GRANTS MANAGEMENT PROCEDURES MANUAL WICHITA FALLS ISD

Transcription

1 GRANTS MANAGEMENT PROCEDURES MANUAL WICHITA FALLS ISD 1

2 Wichita Falls ISD Federal Program Office Grants Fund FY Beg. Date End Date Program Fed/St Funding Agency /1/2012 8/31/2013 TITLE X, PART C FED TEA McKINNEY VENTO /1/2012 9/30/2013 TITLE I, PART A FED TEA IMPROVING BASIC PROGRAMS 12 10/1/2012 9/30/2013 PROGRAMS TITLE I, PART C FED TEA - MIGRANT /1/2012 9/30/2013 TITLE I, PART D - JUVENILE DETENTION FED TEA /1/2012 9/30/2013 TITLE II, PART A - TPTR /1/2012 9/30/2013 TITLE III, PART A - LEP & IMMIGRANT /12 9/30/13 SCHOOL IMPROVEMENT PROGRAMS STATE COMPENSATORY ED FED FED FED ST TEA TEA TEA TEA 2

3 Department Responsibilities Duties Review CIP and DIP for compliance Conduct Comprehensive Needs Assessment for district Conduct Comprehensive Needs Assessment for campuses and develop CIPs Review, complete, and submit compliance reports Inform key personal on grant budgeting, budget amendments, coding, time and effort Inform key personnel on credit cards, contract monitoring, travel reimbursements and other reimbursements, and selected unallowable costs *Approve all purchases to ensure compliance with grant requirements, coding, allowability of costs *Complete financial procedures *Periodic reporting (cash draw-downs) *Quarterly reporting *Reconciliation of accounting reports *Grant application preparation/budget maintenance for grant programs *Review program financial reports Position/Department responsible Assistant Superintendent, Instructional Services Directors of Elementary and Secondary Curriculum Director of Special Education Directors of Federal Programs Director of Human Resources Coordinator of Instructional Technology Curriculum Specialists Assistant Superintendent, Instructional Services Directors of Elementary and Secondary Curriculum Curriculum Specialists Director of Special Education Directors of Federal Programs Coordinator of Student Assessment District Action Committee Campus Principal and committees Directors of Federal Programs Directors of Federal Programs Budget and Finance Personnel Directors of Federal Programs Budget and Finance Personnel Directors of Federal Programs Budget and Finance Personnel Directors of Federal Programs 3

4 General Guidelines Grants management procedures are used for the financial and regulatory administration of all state and federal financial assistance to the district. Overall responsibility for submitting proposals and for executing and submitting awards rests with the Superintendent. The guidelines establish lines of authority within the district related to financial transactions on government assistance received. General information provided in this document is based on multiple sources. For more specific information, consult the grant application and regulations and OMB Circular A-87 for federal cost principles. All applicable WFISD Policies and Procedures and Administrative Guidelines and WFISD Purchasing Procedures are to be followed for expenditures. Procedures in the WFISD Policies and Procedures and WFISD Employee Handbook are to be followed for personnel. Supplement Not Supplant Procedures The district has implemented guidelines to ensure compliance with the federal fiscal requirement of supplement not supplant. The purpose of the procedures is to ensure that the level of state and local financial support for programs remains at least constant and is not replaced by federal funds. Federal funds are used to supplement (add to, enhance, expand or increase) the funds available from non-federal sources, and not to supplant (replace or take the place of) existing non-federal funds. TEA-SE Access TEA-SE access is required for program access such as compliance reporting, application submission, budget amendment submission and expenditure reporting/draw-downs. If an employee with TEA-SE access terminates employment from the district, a request will be submitted to de-activate access to the TEA-SE system. If a replacement is employed for the terminated employee, then it will be determined if TEA-SE access is required and, if so, a request will be submitted to gain access to the system. All submission and de-activations are processed through the superintendent s office. Time and Effort Title I A/ Title I C/ Title I D/ Title 2 A/ Title 3 A/ Title X C: Full time/ split funded federal positions WFISD follows the procedures outlined in P.L which requires the following monthly documentation: The district splits the pay by assigned time periods to cover the whole salary. The district determines what percent will be paid from each fund source based on assigned time periods. A weekly time and effort certification signed by the employee is submitted to the federal programs office for verification. 4

5 Full-time fully funded federal grant positions Fully funded full time personnel complete semi-annual certification at the beginning of each semester. The semi-annual certification requires signature of the employee as well as signature of the supervisor/principal. These are due to the federal program contact at the beginning of the first semester and at the beginning of the second semester. The semi-annual certification must be signed and dated by the employee and the supervisor. The original is archived in the Federal Programs Office. Extra duty supplemental tutoring federal positions Tutors complete monthly payroll sheets in accordance with pay periods. Signed job descriptions entailing the extra duties of the tutor will be signed and submitted to federal and state programs denoting the funding source. Campuses will keep copies of teacher/student sign in documents for their documentation of the tutors effort, and the tutor reports their time monthly. The supplemental tutoring payroll sheet is certified by the teacher s signature and then goes to the campus administrator for verification and signature as well. Upon both tutor and campus administrator s signatures verifying the tutors effort, timesheets are submitted in accordance with payroll guidelines to the Federal Programs Office. Upon certification of time and effort of tutoring, payroll sheet is submitted to payroll and a copy is archived in the Federal Programs Office. Job Description Each employee funded federally must have current, detailed job description describing the work performed by the employee under the grant fund. It is to be signed and dated by the employee and supervisor. The original is archived in the Federal Programs Office. State Funded Programs: Compensatory Education/ Optional Extended Year/ Student Success Initiative: Full time fully funded state positions WFISD will follow the procedures outlined in Texas Education Code for time and effort documentation. This will account for keeping a copy of a signed job description for professional positions describing how the position is funded as well as the duties of the supplemental professional position. Full time split funded state/local positions WFISD will follow the procedures outlined in Texas Education Code for time and effort documentation. This will account for keeping a copy of a signed job description for professional positions annually in accordance with funding split describing how the position is funded as well as the duties of the supplemental professional position. For split funded support positions, duty schedules will submitted by campus administrators for each support position. These will be certified by support person signature and campus administrator signature. 5

6 Full time split funded state/federal positions WFISD will follow the procedures outlined according to federal guidelines. Extra duty supplemental tutoring state positions WFISD will follow same procedures as extra duty supplemental tutoring federal positions. (Source documentation: Certification of time and effort, job descriptions, signed duty schedules, and semi-annual certifications are kept at the district level. Teacher/support staff/ tutorial students sign in sheets, time sheets, and campus plans are kept at the campus level, District and campus plans as well as applications for funding are kept at the district level. Allowable Use, Amendments, and Reporting Allowable Use of Funds: All Grants Upon receiving NOGAs for all federal and state grants, campus awards will be made in accordance with the grant application and allowable expenditures of the specific grant. All purchases (payroll, contracted services, supplies and travel) will be monitored by the directors of the programs for programmatic compliance of the grant and will follow the accounting procedures outlined by the finance office. Requisitions requests for all federal NCLB grants will be supported through reference on the requisition to the aligning campus/ district strategic plan goal number that supports the expenditure. Amendments: All Grants Federal and state grants will be monitored for programmatic and budgetary compliance with the approved NOGA. If it becomes necessary to file an amendment due to a need identified by the district, a campus or a program that was not approved in the initial award, the amendment will be processed after the director approves the amendment. Funds will become available upon the receipt of approval of the amendment. Amendments will be required for the following reasons: o Change in federal or state entitlement amounts (ex. maximum entitlements) o An increase or decrease in the number of the positions approved according to the NOGA. o The addition of a capital outlay item that is not currently approved by the NOGA. o A programmatic change in activity that is not currently approved by the NOGA, either adding to the current allowable planned activities or taking away from the current planned activities as approved. o Budgetary moves that are necessary to fulfill the program s intent beyond the 25% allowable move for approved expenditures according to the NOGA. Reporting data: All Grants Federal and state programs director will be responsible for assuring the compliance of all programmatic reports for NCLB. Finance will be responsible for assuring the compliance of all expenditure reports relating to all federal and state programs. 6

7 Business Office Responsibilities Maintaining fiduciary and financial responsibility for all grant activities Processing and maintaining the accounting data for the grant Grant accounting shall include the details of all grant transactions by the grantee and grantor Requesting funds through the automated payment request systems Preparing and submitting written expenditure reports and certifying expenses are true and correct Classifying and reporting the accounting transactions properly according to TEA guidelines Filing the following reports: Periodic expenditure reports Final expenditure reports Revised final expenditure report (if necessary) Process for Completing Monthly Expenditure Reports The following steps will be completed each month: Financial Accountant will run appropriate general ledger reports and update Excel files as necessary. Federal Programs office, through purchase requisition and time and effort documentation, will verify transactions/ expenditures and sign off on them. The Financial Accountant will enter the cumulative expenditures and request funds via E-grants system expenditure reporting for each NOGA that incurred expenses. If threshold amount is exceeded, provide written documentation for NOGA with a breakout by object code to justify expenditures and fax to the appropriate department with TEA. Budget Budget Planning When tentative entitlements are received, the budget planning process begins officially with additional communication between program administrators and campuses to gather data needed to create the application to be submitted to TEA. Input for budget planning is derived from additional, focused communication with campus principals, other stakeholders, and other program administrators as part of the Comprehensive Needs Assessment (CNA). After prioritizing needs based on the CNA findings, goals and objectives are written and strategies are selected based on student needs. Funds are set in the accounting system and account code distributions are verified by the federal program administrator. Notification of grant approval is received from TEA via NOGA. Budget Amendments Federal and state grants will be monitored for programmatic and budgetary compliance with the approved NOGA. If it becomes necessary to file an amendment due to a need identified by a campus or by a program that was not approved in the initial award and the amendment is within 7

8 the budget variances of the application, then the amendment will be processed in egrants. The amendment must be officially approved by TEA before the expenditure is allowable. A budget amendment is required to do the following: add a class/object code not previously budgeted on the Program Budget Summary increase or decrease the amount budged in an class/object code on the Program Budget Summary by more than 25% of the current amount approved in the class/object code (discretionary grants) or the total approved budget (formula grants) add a new item that requires specific approval in the itemized costs or any requirements specified by grant for budget amendment Reviewing Budgets Grant budgets are to be reviewed regularly to review account code expenditures and to monitor if an amendment will be needed. Account codes The primary resource on accounting and business operation for Texas public schools is the TEA Financial Accounting System Resource Guide (FASRG). Please refer to the WFISD-Business Procedure Manual for a detailed explanation of the WFISD account code structure, valid codes, and account code rules based on FASRG. Understanding Account Codes (1) (2) (3) (4) (5) (6) (7) (8) XXX. XX. XXXX. XX. XXX. X. XX. XXX (1) Fund Code - a mandatory 3 digit code used for all financial transactions to identify the fund group and specific fund. The first digit refers to the fund group, and the second and third digit specifies the fund. (2) Function Code - a mandatory 2 digit code applied to expenditures/expenses that identify the purpose f the transaction. The first digit identifies the major class and the second digit refers to the specific unction within the area. (3) Object Code - a mandatory 4 digit code identifying the nature and object of an account, a transaction source. The first of the four digits identifies the type of account or transaction the second digit identifies the major area, and the third and fourth digits provide further sub-classifications. (4) Sub-Object Code an optional 2 digit code not reported to PEIMS. This code can be used to add further description to an object code. (5) Organization Code - a mandatory 3 digit code identifying the organization. (6) Fiscal Year Code - a mandatory single digit code that identifies the fiscal year of the transaction or the project year of inception of a grant project. (7) Program Intent Code - a 2 digit code used to designate the intent of a program provided to students. These codes are used to account for the cost of instruction and other services that are directed toward a particular need of a specific set of students. The intent determines the program intent code; the demographic makeup of the students served. (8) Project Code an optional 3 digit code not reported to PEIMS. This code can be used to add further description to a project within a program. 8

9 Fiscal/Accounting Records All fiscal/accounting records are to be maintained and should include at a minimum, a general ledger of all expenditures, charges made to payroll as documented in a payroll sheet, purchase orders, invoices, receipts, travel vouchers showing expenses reimbursed to employees, cancelled checks, bank statements, and any other documentation that supports the financial transaction. Program Records Program records would be any documentation which provides evidence that program activities as described in the application authorizing program statute actually occurred. Program records might include: class rosters, attendance rosters, sign-in sheets, lesson plans, student test scores, agendas of meetings/trainings with times/dates/location of occurrence, copies of materials, handouts, minutes from meetings, etc. Purchasing Guidelines The district must make its purchases following relevant statues and policies. Although bound by these constraints, the school district's objective is to purchase the best products, materials and services that provide the best value to the district. The following procedures are based on State of Texas statutes, WFISD Policies and Procedures and Administrative Guidelines, and WFISD Purchasing Procedures. A purchase request gives staff members a method to ask for goods and services. A purchase request is normally created electronically and approved by the appropriate administrator who has evaluated and verified the need for the goods or services and specified the proper account code. Once the request is approved, it is entered electronically as a purchase requisition with budget coding verified as to correctness and availability of funds. It must meet district criteria outlined in the Business Procedures Manual. A purchase order is generated by the Purchasing Department which encumbers the funds in the finance program. The purchase order is then forwarded to the vendor. Once shipments have been processed and received, the receiving department enters information into the financial system. The Business Office verifies the invoice and receipt of the item(s) prior to processing payment. Purchases using special revenue funds must match the approved grant application from the funding agency and comply with all program guidelines and assurances. All purchase orders using federal title funds must be approved by the directors of the federal program office. An approved requisition form must accompany all requests for purchases. Accurate coding must be used for purchases/ payments. All purchases will follow the procedures defined in the WFISD purchasing guidelines. Orders must not be deliberately split to avoid the necessity for quotes or competitive bids. Computer purchases must be approved by the Technology department and purchased through the Purchasing department. 9

10 Use of District Credit Cards Credit card uses are specifically defined in the WFISD Purchasing Manual. Purchases made with credit cards in the WFISD are minimal and are limited to specific uses such as district business travel. Grant Retention Records Financial and program records, supporting documents, statistical records, and all other records pertinent to program regulations on the grant award will be retained per the WFISD s Record Control Schedule. With a pending audit, all records must be retained until audit is settled. Reimbursements Expenses incurred that are charged to federal funds must follow federal program allowable cost guidelines. Employees seeking reimbursement for prior approved expenses incurred out of pocket should submit a requisition for check to his/her supervisor requesting reimbursement of expenses with original itemized receipts. Itemized receipts must be submitted to the Business Office with approved check requisition. Normal purchasing guidelines apply. Expenses incurred charged to federal funds must follow federal program allowable cost guidelines. Petty Cash Funds Federal grant funds are not allowed to be reimbursed out of petty cash. Internal Controls Internal control is a process designed by the district to provide reasonable assurance regarding the achievement of these objectives: effectiveness and efficiency of operations; reliability of financial reporting; consistency from one grant program to another; and compliance with applicable laws and regulations. The controls will include all methods adopted by the district to safeguard its assets, comply with management policies and grant terms and conditions, and provide reliability of accounting information data. The Superintendent, Chief Financial Operations Officer, or Director of Finance signature is the required signature for check processing for accounts payable and payroll checks. Electronic transfer of funds is performed via an-on line banking system with authority rights given to the Director of Finance and specific finance department designees of the district. The transactions are performed with documentation referencing transaction numbers and backup documentation justifying said transfers. The district has adopted policies to comply with internal controls, and the controls are tested each year by an independent audit firm. Cash Management Requirements The district operates on a reimbursement basis for expenditures incurred for federal programs. The expenditures must be paid before requesting reimbursement from TEA. All transactions for requesting reimbursement of funds are maintained with the monthly expenditure report justifying the request for reimbursements. The district should not have more cash on hand than is necessary to meet three days cash needs for federal programs. Fixed Assets Guidelines The district's fixed asset system allows the district to purchase, record, track, and report items such as land/buildings, vehicles, equipment, and computer equipment. This system allows the 10

11 district to meet State and federal cost accounting requirements. Like items with an aggregate cost of $5,000 or more must be capitalized. They must have a useful life of at least seven years; be non-expendable; retain original shape and appearance; and not lose its identity through incorporation into a different or more complex unit or substance. If parts are purchased separately to assemble into one item or one unit, the total cost determines if the unit is to be considered a fixed asset. Budget items coded 6600 are considered fixed assets. An inventory item is defined in WFISD policy and under CFB regulations. Fixed assets that are no longer in working condition and are to be disposed of will be reported to the Coordinator, Fixed Assets to be removed from the fixed assets reporting system. Items which are no longer in working condition may be sent to auction conducted by the district's operations department. Items to be sold will be removed from the fixed assets system. Proceeds from sale of property will be booked as revenue from sale of property. Fixed assets that have been stolen or destroyed must also be reported to the Business Office and removed from fixed assets reports. For federal fund grant award purposes, fixed assets are coded to the grant funds in the fixed assets system and meet the specifics of the grant. Fixed assets purchased with federal funds are labeled as purchased with federal funds. The fixed asset must be used for the original intent of the purchase according to grant allowances. Guidelines for Allowable Costs Guidelines for allowable costs under the grant can be found in OMB Circular A-87. In addition, processes in WFISD Policies and Procedures and WFISD Purchasing Procedures must be followed. The purchases must be aligned with the appropriate Campus/District Plan and must follow the OMB cost principles, applicable grant requirements in determining reasonableness, allowability, allocability costs. Purchases must be approved by the appropriate federal program or campus administrator as part of the process. Funds must be expended for reasonable and necessary costs in conducting grant activities. Professional and Contracted Services Cost of professional and consultant services rendered by persons who are members of a particular profession or posses a special skill, and who are not officers or employees of the district, are allowable, when reasonable in relation to the services rendered and when such services are necessary to meet the intent and purpose of the grant. Supplies and Materials Supplies are defined as tangible personal property other than equipment. Supplies are to be used for the originally authorized purposes as long as needed for that purpose. Supplies purchased with grant funds, as budgeted in the grant agreement, belong to the district and should remain on the campuses. Campuses maintain the responsibility for tracking these items. Capital Outlay If the district purchases capital outlay (furniture and/or equipment) to accomplish the goals of the project, the title will remain with the district until disposed of by the district. When capital outlay items are no longer needed for the originally authorized purposes, the items may be redistributed 11

12 through the WFISD following EDGAR guidelines. Property Management Requirements The district is required to manage property acquired in whole or in part with grant funds by establishing and using procedures that meet 34 CRF including the following requirements: Maintain property records within a fixed asset inventory system to include the description of the property, the serial number; the source of the property; the name of the entity that holds title; the acquisition date and cost; the percentage of federal/state participation in the cost of the property; the location and condition of the property; and any disposition data including date of sale of the property. TEA must be contacted for written instructions on the disposal of property. Travel Costs The need for travel tied to the goals of grant program must be determined prior to travel. In order for travel costs to be paid or reimbursed, the employee must complete a travel form and have supervisor approval. Allowable travel costs are paid and reimbursed according to the WFISD travel procedure guidelines. All itemized receipts for costs incurred must be attached to original travel form with check requisition prepared by the traveler and/or the campus/program secretary for reimbursement. Expenses are verified by federal program contact as part of approval process. After attending a conference/training/meeting, verification of completion of the event must be submitted. Travel costs will comply with OMB Circular A-87 and district travel policy. The federal program administrator shall ensure that the allowable costs expended to federal funds do not exceed allowed rates as indicated for site for lodging as per U.S General Services Administration. Verify allowable amount at Meal reimbursement will be paid at the state rate or the district rate (whichever is lower). Mileage will be reimbursed at the state rate or district rate (whichever is lower). Reference OMB Circular A-87 for airfare guidelines. Program Directors should use 0MB Circular A-87 a /?print=l to assist in determining allowable and unallowable cost for federal grants 12

13 Federal Program Guidelines Questions 1. How is the program, activity, or strategy reasonable and necessary to carry out the intent and purpose of the program? 2. How does the program, activity, or strategy address a need previously identified in the campus comprehensive needs assessment? 3. How is the program, activity, or strategy to be funded? It should be described in the campus or district improvement plan before the decision of whether to pay the expenditure from Title I, Part A funds? 4. How will the program, activity, or strategy be evaluated to measure a positive impact on student achievement? 5. If for a school-wide campus, how will the program, activity, or strategy upgrade the entire educational program on the campus? 6. How is the program, activity, or strategy supplemental to other non-federal programs? On a school-wide program, the amount of federal funding on a campus must be supplemental. On a targeted assistance program, the program, activity, or strategy must be supplemental. Are any rebuttals to the assumptions of supplanting clearly documentable for auditor? 13

14 Spending Guidelines 1. Expense must be supplemental 2. Expense must be reasonable and necessary 3. Expense cannot supplant state or local funds 4. Expense cannot meet any state or local (school board) requirement. 5. Expense must tie to district or Campus Needs Assessment. 6. Expense must tie to District or Campus Improvement Plan. 7. Expense cannot be for food unless directly related to parent involvement or snacks for tutoring (Pizza is not a snack). 8. Expense cannot to tied to any activity that is seen as entertainment-- Six Flags, soccer games 9. Expense cannot be for promotional items - red-ribbon week, character counts. 10. Expense cannot be rounded up or down. 11. Expense must be related to federal program from which reimbursement is being requested. Payroll (6100) documentation needs List of teachers, aids, staff and amounts paid out of federal funds. Job description for each person that is paid out of federal funds, signed and dated. Semi-annual certifications signed and dated For extra duty pay, employees must sign an Extra Duty Addendum and have supervisor's signature with a copy to federal program administrator. Supervisors will need to complete an Extra Duty Pay request with required documentation of teacher sign-in sheets. List of students tutored remains at the campus. Contracted Services (6200) documentation needs Copy of itemized invoice Contracted services invoiced - if itemized (line-by-line charge for hotel, gas, flight, meals) then receipts are required to support each charge. If invoice states - "travel expense" and amount, then no receipts are required. These criteria below should be documentable by the administrator for any contracted service: 1. Purpose of invoice: 2. How is expense supplemental? 3. Date of Service: 4. Number of teachers / students served: 5. Does the contracted service tie back to the District / Campus needs assessment? Yes/No

15 Materials and Supplies (6300) and Capital Outlay (6600) documentation needs Must have copy of itemized invoice or itemized receipt Ensure purchase is not a Capital Outlay (6600) purchase over $5,000 These criteria should be documented by the administrator: Purpose of invoice: How is expense supplemental? Who benefits from this expenditure? How does this expenditure benefit the student? Was this a planned expense? Yes/No Does the expenditure tie back to the District / Campus needs assessment? Yes/No This expenditure is not considered to be Capital Outlay? Yes/No Other Operating Costs and Travel (6400) documentation needs Federal Funds Travel Request completed to include actual mileage for travel; correct hotel rate, no in-state taxes (out of state alright). Original itemized receipts for meals and related travel costs (i.e. parking, taxi) are required. Hotel bill that is itemized is required--cannot use hotel confirmation. Use Google Maps or odometer for mileage reimbursement. Excessive mileage will not be reimbursed. Supplemental certifications receipt needs to show name, date of test, test name and amount paid.

16 Purchasing Requisition/Purchase Order Flow Chart Requisition generated in WFISD Authorization secured Requisition routed to Purchasing Completeness of requisition verified by Purchasing Department Purchase order generated Signed purchase order sent to Accounts Payable for distribution Requisition returned to site for additional information if necessary Items received in warehouse Items delivered to site Items verified as received Accounts Payable pays invoice after 3-way match (PO number, record of receipt at site, invoice)

17 Supplemental Addendum Federal & State Programs School Year Reports To: Department/School: Date Prepared: Current Employee Name: During the school year, the employee named above will conduct supplemental extra duty activities paid 100% out of NCLB and /or SCE program funds: Title I A Title I C Title IIA Title III Title IV SCE Supplemental extra duties Include: - Develop a SLP, in coordination with classroom teacher, to address areas of weakness as indentified from previous TAKS, benchmarks classroom exams, and other formative and summative measures. - Use multiple approaches, differentiation, and if appropriate accommodate modifications to increase student achievement - Report student performance bi- weekly to classroom teacher I agree to perform these activities as assigned and understand that these activities are supplemental and supported by the NCLB/SCE program specified. I agree to provide supporting documentation of all supplemental activities as required by Federal and State guidelines. I understand that extra duty pay is for supplemental activities that take place outside of my regular scheduled day. Signature of Employee: Date: The foregoing statements describe the extra duty responsibilities assigned to this staff member. APPROVED BY: Date: