Frequently Asked Questions
1. What is the Uniform Grant Guidance, (UGG)?
The Office of Management and Budget's (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly called "Uniform Guidance") was officially implemented in December 2014 by the Council on Financial Assistance Reform (COFAR). The Uniform Guidance – a "government-wide framework for grants management" – synthesizes and supersedes guidance from earlier OMB circulars.
The reforms that comprise the Uniform Guidance aim to reduce the administrative burden on award recipients and, at the same time, guard against the risk of waste and misuse of Federal funds. Among other things, the OMB's Uniform Guidance does the following:
· Removes previous guidance that is conflicting and establishes standard language;
· Directs the focus of audits on areas that have been identified as at risk for waste, fraud and abuse;
· Lays the groundwork for Federal agencies to standardize the processing of data;
· Clarifies and updates cost reporting guidelines for award recipients.
The Guidance was drawn from OMB Circulars A–21, A–87, A–110, and A–122 (which have been placed in past OMB guidance); Circulars A–89, A–102, and A–133; and the guidance in Circular A–50 on Single Audit Act follow-up. (2 CFR Part 200) -Uniform Grant Guidance or UGG https://ecfr.federalregister.gov/
2. What is Every Student Succeeds Act, ESSA?
The Every Student Succeeds Act (ESSA) was signed by President Obama on December 10, 2015, and represents good news for our nation’s schools. This bipartisan measure reauthorizes the 50-year-old Elementary and Secondary Education Act (ESEA), the nation’s national education law and longstanding commitment to equal opportunity for all students.
The new law builds on key areas of progress in recent years, made possible by the efforts of educators, communities, parents, and students across the country.
For example, today, high school graduation rates are at all-time highs. Dropout rates are at historic lows. And more students are going to college than ever before. These achievements provide a firm foundation for further work to expand educational opportunity and improve student outcomes under ESSA.
The previous version of the law, the No Child Left Behind (NCLB) Act, was enacted in 2002. NCLB represented a significant step forward for our nation’s children in many respects, particularly as it shined a light on where students were making progress and where they needed additional support, regardless of race, income, zip code, disability, home language, or background. The law was scheduled for revision in 2007, and, over time, NCLB’s prescriptive requirements became increasingly unworkable for schools and educators. Recognizing this fact, in 2010, the Obama administration joined a call from educators and families to create a better law that focused on the clear goal of fully preparing all students for success in college and careers. https://www.ed.gov/essa?src=rn
3. Does the federal programs team offer any local trainings?
Currently the federal program team offers the following trainings:
1. Beginning of the Year Webinar
2. Individual Operator Quarterly Conference Calls
3. Mid-Year Check In
4. Quest for Success Training Program
5. Grant Program Specific Webinars and Check-Ins
6. Hot Topic Webinars
7. End of Year Closeout Conference Calls
The federal programs team is more than happy to facilitate any additional trainings, please email us the following at firstname.lastname@example.org:
1. Area of need- Specific training topic
2. Brief description of the issue or difficultly you may be having (We want to ensure we are covering all areas that you specifically need).
4. When should operators receive payments from their reimbursement request?
The ASD Federal Programs team understands the need for schools to be reimbursed for expenses in a timely manner and consider payment a top priority. Reimbursement requests are handled as quickly as possible from the time they are submitted. At this time, we cannot guarantee a set time of payment. However, here is the process for payments:
Step 1: Federal Programs Review- Blanket POs are created for each school for each funding source. If there are any issues and/or concerns with information provided in the reimbursement request, a request will be made to correct or provide additional support.
Step 2: Finance Team Review- Once the request receives two levels of approval, the Finance team will receipt the signed and approved reimbursement request against the POs and submit to Accounts Payable.
Step 3: Accounts Payable- Accounts payable will then match the POs against the receipts, check for all approved signatures, and create a voucher. Once Accounts Payable approves the POs, the reimbursement requests are scanned and uploaded into Edison.
Step 4: Payment- The reimbursement request payments are sent to organization’s address entered on the W9. Payments will be made by check or EFT (electronic fund transfer).
Step 5: Drawing Funds - Once the payments are made to schools, a consolidated draw reimbursement request for the district is created and submitted in ePlan to draw down the appropriate funds for the district.
5. What if an employee has been terminated and is not available to sign their PAR?
Personnel Activity Report -should be used when a person is paid from multiple funding sources and meet the following requirements:
· Reflect actual time and effort, not budget estimate, determination of activities
· Account for total work activity of employee.
· Be signed by the employee
· Be prepared at least monthly (a separate PAR for each month) and coincide with one or more pay periods.
Distribution of activity on PAR should represent actual work performed by employee during periods covered by reports.
The PAR must be signed by the employee. If possible, schools should try and retrieve a signature during the employees’ exit interview.
To remain in compliance with federal regulations, we MUST have the employee’s signature, we cannot honor the reimbursement request if we do not have the employee’s signature.
6. What types of supporting documentation is required when claiming reimbursement for salary and fringe benefits?
Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed (CFR 200.430). The records must:
· Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated
· Be incorporated into the official records of the grantee
· Reasonably reflect the total activity for which the employee is compensated by the grantee, not exceeding 100% of compensated activities
· Encompass both federally assisted and all other activities compensated by the grantee
· Comply with the established accounting policies and practices of the grantee
· Support the distribution of the employee’s salary or wages among specific activities or cost objectives
When claiming reimbursement for fringe benefits, please remember that the amount claimed must be directly associated and aligned with the amount of salary claimed. The percentage of fringe claimed cannot exceed the percentage of salary claimed.
7. What types of supporting documentation does a school need to provide when claiming reimbursement for leasing technology?
For all non-personnel expenses, schools must submit an invoice verifying that the expense was incurred during the grant award period. Also, the invoice must contain a paid date.
8. What is the process for disputing Shelby County Schools’ billing?
Shelby County Schools’ billing will come from the Finance Team on a monthly basis. We are in the process of working out the policies and procedures for disputes and how they are handled. For more information, please email email@example.com.
9. What is the schedule for BEP payments and adjustments?
Monthly Payments Schedule
In August, September, October, November, December, January, February, March, April, and June, a BEP payment will be made on or shortly after the 15th of each month. However, in June, only 75% of the payment will be made on the 15th, the remainder will be made after the ADMs reconciled in late June or early July.
Adjustments (October, February)
Twice during the year, BEP dollars will be adjusted based on updated enrollment from EIS. Typically pulled during the first week of the month of the change (either October or February), the adjustments are changes made to the entire district’s allocation, as well as each school’s allocation. The new allocations follow the same formula as the initial allocation. However, the payment in the month of the change will be adjusted to accommodate the new annual award. The adjusted payment will be calculated by taking the revised year to date payments that would have been generated under the revised enrollment, and subtracting the amount paid.
10. How should a school request a budget revision?
It is expected that schools will make every attempt to adhere to their awarded grant budget. However, the ASD recognizes that changes to the budgets and timelines may become prudent or unavoidable. As such, the process for requesting a budget revision is as follows:
· A request for budget change must be submitted to the federal programs team at firstname.lastname@example.org.
· Requests for budget change must include the following information: A revised budget, and detailed narrative for each budget line-item changed.
The federal programs team will review the request and contact school if additional clarification is needed.
When the request is approved, the grant award notification and reimbursement workbook will be amended to reflect the approved budget change (if there is a change in the allocation) and a revised reimbursement workbook will be provided to the school to include the approved revised budget.
The budget revision windows are normally September 1-30 and March 1- 20. All budget revisions require prior approval from the federal programs team.
11. Can schools claim reimbursement for indirect costs?
Historically, the district has not allowed indirect costs to be charged to grant awards. As such, indirect costs are not included in the grant awards provided to schools and therefore cannot be claimed on any reimbursement requests. If in the future the district’s position on this changes, federal programs will notify schools.
12. Are schools required to participate in federal programs and finance conference calls and/or technical training sessions?
YES, schools are required to have at least one representative from their school present at ALL scheduled federal program and finance conference calls, webinars and technical training sessions.
13. How can a school download a complete copy of the TSIP in InformTN?
Schools can download a copy of the school improvement plan by following these steps:
• Navigate to the respective plan in InformTN
• Click on the review and submit plan section on the navigation bar at the top of the page
• At the top right side of the screen, you will see a few options for exporting (word and pdf).
• Select your desired file type.