MODULE DESCRIPTIONS A Brief Introduction to SMART Training (20 minutes) This module introduces the SMART theme for the series of training modules on developing and implementing sound financial management systems and practices when operating Department of Labor funded awards. SMART stands for Strategies for Monitoring, Accountability, Risk mitigation and Transparency. The training is based on the new provisions in the OMB Uniform Guidance, the DOL exceptions to the Uniform Guidance, and the Workforce Innovation and Opportunity Act (WIOA). This module identifies the seven basic content areas of the training: Uniform Guidance, Controls and Compliance, Allocating Costs, Procurement, Financial Information and Reporting, Oversight, and Discretionary Grantees. It identifies the modules that comprise each content area and the SMART theme applicable to each module. It also provides the agenda for each day of training. Accrued Expenditures and Obligations (75 minutes) This module covers the definitions of accrued expenditures and obligations and provides examples to illustrate how they are to be properly classified, tracked, and reported. It distinguishes an obligation from an encumbrance and an accrual from a cash disbursement. It differentiates a cashbased accounting system from an accrual accounting system, and describes the records that are needed and the process to be used to identify and report accruals in a cash-based system. It provides examples of common mistakes in tracking and reporting obligations and accruals. This module complements the financial reporting module by focusing on accruals and obligations, and the potential impact of inaccurate reporting on recipients. Audits: Reports and Resolution (75 minutes) This module identifies the new audit requirements codified in the Uniform Guidance and the DOL exceptions. The module explains the Single Audit s purpose, process and timing requirements, and the reports and schedules contained in the audit report. It identifies the auditee s responsibilities for complying with these requirements. The audit resolution responsibilities of recipients and passthrough entities, including the issuance of a management decision and pursuit of debt collection, will be addressed. It also covers the audit resolution process between DOL and its direct grant recipients. The presentation explains the appeals and debt collection process, along with the cooperative audit resolution process addressed in DOL s exceptions to the Uniform Guidance. Budget Controls for Program Effectiveness (60 minutes) This module identifies the basic principles of budget controls, including the changes contained in the Uniform Guidance and DOL s exceptions to that guidance. It explains the purposes for and preparation of a budget linked to the SF-424A. The module covers the use of budget controls to manage cost limitations, obligations, and other commitments. It identifies methods for analyzing budget trends and tracking key financial results, and links financial results with program performance in a comprehensive approach to analyzing overall program effectiveness.
Capital Assets, Equipment, Intangible Property, and Supplies (75 minutes) This module reviews definitions of capital assets under the Uniform Guidance and the basic principles governing their acquisition, use, allowable costs, user fees, and disposition. It identifies changes in the Uniform Guidance relating to depreciation and elimination of the use allowance provision. It describes the requirements for a property management system for equipment and other capital assets including prior approval, title, use, inventory, and disposition. The module identifies the Uniform Guidance requirements regarding intangible property, including the different forms of intellectual property. It explains the Federal government s right to use and authorize others to use intellectual property developed using Federal funds, including licensing through creative commons. Supplies, while not a capital asset, are covered due to the differing requirements between equipment and supplies. The presentation distinguishes between the requirements for state recipients and other direct recipients. Cash Management (60 minutes) This module identifies the standards for managing cash and other assets as contained in the Uniform Guidance and the DOL exceptions to that guidance. It focuses on the general principles of proper cash management, including internal controls, written procedures, cash forecasting, improper payments, and interest income. It discusses key changes in processing payments between the Federal awarding agency and direct grant recipients, and the payment process between direct grant recipients and subrecipients including advances, liquidation of advances, and remedies for misuse. The module reviews the handling of cash-like items of tangible value such as debit/credit cards, tokens and passes, and ATM pins, and reviews mistakes commonly found in cash management procedures and practices. Complaints, Grievances, and Incident Reports (75 minutes) This module presents the varying requirements from program statutes and regulations applicable to grant recipients and subrecipients for processing and resolving program-related complaints and grievances, complaints alleging discrimination, and Incident Reports involving allegations of fraud, waste, and abuse. The presentation distinguishes between the three types of allegations and the differences in the processes for addressing them. It describes the WIA/WIOA complaint resolution procedures that recipients must maintain, including timelines and appeal rights, and the role of the Department of Labor in each process. The presentation defines the activities that constitute fraud, waste, and abuse; identifies the laws and regulations that govern wrongful conduct; and describes the role and responsibilities of recipients, ETA, and the Office of the Inspector General in the process of reporting and resolving incidents of wrongful or criminal conduct. Cost Allocation 101 (75 minutes) This module defines the basic terms and requirements from the Uniform Guidance regarding the allocation of costs to Federal grants. It distinguishes between direct and indirect costs, program and administrative costs, and intermediate and final cost objectives. It reviews the cost allocation principles of consistent treatment and proportional benefit. It identifies appropriate and commonly used bases for allocating direct costs, including input and output bases, and provides examples of inappropriate bases for allocating costs. It also covers the bases used for allocating indirect costs. It identifies the new documentation standards in the Uniform Guidance for allocating personnel costs. Understanding the basic concepts covered in this module is a prerequisite for taking the companion module Cost Allocation Methods. Page - 2 -
Cost Allocation Methods (90 minutes) This module covers the requirements of the Uniform Guidance relating to the methods used for allocating direct and indirect costs. It identifies the components of a Cost Allocation Plan (CAP), Indirect Cost Rate (ICR) proposal, de minimis indirect cost rate, and Memorandum of Understanding (MOU). It covers their required contents, and explains the distinctions among these methods, when each method is used, and how each method is applied. It reviews the contents of a CAP and provides excerpts from sample CAPs. It identifies when an ICR is needed, the documentation requirements and forms needed for an ICR proposal, how to obtain an approved ICR, and the different types of indirect cost rates. It describes a de minimis indirect cost rate and how to use it. It addresses the role of the pass-through entity in reviewing and, when applicable, approving the CAPs and ICRs of its subrecipients. The module also reviews common mistakes that are made by recipients and pass-through entities on indirect costs, and how to rectify them. Given the advanced nature of this content, the companion module Cost Allocation 101 is a prerequisite before taking this training, Discretionary Grants Overview (75 minutes) This module provides an overview of the basic requirements applicable to discretionary grants awarded by DOL to direct recipients. It identifies the different sections of the grant agreement, the purpose of each section, and the grant terms and conditions. It reviews the grant and subaward actions that require prior approval and grant modifications. The module describes the steps for preparing and submitting a grant modification, and identifies the different types of modifications. It explains the revisions to the threshold for budget changes that trigger the need for a modification subject to DOL approval. The module briefly covers the responsibilities of the pass-through entity for subgrant modifications and prior approvals. The final section covers the closeout requirements applicable to direct recipients and their responsibilities for closeout of subawards. Facilities and Leases (90 minutes) This module reviews the Uniform Guidance and DOL requirements for facilities and leases. The presentation covers the definition of facilities and leases, capital assets, capital expenditures, and allowable and unallowable costs for non-federal entity property and leases. It describes the rules governing depreciation, the elimination of the use allowance provision, the allowability of idle capacity and facilities costs, prior approval for capital assets and capital improvements, and interest expense. The module distinguishes between capital and operating leases, and identifies the limitations on cost recovery for capital leases and sale and lease-back transactions. It describes the limitations on less-than-arms-length agreements and the unallowability of home office expenses. Financial Reporting for Recipients and Subrecipients (75 minutes) This presentation covers the Employment and Training Administration's (ETA) financial reporting requirements and how to correctly complete the quarterly and final ETA-9130 reports. It provides a line-by-line review of the data elements reported on the 9130, including the Federal share of accrued expenditures and unliquidated obligations, the recipient s share including match and stand-in costs, program income earned and expended, and additional data requirements and remarks. It reviews factors for recipients to consider when establishing reporting requirements for their subrecipients, including timing, data elements, and accruals. The module focuses on areas that are often misunderstood or reported incorrectly. Internal Controls: Providing an Effective Control Environment (90 minutes) The Uniform Guidance has expanded the requirements for, and placed a much greater emphasis on, administrative and internal controls as sound management practices and to mitigate the risk of fraud, waste, or abuse. This module provides an in-depth review of those requirements, and Page - 3 -
identifies the components and activities that create an effective internal control framework. It identifies the policies and procedures that are required to be in place, and recommends others that contribute to an effective internal control system. It identifies key financial and program areas that need strong internal controls, and the potential consequences and increased exposure to risk when those controls are not in place. The presentation describes the internal control framework articulated by the Committee of Sponsoring Organizations of the Treadway Commission (COSO), and the Standards for Internal Control in the Federal Government also known as the "Green Book." It provides examples of common monitoring and audit findings due to weaknesses and limitations in internal controls. Match and Leveraged Resources (60 minutes) This module on Match and Leveraged Resources defines and distinguishes between the terms "match" and "leveraged resources.. It describes the Uniform Guidance requirements and changes affecting match, which is also commonly referred to as cost sharing or recipient share. The module describes the proper valuation and documentation of various types of match expenditures and leveraged resources. It identifies which categories of match and leveraged resources are reported on the recipient share section of the ETA-9130 and the importance of such data when calculating stand-in costs. It discusses common mistakes made on match and their consequences. Personnel Compensation, Labor Distribution, and Payroll Reports (75 minutes) This module reviews the Uniform Guidance standards for allowable personal services and fringe benefit costs, and the methods for distributing payroll and fringe benefit expenses to benefitting cost objectives. It discusses the different types of fringe benefits including leave, pension, and severance payments, and the conditions for use of funded reserves. The module highlights the Uniform Guidance changes on documenting payroll distribution, and the importance of internal controls and written policies and procedures to support that process. The module concludes with coverage of the salary cap limitation applicable to ETA grants. Procurement under the New Requirements (90 minutes) This module covers the updated procurement standards in the Uniform Guidance. It defines key procurement terms, and distinguishes between a subrecipient and a contractor, and between a subaward and a procurement action. It describes the requirements applicable to pass-through entities for selecting subrecipients and being accountability for their performance. The module reviews the common agreement types and the basic procurement standards, including those relating to cost/price analysis, profit, and documentation. The module identifies the 5 methods of procurement, including the new provision on micro purchases. It identifies the different contract types, the required contract clauses, and the new requirement for mandatory disclosure of violations. The module ends on the importance of incorporating performance requirements into subawards and contracts that are measurable with respect to the quality, quantity, and timeliness of performance. Program Income (45 minutes) This module presents the definition of program income found in the Uniform Guidance and the WIA/WIOA provisions that apply to program income. It identifies what is and is not included as program income, such as user fees and interest income. The module describes the requirements for documenting, tracking, and reporting program income. It identifies the methods of accounting for program income, and discusses its allowable uses. It describes how program income impacts the audit threshold, and the responsibility for program income at the subrecipient level. Page - 4 -
Readiness Assessment for New Grantees and New Staff (75 minutes) This module serves as a basic primer for new grantees and for new staff of existing grantees. It provides a readiness checklist to use in self-assessing the grantee s readiness to perform essential activities in each phase of the grant life cycle. Because a common cause of grant failure is delayed start-up, the module emphasizes the start-up activities that should be undertaken during the preaward and initial post-award phases of the grant. It includes an assessment of subrecipients readiness to perform and the recipient s readiness to manage those subawards. It identifies the SMART techniques for managing the grant, which include Strategies for Monitoring, Accountability, Risk management, and Transparency. The module ends with readiness steps for managing the closeout and audit phase of the award and subawards. Subrecipient Management and Oversight (90 minutes) This module provides an in-depth review of the requirements in the Uniform Guidance and WIOA statute governing subrecipient management and oversight by the pass-through entity from preaward through closeout. It reviews the new requirements and methods for conducting risk assessment reviews and selecting subrecipients. It identifies the policies, tools, and resources that need to be in place prior to award to implement a subrecipient management system. The module describes the methods used for conducting oversight, including desk reviews, report analyses, and on-site monitoring. It provides guidance on the structure and content of a monitoring report, and differentiates compliance findings and questioned costs from other areas of concern. The module describes the actions to be taken following a monitoring review or audit, and identifies available remedies for resolving findings. It concludes with the requirements related to closing out subawards, the typical issues that accompany that process, and the consequences of failing to effectively conduct monitoring and oversight. Uniform Guidance # 1: Introduction, Application, and Pre-Award Requirements (45 minutes) This module provides an overview of the Uniform Guidance published by the Office of Management and Budget (OMB) on December 26, 2013 and December 19, 2014 at 2 CFR 200, along with DOL s exceptions also published on December 19, 2014 at 2 CFR Part 2900. Technical corrections to the Uniform Guidance were subsequently published on September 10, 2015.The Uniform Guidance consolidates and updates guidance and requirements applicable to Federal awards from earlier documents including OMB Circulars A-21, A-50, A-87, A-102, A-110, A-122, and A-133. The module reviews the purpose for creating the guidance, its structure and applicability, DOL s exceptions, key pre-award provisions, other key changes, and implementation options and effective dates. Additional material from the Uniform Guidance is covered in two companion modules, OMB Uniform Guidance: Administrative Requirements and OMB Uniform Guidance: Cost Principles. Uniform Guidance # 2: Administrative Requirements (60 minutes) This module provides an overview of the new Uniform Guidance Subparts C and D relating to the new requirements for financial and program management, responsibilities of pass-through entities, enhanced monitoring requirements including performance management, and mandatory contractual provisions. Subpart C Pre-Award requirements covers how the Uniform Guidance changes Federal agencies funding opportunity announcements, grant reviews, and award of grants. The discussion of Subpart D Post Federal Award requirements provides an overview of changes that impact grant operations and policies. Additional material from the Uniform Guidance is covered in two companion modules, OMB Uniform Guidance: Introduction, Application and Pre- Award Requirements, and OMB Uniform Guidance: Cost Principles. Page - 5 -
Uniform Guidance # 3: Cost Principles (60 minutes) The Uniform Guidance consolidates three sets of cost principles from prior OMB Circulars into one uniform set of cost principles. This module reviews the cost principles applicable to recipients and subrecipients, the exceptions to the cost principles and selected items of cost, significant changes and their impact on recipients and subrecipients, and the applicability of the cost principles in determining allowable costs under Federal awards. The module covers the general principles governing the allocability, allowability, and reasonableness of costs, new definitions and significant changes to selected items of cost, and DOL s exceptions to the Uniform Guidance published at 2 CFR Part 2900. Additional material from the Uniform Guidance is covered in two companion modules, OMB Uniform Guidance: Introduction, Application and Pre-Award Requirements, and OMB Uniform Guidance: Administrative Requirements. Page - 6 -