office of grants management, grants management fundamentals

Office of Grants ManagementGrants Management Fundamentals

Office of the National Coordinator for Health Information Technology (O N C)

Grants 101

2

Office of Grants Management – Organization and Functions

Systems and Data ManagementBianca Costa

Collect, report, and manage grants management data

Analyze grant data to identify trends in implementation of funds

ONC administrator for grants management systems

GMO: Workforce

Training and Technical Assistance

Jen Cramer

Develop and deliver grants management training for external stakeholders and ONC staff

Provide customized, direct technical assistance services

Coordinate overall grants management training and technical assistance efforts

GMO: Beacon and SHARP

Grant OperationsArlene Ramsey

Provide procedural and technical business support to award recipients and ONC program offices

Conduct on-site monitoring visits and desk reviews

Develop grants management standard operating procedures

GMO: REC and State HIE

Office of Grants Management (OGM)Lisa Lewis

Chief Grants Management Officer

Policy Wendy Kilgore

Develop and manage ONC grants management policies

Facilitate objective reviews

Liaison with other HHS Grants Management Offices

O G M - Responsible for the Portfolio of O N C Cooperative Agreements

3

Workforce:CompetencyExamination

Workforce:Curriculum

DevelopmentCenters

Workforce:University

BasedTraining Workforce:

Community College

SHARP

Beacon

Regional Extension

Centers

State Health

Information Exchange

O N C’s Program Offices and Grants Office Partnership

AAGAM Chapter 1.04.104

4

Answer grantee questions on complex

technical grants business

management matters

Perform budget analyses & business

mgmt capability assessments & perform budget

negotiations

Take action to withhold payment,

suspend or terminate award or to lift withholding or

suspension

Provide input on satisfaction of business mgmt

special conditions; lift restrictions

via NGA

Identify potential or existing problems (business mgmt

& program)& alert PO

Ensure effective use of funds

by monitoring commitments & projecting future

funding requirements

Review financial status reports &

evaluate financial performance against

budget, program plan, etc.

Document site visits & desk reviews

& coordinate results with program office

Conduct financial monitoring site visits

& desk reviews & provide

post-award TA

Establish &maintain

official award, program information,

& institutional files

GrantsManagement

Team

O N C’s Program Offices and Grants Office Partnership

5

AAGAM Chapter 1.04.104

Answer grantee questions on programmatic grants matters

Assist in ensuring budget submissions

& expenditures comply with statute, regulation, & policy

Provide program input on proposed

withholding of payment/suspension/termination of award

& input before lifting

Provide input on whether programmatic

special conditions are satisfied or

whether other action should be taken

Identify potential or existing problems

(program & business management) & alert

program officials & GMO of findings

Ensure adequate progress toward

meeting milestones

Review program progress reports & evaluate program

performance, progress

& changes in scope or objective

Document reviews & grantee

discussions & provide

documentation to GMO

for official file

Conduct site visits to gauge progress and compliance

or to providepost-award TA

Establish and maintain PO

files

ProjectOfficers

Partnership – The Key to Success

• Maximize program success and integrity

• Foster program credibility

• Ensure rigor in stewardship

• Minimize audit findings

• Reduce disallowed costs

• Strengthen internal controls to prevent fraud, waste, and abuse

• Manage inherent risk

• Encourage professional development

• Foster synergy/collaboration

6

Review FOA Submit Application Revise Application Review Award Package

Accept Award

Drawdown Funds

Submit Financial Reports

Submit Performance Reports

Submit Post-Award Requests

Ensure Audit is Complete

Generate Final Performance Reports

Complete Drawdown of Funds

Generate Final Financial Reports

Submit Closeout Package

Retain Records

Legend:

PHASEGrantee

Office of Grants Management

Program Office

ONC Budget

Other Federal/HHS Entities

PO/GMO Joint

Program and Grants Management Training and Technical Assistance

Assist Applicants

Establish Commitments

APPLY

Review Closeout Package

Conduct Final Financial Reconciliation

Notify Grantee of Closeout

Retain Records

Establish Disposition of Funds

Evaluate Final Performance Reports

CLOSEOUT

Obligate Funds

Set Up Congressional Notification in System

Release Funds

Create Notice of Grant Award

AWARD

Notify Grantee of Award

Conduct Appropriations Analysis

Develop Funding Opportunity Announcement (FOA)

Release FOA

Appropriation

OMB Apportionment

Authorizing Statute

ESTABLISH

Allocate Funds

Review and Approve Post-Award Actions

Conduct Financial Monitoring

Review Financial Reports

Review Performance Reports

Review Audits

Conduct Programmatic Monitoring

MANAGE

Review /Recommend Post-Award Actions

Review Application

Perform Budget Review

Objective Review

AssessFiscal Integrity

Develop Funding Memo

REVIEW

Assess Funds Availability

Grants Management Lifecycle



Release FOA

Appropriation

OMB Apportionment

Authorizing Statute

Review FOA

APPLYESTABLISH REVIEW AWARD MANAGE CLOSEOUT

Allocate Funds

Legend:

PHASEGrantee


Program Office

ONC Budget


PO/GMO Joint

Grants Management Lifecycle – Establish

9

Appropriations and Funding Process

Phase 1: Budget Formulation

Phase 2: Budget Presentation and the Congressional Process

Phase 3: Budget Execution

10

Budget Formulation

• HHS Budgets for Grant Programs

• HHS Budget Request

• HHS Total Budget Request

• O M B/President’s Budget to Congress

11

Appropriations

• Budget Presentation to Congress

• Congressional Budget Resolution

• Appropriation

12

Budget Execution

• Office of Management and Budget (O M B) Apportionment– Budget Authority to distribute funds

• HHS Allotment

• O N C Allotment

• Allocations to Each Grant Program

13

Types of Appropriations

• Annual: Must be obligated within the fiscal year– O N C funds in HHS appropriations

• Multiple Year: Available for obligation for a definite period in excess of one fiscal year– HHS has multi-year funds

• No-year: Available for obligation without financial year limitations– A R R A funding no longer no year (Bennett Amendment)

14

Continuing Resolution

• Applies if new Fiscal Year and annual appropriation is not passed

• Continues existing programs until annual appropriation passes

• Can impact internal operations and activities

15

Funding Opportunity Announcement (FOA)

• All information integral to the competition must be explicitly addressed • General description• Authorizing statute/Award information• Eligibility requirements• Cost share/matching requirements• Application requirements

– Forms– Budget and budget narrative– Program narrative– Other submission requirements

• Due dates• Review Criteria• Announcement dates• Reporting requirements• Other information

Submit Application

Assist Applicants



Legend:

PHASEGrantee


Program Office

ONC Budget


PO/GMO Joint

Grants Management Lifecycle – Apply

Applying for Funding

• HHS policy requires all competitive funding opportunities be announced at www.Grants.gov

• O M B mandated initiative

• No paper

• No other submission method accepted

17

http://www.grants.gov/

http://www.grants.gov/

18

Critical Application Information

• Applications must be complete and timely– All forms and attachments must be submitted– Incomplete applications will not be sent forward for review– Late applications will not be sent forward for review

• All applicants must have a Dun and Bradstreet (D&B) Data Universal Numbering System (D U N S) number

• All applicants must register in the Central Contractor Registry (CCR)– Applicants should allow a minimum of five days to complete the CCR

registration. CCR online registration (http://www.ccr.gov)– CCR registrations must be current and renewed every 12 months

• Applicants that do not have a D U N S number or have not registered with the CCR will not move forward for review.

http://www.ccr.gov/

Review Application


Objective Review



Revise Application


Legend:

PHASEGrantee


Program Office

ONC Budget


PO/GMO Joint


Grants Management Lifecycle – Review

Objective Review Process

• Completeness Review

• Grants staff

• All required forms

• All required attachments

• On-time submission

• Responsiveness Review

• Program staff

• All required program elements

If YES to both → Panel review

20

Objective Review Process - continued

• Panels of unbiased subject matter experts

• Endure no conflicts of interest and consistent examination of applications

• Intended to provide recommendations and advice on funding proposals

• Scores and ranking developed• Final decisions determined by the program office• Funding decision memo sent to Grants Management Office

21

22

Program Office Financial Review

• Program Office Staff– Review application budget to determine if costs are in line

with program goals and objectives– Review to ensure costs are for intended program

purposes– Signed transmittal slip indicating approval of budget

• Grants Management Staff – Conduct detailed financial reviews– Based on Program Office recommendations

23

Financial Review

• A-133 Compliance– http://harvester.census.gov/sac/

• No Conflict of Interest• Applicant’s Standing (Good, Debarred, Suspended)

– https://www.epls.gov/• Dun and Bradstreet• Budget Review

http://harvester.census.gov/sac/

https://www.epls.gov/

Budget Review and Approval Process

• Each application must include a detailed budget (SF424A) and budget narrative for the project.

• The budget must be complete, reasonable, allowable, allocable and cost effective in relation to the proposed project.

• The budget narrative must provide a detailed justification for each cost included in the budget.

• All project related costs must be included in the appropriate cost categories.

24

25

Budget Review – Cost Principles

• Uniform cost principles when implementing Federal grant programs

– 45 CFR 74.27 and by reference 2 CFR Part 220 (A-21) – Educational Institutions

– 2 CFR Part 225 (A-87) – State Local and Indian Tribal Governments

– 2 CFR Part 230 (A-122) – Non-Profit Organizations

– 48 CFR 31.2 (Federal Acquisition Regulation (F A R)) – For Profit Organizations

Budget Review – Object Categories and Key Requirements

Example of a 424a

26

Budget Review – Personnel Budget Category

Personnel • Must pay personnel at a rate paid with non-Federal dollars or comparable

to like organizations/positions.

• Is the basis for determining each employee’s compensation described (annual salary and % time devoted)?

• Is each position identified by title/responsibility?

• Are time commitments and the amount of compensation stated and reasonable?

• Are salary increases anticipated during the grant period and are they justified (C O L A, etc)

• Are any personnel costs unallowable?

• Dual Compensation?

• Federal Employee?

27

Budget Review – Fringe Budget Category

Fringe Benefits – typically include health care, retirement plans, etc. Must consider:

• Is the amount specified as a separate line item?

• Is each type of benefit indicated separately or does the organization have an approved fringe benefit rate?

• Are fringe increases contemplated during the grant period?

• Are costs included in fringe benefits that are unallowable?

28

Budget Review – Travel Budget Category

Travel• Is the basis for computation provided?

• Is the travel necessary for the purpose of the program?

• Are travel costs separately identifiable and reasonable (location, transportation, hotel, meals, mileage)?

• Does the organization have a written travel policy? Is this travel policy being followed?

• If no written policy—must follow Federal guidelines

29

Budget Review – Equipment Budget Category

Equipment• Capitalization threshold

• Federal $5K and useful life more than 1 year

• Are equipment items specified by unit and cost?

• Is the request reasonable and allowable under the project?

• Does the organization have a procurement policy in place?

• Is a lease vs. purchase study necessary (vehicles, large items of equipment)?

• Are purchases distinguishable from rentals?

30

Budget Review – Supplies Budget Category

Supplies• Are supplies listed separately?

• Office

• Training

• Research

• Other types of supplies

• How was cost determined?

• Is the basis for the cost reasonable?

• Monthly estimates are sufficient

• Consistently treated

31

Budget Review – Contractual Budget Category

Contractual• Is the type of each service to be rendered described?

• For Consultants/Individuals

• Is an hourly, daily or weekly base rate given?

• Are rates allowable, justified, reasonable and comparable to market?

• Is procurement method described?

• Are appropriate procurement procedures being followed?

32

Budget Review and Approval – Subrecipient Relationships

Subrecipient Relationships (Subgrants/Subawards or Contracts)• Is a substantial portion of the programmatic work being performed by another

entity - a grant or contract?• Subawards are documented in the “other” category• Subrecipient relationships in the form of a contract will be put in

“contractual”

• If so, the following questions must be answered in regard to that specific grant or contract:• Name of the subrecipient• Method of selection• Period of performance• Scope of Work• Method of Accountability• Itemized budget and justification (separate SF 424As for the subrecipient)

33

Budget Review – Other Budget Category

Other• Are items listed by major type (space rental, printing, phone,

maintenance, etc.)?• Are all costs justified, reasonable and allowable?• List each subaward and amount of award

• Ensure adequate subrecipient information is provided (see 6 elements)

• Include separate SF 424 A for each sub

34

Budget Review – Indirect Costs

Indirect Costs• Costs incurred for a common/joint objective and cannot be

readily identified with a specific activity• typically include utilities, rent, administrative staff

• An organization may not charge specific costs both directly and indirectly

• Costs may not be assigned as an indirect cost to an award if any other cost incurred for the same purpose has been allocated to an award as a direct cost

35

Budget Review – Indirect Costs

Indirect Costs (continued)• Must have a current Federally

approved indirect cost rate agreement

• Is the rate applied to the correct distribution base?

36

Recently in the News

• TierOne loses $19 million federal grant over CEO's fraud allegations

• September 6, 2010

• University of Florida professor and wife indicted for fraudulent grant proposals

• October 30, 2009

• Cornell University Will Pay $2.6M in Fraud Case

• March 24, 2009

• Former Professor Pleads Guilty to Fraud on NSF Grant

• May 3, 2007

37

Categories of Misuse of Federal Funds

Indicators of Fraud, Waste and Misuse of grant funds can be due to a variety of causes. We must manage with due diligence to ensure that DHHS funds are not misused.

38

Mistakes Gross Negligence Criminal Fraud

Recipient includes costs in budget which are unallowable under specific O N C awards. Examples include: Food, Scholarships, Contingencies

Direct recipient failed to implement proper internal controls and adequately monitor subrecipient activity and expenditures resulting in theft of Federal funds.

Recipients used Federal funds to pay for a wedding reception, building construction, and personal credit card bills. Resulted in loss of $500K and jail time.

Who Commits Grant Fraud?

• When business entities, individuals, communities, and other organizations receive federal grant dollars, they are entrusted with their appropriate expenditure.

• Grant fraud is most often committed by:

• Grant recipients, company officers, business partners, board members, and managers

• Bookkeepers, financial staff, and employees

• Contractors and subcontractors engaged with the recipient

• Recipient consultants

39

Common Grant Fraud Scenarios

• Grant fraud occurs in many ways, but some of the most common fraud scenarios include:

• Charging personal expenses as business expenses against the grant

• Charging for costs which have not been incurred

• Charging for inflated labor costs or hours

• Submitting invoices for personal expenses

• False information on grant applications, progress reports, etc.

• Creating fictitious records

40

Fraud Indicators

• Fraud is often difficult to detect and is a conclusion that is determined only after a careful examination of all the facts and circumstances.

• Indicators of fraud include:

• One person in control

• Lack of internal controls

• Altered records

• No separation of duties

• No prior audit

• Lack of responsiveness

• Allegations of fraudulent conduct

Obligate Funds

Ensure Congressional Notification

Release Funds




Legend:

PHASEGrantee


Program Office

ONC Budget


PO/GMO Joint

Grants Management Lifecycle –Award

43

Notice of Grant Award (NGA)

• The Notice of Grant Award NGA is the official document used for grants/cooperative agreements– Establishes legally binding arrangement between O N C

and recipient– Establishes Period of Performance– Contains or references Terms and Conditions of the

grant or cooperative agreement– Obligates Federal Funds

44

Notice of Grant Award (NGA)

NGA includes:• Grantee information• Award information

– Project Period of Performance

– Budget Period of Performance

• Terms and Conditions of the award

45

Award Notification and Acceptance

• Award Notification– Grants Solutions– NGA– Terms and Conditions

• Award Acceptance– First request for disbursement of funds– Agree to abide by all applicable laws, regulations, program

requirements, policy and terms and conditions– Specific A R R A terms and conditions (incorporated by reference)

• http://www.hhs.gov/recovery/grantscontracts/recoverytermsconditions.html

http://www.hhs.gov/recovery/grantscontracts/recoverytermsconditions.html

Grant vs. Cooperative Agreement

• Grants are awarded to States, units of local government, or private organizations at the discretion of the awarding agency or on the basis of a formula. Grants are used to support a public purpose.

• Cooperative Agreements are awarded to States, units of local government, or private organizations at the discretion of the awarding agency. Like grants, cooperative agreements also support a public purpose.

• Substantial involvement is anticipated between the awarding agency and the recipient during performance of the contemplated activity. View as a “partnership”

• Cooperative agreements are not contracts

46





Review Audits




Legend:

PHASEGrantee


Program Office

ONC Budget


PO/GMO Joint

Grants Management Lifecycle – Manage

Order of Precedence-Who is Top Dog?

• Constitution of the United States• Statutes

• Program Statutes (Authorizing Statutes)

• Generally Applicable Statutes

• Annual Appropriations

• Regulations• Executive Orders• O M B Circulars• Policies• Procedures

48

49

Administrative Requirements vs. Cost Principles

Administrative Requirements Cost Principles

Prescribe standards for grant administration to achieve uniformity and consistency for recipients of Federal Assistance

Define allowable costs for different types of recipients; failure to mention a particular item of cost in the Cost Principles is not intended to imply that it is either allowable or unallowable

50

Applicable Regulations

Summary of Applicable RegulationsGrantee Type Administrative

RequirementsCost Principles Audit

Requirements

State & Local Governments 45 CFR Part 92 2 CFR, Part 225(A-87)

A-133

Educational Institutions45 CFR Part 74 45 CFR 74.27 and by

reference 2 CFR Part 220 (A-21)

Non-Profits 2 CFR, Part 230(A-122)

Recipient Grants Management Responsibilities

Grantee responsibilities include:• Cash management

• Maintaining adequate financial records

• Returning Federal funds for disallowed expenditures

• Complying with reporting requirements

• Reviewing and recording financial operations

• Budgeting and budget review

• Reporting irregularities

• Refrain from doing business with debarred and suspended organizations

51

Recipient Grants Management ResponsibilitiesManaging Subawards

• A recipient has full responsibility for the conduct of the project or activity supported and for the results achieved

• Direct recipients are responsible for adequate monitoring of subawardee activities

• 45 CFR Part 92.40 or 74.51, Monitoring and Reporting Program Performance

52

Financial Management Systems

• At a minimum, a grantee’s financial system should be able to:

• Meet 45 CFR 92.20 or 74.21, Standards for financial management systems

• Provide financial and performance reporting required by 45 CFR Part 92 and 74, and other regulations

• Associate grant expenditures with the specific funding source and application of funds

• Provide a clear audit trail

• Comply with the Cash Management Improvement Act• Minimize the time elapsing between the transfer of funds and

disbursement by the grantee or subgrantee in accordance with Treasury Regulation 31 CFR 205.

• A State should follow the same state laws and procedures as they would for non-Federal funds

53

Financial Management Systems – continued

• In order for an accounting system to be considered adequate, it must meet the following criteria:• Internal controls / segregation of duties (For example, the person authorizing

an expenditure should not sign the check)

• Ability to track expenditures on an accrual basis (budget control)

• Grantees can use a cash or accrual basis for their accounting method

• Ensure allowability of costs charged to Federal grants

• Documentation for all grant-related expenditures, broken down by award

• Ability to fulfill government-required financial reporting

54

55

Understanding Match

Matching and cost sharing are often used interchangeably

•Matching usually refers to a statutorily specified percentage– Specified as a fixed or minimum percentage of non-Federal

participation in allowable program or project costs that must be contributed by a recipient in order to be eligible for Federal funding or a not-to-exceed percentage of Federal participation.

•Cost Sharing refers to any situation in which the recipient shares in the costs of a project other than as statutorily required matching•Approved/accepted matching or cost sharing is shown in the NGA

Understanding Match – continued

• Cash Match• Cash spent for project related costs

• Matching costs must adhere to Federal rules

• If not allowed with Federal dollars, not allowable with matching dollars

• In-kind Match• are the value of goods and/or services third parties donate for program or

project purposes without charge to a recipient

• Third party in-kind contributions • May satisfy a matching or cost-sharing requirement only when payment for

them would be an allowable cost if the party receiving the contributions (recipient, subrecipient, or cost-type contractor) were to pay for them

56

57


• All costs and contributions used to satisfy a matching or cost-sharing requirement must be documented by the recipient at the same level of detail as Federal funds

• Matching contributions are subject to audit

• If a recipient fails to provide required cost sharing, the GMO generally will make a downward adjustment in the Federal award amount

58


Valuation of in-kind contributions:• Rates for volunteers must be consistent with established rates paid for

similar work by the recipient or subrecipient

• If a third party donates the use of equipment or space in a building but retains title, the contribution shall be valued at the fair rental rate of the equipment or space

• If a third party donates supplies, the contribution shall be valued at the market value of the supplies at the time of donation

Program Income

• Gross income earned as a result of the award• directly generated by the grant-supported activity or earned

• There would be no income of this type or level.

• Activities that generate program income include• Registration fees

• Sale of videos, publications, other media

• Rental/usage fees

• Service fees

• Subject to same requirements as Federal funds• Must be reported on FFR (SF 425)

59

Program Income

• The Notice of Grant Award includes the type of program income applicable to the Program/award

• Deduction alternative

• Addition alternative

• Cost Sharing/Matching alternative

• Combination alternative

60

Prior Approval

Several changes to an award require O N C prior approval• Changes of grantee organization• Change in scope

• Transfer of substantive programmatic work if not previously approved• Significant rebudgeting (lesser of 25% or $250K, cumulative)• Other as defined by program office

• Changes in key personnel• Carry over funds• Indirect costs (if indirect costs not approved in initial budget)Request from grantee, with written justification, should be 30 days from

when need approval

61

Payments to Grantees

Grantees request funds from HHS’ Payment Management System (PMS)• Payment requests may be made as often as needed: (daily, weekly, monthly,

etc.)• No checks; electronic transfers only• Also used to submit quarterly financial reports• PMS is administered by HHS’ Division of Payment Management

• PMS Helpdesk: (877) 614-5533 or [email protected]

Grantees must minimize time between draw and expenditure• Cash Management Improvement Act (CMIA)• Immediate needs basis; funds must be spent within three business days

What may impact a grantee’s ability to draw funds?• No budget approval• Late report submission• Other restrictions

62

mailto:[email protected]

63

Grantee Reporting Requirements

Report Required Frequency Reporting Period Due Date Submission Method

American Recovery and Reinvestment Act (ARRA) Report

Quarterly

April 1 – June 30 July 10

Federalreporting.gov July 1 – September 30 October 10

October 1 – December 31 January 10

January 1 – March 31 April 10

Federal Financial Report (FFR) Federal

Cash Transaction Report (SF-425)

Quarterly

April 1 – June 30 July 30

Payment Management System (PMS)

July 1 – September 30 October 30

October 1 – December 31 January 30

January 1 – March 31 April 30

Federal Financial Report (FFR) Federal

(SF-425)Annually October 1 – September 30 December 30 Online Data Collection

System (OLDC)

Program Progress Report

Semi-Annually Determined by Program Office CRM, email, etc.

Official Grant and Program Files

• Office of Grants Management files• Official award file

• All award transactions, financial information, correspondence, approvals, etc

• Program information file• Information for each program announcement• Information related to all applications

• Institution file• Contains information on a specific entity which receives multiple awards from

multiple programs

• Project officer files• Documents project management activities from inception to closeout• Record of that PO’s activities with respect to the award • Auditor or reviewer will request to review for adequate documentation

64

Sample Checklist

• Section 1Applicant Submissions and Contacts – New Awards and Other Competing Awards

• Section 2Review, Evaluation, and Negotiations – New Awards and Other Competing Awards

• Section 3Award Notices and Restrictions/Special Conditions

• Section 4Post-Award Prior-Approval Requests

• Section 5Post-Award Monitoring and Closeout

• Section 6Other

65

Financial and Programmatic Monitoring

Financial Monitoring Programmatic Monitoring

• Evidence of expenditures show that purchases are necessary, reasonable, allocable and allowable

• Flow of Funds

• Accounting System

• Internal Controls

• Cash Management

• A-133 Submission

• Interest accrual (as necessary)

• Programmatic Administration

• Compare accomplishments to goals and objectives

• Reinforce priorities and policies

• Adherence to project scope

• Performance according to Ops Plans

• Progress (completion on time)

• Objectives

66

67

Financial Monitoring – Goals

The goals of financial monitoring include:– To ensure that grant funds are used as intended and compliant

with regulatory requirements

– To ensure O N C is meeting the highest of management and fiduciary standards

– To ensure grantee compliance with the terms and conditions of the grant award

– To meet requirements imposed on O N C by law (A R R A)

68

Financial Monitoring – Risk Factors

• General Selection Criteria – New Grantee– Dollar Amount of Award– Multiple Awards – Entity Type– Subawards– Reporting Findings (FSR, Audit, A R R A)– Unobligated/Unexpended Balances– Program Office Referral/Recommendations– Samples

• The above general criteria was weighted based on various factors

• Other risk factors not included above may also be considered based on data analysis -out life of award

69

Types of Financial Monitoring that OGM Conducts

• Desk-based Financial Monitoring– Cash Analysis– Desk Review

• On-Site Financial Monitoring

70

Desk-based Monitoring – Cash Analysis

Cash analysis reviews:– Recipient cash transactions– Rate of draws– Payment trends– Unobligated balance– Grant status– Review of last program report

71

Desk-based Monitoring – Cash Analysis continued

During the O G M quarterly review, O G M and Project Officers discuss thefollowing :

• Has the grantee submitted timely performance reports?• Is the grantee on target as outlined in their approved plan?• Has contact been made with the grantee if not on target?• If contact has been made, what corrective action has been discussed?

72

Desk-based Monitoring – Desk Reviews

• Limited verification of grantee compliance– Federal regulations– Terms and conditions

• Identifies potential issues• Grants reviewed on a regular basis• Core review of a grantee’s general management

practices• May require further scrutiny - on-site financial

monitoring

73

On-Site Monitoring Visits are performed at grantee location• Ensure adequate internal controls, policies, processes, and systems exist

to appropriately manage awards• Assess capability, performance and compliance against administrative

regulations and public policy requirements• Report on the effectiveness of O N C grantees and grant programs and

the stewardship of public funds• Collaboration with program office(s) is key to successful monitoring

– Joint site visits with program office when feasible– Pre-site visit meeting with program staff

On-Site Monitoring Visits

74

• No written policies and/or procedures• Inadequate procurement standards• Lack of documentation • Inadequate/untimely submission of reports• Inadequate Subaward Monitoring• Inadequate time and effort records• Lack of competition during procurement• Conflicts of interest• Questioned expenditures• Excess Cash on Hand• Commingling of funds

Common Issues Discovered During Financial Monitoring

75

Monitoring vs. Auditing

• Monitoring is preventative– Performed by grants and program staff– Resolve before audits

• Auditing is corrective / curative– Performed by auditors– In the record books

76

Audits – What is a Statewide Single Audit (A-133)?

• Required for Entities that Expend $500K or More in Federal Funds during their Fiscal Year

• Review of All Federal Grant Programs and Requirements• Audit Report Is Due 9 Months after the End of the Fiscal Year• Submit the Audit Package to the Federal Audit Clearinghouse

(FAC)– http://harvester.census.gov/fac/collect/ddeindex.html

http://harvester.census.gov/fac/collect/ddeindex.html

77

A-133: Most Common Audit Findings

• Unallowable activities• Unallowable costs • Poor cash management• Inadequate equipment and real property management

practices• Expending funds outside of the period of availability of funds• Inadequate procurement standards• Untimely and inaccurate reporting• Lack of subrecipient monitoring

78

Audit Resolution

• Health and Human Services– ASFR, Division of Systems Policy, Payment Integrity,

and Audit Resolution (DSPPIAR) is responsible for A-133 audit resolution

• OGM will assist in resolution of audit findings only as requested by DSPPIAR

– ASFR also serves as a liaison with O M B, the O P D I Vs, and the OIG on grant-related audit issues

• Recipient responsibilities– Resolve audit findings of subawards

• Most O N C programs have a large number of subs

79

Audit Resolution

• Corrective Action Plan (C A P) should include:– Description of each finding– Specific steps to be taken to implement

the recommendation– Timetable for performance of each

corrective action– Description of monitoring to be

performed to ensure implementation of the C A P

80

HHS Office of the Inspector General (OIG) Performance Audits

• Evaluates HHS Goals and Objectives with grantee activities• Rotating schedule of states and programs• Annual audit plan

– Identifies key issues– Implementation plan

• Conducted by OIG staff • Compares expenditures to program impact• Reports posted on OIG website (http://oig.hhs.gov/reports.asp)

http://oig.hhs.gov/reports.asp

81

Examples of Inspector General Audit Findings

• No measurable program goals and objectives• Lack of monitoring and oversight• Untimely/incorrect financial reporting• Questioned costs• Inadequate procurement practices• Inadequate personal property controls




Retain Records




Legend:

PHASEGrantee


Program Office

ONC Budget


PO/GMO Joint

Grants Management Lifecycle – Closeout

83

Recipient Closeout

• Due within 90 Days after End of Award • Final Progress Report • Final SF-269 Financial Status report

– Unobligated funds balance– No unliquidated obligations– Final drawdown– Return excess funds

• Invention Disclosure (if applicable)• Federally Owned Property Control (if applicable)

Retention of Records – Grantees

• Grantee Requirements (45 CFR 92.42 and 74.53)

• At least 3 years from the date of submission of the final expenditure report

• If litigation, claim or an audit is initiated prior to the expiration of the 3 year period, records must be retained until completion of the action and resolution of issues or the end of the 3 year period, whichever is later

• Records may be retained in an electronic format

84

Retention of Records – ONC

• Office of Grants Management

• 1 year unsuccessful applications

• 6 years 3 months official files

• If open audit, litigation, administrative proceeding retention may be longer

• Project Officer files

• 2 years after closeout

• If open audit, litigation, administrative proceeding retention may be longer

85

Review FOA Submit Application Revise Application Review Award Package

Accept Award

Drawdown Funds

Submit Financial Reports

Submit Performance Reports

Submit Post-Award Requests

Ensure Audit is Complete

Generate Final Performance Reports

Complete Drawdown of Funds

Generate Final Financial Reports

Submit Closeout Package

Retain Records

Legend:

PHASEGrantee


Program Office

ONC Budget


PO/GMO Joint

Assist Applicants


APPLY




Retain Records



CLOSEOUT

Obligate Funds

Set Up Congressional Notification in System

Release Funds


AWARD




Release FOA

Appropriation

OMB Apportionment

Authorizing Statute

ESTABLISH

Allocate Funds





Review Audits


MANAGE


Program and Grants Management Training and Technical Assistance

Review Application


Objective Review



REVIEW


Grants Management Lifecycle

87

Critical Reference Documents

American Recovery and Reinvestment Act of 2009 (Recovery Act)• What does the law say• Statute is highest in order of precedence

45 CFR Part 74 and Part 92 - Administrative Requirements• Part 92 – Government organizations (Including Tribal)• Part 74 – NGO• Uniform administrative rules when implementing Federal grant programs

Cost Principles • 2 CFR Part 220 – Educational Institutions• 2 CFR Part 225 – Government Organizations (Including Tribal)• 2 CFR Part 230 – Non-Profit Organizations• FAR 31.2

OMB Circular A-133 - Audits of States, Local Governments, and NonProfit Organizations

88

• HHS Grants Policy Statement (GPS) – Grants policy for recipients– Incorporated as a term in NGA– Dos and Don’ts– ONC staff should also know the GPS in order to provide support to grantees– http://dhhs.gov/asfr/ogapa/grantinformation/hhsgps107.pdf

• Funding Opportunity Announcement (F O A)• Notice of Grant Award (NGA) with Award Terms and Conditions• Grants Management Advisories (GMAs)• Grants Management Memorandum (GMM)• Program Information Notices (P I Ns)• Program Assistance Letters (P A Ls)

Critical Reference Documents – continued

http://dhhs.gov/asfr/ogapa/grantinformation/hhsgps107.pdf

89

• Grants Management Advisories (GMAs) – technical assistance resource which will provide additional information in specific grants management areas for Grantees

– O N C-GMA-2010-01 Roles and Responsibilities Grants and Cooperative Agreements– O N C-GMA-2010-02 Review of Proposed Subawards and Procurement Contracts Under

Grants– O N C-GMA-2011-01 Matching and Cost Sharing– O N C-GMA-2011-02 Use of Unobligated Balances under Grants and Cooperative

Agreements– O N C-GMA-2011-03 Allowability of Food Costs– O N C-GMA-2011-04 Program Income– O N C-GMA-2011-05 Subrecipient Monitoring– O N C-GMA-2011-06 Allowability of Payments to Uniformed Services and Civilian Federal

Employees

Critical Reference Documents – continued

90

ONC Office of Grants Management has a Training and Technical Assistance (T A) Plan based on three different levels of assistance:•Level I: Guidance and Information Sharing – Consists of the daily technical assistance of grants administration.

•Level II: Sample Protocols, Templates and Models – Targeted telephone and electronic assistance involves assisting recipients in the development of protocols and templates, as well as other specific needs, as requested by a recipient.

•Level III: Targeted Training Deliveries and Direct On-Site Assistance – Includes targeted internal and external training sessions.

Training and Technical Assistance Plan

91

Grants Management T A request form– Please use this form to

request Training and Technical Assistance from the ONC Office of Grants Management

– Completed forms are available from, and should be submitted to [email protected]

Office of Grants Management – TA Requests


Grants Management Questions

92

[email protected]
