n e hsa fiscal systems
TRANSCRIPT
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Belinda Rinker, JD
Senior Advisor to the Office of Head [email protected]
The Elements OfAn Effective Fiscal System
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HumanResource
s
ProgramGovernan
ce
ERSEA
Child andFamily
Outcomes
Self-Assessme
nt
Child andFamily
Outcomes
Communication
Records &Reporting
Facilities,Materials &Equipment
Planning
OngoingMonitoring
Head Start
Performance Standards
1301, 1304.50,1304.511304.52, 1304.53, 1305
Fiscal Regulations
45 CFR 74 or 92;2 CFR 220,225 or 230
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Families
Community
Children
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Head Start
Early Head
Start
Grantee
Organization
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Governance
FiscalProgram
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Governance
FiscalProgram
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Governance
FiscalProgram
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Fiscal System Elements
Financial
Management Systems
Recordkeeping and
Reporting
Procurement
Compensatio
n
CostPrinciple
s
Facilitiesand
Property
Non-federalShare
Cost Allocation
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Systems
45 CFR 74.21 or 45 CFR 92.20
Accurate, current and complete disclosure of programfinances.
Records that adequately identify the source andapplication of funds.
Effective control over and accountability for funds,
property and program assets. Separation of fiscal duties
Board member with fiscal management or accountingexpertise
Annual Financial Audit
Comparison of actual outlays (amounts spent) withbudgeted costs.
Written procedures to minimize the time betweendrawdown and expenditure (payment) of costs and
expenses.
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Recordkeeping and Reporting Personnel files.
Volunteer files. Food service and menu records.
USDA Nutrition Assistance Programs
Facilities and equipment records. Property inventory and facilities records
Valid licenses and registrations required by Federal, State orlocal law
Insurance records. General liability, property, student accident, title insurance
(facilities) Fiscal records.
Status of grant funds (budget, projected and actual)
Cost are reasonable, allocable and allowable (cost principles)
Fiscal reports. Internal: Board, Policy Council (monthly), budgets, aged
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Procurement45 CFR 74.42, 74.44 or 45 CFR 92.36
Written procurement procedure applicable to goodsand services purchased.
Complies with all Federal, State and local regulations: bidprocess, Davis-Bacon Act compliance
Includes written code of conduct for employees engagedin awarding or administering contracts: related parties,conflicts of interest
Contracts are accurate, complete, signed and up to
date. Purchases of goods: supplies, equipment, vehicles
Personal service contracts: nutrition consultant, mentalhealth professional
Delegate agency agreements
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Compensation Compensation for all employees meets the cost
principle requirements: necessary, allocable and
reasonable. Wages, benefits, bonus and incentives
Executive Level II limitation is met ($179,700)
Adequate records are available to supportcompensation.
Time records for all non-exempt employees
Payroll records for all employees
Personnel activity reports Compensation costs for employees whose services
benefit more than one program are property allocated.
Compensation reporting (external) is timely, complete
and accurate: IRS, state taxes, workers compensation,
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Cost Principles2 CFR Part 220, 2 CFR Part 225 or 2 CFR Part 230
Written procurement procedures to determine that all
expenses are allowable, necessary and allocable.Adequate documentation supports expenditure.
Allowable: Reasonable for performance of the award (see below)
Consistent with policies and procedures and treated consistently Not charged to another program
Adequately documented
Cost limitations and exclusions are followed
Reasonable: does not exceed what a prudent person
would pay under similar circumstances at the time thedecision was made. Generally recognized as ordinary and necessary
Complies with sound business practices: arms length transactions
Prudence was exercised in light of responsibilities Follows established ractices and does not un ustifiabl increase
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Cost Principles (Continued)2 CFR Part 220, 2 CFR Part 225 or 2 CFR Part 230
Allocable: A cost is allocable (can be charged) to aparticular grant if it is charged in accordance with thebenefit to the grant:
The cost is incurred specifically (100%) for the chargedgrant, or
The cost benefits both the award and grant(s) and can bedistributed between or among programs in reasonableproportion to the benefits received, or
The expense is necessary to the overall operation of the
organization, although a direct relationship to anyparticular grant cannot be shown.
Costs may not be shifted from one grant to another tocover deficiencies in funding or avoid restrictions.
The cost principles also apply to costs and expenses
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Non-federal Share
The grantee agency must provide 20 percent of the
total costs of the Head Start program unless a waiverhas been granted.
For every federal Head Start dollar received the granteemust provide twenty-five cents (absent a waiver)
Criteria for application for waiver (written) are lack ofcommunity resources, initial costs, unanticipated costincreases, major disaster and community impact (See
ACF-PI-HS-12-02)
Allowable non-federal share costs meet applicable costprinciples: necessary, reasonable and prudent.
Adequate documentation is required to support non-federal share costs.
Except where specifically authorized by statute, other-
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Cost Allocation
Cost allocation is required when costs are shared by
two or more programs. Includes costs shared between Head Start and Early
Head Start
Includes costs shared between either Head Start or EarlyHead Start and programs or services from anotherfunding source
Exception is either Head Start or Early Head Start and itsassociated USDA Nutrition Assistance Program
Shared costs must be fairly allocated between oramong the programs that benefit from those costs inaccordance with a cost allocation plan.
Grantees have the option to apply for a negotiated
indirect cost rate or allocate indirect costs.
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Facilities and Property45 CFR Part 1309, 45 CFR Part 74 or 45 CFR Part 92
Special requirements apply to all facilities which are
purchased (initially or through mortgage payments),constructed or undergo major renovations using Head Startfunds (in whole or in part).
Special notices must be filed in the official (real property)records to protect federal funds used for facilities activities.
Personal property (worth at least $5,000) must be includedon a detailed inventory prepared every two years.
Permission is required before a program can use anyproperty purchased in whole or in part with Head Start funds
as collateral for a loan, including lines of credit. Permission is required before any property worth $5,000 or
more purchased in whole or in part with Head Start funds issold or transferred.
Detailed facilities and property records are required,including proof of insurance.
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Questions and Comments