Financial Compliance Issues More Than You Ever Wanted to Know About Administrative Costs Leveraged Resources Accrued Expenditures & Unliquidated Obligations MoHealthWINs TAACCCT Grant Prepared by the OTC Finance Office October 26, 2012 www.mohealthwins.org Grant Detail and Contact Info Total Award: $19,982,296.00 CFDA #17.282 Period of Performance: 10/1/11 to 9/30/14 Fiscal Lead: Ozarks Technical Community College Finance Office Vice Chancellor of Finance – Marla Moody Senior Staff Accountant – Chasity Daniels Grants Accountant – Betty Denson: 417-447-4831, [email protected] Program Director – Dawn Busick housed at MCCA Office: 573-634-8787 Information Resources on MCCA Website: www.mccatoday.org New Reimbursement Report • MHW Reimbursement Report updated: • Lines for Accrued Expenditures and Unliquidated Obligations • Funds expended to date (actual requests) and committed to date (includes accrued expenditures and unliquidated obligations) • Additional field to show percentage of administrative funds spent to date www.mohealthwins.org Administrative Costs • 8% administrative cap applied across total budget • Consortium members with ICR may want to claim all administrative costs as indirect • Consortium members without indirect costs may claim administrative costs in direct line items • Must report total administrative costs claimed on each reimbursement report Administrative Costs • Not related to direct provision of workforce investment services, including services to participants and employers • Can be personnel or non-personnel • Can be direct or indirect Administrative Costs - Examples • Accounting, budgeting, auditing • General legal services functions • Information system development (unless related to program delivery) • Support personnel, travel costs, other goods and services related to administrative functions Program Costs • Directly related to provision of workforce investment services, including services to participants and employers • Can be personnel or non-personnel • Can be direct or indirect Program Costs - Examples • Vendor contracts (unless solely for administrative functions) • Case management • Information system development for tracking participant and performance information • Support personnel, travel costs and other goods and services related to program functions Administrative vs. Program Costs • • • • Not to be confused with direct or indirect costs Reasonable and based on benefit received Some costs may need to be prorated Allocate based on actual costs involved or duties performed - not job titles or general categories be prepared to defend • Program guidance found at 20 CFR 667.220 The MHW Grant & Leveraged Resources • MHW Grant does not require match – requires leveraged resources reporting • Leveraged resources not defined in federal regulations or related administrative requirements • 29 CFR 95.23 provides limited guidance • Leveraged resources could be described as: •“all resources used by the grantee to support grant activity and outcomes, whether or not those resources meet the standards required for match”* •DOL Training Handout: Background for Match and Leveraged Resources What are Leveraged Resources? • • • • • May be paid for with federal or non-federal funds. Includes both cash and in-kind contributions. Must be allowable under the OMB cost principles. No administrative cost limitation on LR. Consortium committed to report over $11 million in leveraged resources over the life of the grant. • Federal Project Officer will decide what actions to take if consortium not able to meet commitment. Reporting Leveraged Resources • Reported each quarter - 9130 Report (OTC Finance Office) and Program Narrative (Program Director) • Colleges report at least quarterly • Totals listed on Reimbursement Report Form • Summary sheet attached - for reporting and verification • Keep backup documentation for on-site monitoring Leveraged Resources - Examples • Unclaimed indirect costs • Direct costs that could have been charged to the grant, but were not: donated space, staff salaries, supplies, outreach, web costs, travel costs in support of the grant, etc. • Equipment used for grant – purchased with institutional funds, other federal funds, or donated • Curriculum costs not charged to grant • Documented third party donations of space, personnel, or other resources Leveraged Resources Valuation • Guidance available at 29 CFR part 95.23 • Not used for contributions on other federal projects • Necessary, reasonable, verifiable • Allocate to show amount of benefit to grant • Document and be prepared to defend valuation Accruals and Obligations • • • • • • DOL requires accrual reporting Better reflection of true program costs Colleges report totals on Reimbursement Report Retain documentation for on-site monitoring OTC Finance Office reports on Form 9130 Failure to report on accrual basis could lead to loss of funds Accrued Expenditure or Unliquidated Obligation? • An obligation is a commitment of funds • All accrued expenditures are obligations, but not all obligations are accrued expenditures Questions to Ask: • Has performance been completed? • What is our obligation to pay if the program ends? Details of the Obligation • Unpaid delivered goods - accrued expenditure • Contracted goods - unpaid, but not yet delivered – unliquidated obligation • Payroll - accrual if work performed, not yet paid • Travel expenses or utilities - may be accrual • Contracts - may be accrual or obligation • Contract - work performed, not paid - accrual • Contract with legal commitment - may be obligation • Review contract terms Questions? This PowerPoint and Other Informational Resources are Available on the MCCA Website at www.mccatoday.org This workforce solution was funded by a grant awarded by the U.S. Department of Labor's Employment and Training Administration. The solution was created by the grantee and does not necessarily reflect the official position of the U.S. Department of Labor. 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