Grants Management Training. Office of Federal Programs August 19, 2015
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1 Training Office of Federal Programs August 19, 2015
2 MS State Board of Education s Vision and Mission Vision To create a world-class educational system that gives students the knowledge and skills to be successful in college and the workforce, and to flourish as parents and citizens Mission To provide leadership through the development of policy and accountability systems so that all students are prepared to compete in the global community MDE Office of Federal Programs 2
3 State Board of Education Goals 5-Year Strategic Plan for All Students Proficient and Showing Growth in All Assessed Areas Every Student Graduates High School and is Ready for College and Career Every Child Has Access to a High-Quality Early Childhood Program Every School Has Effective Teachers and Leaders Every Community Effectively Using a World-Class Data System to Improve Student Outcomes MDE Office of Federal Programs 3
4 Office of Federal Programs Vision, Mission, & Goals 4
5 Questions? MDE Office of Federal Programs 5
6 Legal Structure of Federal Programs Statutes Regulations Good Guidance Guidance 7
7 Where to Find the Requirements Statutes: Elementary and Secondary Education Act of 1965 (ESEA) Regulations: Code of Federal Regulations (Uniform Guidance) e&tpl=/ecfrbrowse/title02/2cfrv1_02.tpl Good Guidance: Non-regulatory Guidance 8
8 How to Determine Allowable Cost Is the proposed cost allowable under the relevant program? Is the proposed cost consistent with program specific fiscal rules? Is the proposed cost consistent with federal cost principles? Is the proposed cost consistent with the Uniform Guidance? 9
9 How to Determine Allowable Cost Is the proposed cost consistent with special conditions imposed on the grant? Is the proposed cost consistent with the underlying needs of the program Data driven decision making Target funds to areas of weakness 10
10 Program Allowability In general, there are 2 types of programs Specific rules regarding allowable costs Title IV, Part B - 21 st CCLC Title X, McKinney Vento Homeless Education SEA level allowability activities Flexible program general criteria Title I, Part A program funds Eligible students Purposes of program 12
11 Title 34 CFR Education Part 76 State-Administered Programs 13
12 Title 34 CFR Part 76 Allowable Costs The general principles to be used in determining costs applicable to grants is 2 CFR Part 200 Subpart E Prohibited: Use of funds for religion Real property and construction (unless authorized)
13 Title 34 CFR Part 76 When Obligations Are Made
14 Title 34 CFR Part 76 When May Funds Be Obligated For discretionary grants obligations can be made when the grant agreements are signed. 17
15 Title 34 CFR Part 76 Records A State and subgrantee shall keep records that fully show: The amount of funds; How funds were used; Total cost of the project; Share of the cost provided from other sources; and Other records to facilitate an effective audit. 18
16 Title 2 CFR Grants and Agreements Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 19
17 Title 2 CFR Part 200 Subpart A Definitions Subpart B General Provisions Subpart C Pre Award Requirements Subpart D Post Award Requirements Subpart E Cost Principles Subpart F Audit Requirements 20
18 Factors Affecting Allowability of Costs All Costs Must Be: 1. Necessary, Reasonable and Allocable 2. Conform with federal law & grant terms 3. Consistent with state and local policies 4. Consistently treated Subpart E 5. In accordance with GAAP 6. Not included as match 7. Net of applicable credits (moved to ) 8. Adequately documented Cost Principles 22
19 Necessary & Reasonable Necessary and Reasonable Must be necessary for the performance or administration of the grant Must follow sound business practices: Arms length bargaining (hint: procurement processes) Follow federal, state and local laws Follow terms of the grant award Fair market prices Act with prudence under the circumstances No significant deviation from established prices 23
20 Necessary & Reasonable (cont.) Data Driven Decision Making Critical Needs Strategic Goal Current Performance (based on data) Measurable Objective 24
21 Necessary & Reasonable (cont.) Practical aspects of necessary Do I really need this? Is this the minimum amount I need to spend to meet my need? Practical aspects of reasonable Is the expense targeted to valid programmatic/administrative considerations? Do I have the capacity to use what I am purchasing? Did I pay a fair rate? Can I prove it? If I were asked to defend this purchase, would I be comfortable? 25
22 Allocable Allocable Can only charge in proportion to the value received by the program Example: LEA purchases a computer to use 50% in the Title IV program and 50% in a state program can only charge half the cost to Title IV 2 Methods of allocating costs: Direct cost allocation Indirect cost allocation 26
23 Basic Guidelines Legal under state and local law If you can t do it under state law, you can t pay for it with federal funds Conform with federal law & grant terms Example: Match Requirements Consistently treated Must follow uniform policies that apply equally to federal and non-federal activities Cannot assign cost as direct cost if indirect under state programs 27
24 Basic Guidelines (cont.) Adequately documented Amount of funds under grant How the funds are used Total cost of the project Share of costs provided by other sources Records that show compliance Records that show performance Other records to facilitate an effective audit 28
25 Subpart E Cost Principles Factors Affecting Allowability of Costs continued Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-federal entity. Be afforded consistent treatment Be determined in accordance with GAAP Not be included as a cost or used to meet cost sharing or matching 29
26 Subpart E Factors Affecting Allowability of Costs (g) continued Adequately documented Amount of funds under grant How the funds are used Total cost of the project Cost Principles Share of costs provided by other sources Records that show compliance and performance Other records to facilitate an effective audit (see ) 30
27 Methods for Collection, Transmission and Storage of Information o NEW: When original records are electronic and cannot be altered, there is no need to create and retain paper copies. o When original records are paper, electronic versions may be substituted through the use of duplication or other forms of electronic media provided they: o o o Subpart E Cost Principles Are subject to periodic quality control reviews, Provide reasonable safeguards against alteration; and Remain readable. 31
28 Selected Items of Cost There are 55 specific items of cost! Starting at
29 Selected Items of Cost 1. Advertising/PR Allowable for programmatic purposes including: a) Recruitment b) Procurement of goods c) Disposal of materials d) Program outreach e) Public relations (in limited circumstances) 3. Alcohol a) Not allowable 4. Collections of Improper Payments a) The costs incurred by the non-federal entity to recover improper payments are allowable as either direct or indirect costs, as appropriate. 36
30 Selected Items of Cost 5. Conferences a) Prior Rule: Generally allowable b) Includes Meals / Conferences / Travel and Family Friendly Policies c) Allowable conference costs include rental of facilities, costs of meals and refreshments, transportation, unless restricted by the federal award d) NEW: Costs related to identifying, but not providing, locally available dependent-care resources e) Conference hosts must exercise discretion in ensuring costs are appropriate, necessary and managed in manner than minimizes costs to federal award 37
31 Selected Items of Cost 6. Pre-award Costs a) Those costs incurred prior to the effective date of the Federal award directly in negotiation or anticipation of the award b) Costs must be necessary for efficient and timely performance of the scope of work c) Allowable to the extent they would have been allowable if incurred after the effective date and ONLY with written approval from the Federal awarding agency. 38
32 Selected Items of Cost 7. Travel Costs a) Travel costs may be charged on actual, per diem, or mileage basis b) NEW: Travel charges must be consistent with entity s written travel reimbursement policies c) NEW: Allows costs for above and beyond regular dependent care d) Grantee must retain documentation that participation of individual in conference is necessary for the project e) NEW: Travel costs must be reasonable and consistent with written travel policy / or follow GSA 48 CFR (a) 39
33 Selected Items of Cost 8) Salaries and Wages Allowable if proper time distribution records Time Distribution Records must be maintained for all employees whose salaries are: Paid in whole or in part with federal funds Used to meet a match/cost share requirement 40
34 Time Distribution Records Overview of process: Estimate how employee will work Pay based on estimate Reconcile estimates to how actually worked Necessary documentation: Payroll records Personnel activity report Semi-annual certifications 41
35 Time and Effort Type of documentation depends on how many cost objectives the employee worked on These cost objectives must be connected to the employee s salary source What is a cost objective? Cost Objectives A specific grant award, or other category of costs, that requires the grantee to track specific cost information. Program, function, activity, award, organizational subdivision, contract, or work unit for which cost data are desired and for which provision is made to accumulate and measure the cost of processes, products, jobs, capital projects, etc. 42
36 Single Cost Objectives Semi-Annual Certification If an employee works on a single cost objective: Semi-Annual Certification After the fact Account for the total activity Signed by employee or supervisor every six months Prepared at least twice a year Example: I hereby certify that for the period January 1, 2009 through June 30, 2009 one-hundred percent (100%) of my time and effort was spent on Title I Administration. 43
37 Multiple Cost Objectives Personnel Activity Report (PAR) If an employee works on multiple cost objectives: Personnel Activity Report (PAR) or equivalent documentation After the fact Account for total activity Signed by employee Prepared at least monthly and coincide with one or more pay periods 44
38 Distributing Payroll Costs Estimate how employee will work Must produce reasonable approximations of the activity actually performed Quarterly comparison of estimates to actual costs If difference is less than 10% - annual adjustment If difference is more than 10% - quarterly adjustment 45
39 Time and Effort Documentation Documentation for Personnel Expenses (i) NEW: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. - How staff demonstrate allocability If employee paid with federal funds, then must show that the employee worked on that specific federal program cost objective (a) 46
40 Who must participate? (i)(1) & (i)(4) Must be maintained for all employees whose salaries are: Paid in whole or in part with federal funds Used to meet a match/cost share requirement NOT contractors Time and Effort Documentation 47
41 Time and Effort Semi-Annual Certification If an employee works on a single cost objective: After the fact Account for the total activity Signed by employee or supervisor Every six months (at least twice a year) Personnel Activity Report (PAR) If an employee works on multiple cost objectives: After the fact Account for total activity Signed by employee Prepared at least monthly and coincide with one or more pay periods 48
42 Semi-Annual Certification (Only for staff working on a single cost objective) This is to certify that has worked (Employee s Name) 100% of his/her time for the period through (Beginning of time period) on single cost objective. (End of time period) (Program number/position; [e.g. Title I teacher) Employee Signature Date Printed Name of Employee Immediate Supervisor Date Printed Name of Supervisor OMB Circular A-87, Appendix A, B11 (p. 291) defines cost objective as a function, organizational subdivision, contract, grant, or other activity for which cost data are needed and for which costs are incurred. OMB Circular A-87, Appendix B, 8h(3) (p. 297) states that semi-annual certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having first hand knowledge of the work performed by the employee. 49
43 50
44 MDE - Office of Federal Programs 51
45 Procurement Contract vs. Grant Entities must clearly determine what is a subgrant and what is a contract. General Procurement Standards (a) All nonfederal entities must have documented procurement procedures which reflect applicable Federal, State, and local laws and regulations. 59
46 Nature of Funding Subgrant Contract Allowable activities based on applicable statute, local plan, State rules Management rules EDGAR; Applicable OMB Circular; and State law/policies and procedures Allowable activities based on terms and conditions of contract Management rules Terms of the contract; and State contract law 60
47 Subgrant vs. Contract Subgrantee Determines who is eligible to participate in a federal program Has its performance measured against whether the objectives of the federal program are met Is responsible for programmatic decision making Is responsible for complying with federal program requirements Uses the federal funds to carry out a program as compared to providing goods or services for a program 61
48 Subgrant vs. Contract (cont.) Contractor Provides the goods and services within normal business operations Provides similar goods or services to many different purchasers Operates in a competitive environment Provides goods or services that are ancillary to the operation of the federal program Is not subject to compliance requirements of the federal program 62
49 Procurement Mandatory Disclosures NEW: Must disclose in writing, in a timely manner: All violations of Federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the Federal award. Failure to make disclosures can result in remedies in (remedies for noncompliance) including suspension and debarment. 64
50 Procurement Vendor Selection Process (h) Must award contracts only to responsible contractors possessing the ability to perform successfully: Contractor integrity Compliance with public policy Record of past performance Financial and technical resources 65
51 Procurement Methods of Procurement NEW: Micro-purchase Small purchase procedures Competitive sealed bids Competitive proposals Noncompetitive proposals 69
52 Procurement Micro-Purchase (a) NEW: Acquisition of supplies and services under $3,000 or less. May be awarded without soliciting competitive quotations if nonfederal entity considers the cost reasonable. To the extent practicable must distribute micropurchases equitably among qualified suppliers. 70
53 Procurement Small Purchase Procedures (b) Good or service that costs $150,000 or less (NEW: Simplified Acquisition Threshold was raised under ) Organization may set lower threshold Must obtain price or rate quotes from an adequate number of qualified sources Relatively simply and informal 71
54 Procurement Noncompetitive Proposals (f) Appropriate only when: The item is only available from a single source; There is a public emergency that will not permit delay; NEW: The Federal awarding agency or pass-through expressly authorizes noncompetitive proposals in response to a written request from non-federal entity; or After soliciting a number of sources, competition is determined inadequate. 72
55 Procurement Contract Cost and Price NEW: Must perform a cost or price analysis in connection with every procurement action over $150,000, including contract modifications Independent estimate before receiving bids or proposals. Cost analysis generally means evaluating the separate cost elements that make up the total price (including profit) Price analysis generally means evaluating the total price 73
56 Procurement Suspension and Debarment Appendix II(H) Cannot contract with vendor who has been suspended or debarred Excluded Parties List System in the System for Award Management (SAM) 2 CFR Part 180 (OMB Debarement Suspension Rules) and 2 CFR 3485 (USDE Rules) 74
57 Procurement Suspension and Debarment 2 CFR For contracts over $25,000 you must verify that the person with whom you intend to do business is not excluded or disqualified. This MUST be done by either: a. Checking SAM; or b. Collecting a certification from that person; or c. Adding a clause or condition to the covered transaction with that person. 75
58 Property Management Equipment Equipment: tangible, nonexpendible, personal property having a useful life of more than one year and an acquisition cost of $5,000 or more per unit. Grantee may also use its own definition of equipment as long as the definition would at least include all equipment defined above. 76
59 Property Management Supplies All tangible personal property other than equipment - NEW: Computing devices are supplies if less than $5,000 NEW: Computing devices Machines used to acquire, store, analyze, process, public data and other information electronically Includes accessories for printing, transmitting and receiving or storing electronic information 77
60 Property Management Internal Controls (b)(4) Regardless of cost, grantee must maintain effective control and safeguard all assets and assure that they are used solely for authorized purposes. 78
61 Property Management Equipment (a) and (c)(4) NEW: Conditional Title vests with the non-federal entity. NEW: Cannot encumber the property without approval of Federal agency or Pass-through agency But NEW: When acquiring replacement equipment, may use the equipment to be replaced as a trade-in or sell the property and use the proceeds to offset the cost of the replacement property. 79
62 Property Management Use of Equipment (c)(1) and (2) Equipment must be used by the Non-Federal entity in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the Federal award. When no longer needed, may be used in other activities with the following priority: 1. Projects supported by Federal awarding agency 2. Project funded by other Federal agencies When used, it may be shared (according to the above priorities) provided such use will not interfere with work on the original projects/programs. Exception Private Schools
63 Property Management Equipment Procedures (d) Procedures for managing equipment must meet the following requirements: 1. Property records 2. Physical inventory at least every two years 3. Control system to prevent loss, damage, theft All incidents must be investigated 4. Adequate maintenance procedures 5. If authorized or required to sell property, proper sales procedures to ensure highest possible return. 81
64 Property Management Disposition of Equipment (e) When property is no longer needed in any current or previously Federally-funded supported activity, must follow disposition rules: NEW: Nonfederal entity must request disposition instructions from the federal awarding agency if required by the terms of the grant. Otherwise, may be retained, sold or otherwise disposed as follows: Over $5,000 pay federal share If equipment is sold: Federal awarding agency may permit non- Federal entity to deduct and retain $500 or 10% of the proceeds for selling and handling instructions. Under $5,000 no accountability (still must formally dispose) 82
65 Financial Management Controls 1) Identification of Awards (b)(1) NEW: All federal awards received and expended The name of the federal program Identification # of award CFDA Title and Number Federal Award I.D. # Fiscal Year of Award Federal Agency Pass-Through (If S/A) 83
66 Financial Management Controls 2) Financial Reporting (b)(2) Accurate, current, complete disclosure of financial results of each award in accordance with and NEW : Federal awarding agency can only collect OMB approved data elements, no less than annually, no more than quarterly NEW : Non-federal entity must submit performance reports at intervals required by federal agency or pass through. Annual performance reports due 90 days after reporting period; Quarterly performance reports due 30 days after reporting period 84
67 Financial Management Controls 2) Financial Reporting (b)(2) continued NEW: Performance Metrics 1. Compare actual accomplishments to objectives. (quantify to extent possible) 2. Reasons goals were not met if appropriate 4. Additional pertinent information (e.g. analysis and explanation of cost overruns, high unit costs) Significant developments a. Problems, delays. Adverse conditions that would impair ability to meet objective of the award b. Favorable developments. Finishing sooner or at less cost 85
68 Financial Management Controls 3) Accounting Records (b)(3) Source Documentation Must Be Kept On: 1. Federal Awards 2. Authorizations 3. Obligations 4. Unobligated balances 5. Assets 6. Expenditures 7. Income 8. Interest (New) (Eliminated liabilities) 86
69 Financial Management Controls 4) Internal Controls (b)(4) Effective control over and accountability for: 1. All funds 2. Property 3. Other assets Must adequately safeguard all assets Use assets solely for authorized purpose 87
70 Financial Management Controls 4) Internal Controls continued a. Non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurances that the entity is managing the award in compliance with federal statutes, regulations, and terms of the award. b. Comply with Federal statutes, regulations, and the terms and conditions of the Federal awards. 88
71 Financial Management Controls 4) Internal Controls continued c. Evaluate and monitor the non-federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. d. Take prompt action when instances of noncompliance are identified including in audit findings. e. Take reasonable measures to safeguard protected personally identifiable info (PII) and other information designated or deemed sensitive 89
72 Financial Management Controls Required Certification NEW: An official authorized to legally bind the nonfederal entity must certify on annual and final fiscal reports or vouchers requesting payment: By signing this report, I certify to the best of my knowledge and belief that the report is true, complete and accurate and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the federal award. I am aware that any false, fictitious, or fraudulent information or the omission of any material fact, may subject me to criminal civil or administrative penalties for fraud, false statements, false claims, or otherwise. 90
73 Financial Management Controls 5) Budget Control (5) Comparison of expenditures with budget amounts for each award 91
74 Financial Management Controls 6) Written Cash Management Procedures (6) NEW: Written Procedures to implement the requirements of
75 Financial Management Controls Cash Reimbursement Payment Process Obligation Payment Liquidation (Drawdown) Obligation means orders placed for property and services, contracts and subawards made and similar transactions during a given period that require payment during the same or a future period
76 Financial Management Controls Payment (a) and (b) For all non-federal entities, payments must minimize time elapsing between draw from G-5 and disbursement (not obligation) General Rule: 72 hours 94
77 Financial Management Controls Payment (b)(1)-(4) continued Written procedures must describe that the non-federal entity uses the reimbursement method for requesting funds from the pass through agency. Pass through must make payment within 30 calendar days after receipt of the billing 95
78 Financial Management Controls 7) Written Allowability Procedures (b)(7) NEW: Written procedures for determining allowability of costs in accordance with Subpart E Cost Principles Procedures can not simply restate the Uniform Guidance Subpart E Should explain the process used throughout the grant development and budget process Training tool and guide for employees 98
79 Written procedures and policies are required Written Procedures: Cash Management (b)(6) & Allowability (b)(7) Procurement (c) Written Policies Written Policies and Procedures Conflicts of Interest (c) Travel (b) Written Method for Conducting Technical Evaluations of Proposals and Selecting Recipients (d)(3) 99
80 Written Policies and Procedures The purpose of updating policies and procedures is to ensure the administration of compliant programs. 100
81 Written Policies and Procedures Where to start? Review & collect available policies & procedures from different offices and websites If starting from scratch, get information from people who perform grant related activities 101
82 Written Policies and Procedures Who should be involved? Program AND Fiscal staff Use team approach to capture entire grant process Everyone involved should sit in the same room: To review grant activities To help with decision making To determine job responsibilities 102
83 Written Policies and Procedures What is the process? Review existing policies and procedures Develop questions Schedule interviews with relevant staff Gather information on actual practices Draft policies and procedures Review internally with appropriate staff Revise, formally adopt, and implement Train staff Annually review and revise! 103
84 Written Policies and Procedures How long does it take? Depends on need Review of existing policies and procedures is less time than starting from scratch Set deadlines for actions Don t get overwhelmed! 104
85 Written Policies and Procedures Resources OMB Uniform Administrative Guidance ESEA statute, regulations and guidance State and Local rules, regulations, policies and procedures 105
86 Written Policies and Procedures Suggested Sections Organization, Structure and Function Financial Management System Programmatic and Fiscal Requirements Procurement Inventory / Property Management Time and Effort Record Keeping / Record Retention Monitoring / Audit Resolution 106
87 Written Policies and Procedures Conflict of Interest NEW: All non federal entities must establish conflict of interest policies, and disclose in writing any potential conflict to federal awarding agency in accordance with applicable Federal awarding agency policy
88 Written Policies and Procedures Conflict of Interest Must maintain written standard of conduct, including conflict of interest policy (c)(1) A conflict of interest arises when any of the following has a financial or other interest in the firm selected for award: Employee, officer or agent Any member of that person s immediate family That person s partner An organization which employs, or is about to employ, any of the above or has a financial interest in the firm selected for award 108
89 Written Policies and Procedures Conflict of Interest Policy Includes: Definition Chain for reporting potential conflicts Alternate member of chain is involved in a potential conflict Definitions and examples of nominal items Sanctions Signed certification that employee received and understands conflict policy Training on policy 109
90 Written Policies and Procedures Conflict of Interest Policy Must neither solicit nor accept gratuities, favors, or anything of monetary value from contractors/ subcontractors. However, may set standards for situations in which the financial interest is not substantial or the gift is an unsolicited item of nominal value. Standards of conduct must include disciplinary actions for violations. 110
91 Written Policies and Procedures Reminder Now that policies and procedures are completed: Train Review Revise Where are Policies and Procedures Located? 111
92 Record Keeping Statute of Limitations , Retain records for 3 to 5 years after the grant closes. State Policy Entity Policy 112
93 Record Keeping Helpful Questions to Ask How long must records be maintained? How are records maintained? Hard copy, electronic 113
94 Monitoring Policies and procedures are evidence of compliance under all program monitoring tools 114
95 Monitoring Compliance Supplement, Part 6: Internal Controls, Section M. Subrecipient Monitoring Written policies and procedures exist establishing: Communication of Federal award requirements to subrecipients Responsibilities for monitoring subrecipients Process and procedures for monitoring Methodology for resolving findings Requirements related to subrecipient audits, including appropriate adjustment of pass-through s accounts 115
96 Monitoring Monitoring of Subrecipients Onsite Reviews Remote Monitorings Desk Reviews Self-Assessments Follow-Up 116
97 Monitoring Helpful Questions to Ask Process for when agency is monitored? - Notification, preparation, Responding, Follow-Up Process for monitoring subrecipients? - From notification to issuing report and Timeline Who is responsible for monitoring? Fiscal? Programmatic? What gets monitored? How do you determine which subrecipients will be monitored? How often does monitoring occur? - Site visits, desk reviews, self-assessments How do you ensure findings are resolved? - Corrective action plan, Closeout letter, Future monitoring 117
98 Audit Requirements NEW: Threshold increased to $750,000 The federal agency, OIG, or GAO may arrange for audits in addition to single audit
99 Audit Findings The auditor must report (for major programs): Significant deficiencies and material weaknesses in internal controls Significant instances of abuse Material noncompliance Known questioned costs > $25,000 Auditor will not normally find questioned costs for a program that is not audited as a major program NEW: But if auditor becomes aware of questioned costs > $25,000 for non-major program, must report
100 Single Audits Auditors ask about policies and procedures Some tests specifically require written policies and procedures 120
101 Audit Resolution Helpful Questions to Ask Who is responsible for overseeing single audit compliance and resolution? What is the audit process? How are findings resolved? Corrective Action Plan with Timeline 121
102 Upcoming Events OFP University (less than 3 years as FP Director) 09/15/2015 Library Commission Jackson 10/15/2015 Library Commission Jackson ESEA and IDEA Fiscal Conference 10/27 28/2015 Vicksburg Convention Center N & D Annual Conference 10/29 30/2015 Columbus School District 122
103 Contact Information Marcus E. Cheeks Executive Director Office of Federal Programs Melanie Diggs Director of Finance Barabara Greene Homeless Education Coordinator Karen Austin Director of Competitive Grants Kimberly Williams 21 st CCLC Coordinator THANK YOU FOR ATTENDING!! 123
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