GFMD Pre Application Call Presentation - Consolidated Youth - FOR EXTERNAL DISTRIBUTION.pptx

Grants Financial Management Division

Pre-Application Call Consolidated Grant Programs to Address Children and Youth Experiencing Domestic and Sexual Assault and Engage Men and Boys as Allies

January 2018

OVW

Thank you for having us on the call today. My name is Suheyla Lasky and I am a Financial Analyst with the Grants Financial Management Division. We are the financial team for OVW awards and provide an array of financial services for our grantees and applicants, but today we’re just going to focus on some aspects that relate to the documents that we review from your application. More specifically, we will discuss some items that GFMD has identified from prior year applications that could help with expediting our review process.

Grants Financial Management Division

Today’s Discussion Pre-Award Risk Assessments Summary Data Sheet Financial Accounting Practices Budget Reviews Presentation of Budget Items to include

For today, we are going to highlight certain aspects of the pre-award risk assessment and the budget review process that GFMD completes.

Pre-Award Risk Assessments

Summary Data Sheets Single Audit (threshold and fiscal year) IRS three-step safe-harbor procedure– Executive Compensation – Sample Disclosure Letter Address all four parts

Financial Accounting Practices Ten questions; Multiple parts to each question Most Common issues:

Brief list of policies and procedures not provided Budgeted vs. Actual process not provided Record Retention policy not provided Knowledge of rules and regulations

The first few items that we will highlight are the identified in the summary data sheet, which is completed by all applicants.

Specifically, two items we would like to discuss are the Single Audit response and the IRS three step safe harbor procedure.

OVW requests that all applicants provide a statement as to whether they have expended $750,000 or more in federal funds during their last fiscal year. If they have, then they indicate that, and also specify the end date of their last fiscal year. However, we are finding that applicants do not always include this information, and leave out whether or not they have met the threshold, or the end date of the last Fiscal year is not included. Please ensure this question is answered in its entirety on the Summary Data Sheet.

Another item we would like to highlight from the solicitation is specifically for non profit organizations. If you use the IRS three step safe harbor procedure to determine your executives’ compensation, you must reference the additional information section that provides the required disclosure letter. We would like to highlight that there are 4 parts of this disclosure letter that must be provided to OVW in order to comply with this requirement. The sample letter that outlines all 4 parts of the disclosure, so please be sure to follow the sample and provide a response to each of the four pieces.

The next item we would like to discuss are the financial accounting practices, which assist us during our pre award risk assessment review for all applications. Each applicant must prepare a response to all ten questions, and each question has multiple parts.

We have noticed from prior years that applicants do not always fully answer all parts of the questions, which in turn, requires GFMD to reach out to the applicant which may delay recommendations. Some of the most common issues that we have encountered have been, for example, question #2, where the applicant indicates that they do indeed have internal policies, but they do not provide a brief list of topics covered in the policies and procedures. Another example of incomplete responses include question #3, where the applicant does not provide a brief summary of the organization’s process for tracking expenditures, and more specifically whether or not they tracks budgeted versus actual expenditures.

These are just a few examples, so please make sure you read each piece of each question and provide a full and comprehensive response.

Federal Resources

Uniform Guidance - 2 CFR Part 200

DOJ Financial Guide – https://ojp.gov/financialguide/doj/index.htm

Program Specific Solicitation - https://www.justice.gov/ovw/open-solicitations

We want to quickly highlight some resources that are available that should be used as you are creating the budget to be submitted with the application.

First is uniform guidance which can be found at 2 CFR 200, then another resource is the DOJ Financial Guide, as well as the program specific solicitation. If you need assistance finding these resources, please contact our GFMD helpdesk.

Budget Review

Federal Cost Categories:

Direct Costs Personnel Fringe Benefits Travel Equipment Supplies Contracts/Consultants Other Costs

Indirect Costs

TOTAL COSTS

Budgets MUST include:

Itemized breakdown for all costs Detailed narrative for all line items (budget is independent of project narrative) Accurate calculations

Now we can move on to our budget review conversation. There are 8 Federal cost categories that are used within OVW’s budgets. You can also find these in the solicitation in the Sample Budget Worksheet.

We are going to go through each category separately and highlight specific areas that we would like all applicants to include in their submitted budgets.

First, let us go over some general notes about budgets. All budgets must include itemized breakdowns of all costs and be supported by a detailed narrative for each line item. Also, please make sure to double check all your calculations, as they should all be correct.

For applicants who have received funding from OVW in the past, please make sure that you incorporate previous budget review comments and questions into the budget creation this time around. We will ask you the same questions and comments, so it will expedite the review if they are already incorporated into the budget.

Budget Review

Personnel Recipient staff for direct activity only Show calculation by salary/hourly rate times percentage of time

Fringe Benefits Examples: Social Security, Medicare, Health Insurance, Unemployment Insurance, Retirement Associated with staff in Personnel and follows organizational policy

Travel Direct recipient travel; Follow organizational travel policy OVW Mandated technical assistance/training

Not budgeted in this category:

Consultant and partner travel Consultants/Contracts Client/survivor assistance Other Attendee travel assistance Other

Going through the budget by categories, the first category that we will discuss is the Personnel section. This category is for recipient staff that work directly on this award’s activities. Please ensure that all staff time is broken down by the staff’s salary or hourly rates, and their percentage of time is included as well.

The next category is Fringe Benefits. Some examples include Social Security, Medicare, Health Insurance, Unemployment Insurance, and Retirement. Fringe benefits are associated with the staff in Personnel and follows the internal organization’s policies.

The Travel category is next, which includes direct recipient travel and should follow the recipient organization’s travel policies. Another item to highlight in this category is to ensure that every budget includes the OVW mandated technical assistance training amount.

It can be confusing sometimes to know which travel costs get placed in this category, so keep in mind that consultant and partner travel is categorized in the “Consultants and Contracts” category; then the travel assistance provided to clients and survivors is categorized in the “Other” category, and last, if travel funds are provided to attendees for travel assistance costs, this is included in the “Other” category as well. Please remember that the Travel category is for Direct Recipient Staff travel only.

Budget Review Equipment Non-expendable tangible property Use organizational capitalization policy (may have lower threshold than the Federal Government)

NOTE: Rented or leased equipment should be included in the “contractual” category.

Supplies Ex. - office supplies, copy paper, training materials, postage, etc.

Computing device is a supply if the cost is less than $5,000 (or less than capitalization threshold), regardless of useful life

Next is the Equipment category, which lists out the non-expendable tangible property. Items in this category fall under your organization’s capitalization threshold. Your threshold may be lower than the Federal Government’s, which is $5,000, so please refer to your organization’s policy if you’re not sure what your threshold is.

Please note that if you have costs in you budget for rented or leased equipment that they should be included in the Contractual category.

The next category is for Supplies, and some examples of these costs include general office supplies, copy paper, training materials, and postage. One thing to note is that if you have costs for computing devices and the cost is below your organization’s capitalization threshold, this cost can be included in the “Supplies” category and not the Equipment category. This is regardless of the useful life of the computing device.

Consultants/Contracts/Subawards

MOU Partner costs Contracts for good and services Consultant Costs Prior Approval threshold = $650/day or $81.25/hour This is threshold, not a standardized rate

Use appropriate agreement type based on the nature of the service Subawards – carry out program activities Contract – procurement for goods or services (including consultants) Substance of the relationship is more important than the form of the agreement

Budget Review

The next category is the Consultants and Contracts category, which is where you will include the costs for your MOU partners, contracts for goods and services, and consultant costs. One quick note about consultant costs is that there is a prior approval threshold of $650/day for an 8-hour day or $81.25/hour. This is not a standard rate, as there is no Federal standard rate for consultants. It is a threshold that, once exceeded, must receive prior approval.

Returning to the different costs that are included in the budget, many grantees likely have MOU partners that are identified in the community to participate on the project. When issuing an agreement with Federal funds, there are two tools to use per the Federal regulations. One is a contract and the other is a subaward. The uniform guidance provides a great outline that describes the characteristics of both subawards and contracts, so applicants must determine which agreement tool is most appropriate to use, which is based on the nature of the services. Please note that the substance of the relationship is more important than the form of the agreement you make with your partners.

Budget Review Subrecipient vs Contractor

GFMD has created a quick reference sheet to show the characteristics of subrecipients and contractors, and which of the characteristics each agreement type most closely aligns with.

Some examples include whether or not MOU partners are generally considered subrecipients or contractors, and the chart shows that they are generally considered subrecipients.

Another is whether or not procurement standards, which include competitive and sole source approval, apply when making the selection. This applies to contractors but not subrecipients. So you can see how the distinction can make a big difference in how you carry out the agreements with your partners.

Other

Ex. – rent, registration fees, client/survivor services, participant support costs, etc.

Itemized breakdown/narrative for all line items Allocate shared costs – equitable distribution method

Example:

Project Coordinator’s office 150 sq ft x $11/sq ft x 12 months x 50% of time devoted to project = $990

Indirect Costs Common or joint purpose costs; Benefiting more than one activity Reimbursable with:

Federally Approved Indirect Cost rate (most recent rate attached) or;

de minimis rate

Budget Review

The last direct cost category is the Other category, which includes rent, registration fees, client/survivor services, and participant support costs, to name a few.

In this category, you will provide an itemized breakdown for each line item and a narrative to support each of the costs listed in the worksheet.

Please note that all shared costs must identify the allocation method that is used by your organization. This method is used to equitably distribute shared costs amongst the funding sources that receive a benefit from the item. If you have any questions about this, please feel free to contact our helpdesk for more information and guidance.

The last category we have to discuss is the Indirect Cost Category. This category is for common or joint purpose costs which benefit more than one activity. Indirect costs are only reimbursable with either a Federally Approved Indirect Cost Rate agreement or by the de minimis rate. If you have an approved rate agreement, make sure to attach it to the application package. Please refer to the solicitation and the uniform guidance for more information on indirect costs.

Contact Information

OVW GFMD Helpdesk:

We want to thank you for your time. We know this can be a lot of information to process, so if you have any questions about the information we discussed, please feel free to contact our helpdesk at 888-514-8556 or by email at OVW.GFMD@usdoj.gov.

Thank you!!!

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