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400 ACCOUNTING AND REPORTING PROCEDURES Click to Jump 400.1 Fiscal Control and Accounting Requirements 400.2 Amendments 400.3 Obligations and Expenditures 400.4 Time and Effort 400.5 Cash Requests 400.6 Program Income and Interest Earned 400.7 Records Retention 400.8 Project Closeouts 400.1 FISCAL CONTROL AND ACCOUNTING REQUIREMENTS Go to Top The federal government requires the Office of Public Instruction (OPI) to set fiscal control and accounting procedures for its own funds and those of its subgrantees in accordance with state laws and policies. These fiscal control and accounting procedures must: a. Permit preparation of required reports for state and federal officials; and b. Permit funds to be traced to a level of expenditures adequate to establish that the funds have not been used in violation of restrictions and prohibitions of program statutes. FEDERAL FINANCIAL MANAGEMENT STANDARDS Federal financial management standards require the OPI and our subgrantees must: a. Provide accurate, current and complete disclosure of federally assisted activities in accordance with financial reporting requirements of the program; b. Maintain records to adequately identify the source and application of funds for federally assisted programs: award letters, authorization statutes, obligations, unobligated balances, assets, liabilities, expenditures and revenue (see RECORDS RETENTION below); c. Maintain effective control and accountability for all grant and subgrant cash, real and personal property and other assets. Subgrantees must adequately safeguard property and ensure it is used solely for authorized purposes; d. Maintain comparisons of actual expenditures to budgeted expenditures for each grant; e. Follow applicable federal Office of Management and Budget (OMB) cost principles, the OPI program regulations and the terms of the grant agreements; REVISED March 2012 Montana Office of Public Instruction Grants Handbook 400-1 f. Support accounting records with source documentation, e.g., approved requisitions and purchase orders, cancelled warrants, paid invoices, payrolls, time and attendance records, contracts and award documents, etc.; and g. Establish reasonable procedures to request funds as close as possible to the time they are needed to make payments for grant activities. REVIEWING A SUBGRANTEE’S FINANCIAL MANAGEMENT SYSTEM The OPI may review the adequacy of the financial management system of any subgrantee as part of the pre-award process or any time subsequent to the award. The OPI reviews the annual or biennial audit reports of each subgrantee to ensure compliance with federal and state audit requirements. For more information, see Audit Requirements and OPI Monitoring in Section 600 of this handbook. SEPARATE ACCOUNTING REQUIRED FOR EACH GRANT PROJECT Subgrantees must maintain a separate accounting of revenues and expenditures by project and by fiscal year. This also applies to funds transferred or REAP-Flexed under the provisions of Title VI of the No Child Left Behind Act. SCHOOL DISTRICTS—DEPOSIT OF GRANT FUNDS FROM THE OPI Nearly all state and federal grants administered by the OPI and distributed to public school districts are required to be deposited into the Miscellaneous Programs Fund (15) of the Prime Applicant school district. Federal Impact Aid, which is paid directly to school districts by the federal government, must be deposited into a district’s Impact Aid Fund (26). FISCAL YEAR PERIOD “Fiscal Year” means a year used as an accounting period. The State of Montana, including Montana school districts, uses a fiscal year that begins July 1 and ends June 30. The federal fiscal year is October 1 through September 30. 400.2 AMENDMENTS Go to Top BUDGETING FOR GOOD MANAGEMENT CONTROL To ensure good fiscal control, each subgrantee of federal or state grant funds must establish a “line item” budget for each project. That means each expenditure account (e.g., instructional salaries, instructional supplies, rent and contracted services) must be allocated based on an estimated amount of what will be spent for that purpose. Planned indirect cost recoveries, equipment purchases, or transfers to other districts must also be budgeted. Federal regulations require a subgrantee to maintain its accounting records in a manner that allows for comparison of actual expenditures to budgeted amounts for each grant. REVISED March 2012 Montana Office of Public Instruction Grants Handbook 400-2 A sample template for a Detailed Line-Item Budget is shown in Appendix B of this handbook. CHANGES THAT DO REQUIRE THE OPI’S APPROVAL A subgrantee must request OPI’s approval for certain types of post-award changes in budgets and projects by submitting an amendment to the approved grant application. Changes that require OPI pre-approval include: Budget Modifications 1. Plans to purchase additional equipment items costing $5,000 or more per unit; 2. A change in the overall funding of the project (such as the addition of carryover or reallocated funds or an increase or decrease of the federal appropriation after the original application was submitted); or 3. A re-budget between line items within an approved budget to meet unanticipated needs, if the new line item was not included in the original approved grant budget or if the change results in a difference of 50 percent or more in any previously approved line item. Program Modifications 1. A change in the program scope and objectives, regardless of whether there is an associated budget revision; or 2. A request to extend the project period from June 30 to September 30. CHANGES THAT DO NOT REQUIRE THE OPI’S APPROVAL Subgrantees may make minor changes in the scope and budget of the approved grant project without OPI approval. Minor changes not requiring amendments include: 1. A change in personnel that does not change the planned activities or scope of the grant project; and 2. Budget changes that do not exceed 50 percent of a line item total which was previously approved on the grant budget, except when the scope of a project is changing. For example, if a project budget included $20,000 for staff and $600 for supplies but the staff person cost only $19,500, the remaining $500 could be spent on supplies without submitting a budget amendment. Previously approved line items are not being affected by more than 50 percent of the original amounts, and the scope was not changed from the originally approved project plan. Contact the appropriate OPI program specialist with questions about whether changes in project plans will require OPI approval. REVISED March 2012 Montana Office of Public Instruction Grants Handbook 400-3 HOW TO SUBMIT AN AMENDMENT REQUEST - DEADLINES Grants amendment requests must be submitted to the OPI by June 1 for programs ending June 30 and by September 1 for programs ending September 30. For E-Grants programs, the subgrantee must submit the request online in the E-Grants system. Contact the OPI E-Grants Coordinator at (406) 444-7841 for assistance, if needed. For non-E-Grants programs, submit a Grant Amendment Request form for the OPI’s approval of an amendment (see Appendix B of this handbook). OBTAINING APPROVAL BEFORE INCURRING OBLIGATIONS Budget amendments which require approval must be submitted to the OPI and approved before making obligations or expenditures. PROJECT EXTENSIONS Most OPI-administered grants end on June 30 or September 30. In limited cases and with the OPI approval, districts/cooperatives may extend the project year to September 30 for a project that would otherwise end June 30. Submit a request for an extension to the OPI no later than June 1. E-Grants programs require an online amendment and non-E-Grants programs require a hardcopy Grant Amendment Request form (see Appendix B of this handbook). Program specific Information about project extensions: IDEA Part B and Preschool Entitlement Grants: IDEA programs allow 100 percent carryover of funds. Carryover is added to the following year’s project allocation, so subgrantees should not need extensions. Extensions may be allowed only for extraordinary circumstances which result in the applicant needing additional time to expend carryover funds. Contact the OPI Special Education Division at (406)444-2504 for assistance. ESEA Titles I-A, II-A, III-A, IV-B, and VI: Extensions are not needed because those programs already end on September 30. Carl Perkins: Extensions are not allowed, and projects end June 30. EFFECT OF A PROJECT EXTENSION If the OPI approves an extension, the subgrantee must obligate funds by September 30 and liquidate all obligations by October 31. REVISED March 2012 Montana Office of Public Instruction Grants Handbook 400-4 PROJECT NUMBER FOR AN EXTENDED PROJECT Approved extensions are treated as an amendment to the district’s/cooperative’s project budget. The same project number will be used to track expenditures incurred during the extension period. That is, for example, If the original project number was: 56-0965-77-03-XXXXX The project number after an extension to September 30 is approved remains unchanged: 56-0965-77-03-XXXXX 400.3 OBLIGATIONS AND EXPENDITURES Go to Top “Obligations” are orders placed, contracts awarded and goods and services received but not paid for during the project period. Obligations must be liquidated (i.e., paid for) within 30 days following the end of the project period. School districts and cooperatives/consortia are required by law to record and report transactions in accordance with the Montana School Accounting Manual. See HAS AN OBLIGTION BEEN MADE? below for details. EARLIEST DATE TO OBLIGATE FUNDS No funds may be obligated or expended before July 1 or before the OPI’s approval of the award, if the approval date is after July 1. The OPI may, on occasion, approve preaward costs in accordance with federal cost principles. DEADLINE FOR OBLIGATIONS Depending on the source of funds, the project period for the OPI-administered programs is usually July 1 through June 30, or July 1 through September 30. This means that for projects ending June 30, program funds must be spent or “obligated” by June 30. For projects ending or extended to September 30, program funds must be spent or “obligated” by September 30. REVISED March 2012 Montana Office of Public Instruction Grants Handbook 400-5 HAS AN OBLIGATION BEEN MADE? The following table (based on 34 CFR 76.707) describes when an obligation occurs with respect to various categories of activities. IF THE OBLIGATION IS FOR: THE OBLIGATION IS MADE: Acquisition of real or personal property (includes real estate, equipment, and supplies) On the date on which the subgrantee makes a binding written commitment to acquire the property (i.e., purchase order or contract). Personal services by an employee When the service has been performed. Personal services by a contractor (not an employee) On the date on which a binding written commitment to obtain the services has been made (provided that the work can be completed within 45 days of the end of the project). Performance of work other than a personal service On the date on which a binding written commitment to obtain the work has been made (provided that the work can be completed within 45 days of the end of the project). Public utility service When the service is received. Travel When the travel is taken. Rental of real or personal property When the property is used. A pre-agreement cost that was approved by the state under the cost principles identified in 34 CFR 74.171 and 80.22 When the pre-agreement costs were approved. REVISED March 2012 (Example: If a project is approved to begin October 1, the subgrantee may request the OPI’s approval to charge the project for costs incurred for a summer program before October 1. In limited cases, and within federal regulations, OPI may choose to approve such pre-award costs.) Montana Office of Public Instruction Grants Handbook 400-6 400.4 TIME AND EFFORT Go to Top TIME AND EFFORT TRACKING REQUIREMENTS Payroll costs charged to federal grant programs must be based on payrolls documented and paid in accordance with school accounting policies and state and federal laws and regulations. Charges must be approved by appropriate officials. Subgrantees must maintain records to document payroll costs charged to each grant award. The records must show the time actually spent by an employee in carrying out the objectives of that program. That is, subgrantees must not charge payroll costs to grants based on estimated allocations of an employee’s time. This applies to both state and federal programs. DOCUMENTATION DEPENDS ON WORK The type of documentation required for time and effort depends on whether an employee works on a “single cost objective” (e.g., 100% special education or 100% Title IA) or if the employee works on “multiple cost objectives” (e.g., 20% special education and 70% Title IA and 10% regular classroom aid). An employee working on multiple cost objectives must complete a personnel activity report (timesheet) at least monthly. An employee working on a single cost objective may complete monthly personnel activity reports or may instead complete a semi-annual certification. The employer must establish policy on the type(s) of time and effort documents required by their staff to ensure compliance with federal regulations Employee Working on Multiple Grant Projects – Personnel Activity Report When an employee works on more than one project (i.e., multiple federal grant programs or a combination of federal and non-federal programs) the subgrantee must keep records showing the salaries, wages, and benefits charged to each program with appropriate time distribution records for the employee. This requires an ongoing accounting, such as a timesheet or detailed daily log of activities performed for each grant. The federal regulations (OMB Circular A-87, 2 CFR Part 225) refer to this timesheet or log as a “personnel activity report” and set criteria for the reports. Personnel activity reports must: a. Show charges to federal projects were made based on actual time spent working on the activities (“after-the-fact record”); b. Account for the total time of each employee; c. Be prepared at least monthly and coincide with one or more pay periods; d. Be signed by the employee; and e. Not be based on budget estimates of the employee’s time, but may be estimated in the interim if revised at least quarterly to reflect actual time and effort. REVISED March 2012 Montana Office of Public Instruction Grants Handbook 400-7 An example of the Time and Effort Form (i.e., timesheet) used by the OPI is included in Appendix B of this handbook for reference. Employee Working on a Single Grant Project – Semi-Annual Time Certification An employee is considered to be working on a single cost objective if the employee: 1. 2. is paid fully or partially with federal grant funds; and works solely on activities allowable under the terms and conditions of a specific federal grant. If an employee works solely on a single federal award or a single cost objective, the subgrantee may document the salaries and benefit costs charged to the single grant by having the employee and immediate supervisor sign a semi-annual (or more frequent) certification stating the employee worked solely on that particular program for the period covered by the certification. Federal regulations require this type of periodic certification to be done at least semi-annually. This method may be an easier alternative to timesheets and logs when only one grant award is used to pay an employee. An Example of Semi-Annual Time Certification is included in Appendix B of this handbook for reference. RECOMMENDED POLICY STATEMENT The OPI recommends the School Trustees adopt and distribute a personnel policy dealing with time and effort reporting similar to the example below: “Office of Management and Budget (OMB) Circular A-87 [now 2 CFR Part 225], Cost Principles for State, Local and Indian Tribal Governments, sets forth federal policies on documenting time spent on federal grant activities. Employees who work on multiple activities (i.e., more than one federal award, an indirect and a direct activity, a federal award and a non-federal activity), are affected by these policies. Staff paid from multiple funding sources must report their hours worked according to the activities actually performed during a given pay period, and not according to how their salary is budgeted. Circular A-87 says compensation for personnel services is an allowable cost of federal programs only if our time sheets reflect an “after-the-fact” distribution of the “actual activity” of each employee. Accordingly, staff is required to complete their timesheet by reporting hours worked according to the activities actually performed during that pay period, and charging the appropriate budget code [funding source]. For audit purposes, employees charging time to a federal grant are expected to have reasonable, creditable evidence to support the charges (i.e., daily calendar, job description, work products, travel schedules, etc.). REVISED March 2012 Montana Office of Public Instruction Grants Handbook 400-8 Paid leave time and hours worked that can’t be reasonably identified to a specific budget code, for example time spent attending an all staff meeting, will initially be allocated according to how an employee’s salary is currently budgeted. If necessary, those charges will be adjusted between budget codes later in the year to correspond with actual hours worked.” TIME AND EFFORT CONSIDERATIONS FOR SCHOOLWIDE PROGRAMS Usually, personnel costs are allowable grant expenditures only if the employee’s time is spent performing activities for that particular grant project. However, when the district has a school that qualifies for a “schoolwide” program under ESEA and the district has approved a Schoolwide Plan for that program, federal regulations and OPI policy allow the subgrantee to charge costs of that school’s programs, including personnel costs, to the general fund, to other non-grant funding sources, or to the school’s grant allocations without regard to a particular grant’s purpose. [NOTE: The district and school are still required to demonstrate certain progress and show certain results in accordance with grant regulations. Also, some grants may not be included in the district’s Schoolwide Plan and so would have to be separately tracked. ] For more information, see Appendix G - Schoolwide Programs in this handbook. For time and effort reporting purposes, staff working in a school that has a schoolwide program is considered to be working on one, rather than multiple activities. Hourly employees only need to report hours worked and leave taken, without associating hours worked with a particular grant(s) and non-grant activities. Payroll for the school can be paid from any combination of grants and non-grant sources at the district’s discretion. For practical purposes, the district may want to apply the same time and effort reporting requirements to all employees, rather than applying a less rigorous system to schoolwide programs. That is, the district can choose to apply the flexibility afforded to schoolwide programs at the payment, rather than reporting level. Consistent reporting of staff time may help avoid confusion, especially for employees that later move to another school or routinely work at more than one school. TIME AND EFFORT AUDITS Retain time and effort records for audit purposes. 400.5 CASH REQUESTS Go to Top OVERVIEW AND DUE DATES A subgrantee must submit a “cash request” to the OPI to request a payment of federal or state program funds. The cash request provides the OPI with a subgrantee’s estimated cash needs. Separate cash requests must be submitted for each program. REVISED March 2012 Montana Office of Public Instruction Grants Handbook 400-9 E-Grant Programs For programs managed on the E-Grants system, cash requests must be submitted using the E-Grants system online. Cash requests should be submitted monthly. The subgrantee must submit an electronic cash request to the OPI by the 25th of the month for disbursement by the 10th of the following month. For example, if a cash request is received by the OPI by October 25th, a payment will be sent on November 10 th. Cash requests are not required to be submitted monthly, but the OPI encourages monthly cash requests. Non-E-Grants Programs For non-E-Grants programs (usually small and discretionary projects), subgrantees typically submit one annual cash request form at the beginning of each fiscal year of the project. The form estimates cash needs by month throughout the fiscal year. Subgrantees must submit a hardcopy Cash Request form (see Appendix B of this handbook) by mail or fax to the OPI. Mailing address: Fax number: Centralized Services Division, OPI Box 202501 Helena, MT 59620-2501 (406) 444-1369 After the OPI approves the form, the OPI will make monthly grant payments to the subgrantee according to the cash request form beginning on the 10th of the following month. The subgrantee may submit a revised Cash Request form to modify the amounts of future months’ payments. DUE DATES AT FISCAL YEAR-END In June, the OPI makes two grant payments: one payment on the 10th and one on or about the 25th of the month. Therefore, requests are due to the OPI by May 25 th and June 20th. In July, the OPI does not process grant payments. So, requests submitted between June 20th (deadline for June 25th payment) and July 25th (deadline for August 10th payment) will be paid on August 10th. FACTORS THAT MAY DELAY PAYMENTS Grant payments may be delayed by such factors as: the timeliness of a subgrantee’s submission of acceptable applications and project reports; the timing of OPI’s approval of the proposed project, including time to review proposed project plans of applicants and time for applicants to revise proposals as needed; the timing of federal program authorizations and notifications to the OPI of the state’s allocations; the subgrantee’s unacceptable performance on previous projects; or unacceptable or late submissions of required reports. REVISED March 2012 Montana Office of Public Instruction Grants Handbook 400-10