Training Office of Federal Programs August 19, 2015
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
State Board of Education Goals 5-Year Strategic Plan for 2016-2020 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
Office of Federal Programs Vision, Mission, & Goals 4
Questions? federalprograms2@mde.k12.ms.us MDE Office of Federal Programs 5
Legal Structure of Federal Programs Statutes Regulations Good Guidance Guidance 7
Where to Find the Requirements Statutes: Elementary and Secondary Education Act of 1965 (ESEA) www.ed.gov Regulations: Code of Federal Regulations (Uniform Guidance) http://www.ecfr.gov/cgi-bin/textidx?sid=2f823fcab0ea941607bb8d19607e025a&mc=tru e&tpl=/ecfrbrowse/title02/2cfrv1_02.tpl Good Guidance: Non-regulatory Guidance http://www2.ed.gov/programs/21stcclc/legislation.html 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
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
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
Title 34 CFR Education Part 76 State-Administered Programs 13
Title 34 CFR Part 76 Allowable Costs 76.530 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 76.532 Real property and construction (unless authorized) 76.533 14
Title 34 CFR Part 76 When Obligations Are Made 76.707 16
Title 34 CFR Part 76 When May Funds Be Obligated 76.708 For discretionary grants obligations can be made when the grant agreements are signed. 17
Title 34 CFR Part 76 Records 76.730 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
Title 2 CFR Grants and Agreements Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 19
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
Factors Affecting Allowability of Costs 200.403 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 200.406) 8. Adequately documented Cost Principles 22
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
Necessary & Reasonable (cont.) Data Driven Decision Making Critical Needs Strategic Goal Current Performance (based on data) Measurable Objective 24
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
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
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
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
Subpart E Cost Principles Factors Affecting Allowability of Costs 200.403 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
Subpart E Factors Affecting Allowability of Costs 200.403(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 76.730) 30
Methods for Collection, Transmission and Storage of Information 200.335 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
Selected Items of Cost There are 55 specific items of cost! Starting at 200.420 35
Selected Items of Cost 1. Advertising/PR 200.421 2. 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 200.423 a) Not allowable 4. Collections of Improper Payments 200.428 a) The costs incurred by the non-federal entity to recover improper payments are allowable as either direct or indirect costs, as appropriate. 36
Selected Items of Cost 5. Conferences 200.432 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
Selected Items of Cost 6. Pre-award Costs 200.458 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
Selected Items of Cost 7. Travel Costs 200.474 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 31.205-46(a) 39
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
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
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 200.28 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
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
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
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
Time and Effort Documentation Documentation for Personnel Expenses 200.430(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 200.403(a) 46
Who must participate? 200.430(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
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
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
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MDE - Office of Federal Programs 51
Procurement Contract vs. Grant 200.330 Entities must clearly determine what is a subgrant and what is a contract. General Procurement Standards 200.318(a) All nonfederal entities must have documented procurement procedures which reflect applicable Federal, State, and local laws and regulations. 59
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
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
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
Procurement Mandatory Disclosures 200.113 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 200.338 (remedies for noncompliance) including suspension and debarment. 64
Procurement Vendor Selection Process 200.318(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
Procurement Methods of Procurement 200.320 NEW: Micro-purchase Small purchase procedures Competitive sealed bids Competitive proposals Noncompetitive proposals 69
Procurement Micro-Purchase 300.320(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
Procurement Small Purchase Procedures 300.320(b) Good or service that costs $150,000 or less (NEW: Simplified Acquisition Threshold was raised under 200.88) Organization may set lower threshold Must obtain price or rate quotes from an adequate number of qualified sources Relatively simply and informal 71
Procurement Noncompetitive Proposals 200.320(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
Procurement Contract Cost and Price 200.323 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
Procurement Suspension and Debarment 200.212 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
Procurement Suspension and Debarment 2 CFR 180.300 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
Property Management Equipment 200.33 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
Property Management Supplies 200.94 All tangible personal property other than equipment - NEW: Computing devices are supplies if less than $5,000 NEW: Computing devices 200.20 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
Property Management Internal Controls 200.302(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
Property Management Equipment 200.313(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
Property Management Use of Equipment 200.313(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 76.661 80
Property Management Equipment Procedures 200.313 (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
Property Management Disposition of Equipment 200.313(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
Financial Management Controls 1) Identification of Awards 200.302(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
Financial Management Controls 2) Financial Reporting 200.302(b)(2) Accurate, current, complete disclosure of financial results of each award in accordance with 200.327 and 200.328. NEW 200.327: Federal awarding agency can only collect OMB approved data elements, no less than annually, no more than quarterly NEW 200.328: 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
Financial Management Controls 2) Financial Reporting 200.302(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
Financial Management Controls 3) Accounting Records 200.302(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
Financial Management Controls 4) Internal Controls 200.302(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
Financial Management Controls 4) Internal Controls 200.303 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
Financial Management Controls 4) Internal Controls 200.303 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
Financial Management Controls Required Certification 200.415 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
Financial Management Controls 5) Budget Control 200.302(5) Comparison of expenditures with budget amounts for each award 91
Financial Management Controls 6) Written Cash Management Procedures 200.302(6) NEW: Written Procedures to implement the requirements of 200.305 92
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. 200.71 93
Financial Management Controls Payment 200.305 (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
Financial Management Controls Payment 200.305(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
Financial Management Controls 7) Written Allowability Procedures 200.302(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
Written procedures and policies are required Written Procedures: Cash Management - 200.302(b)(6) & 200.305 Allowability - 200.302(b)(7) Procurement - 200.19(c) Written Policies Written Policies and Procedures Conflicts of Interest - 200.318(c) Travel - 200.474(b) Written Method for Conducting Technical Evaluations of Proposals and Selecting Recipients - 200.320(d)(3) 99
Written Policies and Procedures The purpose of updating policies and procedures is to ensure the administration of compliant programs. 100
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
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
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
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
Written Policies and Procedures Resources OMB Uniform Administrative Guidance ESEA statute, regulations and guidance State and Local rules, regulations, policies and procedures 105
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
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. 200.112 107
Written Policies and Procedures Conflict of Interest Must maintain written standard of conduct, including conflict of interest policy. 200.318(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
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
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
Written Policies and Procedures Reminder Now that policies and procedures are completed: Train Review Revise Where are Policies and Procedures Located? 111
Record Keeping Statute of Limitations 200.333, 200.335 Retain records for 3 to 5 years after the grant closes. State Policy Entity Policy 112
Record Keeping Helpful Questions to Ask How long must records be maintained? How are records maintained? Hard copy, electronic 113
Monitoring Policies and procedures are evidence of compliance under all program monitoring tools 114
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
Monitoring Monitoring of Subrecipients Onsite Reviews Remote Monitorings Desk Reviews Self-Assessments Follow-Up 116
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
Audit Requirements 200.501 NEW: Threshold increased to $750,000 The federal agency, OIG, or GAO may arrange for audits in addition to single audit 118 118
Audit Findings 200.516 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 119 119
Single Audits Auditors ask about policies and procedures Some tests specifically require written policies and procedures 120
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
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
Contact Information Marcus E. Cheeks Executive Director Office of Federal Programs mcheeks@mde.k12.ms.us Melanie Diggs Director of Finance mdiggs@mde.k12.ms.us Barabara Greene Homeless Education Coordinator bgreene@mde.k12.ms.us Karen Austin Director of Competitive Grants kaustin@mde.k12.ms.us Kimberly Williams 21 st CCLC Coordinator kwilliams@mde.k12.ms.us THANK YOU FOR ATTENDING!! 123