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Office of Grants Management, Grants Management

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Office of Grants Management
Grants Management Fundamentals
Office of the National Coordinator for Health Information
Technology (ONC)
Grants 101
Office of Grants Management – Organization and Functions
Office of Grants Management (OGM)
Lisa Lewis
Chief Grants Management Officer
Systems and Data
Management
Bianca Costa
Policy
Wendy Kilgore
Collect, report, and
manage grants
management data
Develop and manage
ONC grants
management policies
Analyze grant data to
identify trends in
implementation of funds
Facilitate objective
reviews
ONC administrator for
grants management
systems
GMO: Workforce
Liaison with other HHS
Grants Management
Offices
Training and
Technical Assistance
Jen Cramer
Develop and deliver grants
management training for
external stakeholders and
ONC staff
Provide customized, direct
technical assistance
services
Coordinate overall grants
management training and
technical assistance efforts
Grant Operations
Arlene Ramsey
Provide procedural and
technical business support
to award recipients and
ONC program offices
Conduct on-site monitoring
visits and desk reviews
Develop grants
management standard
operating procedures
GMO: REC and State HIE
GMO: Beacon and SHARP
2
OGM - Responsible for the Portfolio of ONC Cooperative Agreements
State
Health
Information
Exchange
Regional
Extension
Centers
Workforce:
Competency
Examination
Workforce:
Curriculum
Development
Centers
Workforce:
University
Based
Training
Beacon
SHARP
Workforce:
Community
College
3
ONC’s Program Offices and Grants Office Partnership
Answer grantee
questions on complex
technical grants
business
management matters
Perform budget
analyses & business
mgmt capability
assessments &
perform budget
negotiations
Take action to
withhold payment,
suspend or terminate
award or to lift
withholding or
suspension
Provide input on
satisfaction of
business mgmt
special conditions;
lift restrictions
via NGA
AAGAM Chapter 1.04.104
Establish &
maintain
official award,
program information,
& institutional files
Conduct financial
monitoring site visits
& desk reviews
& provide
post-award TA
Document site visits
& desk reviews
& coordinate results
with program office
Grants
Management
Team
Identify potential or
existing problems
(business mgmt
& program)
& alert PO
Review financial
status reports &
evaluate financial
performance against
budget, program
plan, etc.
Ensure effective
use of funds
by monitoring
commitments &
projecting future
funding requirements
4
ONC’s Program Offices and Grants Office Partnership
Answer grantee
questions on
programmatic
grants matters
Establish and
maintain PO
files
post-award TA
Assist in ensuring
budget submissions
& expenditures
comply with statute,
regulation, & policy
Provide program
input on proposed
withholding of
payment/suspension/
termination of award
& input before
lifting
Provide input on
whether programmatic
special conditions
are satisfied or
whether other action
should be taken
AAGAM Chapter 1.04.104
Conduct site visits
to gauge progress
and compliance
or to provide
Project
Officers
Identify potential or
existing problems
(program & business
management) & alert
program officials
& GMO of findings
Document
reviews & grantee
discussions &
provide
documentation
to GMO
for official file
Review program
progress reports &
evaluate program
performance,
progress
& changes in scope
or objective
Ensure adequate
progress toward
meeting
milestones
5
Partnership – The Key to Success
•
Maximize program success and integrity
•
Foster program credibility
•
Ensure rigor in stewardship
•
Minimize audit findings
•
Reduce disallowed costs
•
Strengthen internal controls to prevent fraud, waste, and abuse
•
Manage inherent risk
•
Encourage professional development
•
Foster synergy/collaboration
6
Grants Management Lifecycle
ESTABLISH
APPLY
REVIEW
AWARD
MANAGE
CLOSEOUT
Authorizing Statute
Establish Commitments
Objective Review
Create Notice of Grant
Award
Appropriation
Assist Applicants
Assess
Fiscal Integrity
Obligate Funds
OMB Apportionment
Develop Funding Memo
Set Up Congressional
Notification in System
Review /Recommend
Post-Award Actions
Conduct
Appropriations Analysis
Review Application
Release Funds
Review Audits
Evaluate Final
Performance Reports
Review
Closeout Package
Conduct Final
Financial Reconciliation
Establish Disposition
of Funds
Perform
Budget Review
Notify Grantee of Award
Conduct
Financial Monitoring
Notify Grantee of
Closeout
Review
Financial Reports
Retain Records
Allocate Funds
Assess
Funds Availability
Develop
Funding Opportunity
Announcement (FOA)
Conduct Programmatic
Monitoring
Review
Performance Reports
Review and Approve
Post-Award Actions
Release FOA
Program and Grants Management Training and Technical Assistance
Review FOA
Submit Application
Revise Application
Review Award
Package
Drawdown Funds
Complete
Drawdown of Funds
Accept Award
Submit
Performance Reports
Generate Final
Performance Reports
Submit
Financial Reports
Generate Final
Financial Reports
Submit
Post-Award Requests
Submit
Closeout Package
Ensure Audit is
Complete
Retain Records
Legend:
PHASE
Program Office
Grantee
Other Federal/HHS
Entities
Office of Grants
Management
ONC Budget
PO/GMO Joint
Grants Management Lifecycle – Establish
ESTABLISH
APPLY
REVIEW
AWARD
Authorizing Statute
Appropriation
OMB Apportionment
Conduct
Appropriations Analysis
Allocate Funds
Develop
Funding Opportunity
Announcement (FOA)
Release FOA
Review FOA
Legend:
PHASE
Program Office
Grantee
Other Federal/HHS
Entities
Office of Grants
Management
ONC Budget
PO/GMO Joint
MANAGE
CLOSEOUT
Appropriations and Funding Process
Phase 1: Budget
Formulation
Phase 2: Budget
Presentation and the
Congressional Process
Phase 3: Budget Execution
9
Budget Formulation
• HHS Budgets for Grant Programs
• HHS Budget Request
• HHS Total Budget Request
• OMB/President’s Budget to Congress
10
Appropriations
• Budget Presentation to Congress
• Congressional Budget Resolution
• Appropriation
11
Budget Execution
• Office of Management and Budget (OMB) Apportionment
– Budget Authority to distribute funds
• HHS Allotment
• ONC Allotment
• Allocations to Each Grant Program
12
Types of Appropriations
• Annual: Must be obligated within the fiscal year
– ONC funds in HHS appropriations
• Multiple Year: Available for obligation for a definite period
in excess of one fiscal year
– HHS has multi-year funds
• No-year: Available for obligation without financial year
limitations
– ARRA funding no longer no year (Bennett Amendment)
13
Continuing Resolution
• Applies if new Fiscal Year and annual appropriation is not
passed
• Continues existing programs until annual appropriation
passes
• Can impact internal operations and activities
14
Funding Opportunity Announcement (FOA)
•
•
•
•
•
•
•
•
•
•
•
All information integral to the competition must be explicitly addressed
General description
Authorizing statute/Award information
Eligibility requirements
Cost share/matching requirements
Application requirements
– Forms
– Budget and budget narrative
– Program narrative
– Other submission requirements
Due dates
Review Criteria
Announcement dates
Reporting requirements
Other information
15
Grants Management Lifecycle – Apply
ESTABLISH
APPLY
REVIEW
AWARD
Establish Commitments
Assist Applicants
Submit Application
Legend:
PHASE
Program Office
Grantee
Other Federal/HHS
Entities
Office of Grants
Management
ONC Budget
PO/GMO Joint
MANAGE
CLOSEOUT
Applying for Funding
• HHS policy requires all competitive funding opportunities be
announced at www.Grants.gov
• OMB mandated initiative
• No paper
• No other submission method accepted
17
Critical Application Information
• Applications must be complete and timely
– All forms and attachments must be submitted
– Incomplete applications will not be sent forward for review
– Late applications will not be sent forward for review
• All applicants must have a Dun and Bradstreet (D&B) Data Universal
Numbering System (DUNS) number
• All applicants must register in the Central Contractor Registry (CCR)
– Applicants should allow a minimum of five days to complete the CCR
registration. CCR online registration (http://www.ccr.gov)
– CCR registrations must be current and renewed every 12 months
• Applicants that do not have a DUNS number or have not registered with
the CCR will not move forward for review.
18
Grants Management Lifecycle – Review
ESTABLISH
APPLY
REVIEW
AWARD
Objective Review
Assess
Fiscal Integrity
Develop Funding Memo
Review Application
Perform
Budget Review
Assess
Funds Availability
Revise Application
Legend:
PHASE
Program Office
Grantee
Other Federal/HHS
Entities
Office of Grants
Management
ONC Budget
PO/GMO Joint
MANAGE
CLOSEOUT
Objective Review Process
• Completeness Review
• Grants staff
• All required forms
• All required attachments
• On-time submission
• Responsiveness Review
• Program staff
• All required program elements
If YES to both в†’ Panel review
20
Objective Review Process - continued
• Panels of unbiased subject matter experts
• Endure no conflicts of interest and consistent examination
of applications
• Intended to provide recommendations and advice on
funding proposals
• Scores and ranking developed
• Final decisions determined by the program office
• Funding decision memo sent to Grants Management Office
21
Program Office пѓ Financial Review
• Program Office Staff
– Review application budget to determine if costs are in line
with program goals and objectives
– Review to ensure costs are for intended program
purposes
– Signed transmittal slip indicating approval of budget
• Grants Management Staff
– Conduct detailed financial reviews
– Based on Program Office recommendations
22
Financial Review
•
A-133 Compliance
–
http://harvester.census.gov/sac/
•
No Conflict of Interest
•
Applicant’s Standing (Good, Debarred, Suspended)
–
https://www.epls.gov/
•
Dun and Bradstreet
•
Budget Review
23
Budget Review and Approval Process
• Each application must include a detailed budget (SF424A) and
budget narrative for the project.
• The budget must be complete, reasonable, allowable,
allocable and cost effective in relation to the proposed
project.
• The budget narrative must provide a detailed justification for
each cost included in the budget.
• All project related costs must be included in the appropriate
cost categories.
24
Budget Review – Cost Principles
•
Uniform cost principles when
implementing Federal grant programs
– 45 CFR 74.27 and by reference 2 CFR
Part 220 (A-21) – Educational
Institutions
– 2 CFR Part 225 (A-87) – State Local
and Indian Tribal Governments
– 2 CFR Part 230 (A-122) – Non-Profit
Organizations
– 48 CFR 31.2 (Federal Acquisition
Regulation (FAR)) – For Profit
Organizations
25
Budget Review – Object Categories and Key Requirements
Example of a 424a
26
Budget Review – Personnel Budget Category
Personnel
• Must pay personnel at a rate paid with non-Federal dollars or comparable
to like organizations/positions.
• Is the basis for determining each employee’s compensation described
(annual salary and % time devoted)?
• Is each position identified by title/responsibility?
• Are time commitments and the amount of compensation stated and
reasonable?
• Are salary increases anticipated during the grant period and are they
justified (COLA, etc)
• Are any personnel costs unallowable?
• Dual Compensation?
• Federal Employee?
27
Budget Review – Fringe Budget Category
Fringe Benefits – typically include health care, retirement
plans, etc. Must consider:
• Is the amount specified as a separate line item?
• Is each type of benefit indicated separately or does the
organization have an approved fringe benefit rate?
• Are fringe increases contemplated during the grant period?
• Are costs included in fringe benefits that are unallowable?
28
Budget Review – Travel Budget Category
Travel
• Is the basis for computation provided?
• Is the travel necessary for the purpose of the program?
• Are travel costs separately identifiable and reasonable (location,
transportation, hotel, meals, mileage)?
• Does the organization have a written travel policy? Is this travel
policy being followed?
• If no written policy—must follow Federal guidelines
29
Budget Review – Equipment Budget Category
Equipment
• Capitalization threshold
• Federal $5K and useful life more than 1 year
• Are equipment items specified by unit and cost?
• Is the request reasonable and allowable under the project?
• Does the organization have a procurement policy in place?
• Is a lease vs. purchase study necessary (vehicles, large items of
equipment)?
• Are purchases distinguishable from rentals?
30
Budget Review – Supplies Budget Category
Supplies
• Are supplies listed separately?
• Office
• Training
• Research
• Other types of supplies
• How was cost determined?
• Is the basis for the cost reasonable?
• Monthly estimates are sufficient
• Consistently treated
31
Budget Review – Contractual Budget Category
Contractual
• Is the type of each service to be rendered described?
• For Consultants/Individuals
• Is an hourly, daily or weekly base rate given?
• Are rates allowable, justified, reasonable and comparable to
market?
• Is procurement method described?
• Are appropriate procurement procedures being followed?
32
Budget Review and Approval – Subrecipient Relationships
Subrecipient Relationships (Subgrants/Subawards or Contracts)
•
Is a substantial portion of the programmatic work being performed by another
entity - a grant or contract?
• Subawards are documented in the “other” category
• Subrecipient relationships in the form of a contract will be put in
“contractual”
•
If so, the following questions must be answered in regard to that specific grant or
contract:
•
•
•
•
•
•
Name of the subrecipient
Method of selection
Period of performance
Scope of Work
Method of Accountability
Itemized budget and justification (separate SF 424As for the subrecipient)
33
Budget Review – Other Budget Category
Other
• Are items listed by major type (space rental, printing, phone,
maintenance, etc.)?
• Are all costs justified, reasonable and allowable?
• List each subaward and amount of award
• Ensure adequate subrecipient information is provided
(see 6 elements)
• Include separate SF 424 A for each sub
34
Budget Review – Indirect Costs
Indirect Costs
• Costs incurred for a common/joint objective and cannot be
readily identified with a specific activity
• typically include utilities, rent, administrative staff
• An organization may not charge specific costs both directly
and indirectly
• Costs may not be assigned as an indirect cost to an award if any other
cost incurred for the same purpose has been allocated to an award as
a direct cost
35
Budget Review – Indirect Costs
Indirect Costs (continued)
• Must have a current Federally
approved indirect cost rate
agreement
• Is the rate applied to the
correct distribution base?
36
Recently in the News
• TierOne loses $19 million federal grant over CEO's fraud allegations
• September 6, 2010
• University of Florida professor and wife indicted for fraudulent grant
proposals
• October 30, 2009
• Cornell University Will Pay $2.6M in Fraud Case
• March 24, 2009
• Former Professor Pleads Guilty to Fraud on NSF Grant
• May 3, 2007
37
Categories of Misuse of Federal Funds
Indicators of Fraud, Waste and Misuse of grant funds can be due to a variety of
causes. We must manage with due diligence to ensure that DHHS funds are not
misused.
Mistakes
Recipient includes costs in budget
which are unallowable under specific
ONC awards. Examples include:
Food, Scholarships, Contingencies
Gross Negligence
Direct recipient failed to
implement proper
internal controls and
adequately monitor
subrecipient activity and
expenditures resulting in
theft of Federal funds.
Criminal
Fraud
Recipients used Federal
funds to pay for a wedding
reception, building
construction, and personal
credit card bills. Resulted in
loss of $500K and jail time.
38
Who Commits Grant Fraud?
• When business entities, individuals, communities, and other
organizations receive federal grant dollars, they are entrusted with their
appropriate expenditure.
•
Grant fraud is most often committed by:
• Grant recipients, company officers, business partners, board
members, and managers
• Bookkeepers, financial staff, and employees
• Contractors and subcontractors engaged with the recipient
• Recipient consultants
39
Common Grant Fraud Scenarios
• Grant fraud occurs in many ways, but some of the most common fraud
scenarios include:
•
Charging personal expenses as business expenses against the grant
•
Charging for costs which have not been incurred
•
Charging for inflated labor costs or hours
•
Submitting invoices for personal expenses
•
False information on grant applications, progress reports, etc.
•
Creating fictitious records
40
Fraud Indicators
• Fraud is often difficult to detect and is a conclusion that is determined only
after a careful examination of all the facts and circumstances.
• Indicators of fraud include:
• One person in control
• Lack of internal controls
• Altered records
• No separation of duties
• No prior audit
• Lack of responsiveness
• Allegations of fraudulent conduct
Grants Management Lifecycle –Award
ESTABLISH
APPLY
REVIEW
AWARD
Create Notice of Grant
Award
Obligate Funds
Ensure Congressional
Notification
Release Funds
Notify Grantee of Award
Legend:
PHASE
Program Office
Grantee
Other Federal/HHS
Entities
Office of Grants
Management
ONC Budget
PO/GMO Joint
MANAGE
CLOSEOUT
Notice of Grant Award (NGA)
•
The Notice of Grant Award NGA is the official document
used for grants/cooperative agreements
–
Establishes legally binding arrangement between ONC
and recipient
–
Establishes Period of Performance
–
Contains or references Terms and Conditions of the
grant or cooperative agreement
–
Obligates Federal Funds
43
Notice of Grant Award (NGA)
NGA includes:
•
Grantee information
•
Award information
•
–
Project Period of
Performance
–
Budget Period of
Performance
Terms and Conditions of
the award
44
Award Notification and Acceptance
•
Award Notification
– Grants Solutions
– NGA
– Terms and Conditions
•
Award Acceptance
–
First request for disbursement of funds
–
Agree to abide by all applicable laws, regulations, program
requirements, policy and terms and conditions
–
Specific ARRA terms and conditions (incorporated by reference)
•
http://www.hhs.gov/recovery/grantscontracts/recoverytermsconditions.html
45
Grant vs. Cooperative Agreement
• Grants are awarded to States, units of local government, or private
organizations at the discretion of the awarding agency or on the basis of a
formula. Grants are used to support a public purpose.
• Cooperative Agreements are awarded to States, units of local
government, or private organizations at the discretion of the awarding
agency. Like grants, cooperative agreements also support a public
purpose.
• Substantial involvement is anticipated between the awarding agency
and the recipient during performance of the contemplated activity.
View as a “partnership”
• Cooperative agreements are not contracts
46
Grants Management Lifecycle – Manage
ESTABLISH
APPLY
REVIEW
AWARD
MANAGE
Conduct Programmatic
Monitoring
Review
Performance Reports
Review /Recommend
Post-Award Actions
Review Audits
Conduct
Financial Monitoring
Review
Financial Reports
Review and Approve
Post-Award Actions
Legend:
PHASE
Program Office
Grantee
Other Federal/HHS
Entities
Office of Grants
Management
ONC Budget
PO/GMO Joint
CLOSEOUT
Order of Precedence-Who is Top Dog?
• Constitution of the United States
• Statutes
• Program Statutes (Authorizing Statutes)
• Generally Applicable Statutes
• Annual Appropriations
• Regulations
• Executive Orders
• OMB Circulars
• Policies
• Procedures
48
Administrative Requirements vs. Cost Principles
Administrative Requirements
Cost Principles
Prescribe standards for grant
administration to achieve uniformity
and consistency for recipients of
Federal Assistance
Define allowable costs for different
types of recipients; failure to
mention a particular item of cost in
the Cost Principles is not intended to
imply that it is either allowable or
unallowable
49
Applicable Regulations
Summary of Applicable Regulations
Grantee Type
Administrative
Requirements
Cost Principles
Audit
Requirements
State & Local Governments
45 CFR Part 92
2 CFR, Part 225
(A-87)
A-133
45 CFR Part 74
45 CFR 74.27 and by
reference 2 CFR Part
220 (A-21)
Educational Institutions
Non-Profits
2 CFR, Part 230
(A-122)
50
Recipient Grants Management Responsibilities
Grantee responsibilities include:
• Cash management
• Maintaining adequate financial records
• Returning Federal funds for disallowed expenditures
• Complying with reporting requirements
• Reviewing and recording financial operations
• Budgeting and budget review
• Reporting irregularities
• Refrain from doing business with debarred and suspended
organizations
51
Recipient Grants Management Responsibilities
Managing Subawards
• A recipient has full responsibility for the conduct of the project or
activity supported and for the results achieved
• Direct recipients are responsible for adequate monitoring of subawardee
activities
• 45 CFR Part 92.40 or 74.51, Monitoring and Reporting Program
Performance
52
Financial Management Systems
• At a minimum, a grantee’s financial system should be able to:
• Meet 45 CFR 92.20 or 74.21, Standards for financial management
systems
• Provide financial and performance reporting required by 45 CFR Part 92
and 74, and other regulations
• Associate grant expenditures with the specific funding source and
application of funds
• Provide a clear audit trail
• Comply with the Cash Management Improvement Act
• Minimize the time elapsing between the transfer of funds and
disbursement by the grantee or subgrantee in accordance with Treasury
Regulation 31 CFR 205.
• A State should follow the same state laws and procedures as they
would for non-Federal funds
53
Financial Management Systems – continued
• In order for an accounting system to be considered adequate, it must
meet the following criteria:
• Internal controls / segregation of duties (For example, the person authorizing
an expenditure should not sign the check)
• Ability to track expenditures on an accrual basis (budget control)
• Grantees can use a cash or accrual basis for their accounting method
• Ensure allowability of costs charged to Federal grants
• Documentation for all grant-related expenditures, broken down by award
• Ability to fulfill government-required financial reporting
54
Understanding Match
Matching and cost sharing are often used interchangeably
• Matching usually refers to a statutorily specified percentage
– Specified as a fixed or minimum percentage of non-Federal
participation in allowable program or project costs that must be
contributed by a recipient in order to be eligible for Federal
funding or a not-to-exceed percentage of Federal participation.
• Cost Sharing refers to any situation in which the recipient shares in
the costs of a project other than as statutorily required matching
• Approved/accepted matching or cost sharing is shown in the NGA
55
Understanding Match – continued
• Cash Match
• Cash spent for project related costs
• Matching costs must adhere to Federal rules
• If not allowed with Federal dollars, not allowable with matching dollars
• In-kind Match
• are the value of goods and/or services third parties donate for program or
project purposes without charge to a recipient
• Third party in-kind contributions
• May satisfy a matching or cost-sharing requirement only when payment for
them would be an allowable cost if the party receiving the contributions
(recipient, subrecipient, or cost-type contractor) were to pay for them
56
Understanding Match – continued
• All costs and contributions used to satisfy a matching or costsharing requirement must be documented by the recipient at
the same level of detail as Federal funds
• Matching contributions are subject to audit
• If a recipient fails to provide required cost sharing, the GMO
generally will make a downward adjustment in the Federal
award amount
57
Understanding Match – continued
Valuation of in-kind contributions:
• Rates for volunteers must be consistent with established rates paid for
similar work by the recipient or subrecipient
• If a third party donates the use of equipment or space in a building but
retains title, the contribution shall be valued at the fair rental rate of the
equipment or space
• If a third party donates supplies, the contribution shall be valued at the
market value of the supplies at the time of donation
58
Program Income
• Gross income earned as a result of the award
• directly generated by the grant-supported activity or earned
• There would be no income of this type or level.
• Activities that generate program income include
• Registration fees
• Sale of videos, publications, other media
• Rental/usage fees
• Service fees
• Subject to same requirements as Federal funds
• Must be reported on FFR (SF 425)
59
Program Income
• The Notice of Grant Award includes the type of program income
applicable to the Program/award
• Deduction alternative
• Addition alternative
• Cost Sharing/Matching alternative
• Combination alternative
60
Prior Approval
Several changes to an award require ONC prior approval
• Changes of grantee organization
• Change in scope
• Transfer of substantive programmatic work if not previously approved
• Significant rebudgeting (lesser of 25% or $250K, cumulative)
• Other as defined by program office
• Changes in key personnel
• Carry over funds
• Indirect costs (if indirect costs not approved in initial budget)
Request from grantee, with written justification, should be 30 days from
when need approval
61
Payments to Grantees
Grantees request funds from HHS’ Payment Management System (PMS)
• Payment requests may be made as often as needed: (daily, weekly, monthly,
etc.)
• No checks; electronic transfers only
• Also used to submit quarterly financial reports
• PMS is administered by HHS’ Division of Payment Management
• PMS Helpdesk: (877) 614-5533 or PMSSupport@psc.hhs.gov
Grantees must minimize time between draw and expenditure
• Cash Management Improvement Act (CMIA)
• Immediate needs basis; funds must be spent within three business days
What may impact a grantee’s ability to draw funds?
• No budget approval
• Late report submission
• Other restrictions
62
Grantee Reporting Requirements
Report Required
American Recovery
and Reinvestment
Act (ARRA) Report
Federal Financial
Report (FFR) Federal
Cash Transaction
Report (SF-425)
Frequency
Reporting Period
Due Date
April 1 – June 30
July 10
July 1 – September 30
October 10
Quarterly
Federalreporting.gov
October 1 – December 31
January 10
January 1 – March 31
April 10
April 1 – June 30
July 30
July 1 – September 30
October 30
October 1 – December 31
January 30
January 1 – March 31
April 30
October 1 – September 30
December 30
Quarterly
Federal Financial
Report (FFR) Federal
(SF-425)
Annually
Program Progress
Report
SemiAnnually
Submission Method
Determined by Program Office
Payment Management
System (PMS)
Online Data Collection
System (OLDC)
CRM, email, etc.
63
Official Grant and Program Files
•
Office of Grants Management files
• Official award file
• All award transactions, financial information, correspondence, approvals, etc
• Program information file
• Information for each program announcement
• Information related to all applications
• Institution file
• Contains information on a specific entity which receives multiple awards from
multiple programs
•
Project officer files
• Documents project management activities from inception to closeout
• Record of that PO’s activities with respect to the award
• Auditor or reviewer will request to review for adequate documentation
64
Sample Checklist
•
Section 1
Applicant Submissions and Contacts – New Awards and Other Competing Awards
•
Section 2
Review, Evaluation, and Negotiations – New Awards and Other Competing
Awards
•
Section 3
Award Notices and Restrictions/Special Conditions
•
Section 4
Post-Award Prior-Approval Requests
•
Section 5
Post-Award Monitoring and Closeout
•
Section 6
Other
65
Financial and Programmatic Monitoring
Financial Monitoring
• Evidence of expenditures show that
purchases are necessary, reasonable,
allocable and allowable
• Flow of Funds
• Accounting System
• Internal Controls
• Cash Management
• A-133 Submission
Programmatic Monitoring
• Programmatic Administration
• Compare accomplishments to goals and
objectives
• Reinforce priorities and policies
• Adherence to project scope
• Performance according to Ops Plans
• Progress (completion on time)
• Objectives
• Interest accrual (as necessary)
66
Financial Monitoring – Goals
The goals of financial monitoring include:
– To ensure that grant funds are used as intended and compliant
with regulatory requirements
– To ensure ONC is meeting the highest of management and
fiduciary standards
– To ensure grantee compliance with the terms and conditions of
the grant award
– To meet requirements imposed on ONC by law (ARRA)
67
Financial Monitoring – Risk Factors
• General Selection Criteria
–
–
–
–
–
–
–
–
–
New Grantee
Dollar Amount of Award
Multiple Awards
Entity Type
Subawards
Reporting Findings (FSR, Audit, ARRA)
Unobligated/Unexpended Balances
Program Office Referral/Recommendations
Samples
• The above general criteria was weighted based on various
factors
• Other risk factors not included above may also be considered
based on data analysis -out life of award
68
Types of Financial Monitoring that OGM Conducts
• Desk-based Financial Monitoring
– Cash Analysis
– Desk Review
• On-Site Financial Monitoring
69
Desk-based Monitoring – Cash Analysis
Cash analysis reviews:
–
–
–
–
–
–
Recipient cash transactions
Rate of draws
Payment trends
Unobligated balance
Grant status
Review of last program report
70
Desk-based Monitoring – Cash Analysis continued
During the OGM quarterly review, OGM and Project Officers discuss the
following :
•
•
•
•
Has the grantee submitted timely performance reports?
Is the grantee on target as outlined in their approved plan?
Has contact been made with the grantee if not on target?
If contact has been made, what corrective action has been discussed?
71
Desk-based Monitoring – Desk Reviews
• Limited verification of grantee compliance
– Federal regulations
– Terms and conditions
• Identifies potential issues
• Grants reviewed on a regular basis
• Core review of a grantee’s general management
practices
• May require further scrutiny - on-site financial
monitoring
72
On-Site Monitoring Visits
On-Site Monitoring Visits are performed at grantee location
• Ensure adequate internal controls, policies, processes, and systems exist
to appropriately manage awards
• Assess capability, performance and compliance against administrative
regulations and public policy requirements
• Report on the effectiveness of ONC grantees and grant programs and the
stewardship of public funds
• Collaboration with program office(s) is key to successful monitoring
– Joint site visits with program office when feasible
– Pre-site visit meeting with program staff
73
Common Issues Discovered During Financial Monitoring
• No written policies and/or procedures
• Inadequate procurement standards
• Lack of documentation
• Inadequate/untimely submission of reports
• Inadequate Subaward Monitoring
• Inadequate time and effort records
• Lack of competition during procurement
• Conflicts of interest
• Questioned expenditures
• Excess Cash on Hand
• Commingling of funds
74
Monitoring vs. Auditing
• Monitoring is preventative
– Performed by grants and program staff
– Resolve before audits
• Auditing is corrective / curative
– Performed by auditors
– In the record books
75
Audits – What is a Statewide Single Audit (A-133)?
• Required for Entities that Expend $500K or More in Federal
Funds during their Fiscal Year
• Review of All Federal Grant Programs and Requirements
• Audit Report Is Due 9 Months after the End of the Fiscal Year
• Submit the Audit Package to the Federal Audit Clearinghouse
(FAC)
– http://harvester.census.gov/fac/collect/ddeindex.html
76
A-133: Most Common Audit Findings
•
•
•
•
•
•
•
•
Unallowable activities
Unallowable costs
Poor cash management
Inadequate equipment and real property management
practices
Expending funds outside of the period of availability of funds
Inadequate procurement standards
Untimely and inaccurate reporting
Lack of subrecipient monitoring
77
Audit Resolution
• Health and Human Services
– ASFR, Division of Systems Policy, Payment Integrity,
and Audit Resolution (DSPPIAR) is responsible for A133 audit resolution
• OGM will assist in resolution of audit findings only as
requested by DSPPIAR
– ASFR also serves as a liaison with OMB, the OPDIVs,
and the OIG on grant-related audit issues
• Recipient responsibilities
– Resolve audit findings of subawards
• Most ONC programs have a large number of subs
78
Audit Resolution
• Corrective Action Plan (CAP) should
include:
– Description of each finding
– Specific steps to be taken to implement
the recommendation
– Timetable for performance of each
corrective action
– Description of monitoring to be
performed to ensure implementation
of the CAP
79
HHS Office of the Inspector General (OIG) Performance Audits
• Evaluates HHS Goals and Objectives with grantee activities
• Rotating schedule of states and programs
• Annual audit plan
– Identifies key issues
– Implementation plan
• Conducted by OIG staff
• Compares expenditures to program impact
• Reports posted on OIG website (http://oig.hhs.gov/reports.asp)
80
Examples of Inspector General Audit Findings
• No measurable program goals and objectives
• Lack of monitoring and oversight
• Untimely/incorrect financial reporting
• Questioned costs
• Inadequate procurement practices
• Inadequate personal property controls
81
Grants Management Lifecycle – Closeout
ESTABLISH
APPLY
REVIEW
AWARD
MANAGE
CLOSEOUT
Evaluate Final
Performance Reports
Review
Closeout Package
Conduct Final
Financial Reconciliation
Establish Disposition
of Funds
Notify Grantee of
Closeout
Retain Records
Legend:
PHASE
Program Office
Grantee
Other Federal/HHS
Entities
Office of Grants
Management
ONC Budget
PO/GMO Joint
Recipient Closeout
• Due within 90 Days after End of Award
• Final Progress Report
• Final SF-269 Financial Status report
–
–
–
–
Unobligated funds balance
No unliquidated obligations
Final drawdown
Return excess funds
• Invention Disclosure (if applicable)
• Federally Owned Property Control (if applicable)
83
Retention of Records – Grantees
• Grantee Requirements (45 CFR 92.42 and 74.53)
• At least 3 years from the date of submission of the final
expenditure report
• If litigation, claim or an audit is initiated prior to the
expiration of the 3 year period, records must be retained
until completion of the action and resolution of issues or
the end of the 3 year period, whichever is later
• Records may be retained in an electronic format
84
Retention of Records – ONC
• Office of Grants Management
• 1 year unsuccessful applications
• 6 years 3 months official files
• If open audit, litigation, administrative proceeding
retention may be longer
• Project Officer files
• 2 years after closeout
• If open audit, litigation, administrative proceeding
retention may be longer
85
Grants Management Lifecycle
ESTABLISH
APPLY
REVIEW
AWARD
MANAGE
CLOSEOUT
Authorizing Statute
Establish Commitments
Objective Review
Create Notice of Grant
Award
Conduct Programmatic
Monitoring
Evaluate Final
Performance Reports
Appropriation
Assist Applicants
Assess
Fiscal Integrity
Obligate Funds
Review
Performance Reports
Review
Closeout Package
OMB Apportionment
Develop Funding Memo
Set Up Congressional
Notification in System
Review /Recommend
Post-Award Actions
Conduct Final
Financial Reconciliation
Conduct
Appropriations Analysis
Review Application
Release Funds
Review Audits
Establish Disposition
of Funds
Perform
Budget Review
Notify Grantee of Award
Conduct
Financial Monitoring
Notify Grantee of
Closeout
Review
Financial Reports
Retain Records
Allocate Funds
Assess
Funds Availability
Develop
Funding Opportunity
Announcement (FOA)
Review and Approve PostAward Actions
Release FOA
Program and Grants Management Training and Technical Assistance
Review FOA
Submit Application
Revise Application
Review Award
Package
Drawdown Funds
Complete
Drawdown of Funds
Accept Award
Submit
Performance Reports
Generate Final
Performance Reports
Submit
Financial Reports
Generate Final
Financial Reports
Submit
Post-Award Requests
Submit
Closeout Package
Ensure Audit is Complete
Retain Records
Legend:
Program Office
Grantee
Other Federal/HHS
Entities
ONC Budget
PO/GMO Joint
PHASE
Office of Grants
Management
Critical Reference Documents
American Recovery and Reinvestment Act of 2009 (Recovery Act)
•
What does the law say
•
Statute is highest in order of precedence
45 CFR Part 74 and Part 92 - Administrative Requirements
•
Part 92 – Government organizations (Including Tribal)
•
Part 74 – NGO
•
Uniform administrative rules when implementing Federal grant programs
Cost Principles
•
2 CFR Part 220 – Educational Institutions
•
2 CFR Part 225 – Government Organizations (Including Tribal)
•
2 CFR Part 230 – Non-Profit Organizations
•
FAR 31.2
OMB Circular A-133 - Audits of States, Local Governments, and Non
Profit Organizations
87
Critical Reference Documents – continued
•
HHS Grants Policy Statement (GPS)
–
Grants policy for recipients
–
Incorporated as a term in NGA
–
Dos and Don’ts
–
ONC staff should also know the GPS in order to provide support to grantees
–
http://dhhs.gov/asfr/ogapa/grantinformation/hhsgps107.pdf
•
Funding Opportunity Announcement (FOA)
•
Notice of Grant Award (NGA) with Award Terms and Conditions
•
Grants Management Advisories (GMAs)
•
Grants Management Memorandum (GMM)
•
Program Information Notices (PINs)
•
Program Assistance Letters (PALs)
88
Critical Reference Documents – continued
• Grants Management Advisories (GMAs) – technical assistance resource which will
provide additional information in specific grants management areas for Grantees
– ONC-GMA-2010-01 Roles and Responsibilities Grants and Cooperative Agreements
– ONC-GMA-2010-02 Review of Proposed Subawards and Procurement Contracts Under
Grants
– ONC-GMA-2011-01 Matching and Cost Sharing
– ONC-GMA-2011-02 Use of Unobligated Balances under Grants and Cooperative
Agreements
– ONC-GMA-2011-03 Allowability of Food Costs
– ONC-GMA-2011-04 Program Income
– ONC-GMA-2011-05 Subrecipient Monitoring
– ONC-GMA-2011-06 Allowability of Payments to Uniformed Services and Civilian Federal
Employees
89
Training and Technical Assistance Plan
ONC Office of Grants Management has a Training and Technical
Assistance (TA) Plan based on three different levels of assistance:
•
Level I: Guidance and Information Sharing – Consists of the daily technical
assistance of grants administration.
•
Level II: Sample Protocols, Templates and Models – Targeted telephone and
electronic assistance involves assisting recipients in the development of
protocols and templates, as well as other specific needs, as requested by a
recipient.
•
Level III: Targeted Training Deliveries and Direct On-Site Assistance – Includes
targeted internal and external training sessions.
90
Office of Grants Management – TA Requests
Grants Management TA
request form
–
Please use this form to
request Training and
Technical Assistance from the
ONC Office of Grants
Management
–
Completed forms are
available from, and should
be submitted to
ONCGrants@hhs.gov
91
Grants Management Questions
ONCGrants@hhs.gov
92
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