environment: TEASE & TEAL Administering a Grant◦Enforcement Actions◦Guidance◦Handbooks◦Travel Information

TEA Grants Page (continued)

TEA Grant Opportunities Link

TEA Grant Opportunities

All available grants (eGrants & Paper) Listed by school year, then alphabetically Search Function:◦Application Name◦School Year◦Funding Type (Federal, State)◦Application Type (Discretionary, Formula)

TEA Grant Opportunities (continued)

Program Information◦Program Description◦Eligibility◦Statutory Authority

Funding Information◦Funding amount, grant period

TEA Grant Opportunities (continued)

Application and Support Information◦Parts of RFA, including Errata’s & FAQs

Critical Events◦Application due date, reporting dates

Contact Information◦Funding & program contacts

TEA Grant Opportunities (continued)

Administering a Grant

EDGAR Entitlements Grants Awarded◦Current Grant Balances◦Competitive Grant Selection Lists

General Grant Resources◦Expenditure Reporting Guidance◦General and Fiscal Guidance◦Handbooks and Other Guidance

Administering A Grant Page

General Contact Information

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