How to Design an Effective

1

• How to Design an Effective
• Compliance Program for
• Grants

2
Introduction

• Programmatic Compliance
• Teresa Hill, Grants Management Analyst
• Hernando County Office of Management and
  Budget
• Financial Compliance
• Deborah Marenco, Grants Compliance Accountant
• Hernando County Clerk of Circuit Court

3
Grants

• What are they?
• Where do they come from?
• What purpose do they serve?

4
Pre-Planning

• Evaluate Existing Grant Procedures
• Conduct Needs Assessment Survey
• Develop Grant Training Program

5
Compliance Program Elements

• Written policy and procedures
• Training and education
• Compliance oversight
• Monitoring and auditing
• Communication

6
Grant Policy and Procedures

• Policy
• Establish objectives, responsibilities and
  authority, and encourage proper internal controls
  and consistent record-keeping methods
• Procedures
• Assist with implementation of grant policies by
  providing detailed instructions for
  administration of grant activities

7
Hernando County Grant Policy

• Objectives
• Delegation of Authority
• Administrative
• Accounting, Monitoring Financial Reporting
• Applicability

8
Hernando County Grant Procedures

• Pre-Award Phase (Application)
• Analyze objectives and funding needs
• Determine expected results or benefits
• Communicate with affected departments
• Designate Project Administrator
• Prepare application
• Submit Agenda Memo, Legal Request, Application to
  Grants Mgmt Analyst
• BOCC approval

9
Hernando County Grant Procedures

• Award Phase (Administration)
• Understand terms and conditions of award
• Establish liaison with granting agency
• Select reimbursement versus advance
• Prepare internal documents (GFDS, Compliance
  checklists.
• Submit Agenda Memo, Legal Request, Application to
  Grants Mgmt Analyst
• BOCC approval

10
Hernando County Grant Procedures

• Award Phase (Administration) continued
• Contract and Compliance checklist to Purchasing
• Ensure compliance with excluded parties list
  system, Davis-Bacon Act and other policy
  requirements
• Determine all ten criteria of Cost Principles are
  met
• Prepare financial and progress reports
• Track fixed assets separately
• Fiscal Year End procedures

11
Hernando County Grant Procedures

• Post-Award Phase (Close-out)
• Prepare Close-out reports
• Internal documents (GFDS)
• Record Retention
• Grant Procedures Checklist

12
Training Education

• Procedures for Grant Management
• Modules
• Financial Programmatic Reporting
• Level I Level II
• Grant Policy Requirements and Preparation of
• Compliance Checklists
• Preparing for an Audit
• Davis-Bacon Compliance
• Writing Grant Applications

13
Compliance Oversight

• Copies of signed agreements / modifications
• Financial and Programmatic Reports
• Monitoring Checklists
• Grant Funding Data Sheet (GFDS)

14
Monitoring and Auditing

• Local Policy / Ordinances
• Federal and State Laws / Regulations
• Project Administration
• Contractual Compliance
• Reporting
• Recordkeeping

15
Statutes, Regulations Program Requirements

• Federal and State Laws/Statutes
• Executive Orders
• Code of Federal Regulations (CFR)
• OMB Circulars
• Common Rule (A-102)
• A-87 Cost Principles
• A-133 Audits

16
Statutes, Regulations Program Requirements
(continued)

• CFDA and CSFA
• Grant Agreement
• Public Policy Requirements
• Special Conditions or Restrictions
• Program Guidance

17
Communication

• Required for every successful grant program
• (between and among all players)
• Blockages to effective communication

18
Hernando County Checklists

• Grant Procedures
• Grant Monitoring
• Public Policy Requirements
• Davis-Bacon
• Federal Labor Standards Fact Sheet
• Local Agency Responsibilities
• Pre-Construction Conference
• Monitoring Contractor Performance Reviewing
  Payrolls / Employee Interviews

19
Grant Compliance

• Programmatic Compliance
• Conclusion

20
Financial Compliance

• Introduction
• Basic Accounting Principles

21
Financial Compliance (continued)

• Grant v. cooperative agreement v. contract
• Administrative Requirements
• (OMB Circular A-102)
• - Financial administration
• - Equipment/supplies/real property
• - Reporting requirements

22
Financial Compliance (continued)

• Cost Principles (OMB Circular A-87)
• Allocable
• Necessary and reasonable
• Treated consistently (direct or indirect)
• In accordance with GAAP
• Net of all applicable credits

23
Financial Compliance (continued)

• Cost Principles (OMB Circular A-87)
• Not used for cost sharing or matching requirement
  for another federal award
• Adequately documented
• Authorized or not prohibited under under state or
  local laws and regulations
• In conformance with limits or exclusions on types
  of amounts of costs
• Consistent with recipients policies and
  procedures

24
Financial Compliance (continued)

• Cost Principles (OMB Circular A-87)
• Selected items of cost
• Salaries charged to grants

25
Single Audit Act andFlorida Single Audit Act

• Single Audit Act
• Auditor and auditees responsibilities
• Compliance Supplement
• Florida Single Audit Act

26
An Effective GrantCompliance Program

• Written grant procedures
• Checklists
• Grant monitoring and auditing
• Formal and informal grant training program
• Quarterly newsletter
• Web page on Countys Intranet