Delivering Impact through Effective Grants Compliance and Oversight
This webinar provides OVC anti-trafficking grantees with information about effective grants compliance and oversight to meet grant requirements. Learn about subrecipient monitoring, agency internal controls, and common audit findings. The webinar was presented by the Office of Justice Programs' (OJP) Office of Audit, Assessment, and Management.
- The Financial Policies and Procedures Guide Sheets collection, developed by the OVC Tribal Financial Management Center, offers resources on internal controls, and other compliance and oversight topics.
- The DOJ Grants Financial Guide provides guidance and best practices that pass-through entities may consider in developing policies and procedures around making subawards and monitoring subrecipients.
- The Subawards and Procurement Contracts under OJP Awards resources help clarify the differences between subawards and procurement contracts under an OJP award and outlines the compliance and reporting requirements for each.
- The OJP Subaward and Procurement Toolkit provides guidance designed to help recipients of OJP grants and cooperative agreements understand subawards and procurement contracts and their administrative requirements.
- The Mini Toolkit for Subrecipient Monitoring gives high-level guidance on how OVC grant recipients must monitor subrecipients.
DARYL FOX: Good afternoon, everyone and welcome to today's webinar, “Delivering Impact through Effective Grants Compliance and Oversight,” hosted by the Office for Victims of Crime. At this time, it's my pleasure to introduce Kristin Weschler, Victim Justice Program Specialist with the Office for Victims of Crime for welcoming remarks and to begin the presentation. Kristin?
KRISTIN WESCHLER: Thank you, Daryl. And welcome everyone. I want to extend a special welcome to our fiscal year 2022 human trafficking grantees. We're delighted to have you with us today as you launch into your new awards. I'm not going to do any formal introduction, as we have a lot of information to get through.
But our presenter today is Lucy Mungle. She is a Risk Management Analyst with the Office of Audit Assessment and Management, and has many, many, many years of experience that she's going to share with us today. We are going to encourage everyone, as was noted, to post your--any questions during the presentation in the Q&A box that we will address at the end of the presentation. And with that, I'm going to hand it over to Lucy.
LUCY MUNGLE: Thank you, Kristin. Good afternoon everyone. And welcome to my fireside chat on the most exciting subject of grants, compliance, and financial management, and internal controls. Next slide.
So what we are going to talk about today is Effective Grants Compliance & Oversight, including subrecipient monitoring; reducing the risk of fraud, which goes towards requirements that are necessary in your financial management system, and system of internal controls; and audit requirements, so some of the more common findings that we have. Next slide.
So once we get done with the training, and please submit your questions, the idea is that everyone at the end of this training will understand where to go for guidance on grant management requirements. So there's lots of resources out there. They're exciting evening reading, especially if you want to get some sleep, and understand the financial management and internal control requirements that are in those and understand subrecipient management and monitoring requirements. And then recognize some of the common pitfalls that results in audit findings. So Effective Grants Compliance & Oversight will allow you to provide greater support to human trafficking survivors. Next slide.
So some of the key compliance resources, as I said, this is really exciting reading. Uniform Guidance 2 C.F.R. 200. And if you Google eCFR, you can get to it very easily. It's a good reference. It's usually very quick to find what you want in there. It's well- organized as a resource. The Green Book is the GAO's discussion on internal control requirements. And then the DOJ Grants Financial Guide. So the Grants Financial Guide, kind of, takes some key things from the various regulatory requirements and consolidates them along with some of the more unique DOJ requirements based on our programs. Next slide.
So, the 2 C.F.R. 200 is commonly referred to as Uniform Guidance, and it provides overarching guidelines and requirements for how to administer federal awards, and the expenditures associated with them. They are aimed at reducing administrative burden and improving outcomes. And there are lots of things in there that are useful and you should know. So the next slide, please.
We're going to--We're going to focus on some of the key requirements here. So The Green Book basically talks about the internal control principles. And we're going to go into a little bit more discussion on internal controls later. But years ago, and I'm dating myself here, but what happened is back in the '80s, the--there was a financial collapse of savings banks, and that resulted in this Committee of Sponsoring Organizations of the Treadway Commission. It was--It was talking about what do entities have to have in place in terms of internal controls that will prevent those types of things from happening? And then fast forward several years to the Enron issues, and the SOX-- Sarbanes Oxley requirements that, kind of, came out of that. That’s where all of these things, kind of, coalesced in terms of internal control requirements, risk management.
And The Green Book, kind of, takes that--and those--COSO is focused on the commercial environment. But The Green Book kind of takes it and says, "Okay. And the government and not profit environment, how should things really be looking?" So internal controls and processes are managed to help achieve objectives, so we'll go into that a little bit further of what a good internal control system looks like? Next slide, please.
So the DOJ Grants Financial Guide, the starting point, is referenced, right in your terms and conditions. You should be very familiar with the Grants Financial Guide, and the requirements in it. It is--It will reference to where that requirement’s coming from. Is it coming from 2 C.F.R.? Is it coming from some sort of legislation that requires the DOJ? Etc. So for example, it does have a section that's specific to the conference cost requirements. And those conference cost requirements, in many ways are specific to DOJ because there is legislation that is related to that. Next slide.
So the administrative requirements. Next slide.
They are coming from 2 C.F.R. 200 and they generally follow the Grants Lifecycle, which we started out with program planning. So we have an idea of what we think the funding will be and we plan the programs based upon the policymaker objectives, which is Congress and the White House and the programs that they want to advance. And then we start with the solicitations. And the draft goes up and that came in the pre- award cycle. And then applications come in. And then we make decisions on awards.
And then post-award is for managing those activities. And then close out is the final step. And throughout that process, we are looking at everything that happens in those processes, which then roll it back into our program planning, and how can we make it better, how can we effect what we want to in terms of our goals and objectives. Next slide.
So 2 C.F.R. outlines the administrative requirements. And it goes into the standards for financial and program management, we will go into that in a little bit more detail.
Property standards, so if you were purchasing equipment for--using grant funds, it will go through what the requirements are. Procurement standards, in general, you know to summarize that really quickly. For procurement, we're looking for arm's length transaction, competition, in order to ensure that the end result is the best value. Goes through performance and financial monitoring, recording, subrecipient monitoring and management. And subrecipient is more than just the monitoring, it is management of that whole award process. Record retention and access. Remedies for noncompliance. Closeout. Adjustments and continuing responsibilities. And if things are sent to collection, what happens in that process. Next slide.
So we're going to talk a little about Standards for Financial Management--Financial and Program Management.
So, Section 200.302 addresses the requirements for financial management. And the emphasis that I put in here is, my emphasis, but I've taken this language directly from
200.302. It requires that the financial management system identifies all of the federal awards received and expended and the federal programs in which they were received. What does that mean? That means you must track them separately. You must know the award number and with the award number comes the CFDA. Why is that important? Because when you go and do your single audit at the end of the day, at the end of each fiscal year, you're going to need to do what's called a schedule of federal expenditures by CFDA. So it's really important that information gets tracked. It gets tracked separately. When we come out and monitor, when the OIG comes out and audits, first thing we're going to ask for is the general ledger for that particular award. And it has to be tracked separately.
So accurate, current, and complete disclosure of the financial results of each federal award. And again, that's reinforcing and that is tracked separately and is very visible in terms of the results, you know, what money was brought in from the award, what did you draw, what was spent?
And those records should identify the source and application of funds. So there should be accounts related to that and separately, those accounts, right, they should tie into the budget categories for the budget that was submitted for that particular award.
Effective control over and accountability for all funds, property, and other assets. So if you are purchasing any kind of equipment or property, there is a requirement that an inventory be done and managed, that process needs to happen. The assets should be used solely for authorized purposes. So if it's 100 percent purposed--purchased with federal funds, right, it should only be used for those purposes.
Comparison of expenditures of budget amounts for each federal award. So when we come in and monitor, when the OIG comes in to audit, one of the first questions we're going to ask is, "Give us the general ledger, and then show how this is tracking against
the approved budget." So that budget to actual comparison on a continuous basis is a requirement of 2 C.F.R. 200 and it's something that we will look at in monitoring.
And again, the next one is written procedures to implement the requirements of
200.305. 200.305 basically says, "It's cash management." So you should only be drawing what you're going to expend in the next few business days. And I think Cash Management Improvement Act is 10 days. And so one of the things we look for, on our side, is we're looking for anyone that might be in what we call an excess cash position, meaning that they’ve drawn down more than they’ve reported for expenditures.
And when we also come out to monitor, we're going to ask to see your written procedures for managing your federal award, which should include your cash management, which should include in this bottom statement here, how you determine the allowability of costs, who's approving the expenses that are charged to the award, what's that approval process, who has authorization to do that, and etc. So that whole process needs to be documented in written procedures, that is a requirement. Next slide, please.
So internal controls. So 2 C.F.R. spends enough time on internal controls, when I went to do these slides, I came up with three slides for internal controls. And I re-referenced The Green Book here. Now The Green Book is very long, but the way that the GAO built it is, it's clickable by--it's a big PDF and you can click through the appendix that will take you to each subject. And I also linked here the website link for COSO. So again, just you know, COSO is more focused on commercial organizations, but conceptually, right, internal controls aren't that different between commercial organizations, government organizations, and not for profits. The differences are in government, you have the requirements to, you know, maintain a budget, and you have certain people who are authorized to do things and other people are not. So that's one of the major differences.
But the requirement is that the nonfederal entity, which is in this case the recipient of the award, must establish and maintain an effective internal control over the federal award that provides reasonable assurance that the nonfederal entity’s managing that award in compliance with the federal statutes, regulations, including 2 C.F.R. 200, and the terms and conditions of the federal award. So when the award--When you get awarded, there is a list of award conditions. And it's really important that you are familiar with those award conditions, because you're tied into those award conditions, and sometimes there's a lot of them. There's a standard list of conditions on every award. They require sometimes grants financial management training. They require that you comply with the DOJ Grants Financial Guide, and then there's program level requirements as well. And in some cases, if we, in our pre-award risk assessment, if we have assessed a higher risk, there may be some additional conditions that you would see on the award. Next slide.
So what is an effective internal control system? It's made up of these components. First, you have your control environment. So that control environment, that is the policies and
the procedures that define who can do what, and who can approve what, and how many levels of approval need to happen, and how it's all going to be recorded and tracked, etc. So that's the environment, that has to be documented. It's one of the first things we ask and one of the first things the OIG will ask for the audit is, "Give us your policies and procedures. We want to take a look at those."
Then there is a risk assessment process. So how do those work together? Well, that risk assessment process should be looking at what could possibly go wrong and in absence of no controls, what could go wrong? That's the first question when we do a risk assessment. And then, you say, "Okay, but we have these controls in place." So then you look at those controls compared to that risk assessment. And then you say, "Okay, now that we have these controls in place, given what we're doing in that, what could go wrong? And do we need more controls?" So that risk assessment process should be a continuous cycle. Looking at the control value because nothing in this world is static, and things change, regulations change, etc.
The control activities are the things that you're doing to do that. So you're actually signing a timesheet, you're approving a timesheet, or you're approving the booking of a particular expense into that award. That's the control activities.
Information and communication, there should be some sort of reporting functionality that says, "Hey, these are the controls that are happening and they're functioning and we know that nothing is going wrong." So, for example, information and communication would include reports that would tie out subledger balances to the main general ledger balance. And you know that they're in sync. So that type of information, the budget to actual is the information and communication piece, but it's also part of your control activities inscribed in your control environment.
And then monitoring, so there should be some sort of semi-independent process that's testing these controls, making sure they're effective. You could say that you have a control in place, that timesheets are reviewed by the first line supervisor every two weeks. But if it's not actually happening, even though you might have it documented, then that control is not effective. So that monitoring is looking to see that those things are actually happening, and there's a processes. It's basically a control audit type function. And so things combined together make for a control environment.
So some organizations are relatively flat, right? So when you put together your control environment and you maybe have 10 people in your organization, you take into account things like what are you going to report to the board of directors? How independent is that board of directors, those types of things? And compensating controls, like not every organization can get adequate segregation of duties. Well, if you don't have adequate segregation of duties in a particular place, well, then you're going to compensate by sending a report up to maybe the board of directors or your CFO or something like that. So it's really taking a look at what you have available, what your operating environment is, and how to effect a control system that works. Next slide.
So 200.303 and again I've linked these at the top of these slides. So if you click on that title, it's going to take you to 200.303. So the non-federal entity must comply and I bolded this with obviously the laws and regulations, but also the terms and conditions of the awards. Super important, once you accept that award, it is in effect a contract--it is treated as a contractual agreement, so you are bound to those terms and conditions.
You have to monitor the non-federal entity's compliance with the statute. So that goes back to that control environment. How are you making sure you're remaining in compliance with all the requirements and what processes are you putting in place to accomplish that? And, of course, things happen. Mistakes happen. They happen in every organization. But the key is that a good internal control system that will pop right up. You'll say, "Oh, that was booked into the wrong account, we're going to correct it. So we did this correcting entry, it's all approved, we made--we made the correction." And the standard of documentation there, is that an outsider, say and auditor, must be able to pick up that documentation, and figure out exactly what you did without having to ask the question.
And take reasonable measures to safeguard personally identifiable information. This is super important in this world, and making sure that anything that's personally identifiable, it is safeguarded and you have a process in place to do that and handle that. Next slide.
So subrecipient monitoring.
The first question that comes into mind is what exactly is a subrecipient? And we get this all the time. What's the difference between a subaward and a contract? Well, a subrecipient or a subaward is an entity that is going to effect a part of achieving the programmatic goals and objectives of the award. Where a contract is more just like a good or service. So a contract might be, you know, hiring an accountant as a contractor to track the books; that's a contract, or you know, buying a piece of equipment. Fairly straightforward. A subrecipient would be, you know, maybe a contract--I'm going to--I'm going to use this as an example because what is really important here is not the legal document to effect it; it is what is being done. So suppose you contract with an agency to provide counseling services; that contract, even though it is a contract, because it is achieving programmatic objectives of the award is a subaward. So it's--and there is--on our website, there is a whole section on how to make this determination and how to document it. The key is you go through this thought process of making a determination whether this entity is a subaward or a contract and document it. Next slide.
So again, we've talked about this. So a subrecipient might be someone who's determining who might be eligible to provide services to; where a contractor provides the goods and services within normal business operations. Performance is measured in relation to whether the objectives of the award are being achieved. A subaward has responsibility for programmatic decisionmaking. They must adhere to applicable program requirements specified in the award. And in many cases, with subawards, we're going to look to see if you are subawarding, if you're passing down the key award
terms and conditions to that subaward recipient. And then uses the federal funds to carry out a program for a public purpose. Next slide.
So if you have subrecipients, especially if you have several subrecipients, there is a requirement that you monitor them and that you develop a monitoring plan that is based off of a risk assessment of those subrecipients. And so that risk assessment is an important process. It must be tailored to your risk environment and the subrecipients involved. And the pass-through entity should develop a methodology to determine risk levels and the reason for assigning each of the subrecipients into risk categories. I get a lot of people--so I do the risk assessments for OJP and actually COPS, OVW also, and I get a lot of people that ask, well, you know, can you just send the type to do your risk assessment. And it's just--it's not that easy because our environment is not your environment. And so it really has to do with what environment you're operating in. But there are some things that you can look at, like obviously, the amount of the subrecipient award is probably a key risk factor. What's your past history with that subrecipient, have they been compliant in the past, have they not been compliant, but coming up with a logical rubric to look at everybody and you're looking at everybody the same way in order to kind of view them, you know, who poses more risk versus less risk. And then that risk assessment should then determine what your monitoring plan is going to be. Next slide, please.
So the monitoring plan should document the type of monitoring whether you're going to do a desk review, on-site, remote monitoring, and the identification of subrecipients that receive monitoring. And again, it's the plan. Things can change. And if your monitoring plan changes, that's okay. But you should be documenting why you changed the plan. So, for example, we'll have something come up and then we'll say, "Oh, we got to monitor this recipient." Well, we only have so many resources. So when we make a change like that, we will document why we brought that entity into our monitoring plan and why we dropped another entity. And just so that if someone else is coming in looking at it or if we're looking at it, you know, last year and we want to see what we did, it's clear what happened and why we did what we did.
So these monitoring activities should look to see if the subaward recipients carrying out the program activities, if they have adequate internal controls and financial management systems to protect federal funds, if the claims for reimbursement for costs are allowable, reasonable, allocable, and necessary under the program guidelines. Looking for conflicts of interest, you know? Are you conducting the procurement on a competitive basis, are the transactions at arm's length but not, you know, doing everything with their mom or something and you're looking for that type of activity. Maintaining required supporting documentation and records. So we have seen situations where maybe a prime recipient has had subawards and they've recorded expenditures from those subawards, but they couldn't be documented. And then going back to the subrecipient, they couldn't document it either. So I've seen situations where a lot of money has been disallowed in those cases, it's really important that expenditures are documented. Next slide.
So reducing the risk of fraud. Internal Controls are your first line of defense against the risk of fraud, and they can help reduce that risk. And, again, we've talked about the Green Book. And these elements of a good internal control systems. Next slide.
So what is fraud? So when you research fraud, you're going to come across something called the fraud triangle. And when fraud happens, these elements of the triangle typically exist because typically a lack of internal controls, which creates the opportunity, there's some sort of internal or external pressure. So that might be, say someone is, you know, got in over their head financially. So that might create the pressure for them to do something and then they rationalize it. Well, you know, I’ve worked really hard and they don’t pay me enough. And, you know, so then that happens. And those things kind of create that prime situation for fraud to happen. In general, it’s estimated that 10 percent of grant funds are lost to fraud. We’ve seen it happen. It does happen. And it's just one of those, you know, can you totally prevent it? Not always. But if you put in place a good internal control system, you're going to prevent much of it. Next slide.
So I talked about fraud. You know, fraud takes intent. But honestly, what we see most often are errors. And that is where a good internal control system is really going to prevent that. So even if you're making an error and you're booking expenses into a--an award that were not on the approved budget, right; those will be disallowed. And so errors are something we see most often. So, they're a little bit separate from fraud, waste, and abuse.
But fraud takes real intent. It's very hard to prove sometimes, but it takes--it takes real intent. Waste is more kind of like someone's just not really being a good steward of funds, you know? So they go out to buy a piece of equipment and they don't really go through a competitive process. They go to their friend who says, "Oh, yeah, I'll get you this." Right? Well, they could've maybe gotten that piece of equipment for less money, you know, somewhere else. But because they didn't exercise due diligence, then that money that could've gone to other better uses went to that piece of equipment, overpaying for a piece of equipment. So that's waste, not illegal but waste.
Abuse is more someone--so abuse is tied very closely to fraud. But--and I think you recall as we're talking about internal control, can't always catch certain situations. And one of the key things that it can't always catch unless you bring in a forensic auditor is management override, where you have management members that are colluding to basically override the system of internal controls. So that does happen. That is abuse of funds. Next slide.
So I put in--the last year's presentation had more of these in here, but there's a lot of information to cover, so I chose down. But these are kind of fun. So the question is you're planning to have a booth at an upcoming community event to provide information about your program. You purchase a high end projector so that you can have a slideshow playing in the background during the event. You decide that since you'll be able to use it at home to watch movies in the future it is a worthwhile purchase. Is that fraud? Yes or no? So I'm going to say in this situation, no. But is it a waste? Probably. Is
it abuse? I wouldn't go that far, but it's definitely not nothing wrong with this behavior. In this situation, if you don't have a continuing need for the high end projector, then you could probably rent one. Or if you do have a continuing need for that high end projector, should it have been booked entirely to that award or should it have been allocated amongst several expenditure categories. Next slide.
So you're taking a trip to attend the grantee meeting. You charge the penthouse suite to the grant, but when you arrive at the hotel, you actually stay in an economy room. You decide to not update your expense report. I'm going to address this in two ways. So suppose--this is a little bit different. Suppose you booked a penthouse suite for the grant and you do stay in the penthouse suite and you get reimbursed for it. Is that fraud? No. Is it waste? Yes. Is it abuse? Possibly. But in this situation, because you stayed in the economy room and your expense reimbursement will be at the penthouse suite rate that would be fraud because that's a situation where you are benefiting out of it and you've been dishonest on the actual expense report. So that's a case that would be fraud. Next slide.
You were recently awarded a federal grant. You're going to hire a contractor to supply and manage your office equipment. You choose to contract with Randy over at Office Services since you know his wife owns a car dealership and can give you a good deal on your next car. Is it fraud? No. Is it waste? Possibly. Depends on what you pay for the office equipment. It's certainly not an arm's length transaction. Is it abuse? I wouldn't go so far as to say it's abuse, but there's a possibility for waste here. So next slide.
So any time that you think there might possibly be an issue with fraud, you must contact the OIG. And you can find their link is on the U.S. Department of Justice website and how to contact them there. Next slide.
The OIG will conduct audits, and they also conduct investigations. Now, audits are routine. So if you get an audit notification from the OIG, don't panic. It doesn't mean that they think that you’ve conducted fraud or anything. They get from us our whole list of awards, they conduct their own risk assessment and then develop an audit plan from that. Some of them are totally random. Some of the selections are totally random. But investigations, they are looking at reports of possible misconduct. Next slide.
So what are some fraud red flags? And when I talk about red flags, I want to be clear that it doesn't--a red flag doesn't necessarily mean that something is wrong. It just could mean something's a little off or it just--no one red flag in and of itself is necessarily an indicator that fraud is happening. It's an indicator that that little triangle corner for opportunity might have opened. You know, so think of it that way.
So excess cash, that's when funds are being drawn in excess of the expenditures that have been spent on the award. That's an indicator that something might be wrong. Now, it might just be that whoever is calculating what they draw, either they don't understand the cash management requirements or they don't understand, you know, there's some
sort of issue in the way that they're calculating it. But, like I said, it's an indicator nine times out of 10, what we find there are errors, not necessarily fraud.
Unsupported expenditures. So, you know, when we go out and monitor, we will pick some transactions and we will say, "Give us a copy of the documentation to support this transaction." If you can't give that documentation, the next question’s going to be, "Well, why don't you have that documentation?" And again, it could be an error. It could be--I-- I've seen--I've seen situations back in the day where I had--I used to be a public accountant and I had a client whose business, their office building burned, and all of their records were gone with it. So, they couldn't provide support for their expenses. And those types of things do happen on occasion.
Commingling of funds. What does commingling mean? Commingling means that you're not keeping track of the award expenditures and inflows of the draws separately.
Performance and financial data don't match. So one of the things we look at is, you know, when that quarterly FFR comes in, and especially if it's coming in at the same period as that performance report, we're going to take a look at those two things in conjunction with each other. We'll look at where that award is in the period of performance meet the percentage of draws to date on that. So if 80 percent of the award has been drawn, but that performance report as of that same date says, "Oh, we haven't gotten started yet or we're struggling with that." Then those two aren't making sense together.
Conflict of interest. We've talked about that. On conflicts of interest, when you are coming at it from the standpoint of, you know, building a good conflict of interest policy, you want to address actual conflicts of interest and perceived conflicts of interest.
Because perceived conflicts of interest can also be damaging from a reputation standpoint. All it takes is a headline that, you know, so-and-so, you know, doesn't make sense that they would do this, you know, because it's a conflict of interest. Even if a conflict of interest didn’t really exist; if it's--if somebody else would perceive it as a conflict of interest, you have to think about how to handle those types of things.
Substantially high salary and contractor rates, we do have a caps on the contractor rates. There are limitations on salary rates, I think, for the executives, but, you know, that is something too. We’re looking for reasonable. So, if, you know, you're in a part of the country that would pay an accountant $80,000 a year, but you're paying them a
$150,000, is that reasonable? So we--you know, and there's plenty of data out there, especially in terms of labor, to determine what is a reasonable rate.
We're also looking for actual costs versus budgeted costs. Are they making sense? You know, so for example, if one part of the budget is being wildly outspent and the other part is, you know, nothing's happening on it. What's really going on with that particular award?
And then the lack of controls. You know, there are no written policies and procedures. There's no real separation of duties. So, those are some of the things. And a lot of times when something is happening, oftentimes you see multiple of these items together, and that's when--so the more you're seeing of these items together, then the more concern there is. Next slide.
So what do you do when you see these red flags? Like I said, some of them are indicators. You don't want to--you don't go and accuse somebody of fraud. But evaluate every--all the information you have at hand. Take a look at the DOJ Grants Financial Guide. Take a look at the award document and 2 C.F.R. 200. You know, take it in comparison to the information we have and see if something isn't--doesn't seem right.
You can submit that report, if something doesn't seem right. So you can talk to your grant manager, submit a report to the OIG Hotline, but definitely do not ignore it. Next slide.
So reducing the risk of fraud, waste, and abuse. Internal controls. I can't state it enough. Segregation of duties is one of those things that are part of this internal control system, and robust documentation and policies and procedures. Again, take a look at those resources there. We provided the Green Book, the DOJ Grants Financial Guide, 2
C.F.R. 200. And, you know, really take a good hard look at your internal controls. That really is the first line of defense. Next slide.
So, single audits are required for any entity that is expending more than $750,000 in the fiscal year, it's conducted by an external CPA firm of the recipient's choice. And so way back, previously in the conversation I mentioned that, you know, that you have to track that CFDA number, which I think now call the Assistance Listing Number and aggregate that on your schedule of expenditures of federal awards. That gets reported in the single audit. So it's really important to watch if you're going to have over $750,000 of all federal expenditures in a year to get a single audit done.
OIG grant audits. They might be auditing, you know, the key programmers, as part of the audit of that program, they're auditing the award that that you have. That happens. Other times, they're just auditing particular recipients and looking at how they're managing funds. They have a process for making a selection. Sometimes it's just random. Next slide.
We talked about the $750,000 threshold that is including 2 C.F.R. 200.501. Next slide.
So when you arrange for a single audit with your selected CPA firm, the single audit report must be submitted to the Federal Audit Clearinghouse and are due within nine months after the end of the fiscal year. The OIG responds--reviews those. What they do, is they pull the single audits related to DOJ awards. They review them and they will forward them to OJP if they feel that corrective action needs to be required. So, if you have findings on your single audit that are related to DOJ awards, we will end up with that and we’ll be conducting outreach to get those findings cleared up. Next slide.
So the OIG will notify you when they are going to conduct an audit. And then in that, they will set up an entrance conference and go through what that whole audit process will look like. It often takes several months for an audit to be completed. They will do a very deep dive into the records, and then they will issue an audit report at the end. And we’ll go through what they will be putting in that audit report in an exit conference. Next slide.
So, when the OIG audits or when we come out for monitoring, you have to provide the requested documentation in a timely manner. So, if we ask for documentation supporting a particular expenditure and you can't provide it and you can't provide it, you know, pretty much contemporaneously, that cost is going to be disallowed, and you'll have to return those funds. Well, there is an expectation that documentation is maintained contemporaneously and it shouldn't take months to find a supporting document. Next slide.
So what do we see in the audit findings?
So we handle all the OIG audits. We track what the findings look like. We try and develop training to, you know, kind of effectively, so that, you know, we don't see them any longer. So, if--so first, if there are audit findings and the recipient is not responsive to clearing up those findings, it may affect your award. We may hold your funds. New awards may not happen depending upon how severe the situation is. There may be disallowance of costs. You might get designated as high-risk. High-risk is a little bit of a misnomer here. It really means that it’s a known issue with a particular recipient and with their awards. And work very closely and do some close oversight to make sure that those issues are getting resolved. Or we may refer for debt collection to the Department of Treasury. Next slide.
So, again, a high-risk recipient is one, so if you have an audit and your findings don't get resolved within a year, chances are you're going to end up on the high-risk list. On that high risk list, you're going to end up with any new awards might have conditions related to that, your funds might be held, and there's all sorts of things that have to be managed more closely. So there’s--it is--it is not a--It's very labor intensive process, let's put it that way. Next slide.
So the top 10 audit findings, and I apologize the text is a little bit small. But we've seen that procedures are not documented. And again, if you--you know, if you remember way back when I was talking about the finance management system requirements and internal control requirements from 2 C.F.R. 200, there are specific requirements about having written procedures. Written procedures must be in place.
Financial and program reports are not actually prepared. So one of the things we will do is ask for a general ledger that matches up to the as-of-date, as of the most recent FFR and how those numbers tie out. So, you know, when we say, "Give us your FFR or give us your general ledger as of December 31st." And how that--those expenditures reconcile to what you put on the FFR as of that same date. And so the expectation’s it's
a nice, neat little package that shows, you know, total expenditures, and that number either matches the FFR or there's some sort of reconciliation between those two numbers. That is very clear and documented why that reconciliation had to happen.
Award conditions not met by the award recipients. So, we're talking about those conditions, it's really important that you read those terms and conditions, and that you are in compliance with them. So, for example, one of the most common conditions that gets put on an award is “do not obligate, expend, or drawdown funds until the budget is reviewed and approved by OJP.” So what does that mean? It means that you cannot spend any money, not just that you can't drawdown, we've got that taken care of. You know, your account is suspended with ASAP, you can't draw. But if you spend funds before the date that that budget is cleared, say you were paying someone's salary during--you know, say the award started October 1st, and the budget got cleared on November 30th, but you pay--you have a person assigned to that--to manage that award, and you were paying your salary, and booking it to that award for October and November. That cost is not allowable because the--that term says do not expend. You can't have anything before--anything with an incurred date before that budget was cleared. So that's really, really important that you're really familiar with the language of those, and particularly the withholding conditions, and what they require.
Questioned costs. We talked about costs that are unsupported and unallowable is a little bit different. So, an example of an unallowable cost is a cost that's not approved in the approved budget. So, you know, say you went out and bought six computers, but they weren't in the budget. Not allowable because it wasn't in the approved budget.
So the drawdowns not adequately supported or there’s excess cash-on-hand, we talked about that.
Matching funds were not provided or adequately supported. So, there's cash match, right, which is, you know, pretty straightforward. And then there's in-kind match, where you have services that are being provided and you're valuing those services to provide the value of the match. Where we see issues there is that valuation doesn't--isn't documented well in terms of the basis of the valuation. So labor should--those rates should be documented. And, again, census has all sorts of labor data. So, however you value something, there should be good documentation that that is fair market value.
Procurement not supported or inadequate procurement, usually it's not competitive. Or-- a lot of times what we see is that--well, that's number nine.
The suspension and debarment list is not checked in procurement or in the subaward environment. That information is available in SAM.gov. Please, please, check it before you award a contract or a subaward.
And then the accounting system is inadequate or doesn't properly account for grant funds. Next slide.
So we have some time for questions.
KRISTIN WESCHLER: Wow, great job, Lucy. That was a lot--a lot of information. Take a breath.
LUCY MUNGLE: Uh-hmm.
KRISTIN WESCHLER: Get a drink of water. So we do--I have seen--this is Kristin at-- with OVC. I do see that there are folks who have posted some questions in the Q&A box. Thank you so much. So what we'll do is run through these. Now, I believe some of these are more programmatic versus probably what Lucy will speak to. So between Lucy and myself, we'll address the questions. If there is something too specific, we may be directing you to follow-up with your grant manager. So we'll just see what the questions specifically are.
And the first one is one that I forgot to check in with you Lucy prior to the webinar, and that's “whether the slides will be shared with the participants after the presentation. so they have access to the links?”
LUCY MUNGLE: Yes. Yes, we can provide the slides.
KRISTIN WESCHLER: Okay. Thank you. All right. Let's see. All right. Next question is, “Is the Federal Financial Training required by our grant so--which is the DOJ Financial Management Training, is it to be offered in person this year or are we to be completing it online?”
LUCY MUNGLE: I don't know. We'll find about it being whether it's going to be offered in person. And don't hold me for this, but I think they are, at the very least, going to be doing webinar-based grants financial management. So you'll be able to interact with a live instructor, at least, and if they’re not going to be provided, like, in-person--in-person. So, but we'll verify that for you.
KRISTIN WESCHLER: Thanks. Oops. All right. So there was a question “asking for a link that will help distinguish between the subrecipient and contractor. And I know I've gone online but there's various ones. Lucy, is there a specific one that you would suggest that we reference?”
LUCY MUNGLE: Yes. So on ojp.gov, when you go to the top of that page. You know, it says about us, news center, and grants funding. And then over to the right is the training. Is it in training? It might be in grants funding?
KRISTIN WESCHLER: Well perhaps Lucy, what we can also do is… LUCY MUNGLE: We can also find here...
KRISTIN WESCHLER: Yeah, you can send the link to me and Daryl will make sure that we include it in the materials that are posted.
LUCY MUNGLE: It is in the grants funding. But we'll get you the specific link.
KRISTIN WESCHLER: Okay. Question is, “in our application, we described two entities as subawards. After going through the DOJ checklist, we realized they meet the description of a contractor. Does this require a GAM to change?”
LUCY MUNGLE: I personally would suggest that you do change that in your budget.
KRISTIN WESCHLER: Yeah. I was going to say programmatically, I would have the same response. Only because that is--there are two different budget categories in your budget, the subrecipient as well as your procurement. So talk, please, follow-up with your grants--assigned grant manager, if you are going to make that kind of modification, they can walk you through the process through the GAM submission. Okay.
The next question, “in the recent months we have won an OVC award and large-state award. We are working with our CFO to adjust our accounting processes. Is there a webinar or mentor or technical assistance we could access on the most streamlined way to set up our books to track multiple large grant awards?”
LUCY MUNGLE: Hmmm. So you've only had one award previously, is how I'm interpreting this question.
KRISTIN WESCHLER: Oh. LUCY MUNGLE: So...
KRISTIN WESCHLER: They have won, W-O-N; not one, O-N-E. So they did... LUCY MUNGLE: Yeah, yeah.
KRISTIN WESCHLER: …receive, yeah.
LUCY MUNGLE: So there's a couple of--you do have to track them separately. And I understand that systems can take time to put into place. And until you get your system change in place, go old school and track them on a spreadsheet. That is adequate. As long as you're tracking everything on a spreadsheet, it's tracked separately, you’ve got support for it, that is adequate. So you can do that as an interim step until you get whatever you need to do. I don't--I don't know what kind of financial management system you have, but whatever you need to do to get it set-up within the context of your system.
KRISTIN WESCHLER: If you are wanting some technical assistance in that area, I would also encourage you to follow-up with your grant manager. I know within OVC, we
have a number of training and technical assistance providers that might be able to provide some support in that area, so just reach out to them. But I appreciate your suggestion Lucy in the interim just to verify that, at least, you're documenting your costs separately at this point in time.
All right. The next question says, “I'm confused by what you just said about budget clearance. I thought we were told we could accrue and spend 10 percent prior to full budget clearance.”
So I can address this one because it's specific to your award conditions. So as Lucy said in her comments, you need to read your award conditions and the language. So for OVC 2022 grantees, you are correct, there are some parameters where you can spend a certain percentage prior to full budget clearance. However, in previous fiscal years that was not the case. So this is a very clear example where you need to be very familiar with your award conditions. And if you have questions about drawing down, then please, contact your grant manager before you start accruing costs.
LUCY MUNGLE: Yes. I cannot stress that enough, know those award conditions. And I know it's tedious. But it's really important that you really know everything that is going to happen on that award. And a lot of that is coming out in those award conditions.
KRISTIN WESCHLER: Yeah. From the program office--other than the resources that Lucy's gone over today, from the program office perspective, we would affirm definitely the DOJ Financial Management Guide or the DOJ Grants Financial Guide, your award conditions, but also your solicitation that you're funded under, because that will also give you clear guidance about what the parameters are of the activities for that fiscal year and what is allowable and unallowable. So that's another critical document.
All right. Question is, “once our budget is approved, are we able to request funds from the point of the start of the award?”
LUCY MUNGLE: No. So once the budget is approved, but it is--then expenditures can be incurred from that date forward. So like in my example before, right, where that--say that budget was approved on December 1st, come, you know, January, we would still expect that when we're looking at that general ledger, we would see nothing in terms of incurred expenditures for the dates October 1 through November 30th. Because the language on the conditions, and this is assuming a whole withhold, the language on the condition was do not obligate, expend, or drawdown. Now, if you have--can we just-- let's go through this language a little bit. So if you have language that says do not drawdown until the budget is approved, then yes, you can incur expenditures back to that October 1 date. Actually, I haven't told you, you couldn't expend. But we told you couldn't draw, so those are very different things. So if you have do not obligate or drawdown, right? That means, that you can't subaward or obligate--contractually obligate that money to anybody else. So if you go out and do a comp--and tie yourself into a contract during that time period, that would not be allowable because you cannot obligate the money during that timeframe. So it's really important to understand what
that language means. Expenditure means incurring expenses. Obligate means that you have--you have contractually obligated your--part of that money even though you might not have drawn it, even though you're not booking it as an expense, but you said, "We're going to subaward this or we're going to contract that." And you have contractually done that. And then drawdown is just--like it's a "We've got that covered." You know, we--we've got your ASAP account on suspend, that's covered, we're not going to allow that draw. So that piece is easy, but it's really that do not expend and do not obligate language that's really important.
KRISTIN WESCHLER: Yeah. So with--again, there is 2022 awards that have gone out, that have that 10 percent parameter, make sure you read very clearly, as per Lucy's language, like, expended versus drawdown versus commitment. So make sure you read the language clearly.
Next question is, “A nonprofit service partner has written into a grant application narrative and budget. The narrative and budget specifies the nonprofit as a subrecipient. Will there be an issue with a noncompetitive process?”
LUCY MUNGLE: Okay. So when you're working with a partner, right, so there's different subrecipient relationships. And so some applications come in where you are clearly working together as a partnership. So one of you has to be the fiscal agent, you know, the one that's drawing the money and then passing it to the other person, that's a fiscal agent. So that's a little bit different because you, kind of, come in as a partnership, right? So that's a different situation. And that's clear when you made the application, it's clear in that documentation. So I wouldn't say that that's like a sole sourced or anything like that, because you've made it very clear at the outset. Now sole sourced contract is different, right? So we have some cases where it's not too much a partner as it is an administrative contract. Someone who has the system--the computer system to run all of the subaward management, right? Then we would expect--because it’s going to take a big chunk of money and we would expect some sort of competitive process to happen with that. So, you know, that's where you're really getting into, kind of, gray areas where things aren't as cut and dry and we understand that. So that's when, you know, having the discussions with your grant manager are very important.
KRISTIN WESCHLER: Yeah. Lucy, I know this is very common in a number of applications because at the program office we ask them to identify partnerships or subrecipients if they are, you know, identified at the time of application. So if they include then a subrecipient in their budget is that assumed to then be approved or do they still need to do a sole sourced post award?
LUCY MUNGLE: That's a good question. We'll we need to get back to that, there's lot of--
KRISTIN WESCHLER: Okay.
LUCY MUNGLE: So, yeah. That--that's a good question because I don't know necessarily that this subaward--my initial answer is, you know, and my gut answer is if that subaward is approved during the budget process or the program office have seen it, OCFO has seen it, then yes, it's approved. But I just want--I want to double check that.
KRISTIN WESCHLER: Okay. That would be helpful. Because that's--it's very common. So we will make sure we clarify that and get that information out to everyone post- webinar.
I'm just--some of these questions, I think we've already answered. So I'm just reading-- let's see. All right. So this is regarding the 10 percent drawdown condition. “Can you-- when we received our award letter, it stated we could drawdown 10 percent of the award for start-up cost before the budget was approved.”
That is correct for 2022 awards. “Can you clarify this?”
So I'm confirming that.
“Are we only allowed to drawdown these after and or during the start-up?” I'm not quite--Are we...
LUCY MUNGLE: So…
KRISTIN WESCHLER: ...only allowed--go ahead.
LUCY MUNGLE: I think--I see. I’m looking at this and I think I got it. KRISTIN WESCHLER: Okay.
LUCY MUNGLE: So I can see why you're confused, right? So the way that it is structured, right? If we put an amount in there and it says--say you're awarded
$100,000, and we say, “do not draw, expend, obligate or drawdown other than, you know, up--other than the $10,000, right?” That $10,000 will be in your ASAP account available for draw. So you can expend up to that amount. You don't--you don't have to wait until after to do that drawdown. The way our system is structured is if you're allowed to expend that $10,000, it will allow you to draw those funds.
KRISTIN WESCHLER: That's correct. And if you don't see that reflected in your ASAP account, please reach out to your grant manager. Sometimes the award condition is a-- has a setting that might say what's the total withholding 100 percent. And then simply what that means is, as grant managers, we go in and release that 10 percent. So if there's a glitch with that, please contact your grant manager.
All right. And next question I know can be found in the Financial Guide, but I'll ask it and Lucy you can provide your response. “If we have an OVC-funded position at 100 percent, what sort of time sheet does that individual have to present to justify that each hour was an allowable expense?”
LUCY MUNGLE: That is in the Financial Guide. But I don't remember it specifically, Kristin.
KRISTIN WESCHLER: I’m sorry--
LUCY MUNGLE: It's been a long time since I’ve had to answer that question.
KRISTIN WESCHLER: I--yeah. Well, I mean, that's, like, there's a lot of information in the DOJ Financial Guide. I would certainly encourage you to start there. My initial, kind of, thought in response to that is a common one that I see when I do site visits. And that is, that people are a bit--doing timesheet based on budgeted hours and not actual hours. So you need to be tracking actual hours...
LUCY MUNGLE: Actual…
KRISTIN WESCHLER: ...of--yeah. Not the budgeted. So, in your budget, you might have said, you know--again, this is 100 percent position, but I'm going to say a 25 percent position. You're not just going to submit a timesheet with 25 percent and then call it good. We need to see actual hours that correspond with those 25 percent. And I would say the same case even with this 100 percent. Like, if it's a 40-hour workweek at 100 percent, we need to see that there's a timesheet showing 40 hours a week charged to this grant in the timesheet for that individual. Is there anything else you would add, Lucy?
LUCY MUNGLE: Yeah, I think that's important. Timesheets should reflect the actual hours. It's probably the most important thing.
KRISTIN WESCHLER: “What is the process for requesting approval for supplies or equipment that are not specifically included in the budget? Is there any budget flexibility?”
Oh. Do you want--I can answer my--from a program perspective, if you want, Lucy, or do you want to chime in first?
LUCY MUNGLE: Oh, no, go ahead and answer, and then I'll just tack on.
KRISTIN WESCHLER: Okay. So from a program office perspective, yes, we understand in a lot of our awards are 36 months. So things change even from the time of application
to award. So if things are necessary, again, you'll have to make sure it's necessary. If you think of Lucy's example of the projector that's going to be used one time, your grant manager is probably not going to say that's allowable or reasonable. So if there are supplies or equipment that you can justify that are not included in your budget, you will need to do a budget modification to allocate that as an approved line item in your budget. You would do a budget modification GAM in JustGrants and your grant manager can walk you through that process.
LUCY MUNGLE: Right. So this is a case where I really wish Michael Williams was still here because he always explained this beautifully. So there is a touch of flexibility budget and this is described in the Financial Guide. And you can move funds up to 10 percent of the budget. That is a cumulative amount. Right? That's not a one-time amount. So you have to track how much you've moved and whether you've exceeded that 10 percent. So there is a little bit of flexibility. But, you know, the accountant and auditor in me would rather just do a GAM. Quite honestly, do the--do the budget change in Just--and not have to explain something like that after the fact. That's me. I'm very conservative when it comes to financial things, especially when OIG might come and audit down the line. I don't want to have to explain anything. So that would be the conservative side of me, no issue to do that. But like I said, there is--there is a little bit of flexibility, but it's well explained in the Financial Guide.
KRISTIN WESCHLER: Yeah. The other thing I'll add, because--yes, you were correct, Michael Williams would have a lot to say about this. And in the Financial Guide--so, there's the DOJ guidance. And then there is the OJP guidance. And this recently came up in discussion in our office. So the DOJ Financial Guide does say there's the 10 percent flexibility. However, the OJP guidance encourages a budget mod for any change, regardless…
LUCY MUNGLE: Yes.
KRISTIN WESCHLER: …of the 10 percent rule, which kind of speaks to Lucy like the conservative side. Because even as grant manages for us and making sure that everyone, meaning your grant manager, OCFO, OAAM, everyone has the same version of your budget, we encourage a budget mod for any adjustments.
So, okay, someone is asking and I don't know if we can do this without sharing a screen, Lucy, but I'll ask the question and maybe you can provide some guidance or directive is “to go over how to check for debarment on SAM.gov and how to document that that's been done in order to satisfy auditors.”
LUCY MUNGLE: Okay. So there's two ways on SAM.gov to do it. One, you can look them up by their UEI. And if they are debarred, you know, that status page will say that they're debarred, and so I would--or that they are active, right? So the key is take that screenshot with the date on your computer screen, the day that you're, you know, you’re checking that and include that in your procurement file. So you don't have to print that, you can just save it as an electronic screen shot that's fine. So that's how I would check
it. There is also a download from SAM.gov, all of the excluded parties list that you can download and check against that. And so again, when you--if you set up an API or whatever to download that on a regular basis and you're checking it within your own system, again, take that screenshot that shows the most recent download of that excluded parties list, that that entity is not or is on the excluded parties list and the date that you checked and include that in your procurement file.
KRISTIN WESCHLER: Awesome. Thank you. The next question is about audit. “Can you please review the different types of audits and what's required if you are under the
LUCY MUNGLE: Okay. So, over the $750,000 threshold, you are required to have a single audit and that is conducted by a CPA firm of your choice, and then they have to file that report to the Federal Audit Clearinghouse. Under $750,000, you do not have to have a single audit. And so unless there is some sort, and we don't typically do this, but sometimes there is a reason why--and for some other federal entities, why--you know, the terms and conditions might require an audit. So, again, know your terms and conditions. And in those cases those would be like a program level audit or whatever.
And I have never seen that happen for a DOJ award. But so--but if you're dealing with another federal agency, I would say make sure you're checking your terms and conditions to make sure there isn't some sort of audit required, because that can be a requirement, especially if you've been designated high risk and--or have some sort of higher risk situation going on. So that's a single audit requirement.
Now, an OIG audit is different, that's the Office of the Inspector General. And so, for example, if the OVC's Human Trafficking Program were audited as a program by the OIG, several of the recipients of the--that program might also have individual audits conducted by the OIG, and those are what are called OIG Grant Audits. Now, there is no dollar threshold for them or whatever. So an OIG Grant Audit can be precipitated by they’re auditing OJP as part of the program level audit or the OIG is part--because they know all the awards that we make and they do an audit plan. And you may be selected as part of that--part of their risk assessment process. It might not be related to a program audit. Again, there is no dollar threshold for that. It might be totally random. But those are the types of audits. An OIG audit is going to be focused on the awards that they will note to you in the notification letter.
KRISTIN WESCHLER: Thanks, Lucy. Do you--a follow-up question for me is, “Do you have any recommendations just from best practice standard, if there is an entity that has less than $750,000 in federal funds, as far as fiscal responsibility?”
LUCY MUNGLE: So less than $750,000, you know, good internal controls, and that would include, you know--that--those internal controls, which would include production of some sort of periodic set of financial statements that is going to a board or senior management or something and being reviewed, etc. That's good internal control. I mean, there's nothing that doesn't say that you can't--and most entities with a certain amount of revenue are getting audited, especially, if they have any sort of debt,
because the bank will generally require some sort of audit or review by some sort of independent public accountant. So, a periodic audit on an annual basis is great. It doesn't necessarily need to go to the level of a single audit because a single audit has a few more requirements than a regular financial statement audits. But that second set of eyes to take a look at your finances, and--is just kind of a great thing to have. And if for whatever reason you're not doing that, some sort of internal audit would be the next level. And if you can't do that, then the next level is, you know, making sure that those internal financial statements are produced on a periodic basis. There's some sort of policy and procedure around how often you produce them, what they're going to look like, what information they should cover, etc., and who is going to review them.
KRISTIN WESCHLER: Wonderful. Thanks, Lucy.
I do see an “ask about the links for the Green Book, the 2 C.F.R. 200 and the--well, Yellow Book. I'm assuming that's DOJ Financial Guide.”
Oh, the Yellow Book. Oh I think--oh, that was the visual, I do remember in Lucy slides. You'll have access to those links when you get the PowerPoint presentation.
LUCY MUNGLE: Yeah.
KRISTIN WESCHLER: But I know also Tammy put links earlier and she’s just posted them again in the chat. I think those are for everything but the Yellow Book. But you will get links.
LUCY MUNGLE: Yeah, so the Yellow… The Yellow Book is actually the guidance to audit firms that conduct single audits. Just so everyone knows that, that's what the Yellow Book is. The Green Book is internal control guidance. So the Yellow Book is the GAO telling single auditors, "Hey, this is the way we expect that you will conduct single audits."
KRISTIN WESCHLER: Awesome. All right. We're almost there.
“Is a separate audit needed for DOJ funds, if your company is audited, as a whole, yearly?”
LUCY MUNGLE: Well, that depends. You know, if you have federal expenditures. If you have federal expenditures over $750,000, your audit as a whole, that engagement should also include the single audit. Right? So--but outside of that, there's no requirement.
KRISTIN WESCHLER: Where--I can answer this question. “Where in JustGrants can I see the date our budget was approved?”
You should be able to see it--that it'll be under a GAM. That's your--OCFO will issue a GAM document to the program office that the budget has been approved. Your
designated point of contact in JustGrants should also be getting notifications from JustGrants upon GAM approvals. But it's under the GAM tab in JustGrants. And if you have trouble, your grant manager can also help you find that information.
And I think the last question is, “Does a dollar amount or what is paid either in a year or during the full grant period matter in the determination of a subrecipient versus a contractor?”
LUCY MUNGLE: No, it does not. What matters is what they are going to do.
KRISTIN WESCHLER: The one thing I will note, only because the question includes a reference to asking about a dollar amount, is there are FF--FFATA requirements to report over and beyond a certain threshold. I'll let Lucy talk about that.
LUCY MUNGLE: Yeah. So that's $30,000. Any subawards over $30,000 must be reported through FSRS.gov. However, there is some confusion. You can report all of your subawards through FSRS.gov, we have recipients that do that. And so the requirement is over $30,000, but that doesn't mean that you can't report any subaward under $30,000.
KRISTIN WESCHLER: Got it. Another one just come in about timesheet. “Is an electric timecard from a timekeeping system an acceptable form of backup as a timecard to charge payroll to a grant?”
LUCY MUNGLE: Yes. As long as it has the appropriate processes to, you know, facilitate, review and approval of the timecard and track the hours by project.
KRISTIN WESCHLER: Yeah. The important thing when we go out and do site visits, is as long as that electronic system tracks actual hours and we can see that it's been approved by a supervisor. Those are two parameters that are often missed when we do monitoring, so.
Oh, goodness, they keep popping up. All right. “What JustGrants person is responsible for reporting the subawards on FSRS.gov?”
LUCY MUNGLE: So, what's the question?
KRISTIN WESCHLER: Yeah, this--well, the question is, “What JustGrants person is responsible for reporting the FFATA requirements in the FFF--FSRS.gov?”
And those are two separate systems. So any--based on my understanding, anyone can report.
LUCY MUNGLE: So let me explain how the process works. So what happens is we take all of our award information and we submit that data to USAspending.gov and that data then gets populated from USAspending.gov back to FSRS.gov. And then, FSRS is where the prime recipient, that got the award from us, can go in and find their award from us because it's been populated from USAspending.gov people, which we put that there, and they can then enter the subawards in FSRS.gov. That data then populates-- that subaward data then populates back to USAspending.gov as the subaward data for all of the awards. So it's kind of like a figure eight, if you think about it. We're sending the information, OJP submits the award data to USAspending. USAspending takes that prime recipient award data, populates it into FSRS.gov. You, as the prime recipient, go into FSRS.gov, find your award, populate the subrecipient data. Then FSRS takes that subrecipient data and populates it back to USAspending.gov.
KRISTIN WESCHLER: But--so just to clarify, so your assignments in JustGrants are independent of who can submit information in the FSRS. So I just wanted to clarify that.
LUCY MUNGLE: Correct.
KRISTIN WESCHLER: All right. If you have additional questions, we have reached our time. And in fact, that's the end of the questions I see in the Q&A. If you have additional questions, please, please feel free to reach out to your grant manager. We have access to Lucy, as needed.
But I want to really extend a sincere appreciation for Lucy Mungle joining us today and sharing her knowledge and experience on subrecipient monitoring, and audits, and internal controls, and some wonderful resources.
We will be posting this information online. We will make sure that you get that information.
And I'm going to turn it back to Daryl just in case there's any other loose ends that I'm forgetting.
DARYL FOX: Well, that sums it up wonderfully. So once again, just be on a lookout. And we'll send a notice to the registrants for today on where those items will be posted once they are. So on behalf of the Office for Victims of Crime and our panelists, we want to thank you for joining today's webinar. This will end today's presentation.
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