What does the uniform grant guidance mean to you?
MDOEFederal Grant Management
What is the Uniform Grant Guidance?
Published by Federal Office of Budget and ManagementConsolidates eight previously governing OMB CircularsContents of guidance focus on outcomes from use of fundsStrengthens oversight and targets fraud, waste and abuseEffective as of December 26, 2014Electronic Resources:Part 200—Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards:http://www.ecfr.govTechnical assistance documents from US DOE:http://www2.ed.gov/policy/fund/guid/uniform-guidance/index.html
MDOE responsibilities under UGG
Ensure that all sub recipients have the proper internal control systems to ensure fiscal responsibilityIncreased oversight for sub recipients and contractors paid with Federal funds, to include completion of risk assessments to set monitoring priorities for risk mitigationApproval of indirect cost rates for sub recipientsEnhanced documentation to show effort in ensuring sub recipients exercise fiscal responsibility
Sub recipient responsibilities under UGG
Ensure that costs charged to Federal grants are necessary, reasonable and allocable (accurately attributable to the grant)Take timely and appropriate action on any findings issued as a result of MDOE monitoring and/or annual auditRespond to MDOE requests for information and/or documentation in a timely mannerFor sub recipients desiring an indirect cost rate, sub recipient must complete application for approval submission; as the approver, MDOE cannot not do it “on behalf”. School units need to understand implications of recovering indirect costs
Indirect Cost Rates - Overview
Under the Uniform Grant Guidance, pass through entities are required to allow sub recipients to invoice for indirect costsWhile it is a requirement for MDOE to allow sub recipients to invoice, it is not a requirement for sub recipients to seek rate approvalBefore MDOE can approve sub recipient indirect cost rates, a rate calculation plan must be approved by US DOEMDOE is working with MAXIMUS Consulting to create a plan to submit to US DOE for approvalUS DOE approval is time consuming therefore, MDOE has no date certain when indirect cost rate approval may be offered to sub recipients
Indirect Cost Rate Components
System Administration (function 2300 series and 2500 series)Operations and Maintenance (function 2600 series)Extensive documentation required as part of applicationAccounting system reportsOrganizational chartSubcontractor/sub awardsSquare foot allocationsPaid leave at terminationInternal service funds
Indirect Cost Rate Considerations
No double recoveryof costs –if a cost is included in the indirect cost rate calculation, it cannot also be charged as a direct cost to the grant.Recovery of indirect cost charges will be posted as general fund revenue under revenue codes for operation and maintenance and system administrationIndirect cost revenue to the general fund will reduce costs considered in both the tuition rate calculation and the calculation of EPS per pupil rates for system administration and operation and maintenanceRecovery of indirect costs may adversely impact the excess cost calculation used to substantiate compliancein the use ofLocal Entitlement funds.Shifting of costs – no real “gain” in resources for studentsApplication is extensive
Indirect Cost Rates – Next Steps
Await for approval of plan from US DOEContinue to work with MAXIMUS Consulting to create:Sub recipient application packageMDOE process for review and approval of sub recipient applicationMDOE process for monitoring of indirect cost rate charges to Federal grantsTraining materials
Summary
Federal grant management requirements enhanced and now in effect for all Federal grants passed through MDOERequirements are designed to improve outcomes and demonstrate results from use of fundsMonitoring based on annual risk assessments; higher risk = increased sub grantee responsibilitiesMore frequent submission of documentation to demonstrate that costs are necessary, reasonable and allocableParticipation in targeted trainingIncreased site visits by MDOESubmission of corrective action plans for audit findings/site visit findings
Summary, continued
States now must recognize indirect cost rates for sub grantees who wish to invoice for indirect costsIndirect costs include certain system administration and operations and maintenancecostsBefore seeking approval, sub grantees need to understand implications to tuition rates and EPS per pupilamountsBefore a system of sub grantee rate approval can be implemented, MDOE must have a rate calculation plan approved by US DOEMDOE currently working with MAXIMUS Consulting to obtain US DOE approvalOnce MDOE is approved, sub grantees may apply for rate approval with MDOEFormal application process/template will be made available
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