SMPID Fiscal Unit Webinar

1. SMPID Fiscal Unit Webinar March 15, 2012

2. AGENDA • RSA-MIS - New Features and Changes • Presenter: David Steele – SMPID Fiscal Unit Chief • Revised SF-425 PD - Overview • Presenter: David Steele – SMPID Fiscal Unit Chief • Late Liquidation Requests • Presenter: Adrienne Grierson – SMPID Fiscal Unit Specialist • Closeout Process • Presenter: Katherine Courtnage-Clay – SMPID Fiscal Unit

3. RSA-MIS - New Features and Changes David Steele, SMPID Fiscal Unit Chief David.steele@ed.gov

4. Log on to the RSA-MIS • Select: Continue to Data Entry

5. NEW FEATURES ARE ONLY APPLICABLE TO SF-425 FORMS! Select: SF-425 Federal Financial Report

6. Once report is marked as Received by SMPID Fiscal Unit Staff, the report is publicly available.

7. Select: Submit a request to re-open

8. Please allow at least two weeks to process request.

10. Scroll Down the Report View Page.

11. Continue to Scroll Down Form View Page.

12. Displays up to 8 columns of previously submitted SF-425 data including the current report.

13. RSA is tracking the timeliness of report submissions. Agencies are responsible for submitting timely and accurate reports. • If a report is reopened for correction, once the revised report is saved, the “days late” is recalculated using the new submission date. • Repeated late submission of reports can lead to compliance findings.

14. Revised SF-425 PD - Overview David Steele, SMPID Fiscal unit chief

15. SF-425 Data Entry View

16. Final Reports • If the grantee liquidates obligated funds within the 90 day liquidation period, the grantee does not need to submit an SF-425 report on 9/30 and then another SF-425 report after the funds are liquidated. • The grantee submits the Final report at the end of the liquidation period.

17. 9. Reporting Period End Date Data entry may be required for this field if the grantee is submitting a final report. The reporting period end date entered by default will correspond with the required reporting period (3/31 and 9/30). The period covered is always the beginning date of the grant through the end of the reporting period.

18. 9. Reporting Period End Date • When submitting a final SF-425 form: • if all funds are obligated by 9/30 of first year of the award and liquidated within 90 days, the reporting period end date shall be 9/30 of year one; • if federal funds are carried over for obligation in the succeeding fiscal year, and funds are obligated by 9/30 of the carryover year and liquidated within 90 days, the reporting period end date for the final report shall be (9/30) of the carryover year; • if the 3/31 report for the carryover year is the final, the reporting period end date must be changed to 9/30 of the carryover year.

19. 10a. Federal Cash Receipts The grantee must enter the net amount on line 10a that the grantee has drawn down from G5. This amount is obtained by running a G5 External Award Activity Report (https://www.g5.gov) using date parameters.

20. 10a. Federal Cash Receipts - Continued • For semi-annual reports, the date parameters will be the start date of the award and the reporting period end date. • For final reports, the date parameters will be the start date of the award and the date award funds were liquidated. • The net amount of funds drawn down will be shown on the G5 report and should be entered as the amount on line 10a of the SF-425 form. Grantees may want to maintain copies of the G5 External Award Activity Reports to verify the accuracy of the amount reported on line 10a.

21. CAUTION! • RSA will be comparing the amounts reported on line 10a with the G5 drawdown amounts. Discrepancies resulting from inaccurate reporting may lead to findings of non-compliance.

22. 10e. Federal Share of Expenditures Grantees using an accrual basis of accounting can now report an amount that is greater that the amount listed on line 10a.

23. 10e. Federal Share of Expenditures - Continued • For reports prepared on a cash basis, the agency should report federal fund expenditures as the sum of cash disbursements for direct charges for goods and services, the amount of indirect expenses charged, and the amount of payments made to contractors/vendors. • For reports prepared on an accrual basis, grantees should report federal fund expenditures as the sum of cash disbursements for direct charges for goods and services, the amount of indirect expenses incurred, and the amount of payments made to contractors/vendors; and the increase or decrease in the amounts owed by the recipient for goods received and services performed by employees, contractors/vendors, and other payees. • Do not include federal program income received by the grantee on line 10e.

24. 10k. Remaining Recipient Share to Be Provided • CMIA, 31 CFR 205.15(d) - mandatory matching of Federal funds states "In programs utilizing mandatory matching of Federal funds with State funds, a State must not arbitrarily assign its earliest costs to the Federal government. A State incurs interest liabilities if it draws Federal funds in advance and/or in excess of the required proportion of agreed upon levels of State contributions in programs utilizing mandatory matching of Federal funds with State funds."

25. Caution! • The Department is checking to ensure that funds are being drawn down proportionately.

26. Section 12

27. 12a. Non-Federal Share of Expenditures for Construction ….. • Enter the non-federal share of expenditures for construction of facilities for community rehabilitation program purposes and the establishment of facilities for community rehabilitation purposes (34 CFR 361.62(b)). Only include those costs for activities that would meet the definition of construction of a community rehabilitation program at 34 CFR 361.5(b)(12) and establishment of a facility for a community rehabilitation program at 34 CFR 361.5(b)(18). Do not include staffing costs or other costs associated with establishment projects. If no funds were used for this purpose during the reporting period, enter zero on this line.

28. MOE Impact • The amount reported on line 12a will be subtracted from the agency’s non-federal share when determining whether the agency met its Maintenance of Effort (MOE) requirement (34 CFR 361.62(b)).

29. Note • Reports must be submitted electronically through the RSA-MIS. In addition and as done for other reports submitted to RSA electronically, grantees are responsible for maintaining a hardcopy of the report, signed by the certifying official, for verification purposes.

30. Late Liquidation Requests Adrienne Grierson, SMPID Fiscal Unit Specialist Adrienne.Grierson@ed.gov

31. Authority, 1 • Education Department General Administrative Regulations, EDGAR • Provides the authority that establishes the time in which states, as grantees, may use federal funds. • 34 CFR 80.23 • (a) States that grantees may only charge the award during the funding period or carry over period. • (b) States that grantees must liquidate all obligations under that award no later than 90 days after the end of the funding period.

32. Authority, 2 • Provides the ability to obligate federal funds during the carry over period, and states that funds not used will revert to the Federal Government. • 34 CFR 76.709 • (a) Allows states to obligate during a carry over year, provided all conditions are met • (b) Requires states to return unobligated federal funds to the Federal Government

33. RSA Policies • Policy Memorandum dated June 5, 2007 • Provides background and requirements for grantees. • Online at www.ed.gov, under • Policy • Grants and Contracts • Grant Policy Memos • Guidance on Late Liquidation of federal Education Funds (9/27/2007)

34. Grant Period, Carry-Over, Liquidation

35. When to Request Late Liquidation • As early as possible • Obligations which will occur beyond the 90-day liquidation period • Lengthy construction projects • More than $10,000 • 18 months after the carryover year indicates EXTRAORDINRY circumstances

36. Required Documentation • Letter from VR Director, containing • An Attestation that federal funds will only be used for obligations incurred during the grant period and will only be used for allowable costs. • Identification of the principle from the June 2007 ED guidance that justify approval of the request. • An explanation of the inability to liquidate funds timely and a summary of steps taken to prevent recurrence. • The amount of funds to be drawn (and a statement of awareness of monies remaining in the award). • The time period needed to complete the drawdowns.

37. Additional Documentation • Evidence of allowability of obligations • Purchase Orders • Invoices • Dated receipts • Other indicating allowable agency expenses

38. Other Info We Consider • Information also considered • Other late liquidation requests within the last 5 years • Material Weaknesses identified in A-133 audits in the last 5 years • Whether agency has been designated “high-risk” • Whether the agency operates under “special conditions” • Timeliness of A-133 audits in last 5 years • Does “Yes” mean “No”?

39. Contents of Letter • Letter from VR Director, containing • An Attestation that federal funds will only be used for obligations incurred during the grant period and will only be used for allowable costs. • Identification of the principle from the June 2007 ED guidance that justify approval of the request. • An explanation of the inability to liquidate funds timely and a summary of steps taken to prevent recurrence. • The amount of funds to be drawn (and a statement of awareness of monies remaining in the award). • The time period needed to complete the drawdowns.

40. It’s Submitted. Now What? • RSA will review your request for compliance with regulations and policy. • Once request is approved, your Fiscal Unit Specialist will contact you to verify dates.

41. Questions and Contacts • If you have questions or need assistance, contact the Fiscal Unit Specialist for your agency.

42. Closeout Process Katherine Courtnage-Clay, SMPID Fiscal Unit Katherine.Courtnage-clay@ed.gov

43. Closing out Grant Awards • Regulations: 34 CFR 80.50 • Requirements on the Federal Financial Reports (SF-269, SF-425) • Deadlines for completing the SF-425 in compliance to grant regulations

44. Regulations 34 CFR 80.50(a) • The Federal Agency will close out the award when it determines that all applicable administrative actions and all required work of the grant has been completed

45. SF-425 Components: Cash Receipts • Line 10a (cash receipts) must equal the amount of award drawdowns from the G5 System (Net Draws).

46. SF-425 Components Program Income • Line 10 O (Unexpended Program Income) must be zero, indicating that all program income was either expended or transferred to another eligible program.

47. SF-425 Components: Unliquidated Obligations • Lines 10f and 12d (Federal Share Unliquidated Obligations and Recipient Share of Unliquidated Obligations) must be zero, indicating there are no remaining obligations under this grant award which have not been paid.

48. Line Items on the SF-269 • Federal Share of Net Outlays: Line 10j = Net Draws • Undisbursed Program Income: Line 10s = 0 • Unliquidated Obligations: Lines 10k, 10l, and 10m = 0

49. Final Reports • A Final report must be submitted for an award to be closed in compliance • If any of the items listed are incorrect, the agency’s report cannot be submitted as “final” 1) Total Outlays= G5 draw downs 2) Undisbursed Program Income = 0 3) Total Unliquidated obligations=0 4) Line 6 is marked yes for final

50. Submissions • According to 34 CFR 80.50 reports are due “within 90 days after the expiration or termination of the grant, the grantee must submit all financial, performance, and other reports required as a condition of the grant.”