Language Resource Center Program

1. Language Resource Center Program FY 2010 – 2013 Grant Cycle

2. Expectations • Clarity & communication • Please ask questions if/when you have them! • Documentation • Provides greater protection against audit inquiries • Meeting deadlines • Budget revisions – clear and concise • “Open Door Policy” – please let me know if/when you will be in town!

3. LRC Terminology: On Campus • Authorized/Certifying Representative: authorized person on campus to sign for the grant; this person is established at the time of application on the SF-424 • Project Director: person in charge of grant activities; director of the established center • Principal Investigator = We do not use this term

4. LRC Terminology • Additional contacts (IRIS): person(s) who help with the administration of the grant via IRIS; please limit access to a select few • Contract: a procurement contract under an award or subaward, and a procurement subcontract under a recipient's or subrecipient's contract. • Subrecipient: the legal entity to which a subaward is made and which is accountable to the recipient for the use of the funds provided.

5. Subcontract vs. Subgrant • A subcontract covers a specific service(s) to be rendered, while a subgrant means an award of financial assistance to another entity • A subgrant is UNALLOWABLE, per 75.708Prohibition of subgrants: • (a) A grantee may not make a subgrant under a program covered by this part unless specifically authorized by statute. • Subcontractors are not allowed to render services that are outside the parameters of the LRC regulations

6. Language Resource Centers • The Language Resource Centers Program provides assistance to establish, strengthen, and operate centers that serve as resources for improving the nation’s capacity for teaching and learning foreign languages effectively

7. Authorized Activities • The conduct and dissemination of research on new and improved methods for teaching foreign languages, including the use of advanced educational technology; • The development and dissemination of new materials for teaching foreign languages, to reflect the results of research on effective teaching strategies;

8. The development, application, and dissemination of performance testing that is appropriate for use in an educational setting to be used as a standard and comparable measurement of skill levels in foreign languages; • The training of teachers in the administration and interpretation of foreign language performance tests, the use of effective teaching strategies, and the use of new technologies;

9. A significant focus on the teaching and learning needs of the less commonly taught languages, including an assessment of the strategic needs of the United States, the determination of ways to meet those needs nationally, and the publication and dissemination of instructional materials in the less commonly taught languages; • The development and dissemination of materials designed to serve as a resource for foreign language teachers at the elementary and secondary school levels; and

10. The operation of intensive summer language institutes to train advanced foreign language students, to provide professional development, and to improve language instruction through preservice and inservice language training for teachers. • Allowable costs: • Honoraria • Unallowable costs: • T-shirts, souvenirs, gifts

11. Budget

12. Budget Terminology • Allocable: charged in proportion to value received by project • Allowable: either permitted or not specifically prohibited • Budget Revision = changes made to the budget throughout the grant period • Reasonable: costs that would be incurred by a “prudent” person • Revised Budget: agreed upon, edited budget that was resubmitted after receiving the Grant Award Notification (GAN)

13. Budget Guidelines • Budget amounts: • Year 1: Actual amount awarded • Years 2-4: Anticipated amounts, based on current funding. • Indirect costs are limited to 8% • Equipment costs cannot exceed 15% • Grantees need to adhere to budget submitted and approved by US/ED. Some changes may require US/ED approval. • Prior approval is not required for most budget transfers unless they are over 10% or $100K, though program officers like to be notified of changes.

14. Carryover Funds • Carryover from one fiscal year to the next fiscal year is allowable • The amounts of carry over funds must be reported in IRIS • An explanation will be needed for the large sum, as well as a plan to expend it • Be sure to separate carryover from new fiscal year funds in budget and budget reporting.

15. Draw-Downs • Draw down only enough cash to meet grant’s immediate need • Minimize the time between draw down and pay out of funds (three-day rule of thumb) • Reimbursement method is the safest • Drawing down too much or too little will cause you to be flagged by the Department of Education

16. Maintaining Your Budget • Ultimate goal: clear and concise for 4 years • Discuss any changes with the program officer before making permanent amendments on campus • Any programmatic changes and/or reprogramming of funding must be documented in a new budget • Cost shares submitted in the application (ED 524 Section B) must be honored for the duration of the grant

17. Cost Share/Match • If you indicate a non-federal contribution on the SF 524 budget form, you are required to provide that amount and follow the regulations on documenting cost share/match found in EDGAR §74.23 • Matching contributions must be verifiable from the recipient’s records, not included as a contribution for any other federal project (no double counting), necessary and reasonable for the accomplishment of the project, allowable under the cost principles, and not paid by the Federal Government under another award

18. Is that allowable? • OMB Circular A-21: Cost Principles for Educational Institutions • Learn it, live it, love it! • Examples of unallowable costs: • Alcohol • Fundraising • Entertainment

19. Monitoring

20. Project Director Responsibilities • Implementing the project • Compliance with statutory & regulatory requirements • Fiscal management and accountability • Recordkeeping and reporting requirements

21. LRC Monitoring Tools • 34 CFR 655 and 34 CFR 669 • EDGAR Regulations: Parts 74, 75, 77, 79, 80, 81, 82, 85, 86, 97, 98, and 99. • OMB Circular A-21: Cost Principles • OMB Circular A-133: Audit Principles • Department Directives and Bulletins • Individual Grant Terms and Conditions • Approved and Awarded Grant Application

22. Travel • Must be Fly America Actcompliant • Security concerns • Per Diem Rates: • Domestic: as established by General Service Administration (GSA) • International: as established by the Department of State (DOS)

23. Financial Management • EDGAR 34 CFR § 74.21 (b) • Standards for financial management systems • (1) Disclosure of financial results • (2) Records that identify the source and application of funds • (3) Effective control and accountability • (4) Comparison of outlays with budget amounts • (5) Procedures for draw downs • (6) Procedures for determining the reasonableness, allocability, and allowability of costs • (7) Accounting records including cost accounting records that are supported by source documentation

24. Internal Controls • Purpose: • Reliability of financial reporting • Compliance with laws and regulations • Safeguarding of assets • Requirements: • Written policies and procedures • Segregation of duties • Proper authorizations • Sufficient documentation • Reporting

25. Personnel Time and Effort • Personnel costs must be reasonable and reflect actual work performed • Effort includes the time spent working on a sponsored project in which salary is directly charged or contributed (cost-shared) • Effort is expressed as a percentage distribution that adds up to 100% • Effort reports are different from payroll records. Reports must be certified and signed on a regular basis

26. Site Visits: Why us? • Need for technical assistance • A-133 single audit findings • Complaint • Late performance report • Frequent turnover of personnel • Exemplary project • Multiple grants • Large grant award amount • Random selection • We just like you.

27. Common Problems to Avoid • Poor record-keeping/ lack of documentation • Weak internal controls • Unallowable costs • Poor sub-recipient monitoring • Contracting out project activities without approval • Missing time and effort reports

28. Helpful Reminders • Set out clear roles and responsibilities • Develop and follow written policies and procedures • Document, document, document • If in doubt: • Consult the “Monitoring Tools” • Contact your Program Officer

29. Evaluation

30. Evaluation: What is it? • Evaluation is the systematic data collection, analysis and information gathering needed to make decisions. • It is a continuous process – start now to determine where you want to be in four years. • Be selective: What elements/components of your program are you evaluating and why? How do these tie to your objectives?

31. Levels of Evaluation • Programmatic: AIR study and survey • Institutional: Impact of Title VI on campus • Project: Overall impact of LRC grant activities • Component: Curriculum, Outreach, Language Proficiency • Sub-Component: A specific aspect such as a teaching training workshops or summer institutes

32. Why is it important? • Evaluation is vital to the overall international education initiatives at your institutions. It informs priorities, resource allocations, and any adjustments needed to improve instruction, outreach, professional development activities, student services, etc.

33. Core Components • Accountability • Are we doing what we said we would? • Outcome • The immediate or direct effect of the project. • Impact • Is the program making a difference. (gets back to the evidence, i.e., data collection) • Sustainability • What elements exist or will be in place to ensure that improvement will be sustained. Institutionalization. Brand recognition. Leveraging appeal. • Lessons learned • Factors that supported or inhibited the accomplishment of stated objectives. Unexpected outcomes.

34. Other Considerations • A key to successful evaluation is a set of clear, measurable, and realistic project objectives. • If objectives are not realistic or not appropriate to what you have envisioned, you will not be able to demonstrate or provide evidence that project activities have been successful.

35. Grant Maintenance

36. Reporting • Bi-annual reports, fall and spring, are captured through IRIS • The LRCs and NRCs have different spring report due dates! • Please make sure budgets are submitted with the spring report • Information collected in these reports contribute to decisions on non-competing continuations (NCC)

37. Reporting is also used for Departmental measures and requirements • Progress on projects should be clearly explained and indicated • Yes, your reports in IRIS matter!

38. What if something changes? • Call or email to let us aware of the situation • Questions to consider: • Do funds need to be reprogrammed? • How does this affect the grant in the short term? • How does this affect the grant in the long-term? • What could be possible solutions? • Each “problem” will be approached and resolved individually • Please speak to us directly!

39. Staff Changes • Must immediately notify us when – • Change of key personnel • Reduction of 25% of the time devoted to the project • Absence of a project director for more than 3 months • (See EDGAR 74.25) • If a new project director is hired, the Authorized Representative must send his or her CV immediately • Please keep us abreast of any “significant” staff changes

40. Out & About • Prospective goal: two sites visits for fiscal year 2011 • Not attending ACTFL • Please alert me to any LRC-related events within the DC Metro Area

41. Friendly Reminders • The LRCs and NRCs function under different sets of regulations. • If you haven’t heard it from me or via Elaine, then it is likely not true.

42. Helpful Websites • DOS Per Diem: http://aoprals.state.gov/web920/per_diem.asp • Electronic Code of Federal Regulations: http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=/index.tpl • Fly America Act (Airline Open Skies Agreement): http://www.gsa.gov/portal/content/103191 • GSA Per Diem: http://www.gsa.gov/portal/category/21287

43. Helpful Websites • IRIS: http://iris.ed.gov • Joint LRC Website: http://nflrc.msu.edu/ • LRC Website: http://www2.ed.gov/programs/iegpslrc/index.html • OMB Circular A-21 for Educational Institutions: http://www.whitehouse.gov/omb/circulars_a021_2004