2014 AmeriCorpsState and National Symposium

Omni Circular The CNCS Basics

2014 AmeriCorpsState and National Symposium

Session Goal

Raise awareness of the Omni Circular key concepts that will impact AmeriCorps Grantees.

Implementation of the new requirements is a work in progress.

2014 AmeriCorpsState and National Symposium

OMNI Circular

2014 AmeriCorpsState and National Symposium

Omni Circular Overview

What:

– OMB published a single set of regulations that replace the eight separate circulars which govern grant-making across the Federal government.

When:

– December 26, 2013: Rules are applicable for Federal agencies.

– June 26, 2014: Deadline for Federal agencies to submit exemptions of regulations to OMB for review.

– December 26, 2014:

• Deadline for Federal agencies to implement the policies and procedures applicable to federal awards.

• Rules apply to audits of FYs beginning on/after this date.

• Rules apply to all grants and amendments awarded on/after this date.

2014 AmeriCorpsState and National Symposium

What is changing for AmeriCorps Grantees

– Pre-award Assessments

– Single Audits (A-133 audits)

– Indirect Costs

– Time and Activity

2014 AmeriCorpsState and National Symposium

Pre-Award Financial Review

What’s Current:

Grantees should conduct a financial review to determine if sub-grantees have the capacity to manage federal funds.

What’s coming:

Grantees are encouraged to also confirm sub-grantees financial stability.

2014 AmeriCorpsState and National Symposium

Single Audit Act Requirements (A-133)

What’s Current:

Grantees who expend $500,000 of Federal funds in a year must conduct an A-133 audit.

What’s coming:

The threshold for A-133 audits goes up to $750,000. It applies to the grantee’s fiscal year that begins after December 26, 2014.

Example:

Fiscal year is July 1 – June 30. Threshold begins for fiscal year July 1, 2015 – June 30, 2016.

2014 AmeriCorpsState and National Symposium

Performance Measures

What’s coming:

– The regulations place an emphasis on outcomes and community impact as opposed to outputs.

– CNCS is exploring if there are additional requirements that we must implement for this regulation.

2014 AmeriCorpsState and National Symposium

Indirect Costs

What’s Current:

– Grantees must have an established Negotiated Indirect Cost Rate (NIDCR) from their cognizant agency or elect to use the CNCS 5%/10% option for AmeriCorps.

– NIDCR must be renewed annually.

What’s Coming:

– All Federal agencies must allow grantees to claim indirect cost rates.

– Grantees without an NIDCR can choose to accept a 10% de minimis rate. For AmeriCorps grantees this becomes a 5%/5% option.

– Grantees with a current indirect cost rate may elect to apply for a one-time extension for a period of up to 4 years.

– AmeriCorps grantees continue to be capped at 5% of CNCS share.

– AmeriCorps grantees that use the CNCS 5%/10% option and do not have an NIDCR will see a decrease in the amount they can claim as match.

2014 AmeriCorpsState and National Symposium

Indirect Costs

Ramifications of the New Indirect Cost Rate Regulations on AmeriCorps Grantees that Choose the Flat Administrative Cost Option.

Current method allows 5% of the Federal Share and 10% of the total budget as Grantee Share. Total allowable flat rate in this example is between 11% and 12% of the total budget.

Category Federal Share Grantee ShareTotal Approved

Budget

Program Support Costs $200,000 $300,000 $500,000

Member Costs $500,000 $100,000 $600,000

Total Direct Costs $700,000 $400,000 $1,100,000

Allowable Flat Rate $36,820 $110,000 $146,820

Total Costs $736,820 $510,000 $1,246,820

Total Budget $736,820 $510,000 $1,246,820

$146,820 is 12% of the Total Costs    

2014 AmeriCorpsState and National Symposium

Indirect Costs

Future Method allows 10% of the total direct costs for indirect and still only allows 5% to be claimed as Federal Share. Grantees retain the amounts they can claim as Federal Share, but the amount of Grantee Share they can claim decreases. Total allowable indirect in this example is 9% of the total budget.

Category Federal Share Grantee ShareTotal Approved

Budget

Program Support Costs $200,000 $300,000 $500,000

Member Costs $500,000 $100,000 $600,000

Total Direct Costs $700,000 $400,000 $1,100,000

Allowable Deminimus Rate $36,820 $73,180 $110,000

Total Budget $736,820 $473,180 $1,210,000

Allowable Deminimus Amount $110,000  

$110,000 is 9% of the Total Costs.    

2014 AmeriCorpsState and National Symposium

Additional Change for Commission

– Limits now apply to the 1% or 2% of administrative costs commissions can hold back.

– Grantees that choose the de minimis 10% can only apply it to the first $25,000 of any passthrough funding.

– Commissions that choose to retain 1% or 2% should work with subgrantees to establish indirect cost rates. The limit does not apply to subgrantees that have negotiated indirect cost rates.

2014 AmeriCorpsState and National Symposium

Time and Activity

What’s Current: Nonprofit organizations must have a time-keeping system in place that -

– Tracks time and activity on an after-the-fact basis that accounts for total time.

– Is signed by employee or supervisor.

– Is prepared at least monthly and coincides with one or more pay periods.

What’s coming: Time and activity can be supported by -

– A system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.

– A system that is incorporated into the official records of the grantee.

Rules around member time keeping remain the same.

2014 AmeriCorpsState and National Symposium

Time and Activity - Continued

Required Internal Controls

Organizations must have:

– Documented policies and procedures for their time and activity systems.

– Procedures to trace back the allocated time to source documents that can be verified as complete and accurate.

– Clear separation of roles and responsibilities from those who establish or approve payroll for those eligible for payroll, and those who process payments.

2014 AmeriCorpsState and National Symposium

CNCS Implementation

• CNCS will revise the AmeriCorps application instructions related to applying the new indirect cost to reflect the new requirements.

• The AmeriCorps grant Provisions (now called Terms and Conditions) will be revised as needed to reflect the new requirements and changes will be highlighted.

• CNCS is making some changes to eGrants to better track the new requirements, e.g. track grantees who have been given a 4-year extension on their indirect cost rate.

• CNCS will train Commissions on any changes they may need to make to their subgrant agreements related to the new requirements

2014 AmeriCorpsState and National Symposium

Questions?