Overview of Statewide AT Program Fiscal and

Contract Management

This PowerPoint will allow you to…

• Describe what EDGAR is and list relevant EDGAR sections applicable to statewide AT programs.

• Describe the AT Act requirements for allocating percentages of funds to state level and state leadership activities.

• Define the terms obligating funds and liquidating funds, and describe the purpose of the SF 425 Form.

EDGAR Education Department General Administrative Regulations

• EDGAR is a set of cross-cutting rules that statewide AT programs can use to assure that the program is in compliance with general Federal administrative regulations.

• These rules cover issues such as application procedures, financial administration, record retention, and program oversight.

Some EDGAR Parts Applicable to Statewide AT Programs

• Part 74: Administration of Grants and Agreements with Higher Education and Non Profit Organizations

• Part 75: Direct Grant Programs• Part 76: State Administered Programs• Part 80: Uniform Administrative Requirements for

Grants and Cooperative Agreements to State and Local Governments

Some EDGAR Sections Applicable to Statewide AT Programs

• Section 76.702 .Fiscal control and accounting procedures.

• Section 76.709. Funds may be obligated during a “carryover period.”

• Section 76.730. Records for audit.• Section 80.20(a)(2). Procedures to allow tracing of

funds.• Section 74.27 . Allowable costs (See also OMB Circulars

http://www.whitehouse.gov/omb/circulars_default).

EDGAR and the AT Act

The AT Act trumps EDGAR!

If there is a requirement in the statute, the statute will take precedence over EDGAR requirements.

Example:• The AT Act allows for AT Advisory Council Members to be

compensated for travel, lodging, and per diem to attend the Council, but it does not allow members to be paid to attend Council Meetings. EDGAR does allow people to be compensated. The AT Act takes precedence.

Budgeting for State Activities

• At least 60 % of funds must support State Level Activities.

• States can claim “flexibility” and use at least 70% of funds to carry out only two or three State Level Activities.

Transition Activities - 5%

• A state program must also budget for 5% of the 40% (or 30% if applicable) of its state leadership funds towards transition activities.

• Transition activities must include two separate

types of transition activities:– Activities related to students with disabilities

transitioning under IDEA.– Activities related to individuals with disabilities

maintaining or transitioning to community.

Budgeting for Activities - The 60/40 Split vs. the 70/30 Split

For more information on budgeting activities, visit Module One on the RESNA Catalyst website at:

http://www.resnaprojects.org/statewide/newdirectors/mod1ata.html

Expenditures

• Funds are normally distributed to statewide AT programs by RSA on October 1 annually.

• Funds may be awarded to statewide AT programs in full, OR may be awarded partially if Congress fails to complete the annual spending bills that fund various government departments and agencies for the new fiscal year. The award then is based on a “continuing resolution” (CR).

Definitions of Obligation and Liquidation of Funds

• Obligation of Funds: Funds have been assigned (contracted, etc.) to be used prior to September 30th of the second fiscal year (carryover).

• Liquidation of Funds: Funds have been received, assigned to be used, and have been spent by December 30th of the second fiscal year (carry over period).

Obligation and Liquidation of Funds

Section 76.7e9 in EDGAR permits grantees to carryover Federal funds for obligation and expenditure in the subsequent

Federal fiscal year:

• If a state or a subgrantee does not obligate all of its grant or sub grant funds by the end of the fiscal year for which Congress appropriated the funds, it may obligate the remaining funds during a carryover period of one additional fiscal year.

HOWEVER

• The State shall return to the Federal Government any carryover funds not obligated by the end of the carryover period by the State and its subgrantee.

Timeline to Expend Funds

Statewide AT Program:• Receives FY 2012 Funds – October 1, 2011• Must obligate FY 2012 Funds – September 30,

2013• Must liquidate FY 2012 Funds – December 30,

2013

SF 425 Form

• The purpose of the SF-425 is to give recipients of grants and cooperative agreements a standard format for reporting the financial status of their awards.

• All Statewide AT Programs must complete the SF-425. The SF-425 is due 90 days after obligation of funds.

Other Resources in this Module

See List of Resources in this module’s Introduction for details

• Contracting –including information about performance based contracts

• Project Management and Reporting Systems – three models

• Program Income – including information on delivering services for a fee

Contract for ServicesThings to know:

• Developing a request for proposal (RFP)• Scoring and awarding a proposal• Multi-year competitive bidding• A contract package that consists of the program

activity plan, a budget, a narrative, a payment and reporting schedule, and any state and Federal standard clauses

What are Performance Based Contracts?

Performance Based Contracts are used by a statewide AT Act program to ask an independent contractor

for X service for Y outcomes in Z timelines.

Why use Performance Based Contracts?

• Partner with organizations that have specialized areas in the population that they serve (statewideness).

• Statewide AT Act Program can determine contractor outcomes and estimations for loans, reuse, trainings, I&A, & demos.

• Performance based contracts can support sustainable capacity building.

For more information contact:

RESNA Catalyst Project1700 North Moore Street, Suite 1540

Arlington, VA 22209-1903Phone: 703/524-6686 Fax: 703/524-6630 TTY: 703/524-6639

Email: Catalyst@resna.org Website: http://www.resnaprojects.org/