OVC Tribal Victim Services Set-Aside Program: FY 2022 Grantee Orientation Effective Financial Management Webinar

MARLENE MACK: Let me start by introducing myself. I'm Marlene Mack. I'm an enrolled member of the Nome Eskimo Tribe in Alaska, and I'm also a TA specialist here at the T-VSTTA team. You've been invited here today because you've been awarded the fiscal year 2022 Tribal Victim Services Set Aside Grant. We'd like to welcome you to the grantee community. I'd like to share a few helpful housekeeping items before we begin.

This session is going to be recorded and will be available to the public on the OVC TVSSA website in about 10 days. We dropped the link to the site in the chat. If you have any questions throughout the session today, please enter your questions through the Q and A feature at the bottom of your screen instead of the chat feature. This will help us address your questions more quickly. We also invite you to use the chat feature today for general communication with the hosts or fellow participants and find the resources that our presenters will share today.

To help with audio quality, all lines are in listening mode. If you are listening through your computer, please select the speakers or headphones that you wish to use. If you are experiencing any technical issues with this session, please let us know in the chat box and email our technical support using the email address on the screen, [email protected]. And if you haven't already done so, please use the chat now to tell us where you're from and say hello to the group. If you would like to use closed captioning, please click on the CC button at the bottom of your screen. Now to Kristene Moore, thank you Kristene.

KRISTENE MOORE: Thanks, Marlene. Good afternoon or good morning, depending on where you're joining us from. We're excited for you all to be joining us today. For the last part of this webinar series, we're going to be talking about effective financial management of your team. Room for some poll questions and we'll address any other questions at the end of the presentation. So, my name is Kristene Moore and I'm joining you from Long Island, New York. I'm a financial specialist and the training lead with the Tribal Financial Management Center, or TFMC for short. I bring with me years of experience managing the financial aspects of federal, state, local government and private sponsors of sponsored awards and I have been where you are. I have been a grantee of the DOJ award, so hopefully I bring some of that experience with me in the presentation today.

So many of us already work together, but for those of you we haven't had the chance to meet, and those of you who are not on some of the prior webinars from this series, I'd like to tell you a little bit about us. The Tribal Financial Management Center launched in the fall of 2018, and TFMC serves close to 300 Tribal grantees with more than 800 OJP awards. We work closely with your OVC grant managers and the program TA providers, T-VSTTA, to provide training and technical assistance, as well as other resources to support American Indian and Alaska Native grantees and grant applicants.

Our team is composed of skilled financial, TTA and evaluation specialists uniquely qualified to serve grantees with a range of expertise, including working in victim services, vast financial management subject matter expertise, and familiarity with trauma-informed and culturally humbled TA. TFMC support helps build a strong financial management foundation for each community's victim services program. And with that said, let's go ahead and get started.

So again, we're delighted for you to be here today with us. And we look forward to providing additional information and resources to accompany you on your grant's financial management journey. We will share best practices for the financial management of your TVSSA award, and our hope is that you take away some new information or reinforce some already existing knowledge that you have on the following by the end of this presentation. Understanding federal grant award requirements and responsibilities, maintaining a grant folder, basic recordkeeping principles, determining allowable costs, indirect costs, the importance of budget reviews and budget monitoring, being audit ready. And each of these topics could really be their own training webinar. But we just want to touch on elements of each here today to get you started on this journey.

As you saw in the last slide, we have a few stops today. Let's start with talking about some of the basics of grant financial management. Understanding your federal grant award requirements and responsibilities is incredibly important for successfully managing your award. And as we stated earlier, we're going to have a few poll questions throughout today's presentation. So here is the first one. Do you know where your entity's federal grant management responsibilities are documented? There should have been a popup on your screen if you joined us through the computer. And you can go ahead and answer yes or no for this question. Do you know where your entity's federal grant management responsibilities are documented? We'll go ahead and give everybody just a minute or so, and then we can go ahead and close it out, and let's see the results. Okay, so the majority of you do and knowing where those are documented, is a great first step to successful grants financial management. Thank you for participating in that poll.

When a Tribal entity accepts federal grant funds, the entity agrees to accept all the responsibilities for administrating the grant. This includes complying with all the general and special grant provisions. These provisions are things like abiding by federal cost principles, which means only expending grant funds on allowable costs, accounting for administrative costs, retaining all records needed to document grant activities such as payroll, time and effort reports, checks with backup documentation, correspondence with the project partners and funders, and fulfilling any match requirements. And we list the match requirement because it is important, but they're not actually applicable to your TVSSA grants, what we're here to talk about today.

To understand the federal requirements, grantees are strongly encouraged to engage project and financial team members in a thorough review of the notice of your grant award to ensure that the requirements for reporting are allowable costs and providing that matched funds are understood by all of the team members. All project team members are clear on who is responsible for each fiscal task, and which project team members are responsible for each program task. And we want to emphasize the importance of the continued communication between the fiscal and program staff throughout the life of the award. Now that we've touched on understanding your federal grant requirements and responsibilities, we'll continue on this journey to this section about maintaining a grant folder. And we recommend getting this set up at the onset of receiving your new award. We'll talk a little bit how to develop a system to organize, maintain, and track your efforts toward compliance with the grants.

But before we jump into the content for this section, here's another poll question. So up on your screen, it should pop up the question, do you have a grant folder for each of your awards? When it pops up on your screen, you can go ahead and select yes or no for the poll. And a grant folder is like just a designated location where you'll keep all your grant-related documentation. So, do you keep, do you have a folder for your awards, yes or no? Okay, awesome. So, let's see those results, all of you do. That is phenomenal, having that central location is key. So, thank you to everybody who answered, and let's jump into a couple of those details.

A cover page for your grant folder is a great place to start. This will kind of summarize some of the details of the specific federal award. So, this slide you'll see on the screen right now, if you're joining from your computer, provides a sample post-award grant management file information page, and then our chat box monitor, Tamara, should have placed a link to this in the chat box. And if you go through that link, you'll be able to download a copy of the document you see on the slide right now. And you'll see in this image some of the general details that would be included, such as award amount, start and end dates, et cetera. Just again, a lot of the general information for the award that summarizes it when somebody opens it.

Okay, so after the summary page, we actually recommend your grant folder having multiple sections. This slide provides a six-section tried and true example of how to set up a grant folder. Section one would be a grant summary. Section two would be the funding documents, the award notice. Section three would be budgets, the original budget, any subsequent budget modifications. Section four would be your funder correspondence, things like communication with your OVC grant manager. Section five would be project team correspondence, any internal communication that's relevant that you want to keep on record for future reference. Section six, financial reports. And TFMC has put together a job aid that goes into these sections in more detail. And Tamara, would you go ahead and post a link to that specific resource in the chat box for us? Okay, awesome.

Okay, so we talked through the different sections and what those might look like. And now let's talk about the actual documentation you would want included in this folder. So here on the screen you'll see some examples. Reports, these could be programmatic and financial, backup documentation, like expenses, or if you have a particular form that you internally filled out to charge expenses to grants, copies of any procurement contracts, et cetera, stuff like that, that, again, you're going to want to go back and reference or somebody else might want to go back and reference later on.

Okay, so let's pause here for a question. And instead of a poll, let's switch it up a little bit. And we'd like for you to actually use the chat box to provide a response. We want to know what else you might keep in your grant folder for easy access. So go ahead and put that in the chat box. Again, we just touched on a few on the prior slides. So, what's really helpful for you all to have in that one central location, in a grant folder? Great, contact information. Who do you reach out to for what it is very helpful to have, especially in the event of staff turnover. Having that right there in one package helps who's ever filling a position next to have all of that accessible. Training documents, period performance, budget detail worksheet, awesome. Yeah, training certificates, that's one of those grant requirements that DOJ grants financial management training, having the certificates on file if they're ever requested in one spot. Time and task plan. Those are all awesome and all highly recommended to have.

Again, having that one location, and thank you all for contributing and putting all that stuff in the chat. It's just really helpful for everybody to kind of see what everybody else does and learn and grow with it. Having that one location where all the relevant and important documentation can be found will be helpful throughout the life of your grant. Remember, while you're going to set this up at the beginning of the award, it's going to be maintained and updated throughout the life of it through the closeout.

Okay, so now that you have your grant folder set up, let's review some basic recordkeeping principles and provide some recommendations. Backup documentation and recordkeeping is essential when managing your award. Let's start by reviewing the types of records that you need to have on file for your grant. You'll see on the screen some of the grant management records that should be readily available for review. This could be internally or externally if somebody requests it. And these may be kept by different departments, you know, procurement or your finance department and your program group might all keep documents separately. But as we mentioned in the last section, it's extremely helpful to have as much as possible in one central location. So, if anybody needs to access it, they're not going through multiple channels. So, example, if your procurement department keeps the original purchasing documents, whether that's a contractual agreement or whatnot, you may want to keep a copy of that in your grant folder as well.

And due to the important nature of grant records, it is common to have a requirement that your grant records are kept in secure fireproof cabinets, backed up on a regular basis in a secure electronic format, and or stored offsite. We actually recommend keeping both paper and electronic files to document your grants management processes. You know, if you only have electronic and the internet goes out, you might not be able to access them. If you only have paper, and there's a water incident or a fire, again, having both is the most recommended approach here. And this slide shows those examples we just mentioned. And also, some additional best practices for recordkeeping. Regular backups, copies, and originals of receipt, et cetera.

Documenting a cost properly to be in compliance with both your entity's policies and procedures and the federal government's regulations is key to strong grants financial management. You'll see some examples again on this screen of what backup documentation might consist of, but let's go through a couple of specific examples. Let's start with mileage. You are using your personal vehicle for grant related travel. What would the backup for that mileage reimbursement look like? Well, you would want to document the mileage rate you have in your reimbursement calculation. Are you using that GSA personal vehicle mileage rate? Does your entity have a different approved rate, which must be lower than that GSA rate? Again, just something that verifies where that number in your calculation is coming from. So have that as the backup documentation.

And the second piece is how that total mileage was determined, right. So, you travel 300 miles, where does that 300 come from? Something as simple as a Google Maps printout will support that part of the calculation. And then lastly, you want something to document the purpose of your trip. Is there an agenda, can you provide a brief description? Perhaps your reimbursement request has an area to provide that additional detail. Those three pieces will suffice as backup documentation for mileage in that specific instance. So that's an example of that. And another thing to have as backup documentation that's helpful is if you use that GSA mileage rate, just printing out a screenshot of it from the website and having that as backup documentation too. Again, it's just that added level to support where the rate's coming from.

Now let's talk about a more broad travel reimbursement and what some backup documentation for that would look like. Let's say you went to an OVC approved conference or event. Backup documentation for that, you would want all of your itemized receipts, itemized receipts for your actual costs incurred that you're asking to be reimbursed. So, do you have airfare on there? You want the itemized airfare receipt that breaks down all the costs. Do you have lodging, you want that final lodging receipt. Again, that's itemized, shows the breakdown of the costs per night. Any cabs or taxis, again, just to support why you're asking for reimbursement for those costs.

The second piece of documentation you're going to want is the purpose of your trip. Do you have a flyer for it? Is there an agenda for the trip? Can you print something out from the website that confirms, you know, a brief description of it, the title of it, the dates of it, the location, again, just to support why it's being charged to this grant, that it's related. And then one thing I just want to plug here is for hotels, remember that the lodging must be supported by receipts showing your actual costs. So, while the GSA sets what they say is the approved average rate for a certain location at a certain month in time, you can only reimburse for the cost you're incurred. So, you can go up to that GSA rate, but if your actual costs were less than that, and your receipt shows that it was less than that, you can only be reimbursed for that lower amount.

That's why it's important to have all of that itemized backup documentation to justify the cost. Some other backup documentation that can be included for travel costs but might not be relevant in all cases, if you communicate with your funder or your OVC grant manager about a specific expense for travel, print that email out, put it with the backup documentation. Did you reach out to them in advance to make sure that that specific event was allowable, and the cost could be charged to your project? Go ahead and print that out and keep that with your backup documentation. Again, having all this backup documentation at the time of reimbursement, just make sure that it's all set for when it needs to be pulled later for either internal or external review.

And I mentioned the GSA rate a couple of times. And Tamara went ahead and put the link to that in the chat. You want to make sure that you refer back to this each time you're planning any travel event to make sure that you're in compliance with what the government says is those reasonable rates for those locations of where you're going. All right, so we talked in detail about backup documentation for mileage costs and other travel. So now that brings us to the last example of backup documentation we want to touch on today, which is payroll. And we actually gave this example its own slides just to make sure that we cover everything.

But before we jump into that, another poll question. So, when it pops up on your screen, you'll see the question how do you track your time spent working on your award? Do you track it through a paper system, an electronic system, or both? If you could go ahead and just put an answer in for what you all follow, we'll just give you a couple of minutes. Okay, so paper, electronic or both? How do you track the time that you spent working on your award? And the results are in, a lot of you do electronic and a lot of you do both. That is awesome. And let's get into why having a tracking system is important for that.

Let's review the types of records that you need to have on file for your grant award. Personnel expenses. These can include salaries and wages and benefits, and need to be supported by the backup documentation. So generally, employees who charge their time to multiple funding sources, which could be federal awards, or a mix of federal and non-federal programs, they're going to complete time sheets, which should include the following information. You're going to want the number of hours worked on each program for each day. The total number of hours worked during the payroll period, the employee signature and the signature of that employee's supervisor.

Now, employees who don't have their time spread out across multiple funding sources, but who charge 100% of their time to a specific federal award, they can choose to fill out a time sheet just as we described it, or they can complete a time certification. So, time certification state that an employee worked 100% of their time on one federal award. These certifications are generally required to be completed at least semi-annually after the work has been performed and kept on file. Again, you don't want to certify before, it should always be after.

And now what you see here on this next slide is the documentation that you'll want to maintain. And again, these could be requested during a financial review, potentially internally or externally. So, the time sheets. So again, not only do you want the physical time sheets themselves that show the hours, but that documentation should be signed by both the employee and their supervisor. This certifies that the information on the time sheet is true and accurate, those signatures are important. Additionally, a general ledger, which may come from your accounting software system, which is going to show the personnel costs broken down by employee, by their rate of pay, by the total hours they worked on the grant during each pay period, it'll show their fringe benefits for that employee broken out separately, and then it'll show the total paid to each employee. And that touches high level on the time and effort tracking, and kind of wraps up our section on basic recordkeeping principles needed for your effective grants financial management.

We touched on backup documentation, but let's take a few steps back here, and let's talk about how to determine if a cost is actually allowable on your federal award. So even before you have that backup documentation for the costs, can you charge it there? So, understanding the difference between allowable and unallowable costs is key to managing your grant. Make sure you review the grant solicitation and the DOJ grant's financial guide to ensure all your costs are allowable. The TVSSA solicitation is updated each year of funding. So, make sure that you are referencing the fiscal year 2022 solicitation for your fiscal year 2022 award. I'm sure a lot of you have multiple years funding for TVSSA, so again, just make sure you're referencing the right solicitation because they make slight changes year over year.

This slide here on your screen right now shows the three questions you should ask yourself prior to incurring a cost. One of those being is the cost reasonable and justifiable? For example, if you have three project staff assigned to this award, it would not be reasonable or justifiable to request 10 computers for staff. Another question you'll want to ask is can the cost be allocated specifically to this project? Sometimes you may want to use your OVC funds for things that cross over into other programs not funded by TVSSA. An example would be purchasing a case management tracking system. It'll be used for your victim service services program, but also other programs operated by the Tribe. So, a portion of the case management software may be allocated to this award but not the entire amount. You'll need to determine what percentage of use you can charge to this award specifically.

And as we just mentioned, your grant solicitation is a great resource for determining allowable costs. OVC has provided grantees with the chart of allowable and unallowable cost examples. It's very unique and a phenomenal resource for this specific program. So, we're actually going to put a link to that in the chat for you. And again, review the solicitation document in its entirety and use the chart provided to ensure all your costs are allowable. Now for the OVC Tribal grantees that we currently work with, we put together some examples of allowable and unallowable costs under the equipment category that come up pretty frequently. This specific one is, the top one is vehicles, which are allowable in general, but anything that supports the law enforcement activities would be unallowable. And another example is a security system. Cameras, monitors, doors that kind of, like door contacts, that kind of stuff, is allowable, but if it's for public buildings like a courthouse or police stations, that would not be allowable.

In general, some expenses may seem allowable, but having the context of what it's going to be used for will help you really solidify whether you can charge it to the grant or not. So definitely refer back to that cost chart we were talking about. And then when you're unsure whether a specific cost is allowable or unallowable, one of the first things you should always ask yourself is does this cost relate specifically to serving victims? If you're not sure, if you're still unsure after that question, always go to your OVC grant manager. They are a great contact and a great resource, and will be able to talk through it with you, and get to the determination. Now another example of an allowable cost on your TVSSA award is indirect costs, which brings us to our next section. So, let's explore this topic.

The indirect costs are those which cannot be readily identified as benefiting a specific program or cost objective. They're usually referred to as overhead expenses, and can be things such as rent and utilities, as well as admin expenses, including officer salaries, accounting department costs and personnel department costs. And again, that's generally. And indirect costs, like we said, are allowable and may be charged to your award, but only if, A, the recipient has a current unexpired, federally approved indirect cost rate, or B, the recipient is eligible to use and elects to use that de minimis indirect cost rate, which is 10%, as described in part 200, uniform requirements, and the DOJ grant's financial guide.

The grantees that do not have an approved federal indirect cost rate, you may either negotiate an indirect cost rate with your cognizant federal agency. or you can elect a charge, again, that de minimis rate of 10% of modified total direct costs. When you're using a de minimis method, the cost must be consistently charged as either direct or indirect, but you can't double charge or inconsistently charge between those two different categories. And then also, if you're using the de minimis method, you must use it consistently on all of your federal awards until such a time as an indirect cost rate is negotiated if you're choosing to do that.

An indirect cost rate proposal is the documentation prepared by an organization requesting an indirect cost rate from the federal government. This package typically includes the proposal, related audited financial statements, and other details that support, such as the general ledger or the Tribal balance, et cetera. Generally, Tribal nations negotiate their indirect cost rate with the Department of Interior generally, which would be called your cognizant agency. And typically, nonprofits which provide general public assistance have the US Department of Health and Human Services as their cognizant agency. So, a cognizant agency for indirect costs simply means that the federal agency responsible for reviewing and improving the governmental unit's indirect cost rate on behalf of the federal government. The cognizant agency is the federal awarding agency that provide the predominant amount of direct funding to an entity unless otherwise assigned by the White House Office of Management and Budget.

You're going to want to make sure that your entity is on top of your indirect cost rate. Sometimes there is a lag, but the more you're on top of it, the less likely it'll get to the point of being in between. So, check in on this early and often, for those of you on the call today that typically oversee or are involved in that process. And now for an example. So, if your budget has 400,000 in direct costs, the amount of indirect costs recovered would be $40,000 using that 10% de minimis rate, or it'd be 80,000 if you had a negotiated indirect cost rate of 20%.

An important reminder we want to mention is that if you're using a negotiated indirect cost rate, the rate charge to your grant will likely change during your project period if you have a multi-year award. So, if your approved rate during your year one grant period is 20% and your entity negotiates a new rate for 25% for the year two period of your grant, you'll need to submit a budget modification to reflect that higher 25% rate in the year two budget period if you're wanting to charge the higher rate. And again, we're touching on things at a high level here, just because of timing. Each of these could be its own category, but we're hoping the basics that we provide here today are a good foundation to kind of get the ball rolling and keep you moving forward in your grants journey here.

Now that we've talked about those allowable costs, and we've discussed what can be charged to your grant, let's talk about monitoring that budget throughout the life of your award. Each grantee is responsible for sound financial management of federal funding. In order to maximize the benefit of that funding, those responsible for the victim services programs must constantly monitor their respective budgets and adjust as needed to meet their approved program goals. A best demonstrated practice is to review your statement of activities, which could be a profit and loss if you're a for-profit business that reports revenues, expenses, and changes in your net position, you're going to review it for your project individually and then with your finance team. And monthly reviews ensure you, as a program manager, are fully aware of the budget to actual expenditures. And monthly reviews will also make you aware of where your budget stands, how much money do you have left in each category, overall, details like that.

It's also easier to correct a mistake or do a misclassification prior to a monthly close depending on how your finance closes their books. So, the earlier you catch something, if something was charged incorrectly, the better it is for everybody involved. So monthly reviews are definitely recommended.

Another benefit to monitoring your budget is that it'll reveal budget variances. So, variances are differences between the actual and the budgeted amounts. If you don't monitor these, the variances can create big problems for the budget managers. An entity may increase spending if the variance indicates that there's more money left in the budget than it projects it will spend. Now, if the variance shows that spending to that point exceeds what was projected, the entity may have to cut spending. It's very important to learn how to monitor and respond to the variances. It's also helpful, and we recommend, if your variances are expressed in percentages, and you can kind of compare it like your time to dollars.

For example, if you've spent 85% of your budget in the first 50% of your budget period, you might want to do an analysis of this situation just to make sure there's no problems down the road. And again, it's not something that could be wrong, but being on top of it to catch something that might be wrong early on will help you down the line. And again, we strongly recommend these reviews on a monthly basis. However, if it's not possible, you should do a quarterly review to make sure that what you're reporting on those quarterly financial reports is both accurate and matches exactly to your records.

Now we're going to touch a little bit on this budget detail worksheet, as it plays a key role in that monitoring process we just talked about. All of you are probably familiar with this budget detail worksheet, as it was a requirement for your application. It was created by the Office of Justice Programs, and it combines the detailed expenses and the budget narrative in one single document. It's a user-friendly fillable Excel document that has multiple worksheets within it and automated calculations for you. But if you can't access that Excel file, there is also a PDF version that you can use if you need to. We're going to put a link, I think Tamara's already on top of it, she put a link in the chat, where you can find a blank or fresh copy of the documents if you need it at any point in time.

And I'm going to take this opportunity to just plug in a little helpful tip or trick. Because a common situation we've seen frequently relates to the macros in this file. The macros calculate the specific expense line items that you put in on each tab and it carries them to the summary page. But we've been noticing that a lot of computers aren't recognizing this file as trusted anymore, and therefore it's not allowing you to enable those macros, which are needed to actually use the file. So, what we've seen work, and kind of this helpful tip and trick we want to plug right here, is if you're experiencing this, go ahead and save the file to somewhere on your computer, your hard drive, that's not backed up to your cloud storage. So, you don't want it backed up to OneDrive or Dropbox or whatever you might use for cloud storage if you use cloud storage.

Now, once you've successfully saved it in that file and you reopen it, there's usually a popup box that says do you want to make it a trusted file, you click yes. And once you've done those steps, you should then be able to save it anywhere on your computer, backed up to cloud storage or not, and reopen it without any further issue. Okay, so a little bit off topic, but a helpful tip and trick I wanted to just plug there because it's been an issue. So, with that, we will get back to how it's used in the monitoring process.

You can utilize this file, that budget detail worksheet, or BDW file, during the life of your award to make sure you're spending accordingly. So again, you would've completed this file during the application phase of your budget. So, each grantee should have an approved budget in this file format. It presents a complete itemization of all of your proposed costs for the full period of your project. And there are separate tabs in the file to show your costs by grant year if you have more than one year, and also as a cumulative number across the entire period on that budget summary tab of the page. And referring back to this file as you plan your spending will ensure that the costs, you're incurring are related to your grant award and they're also approved by OVC. And if you're reconciling your spending to this budget file, again, you can be sure that your spending is in line with what was approved by the sponsor.

Having this one centralized approved budget document also helps to ensure that all the staff involved in the grant management, both programmatic and financial, are coordinated in their monitoring efforts, right. Because sometimes the program staff know things that the financial staff might not. So being able to refer back to this document kind of brings everybody back together when it comes to allowable costs and monitoring the spending.

Okay, and with that, we are our last stop on today's journey, which is about audits and how to be ready for them. The dreaded audit that nobody likes to hear. But if you're ready, it's a pretty smooth process. So, an acceptable financial management system maintains detailed and auditable records. So, all award recipients must look to the award terms and conditions to determine the audit requirements which the entity must meet under the award. An audit is performed by an independent contractor, typically who gives an objective review, which determines if accounting records are accurate. An audit is a thorough examination of an entity's financial system and its compliance with applicable federal grant requirements.

Now, entities who receive federal funds and spend $750,000 or more of federal dollars in a single financial year are required to have a single audit. A single audit includes an audit of both your organization's financial statements and compliance with federal award requirements for those programs identified as major programs. The results are filed with the Federal Audit Clearing House at the Federal Office of Management and Budget within the earlier of 30 days after the receipt, or nine months after the financial year's end. DOJ award recipients must maintain a bookkeeping or financial management system which is audit ready at all times.

And now to be audit ready, the entity should at a minimum keep receipts of all transactions, organizing them so they are easily accessible, and all documents must be kept for a minimum of three years. There are exceptions that exist for some document types, which must be retained for a different length of time. So, you're going to want to familiarize yourself with all of the different requirements to make sure you're in compliance. And grantees are required to make any documents, papers, or other records related to their federal grants available in a timely and reasonable manner to the federal awarding agency, to the Office of the Inspector General, to the Comptroller General of the United States, and any of the above authorized representatives for the purpose of audits, examinations, excerpts and transcripts. It's just part of the requirements that if at any time any of those groups request the documentation, you're able to provide them in a timely and reasonable manner.

Now, grantees must maintain records which adequately identify the source and application of funds provided for financial activities. These records must contain information pertaining to grant or sub-grant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures and income. The account records must be supported by source documentation such as canceled checks, paid bills, payrolls, time and attendance records, contract and subcontract award documents, et cetera. The independent auditors will examine and test the accounting records and that source documentation as part of the audit. And again, this is, it sounds like a lot, but this is stuff we all touched on a little bit before in each of those categories. So, if you're doing it at those prior levels or periods of time where we talked about, it's not like you have to do all of this if somebody comes in for an audit. It'll set you up, so when they come in, all of this stuff's already ready.

Additionally, to be audit ready, an entity should ensure all accounts payable documents are reviewed and approved by two separate individuals with explicit authority to approve the invoices. You want to stay updated on transactions by posting financial activities on a regular basis. You don't want to sit on something for too long without putting it into the system. And you want to make sure your income and expenses are properly recorded to the appropriate accounts. And then again, that circles back to that budget monitoring. If you check on it on a monthly basis, you should be in compliance with that particular part. And again, just want to plug a little tip here. Keep the copies of the DOJ grant's financial guide and your award solicitation, have it all readily available at any point in time.

Let's talk about some internal control examples. So federal regulations require grantees to have appropriate financial management systems which provide for internal controls. The internal controls are your formal policies and consistent procedures put into place to safeguard the cash and other assets of a grantee. Some examples of internal controls are the separation of duties. The person who writes the check does not also reconcile the bank statement. Budget to actual comparisons, you may identify unexpected overages, pre-approval of transactions requiring travel authorization prior to travel, the monthly bank reconciliations and the physical asset audits. This could mean doing a monthly count of all program equipment. And again, if there's internal controls in place, you're making sure that the funds are used in accordance with all the rules and regulations and there's no funny business going on.

This particular page is just some of the common audit issues that we've seen related to DOJ awards. Pretty commonly we see that the procedures aren't documented, the award conditions aren't met, the accounting system might not be up to par with where it needs to be, your federal or performance reports aren't being filed on time, or there's some suspension or debarment in place. The suspension and debarment, let's, you just want to make sure you aren't contracting with entities or individuals that are prohibited from doing so by the federal government due to their own wrongdoings. So, there's a process on how to check that. And again, one of the common audit issues is that's not checked. So, we just want to plug it here for something to be made aware of, so you can stay on top of it.

And that actually brings us to the end of our high-level overview of effective financial management as it relates to your federal award. So, we really hope that you learned some new information or reinforced some existing information. We just want to say that receiving a federal award is a really great accomplishment, but obviously it also can create a lot of questions. So, we are here to help, we being TFMC. So, you can reach out to TFMC or your grant manager at OVC at any time if you have any questions about the financial management of your award. And we just want to take this opportunity to say again how thankful we are for you all joining us today. And we look forward to hearing from you and working with you to better serve the victims of crime.

And now to the fun part, let's get to the Q and A. So, if you haven't already, if you have some questions, go ahead and use that Q and A section to put them in. I see that there have been some in there that have already been addressed. And I'll, just in case everybody didn't see it, I'll go ahead and say one of them right now. The question was, if you keep electronic folders for grants management, do you also have to have a paper copy as well? Nope, you do not have to have a paper copy as well. You can choose one or the other. And in some instances, it might be helpful to have both, but it's definitely not a requirement. And I'm just going to scroll through the chat really fast to see if there was anything in there. But again, feel free while I scroll through the chat, go ahead and put anything in the Q and A.

Okay, I will do this one because it looks like the other one might be being answered. Are wet signatures required on time and effort sheets? So, it refers back to your policies and procedures. Do you have an electronic filing system? Typically, if that's the case, the electronic certifications suffice, but you want to make sure your policy and procedure on that is well documented to make sure you're in compliance with whatever it is. Hopefully that answered your question. But if it didn't, feel free to put a follow up in there. Just checking to see if there's any other questions.

I see there's a question about needing to do a budget modification every year. If you have a four-year grant period. I believe that that's going to be answered in the Q and A section with a typed-out answer. Which it just was. And the answer to if you need to do a budget modification every year is generally, you're only going to modify your budget if you're making any significant changes. So, there are certain things listed in the DOJ grants financial management guide that spell out when a budget modification would be needed. So, I highly recommend referring back to that in the guide. And it should help guide you, guide you into deciding whether or not you need to do a modification or not. When in doubt, if the guide doesn't give you a clear enough answer, you can always reach out to your grant manager and provide them the specifics of the situation and they'll be able to give you a more definitive yes or no answer as to whether it'll require an official budget modification or not.

Okay. I'll just give everybody just one more minute. See if any other questions come through. I see a question about the recordings for the webinars. They will be available on the OVC website, I believe within 10 days or so. But I think when we pass it back over to Marlene at T-VSTTA, she might be able to confirm that or not. And Reyna, the PowerPoint will be provided or available and that also has the links in it. Okay, so I don't think that there are any more financial management specific questions that are coming in. So, I'm just going to do a little bit of housekeeping here at the end of our presentation.

And the next slide is the tried and true federal resources links. Bookmark these, have them very accessible. The 2-CFR-200 establishes that uniform administrative requirements, cost principles and audit requirements for federal awards. And that DOJ grants financial management guide is a great starting point for all recipients and subrecipients of DOJ specific grants, just to ensure the effective day-to-day management of the awards. And we're going to go ahead and put those in the chat as well. And the last piece is the TFMC specific resources. TFMC has developed close to 50 guide sheets and job aids, as well as webinars and micro learnings. A lot of different formats here. For you to use as a reference while navigating the management of your federal awards. And each of those is broken out by specific topics, so you'll be able to narrow down a resource on the topic you're looking for more information on. And with that, I am going to go ahead and pass it back over to Marlene, I believe.

MARLENE MACK: Thank you, Kristene. This was wonderful information, very valuable. And I want to remind everybody that this recording will be available in 10 days, about 10 days, and it'll be on the OVC TVSSA website, and keep an eye out for that. We want to thank everyone who took the time to join us today. We're looking forward to walking with you as you continue to serve your communities. Again, thank you and take care.