Office of Grants Management

Grants Management Fundamentals

Office of the National Coordinator for Health Information

Technology (O N C)

Grants 101
 Office of Grants Management – Organization and Functions

Office of Grants Management (OGM)

Lisa Lewis
Chief Grants Management Officer

Systems and Data Policy Training and Grant Operations

Management Wendy Kilgore Technical Assistance Arlene Ramsey
Bianca Costa Jen Cramer
Provide procedural and
Collect, report, and Develop and manage technical business support
Develop and deliver grants
manage grants ONC grants management training for to award recipients and
management data management policies external stakeholders and ONC program offices
ONC staf
Analyze grant data to Facilitate objective Conduct on-site monitoring
identify trends in reviews Provide customized, direct visits and desk reviews
implementation of funds technical assistance
Liaison with other HHS Develop grants
services
ONC administrator for Grants Management management standard
grants management Offices operating procedures
Coordinate overall grants
systems management training and
technical assistance eforts
GMO: Workforce GMO: REC and State HIE
GMO: Beacon and SHARP

2
O G M - Responsible for the Portfolio of O N C Cooperative Agreements

State
State
Health
Health
Information
Information
Exchange
Exchange
Workforce:
Workforce: Regional
Regional
Competency
Competency Extension
Extension
Examination
Examination Centers
Centers

Workforce:
Workforce:
Curriculum
Curriculum Beacon
Beacon
Development
Development
Centers
Centers

Workforce:
Workforce:
University
University SHARP
SHARP
Based
Based
Training
Training Workforce:
Workforce:
Community
Community
College
College

3
 O N C’s Program Offices and Grants Office Partnership
Establish
Establish&&
maintain
maintain
official award,
official award,
Answer
Answergrantee
grantee program information, Conduct
Conductfinancial
financial
questions on complex program information, monitoring site visits
questions on complex &&
institutional files monitoring site visits
technical grants
technical grants institutional files &&desk reviews
desk reviews
business
business && provide
provide
management
management matters
matters post-award
post-award TATA

Grants
Grants
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Team
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e

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inputonon Ensure
Ensureeffective
effective
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satisfaction of use of funds
use of funds
business
business mgmt
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monitoring
special conditions;
special conditions; Identify potential
Identify oror
potential commitments
commitments &&
liftlift
restrictions
restrictions existing problems
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projecting future
viavia
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(business mgmt
mgmt funding
fundingrequirements
requirements
AAGAM Chapter 1.04.104 && program)
program)
&& alert POPO
alert
4
 O N C’s Program Offices and Grants Office Partnership

Establish and
Establish and
maintain
maintainPOPO Conduct site visits
files Conduct site visits
Answer
Answergrantee
grantee files toto
gauge progress
gauge progress
questions
questionsonon and compliance
and compliance
programmatic
programmatic oror
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provide
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grants matters post-award
post-awardTATA

ring rer
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atute,
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ogram
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whether programmatic Ensure adequate
Ensure adequate
whether programmatic
special conditions progress toward
progress toward
special conditions Identify potential or or
areare
satisfied or or Identify potential meeting
meeting
satisfied existing problems
whether other action existing problems milestones
milestones
whether other action (program && business
should be taken
should be taken (program business
management)
management) && alert
alert
program officials
AAGAM Chapter 1.04.104 &&
program officials
GMO of of
findings
GMO findings
5
 Partnership – The Key to Success

• Maximize program success and integrity

• Foster program credibility
• Ensure rigor in stewardship
• Minimize audit findings
• Reduce disallowed costs
• Strengthen internal controls to prevent fraud, waste, and abuse
• Manage inherent risk
• Encourage professional development
• Foster synergy/collaboration

6
 Grants Management Lifecycle
ESTABLISH APPLY REVIEW AWARD MANAGE CLOSEOUT
Create Notice of Grant Conduct Programmatic Evaluate Final
Authorizing Statute Establish Commitments Objective Review
Award Monitoring Performance Reports
Assess Review Review
Appropriation Assist Applicants Obligate Funds Closeout Package
Fiscal Integrity Performance Reports
Set Up Congressional Review /Recommend Conduct Final
OMB Apportionment Develop Funding Memo
Notification in System Post-Award Actions Financial Reconciliation
Establish Disposition
Conduct Review Application Release Funds Review Audits of Funds
Appropriations Analysis
Perform Conduct Notify Grantee of
Allocate Funds Notify Grantee of Award Closeout
Budget Review Financial Monitoring
Assess Review
Develop Retain Records
Funds Availability Financial Reports
Funding Opportunity
Announcement (FOA) Review and Approve Post-
Award Actions
Release FOA

Program and Grants Management Training and Technical Assistance

Review Award Complete

Review FOA Submit Application Revise Application Drawdown Funds
Package Drawdown of Funds
Submit Generate Final
Accept Award Performance Reports
Performance Reports
Submit Generate Final
Financial Reports Financial Reports
Legend:
Submit Submit
Other Federal/HHS Post-Award Requests Closeout Package
Program Office Grantee
PHASE Entities
Office of Grants Ensure Audit is Complete Retain Records
Management ONC Budget PO/GMO Joint
 Grants Management Lifecycle – Establish
ESTABLISH APPLY REVIEW AWARD MANAGE CLOSEOUT

Authorizing Statute

Appropriation

OMB Apportionment

Conduct
Appropriations Analysis

Allocate Funds

Develop
Funding Opportunity
Announcement (FOA)

Release FOA

Review FOA

Legend:
Other Federal/HHS
Program Office Grantee
PHASE Entities
Office of Grants
Management ONC Budget PO/GMO Joint
 Appropriations and Funding Process

Phase 1: Budget
Formulation

Phase 2: Budget
Presentation and the
Congressional Process

Phase 3: Budget Execution

9
 Budget Formulation

• HHS Budgets for Grant Programs

• HHS Budget Request

• HHS Total Budget Request

• O M B/President’s Budget to Congress

10
 Appropriations

• Budget Presentation to Congress

• Congressional Budget Resolution

• Appropriation

11
 Budget Execution

• Office of Management and Budget (O M B) Apportionment

– Budget Authority to distribute funds

• HHS Allotment

• O N C Allotment

• Allocations to Each Grant Program

12
 Types of Appropriations

• Annual: Must be obligated within the fiscal year

– O N C funds in HHS appropriations

• Multiple Year: Available for obligation for a definite period in

excess of one fiscal year
– HHS has multi-year funds

• No-year: Available for obligation without financial year

limitations
– A R R A funding no longer no year (Bennett Amendment)

13
 Continuing Resolution

• Applies if new Fiscal Year and annual appropriation is not

passed
• Continues existing programs until annual appropriation
passes
• Can impact internal operations and activities

14
 Funding Opportunity Announcement (FOA)

• All information integral to the competition must be explicitly addressed

• General description
• Authorizing statute/Award information
• Eligibility requirements
• Cost share/matching requirements
• Application requirements
– Forms
– Budget and budget narrative
– Program narrative
– Other submission requirements
• Due dates
• Review Criteria
• Announcement dates
• Reporting requirements
• Other information

15
 Grants Management Lifecycle – Apply
ESTABLISH APPLY REVIEW AWARD MANAGE CLOSEOUT

Establish Commitments

Assist Applicants

Submit Application

Legend:
Other Federal/HHS
Program Office Grantee
PHASE Entities
Office of Grants
Management ONC Budget PO/GMO Joint
 Applying for Funding

• HHS policy requires all competitive funding opportunities be

announced at www.Grants.gov
• O M B mandated initiative
• No paper
• No other submission method accepted

17
 Critical Application Information

• Applications must be complete and timely

– All forms and attachments must be submitted
– Incomplete applications will not be sent forward for review
– Late applications will not be sent forward for review

• All applicants must have a Dun and Bradstreet (D&B) Data Universal
Numbering System (D U N S) number

• All applicants must register in the Central Contractor Registry (CCR)

– Applicants should allow a minimum of five days to complete the CCR
registration. CCR online registration (http://www.ccr.gov)
– CCR registrations must be current and renewed every 12 months

• Applicants that do not have a D U N S number or have not registered

with the CCR will not move forward for review.

18
 Grants Management Lifecycle – Review
ESTABLISH APPLY REVIEW AWARD MANAGE CLOSEOUT

Objective Review

Assess
Fiscal Integrity

Develop Funding Memo

Review Application

Perform
Budget Review
Assess
Funds Availability

Revise Application

Legend:
Other Federal/HHS
Program Office Grantee
PHASE Entities
Office of Grants
Management ONC Budget PO/GMO Joint
 Objective Review Process

• Completeness Review
• Grants staf
• All required forms
• All required attachments
• On-time submission

• Responsiveness Review
• Program staf
• All required program elements

If YES to both → Panel review

20
 Objective Review Process - continued

• Panels of unbiased subject matter experts

• Endure no conflicts of interest and consistent examination
of applications
• Intended to provide recommendations and advice on
funding proposals
• Scores and ranking developed
• Final decisions determined by the program office
• Funding decision memo sent to Grants Management Office

21
 Program Office  Financial Review

• Program Office Staf

– Review application budget to determine if costs are in line
with program goals and objectives
– Review to ensure costs are for intended program purposes
– Signed transmittal slip indicating approval of budget

• Grants Management Staf

– Conduct detailed financial reviews
– Based on Program Office recommendations

22
 Financial Review

• A-133 Compliance
– http://harvester.census.gov/sac/
• No Conflict of Interest
• Applicant’s Standing (Good, Debarred, Suspended)
– https://www.epls.gov/
• Dun and Bradstreet
• Budget Review

23
 Budget Review and Approval Process

• Each application must include a detailed budget (SF424A) and

budget narrative for the project.
• The budget must be complete, reasonable, allowable,
allocable and cost efective in relation to the proposed
project.
• The budget narrative must provide a detailed justification for
each cost included in the budget.
• All project related costs must be included in the appropriate
cost categories.

24
 Budget Review – Cost Principles

• Uniform cost principles when

implementing Federal grant programs
– 45 CFR 74.27 and by reference 2 CFR
Part 220 (A-21) – Educational
Institutions
– 2 CFR Part 225 (A-87) – State Local
and Indian Tribal Governments
– 2 CFR Part 230 (A-122) – Non-Profit
Organizations
– 48 CFR 31.2 (Federal Acquisition
Regulation (F A R)) – For Profit
Organizations

25
 Budget Review – Object Categories and Key Requirements

Example of a 424a

26
 Budget Review – Personnel Budget Category

Personnel
• Must pay personnel at a rate paid with non-Federal dollars or comparable to
like organizations/positions.
• Is the basis for determining each employee’s compensation described
(annual salary and % time devoted)?
• Is each position identified by title/responsibility?
• Are time commitments and the amount of compensation stated and
reasonable?
• Are salary increases anticipated during the grant period and are they justified
(C O L A, etc)
• Are any personnel costs unallowable?
• Dual Compensation?
• Federal Employee?

27
 Budget Review – Fringe Budget Category

Fringe Benefits – typically include health care, retirement plans,

etc. Must consider:
• Is the amount specified as a separate line item?
• Is each type of benefit indicated separately or does the organization
have an approved fringe benefit rate?
• Are fringe increases contemplated during the grant period?
• Are costs included in fringe benefits that are unallowable?

28
 Budget Review – Travel Budget Category

Travel
• Is the basis for computation provided?
• Is the travel necessary for the purpose of the program?
• Are travel costs separately identifiable and reasonable (location,
transportation, hotel, meals, mileage)?
• Does the organization have a written travel policy? Is this travel
policy being followed?
• If no written policy—must follow Federal guidelines

29
 Budget Review – Equipment Budget Category

Equipment
• Capitalization threshold
• Federal $5K and useful life more than 1 year
• Are equipment items specified by unit and cost?
• Is the request reasonable and allowable under the project?
• Does the organization have a procurement policy in place?
• Is a lease vs. purchase study necessary (vehicles, large items of
equipment)?
• Are purchases distinguishable from rentals?

30
 Budget Review – Supplies Budget Category

Supplies
• Are supplies listed separately?
• Office
• Training
• Research
• Other types of supplies
• How was cost determined?
• Is the basis for the cost reasonable?
• Monthly estimates are sufficient
• Consistently treated

31
 Budget Review – Contractual Budget Category

Contractual
• Is the type of each service to be rendered described?
• For Consultants/Individuals
• Is an hourly, daily or weekly base rate given?
• Are rates allowable, justified, reasonable and comparable to
market?
• Is procurement method described?
• Are appropriate procurement procedures being followed?

32
 Budget Review and Approval – Subrecipient Relationships

Subrecipient Relationships (Subgrants/Subawards or Contracts)

• Is a substantial portion of the programmatic work being performed by another
entity - a grant or contract?
• Subawards are documented in the “other” category
• Subrecipient relationships in the form of a contract will be put in
“contractual”

• If so, the following questions must be answered in regard to that specific grant or
contract:
• Name of the subrecipient
• Method of selection
• Period of performance
• Scope of Work
• Method of Accountability
• Itemized budget and justification (separate SF 424As for the subrecipient)

33
 Budget Review – Other Budget Category

Other
• Are items listed by major type (space rental, printing, phone,
maintenance, etc.)?
• Are all costs justified, reasonable and allowable?
• List each subaward and amount of award
• Ensure adequate subrecipient information is provided
(see 6 elements)
• Include separate SF 424 A for each sub

34
 Budget Review – Indirect Costs

Indirect Costs
• Costs incurred for a common/joint objective and cannot be
readily identified with a specific activity
• typically include utilities, rent, administrative staf
• An organization may not charge specific costs both directly
and indirectly
• Costs may not be assigned as an indirect cost to an award if any other cost
incurred for the same purpose has been allocated to an award as a direct
cost

35
 Budget Review – Indirect Costs

Indirect Costs (continued)

• Must have a current Federally
approved indirect cost rate
agreement
• Is the rate applied to the
correct distribution base?

36
 Recently in the News

• TierOne loses $19 million federal grant over CEO's fraud allegations
• September 6, 2010

• University of Florida professor and wife indicted for fraudulent grant

proposals
• October 30, 2009

• Cornell University Will Pay $2.6M in Fraud Case

• March 24, 2009

• Former Professor Pleads Guilty to Fraud on NSF Grant

• May 3, 2007

37
 Categories of Misuse of Federal Funds

Indicators of Fraud, Waste and Misuse of grant funds can be due to a variety of
causes. We must manage with due diligence to ensure that DHHS funds are not
misused.

Mistakes Gross Negligence Criminal

Fraud
Recipient includes costs in budget Direct recipient failed to Recipients used Federal
which are unallowable under specific implement proper funds to pay for a wedding
O N C awards. Examples include: internal controls and reception, building
Food, Scholarships, Contingencies adequately monitor construction, and personal
subrecipient activity and credit card bills. Resulted in
expenditures resulting in loss of $500K and jail time.
theft of Federal funds.

38
 Who Commits Grant Fraud?

• When business entities, individuals, communities, and other

organizations receive federal grant dollars, they are entrusted with their
appropriate expenditure.

• Grant fraud is most often committed by:

• Grant recipients, company officers, business partners, board members,
and managers
• Bookkeepers, financial staf, and employees
• Contractors and subcontractors engaged with the recipient
• Recipient consultants

39
 Common Grant Fraud Scenarios

• Grant fraud occurs in many ways, but some of the most common fraud
scenarios include:
• Charging personal expenses as business expenses against the grant
• Charging for costs which have not been incurred
• Charging for inflated labor costs or hours
• Submitting invoices for personal expenses
• False information on grant applications, progress reports, etc.
• Creating fictitious records

40
 Fraud Indicators

• Fraud is often difficult to detect and is a conclusion that is determined only

after a careful examination of all the facts and circumstances.
• Indicators of fraud include:
• One person in control
• Lack of internal controls
• Altered records
• No separation of duties
• No prior audit
• Lack of responsiveness
• Allegations of fraudulent conduct
 Grants Management Lifecycle –Award
ESTABLISH APPLY REVIEW AWARD MANAGE CLOSEOUT
Create Notice of Grant
Award

Obligate Funds

Ensure Congressional
Notification

Release Funds

Notify Grantee of Award

Legend:
Other Federal/HHS
Program Office Grantee
PHASE Entities
Office of Grants
Management ONC Budget PO/GMO Joint
 Notice of Grant Award (NGA)

• The Notice of Grant Award NGA is the official document

used for grants/cooperative agreements
– Establishes legally binding arrangement between O N C
and recipient
– Establishes Period of Performance
– Contains or references Terms and Conditions of the grant
or cooperative agreement
– Obligates Federal Funds

43
Notice of Grant Award (NGA)

NGA includes:
• Grantee information
• Award information
– Project Period of
Performance
– Budget Period of
Performance
• Terms and Conditions of
the award

44
 Award Notification and Acceptance

• Award Notification
– Grants Solutions
– NGA
– Terms and Conditions

• Award Acceptance
– First request for disbursement of funds
– Agree to abide by all applicable laws, regulations, program
requirements, policy and terms and conditions
– Specific A R R A terms and conditions (incorporated by reference)
• http://www.hhs.gov/recovery/grantscontracts/recoverytermsconditions.html

45
 Grant vs. Cooperative Agreement

• Grants are awarded to States, units of local government, or private

organizations at the discretion of the awarding agency or on the basis of a
formula. Grants are used to support a public purpose.

• Cooperative Agreements are awarded to States, units of local

government, or private organizations at the discretion of the awarding
agency. Like grants, cooperative agreements also support a public
purpose.
• Substantial involvement is anticipated between the awarding agency
and the recipient during performance of the contemplated activity.
View as a “partnership”
• Cooperative agreements are not contracts

46
 Grants Management Lifecycle – Manage
ESTABLISH APPLY REVIEW AWARD MANAGE CLOSEOUT
Conduct Programmatic
Monitoring
Review
Performance Reports
Review /Recommend
Post-Award Actions

Review Audits

Conduct
Financial Monitoring
Review
Financial Reports
Review and Approve Post-
Award Actions

Legend:
Other Federal/HHS
Program Office Grantee
PHASE Entities
Office of Grants
Management ONC Budget PO/GMO Joint
 Order of Precedence-Who is Top Dog?

• Constitution of the United States

• Statutes
• Program Statutes (Authorizing Statutes)
• Generally Applicable Statutes
• Annual Appropriations
• Regulations
• Executive Orders
• O M B Circulars
• Policies
• Procedures

48
 Administrative Requirements vs. Cost Principles

Administrative Requirements Cost Principles

Prescribe standards for grant Define allowable costs for diferent

administration to achieve uniformity types of recipients; failure to
and consistency for recipients of mention a particular item of cost in
Federal Assistance the Cost Principles is not intended to
imply that it is either allowable or
unallowable

49
 Applicable Regulations

Summary of Applicable Regulations

Grantee Type Administrative Cost Principles Audit
Requirements Requirements

State & Local Governments 45 CFR Part 92 2 CFR, Part 225 A-133
(A-87)

Educational Institutions
45 CFR Part 74 45 CFR 74.27 and by
reference 2 CFR Part
220 (A-21)

Non-Profits 2 CFR, Part 230

(A-122)

50
 Recipient Grants Management Responsibilities

Grantee responsibilities include:

• Cash management
• Maintaining adequate financial records
• Returning Federal funds for disallowed expenditures
• Complying with reporting requirements
• Reviewing and recording financial operations
• Budgeting and budget review
• Reporting irregularities
• Refrain from doing business with debarred and suspended
organizations

51
 Recipient Grants Management Responsibilities
Managing Subawards

• A recipient has full responsibility for the conduct of the project or

activity supported and for the results achieved

• Direct recipients are responsible for adequate monitoring of subawardee

activities
• 45 CFR Part 92.40 or 74.51, Monitoring and Reporting Program
Performance

52
 Financial Management Systems

• At a minimum, a grantee’s financial system should be able to:

• Meet 45 CFR 92.20 or 74.21, Standards for financial management
systems
• Provide financial and performance reporting required by 45 CFR Part 92
and 74, and other regulations
• Associate grant expenditures with the specific funding source and
application of funds
• Provide a clear audit trail
• Comply with the Cash Management Improvement Act
• Minimize the time elapsing between the transfer of funds and
disbursement by the grantee or subgrantee in accordance with Treasury
Regulation 31 CFR 205.
• A State should follow the same state laws and procedures as they
would for non-Federal funds

53
 Financial Management Systems – continued

• In order for an accounting system to be considered adequate, it must

meet the following criteria:
• Internal controls / segregation of duties (For example, the person authorizing
an expenditure should not sign the check)
• Ability to track expenditures on an accrual basis (budget control)
• Grantees can use a cash or accrual basis for their accounting method
• Ensure allowability of costs charged to Federal grants
• Documentation for all grant-related expenditures, broken down by award
• Ability to fulfill government-required financial reporting

54
 Understanding Match

Matching and cost sharing are often used interchangeably

•Matching usually refers to a statutorily specified percentage

– Specified as a fixed or minimum percentage of non-Federal
participation in allowable program or project costs that must be
contributed by a recipient in order to be eligible for Federal
funding or a not-to-exceed percentage of Federal participation.
•Cost Sharing refers to any situation in which the recipient shares in the
costs of a project other than as statutorily required matching
•Approved/accepted matching or cost sharing is shown in the NGA

55
 Understanding Match – continued

• Cash Match
• Cash spent for project related costs
• Matching costs must adhere to Federal rules
• If not allowed with Federal dollars, not allowable with matching dollars
• In-kind Match
• are the value of goods and/or services third parties donate for program or
project purposes without charge to a recipient
• Third party in-kind contributions
• May satisfy a matching or cost-sharing requirement only when payment for
them would be an allowable cost if the party receiving the contributions
(recipient, subrecipient, or cost-type contractor) were to pay for them

56
 Understanding Match – continued

• All costs and contributions used to satisfy a matching or cost-

sharing requirement must be documented by the recipient at
the same level of detail as Federal funds
• Matching contributions are subject to audit
• If a recipient fails to provide required cost sharing, the GMO
generally will make a downward adjustment in the Federal
award amount

57
 Understanding Match – continued

Valuation of in-kind contributions:

• Rates for volunteers must be consistent with established rates paid for
similar work by the recipient or subrecipient
• If a third party donates the use of equipment or space in a building but
retains title, the contribution shall be valued at the fair rental rate of the
equipment or space
• If a third party donates supplies, the contribution shall be valued at the
market value of the supplies at the time of donation

58
 Program Income

• Gross income earned as a result of the award

• directly generated by the grant-supported activity or earned
• There would be no income of this type or level.
• Activities that generate program income include
• Registration fees
• Sale of videos, publications, other media
• Rental/usage fees
• Service fees
• Subject to same requirements as Federal funds
• Must be reported on FFR (SF 425)

59
 Program Income

• The Notice of Grant Award includes the type of program income

applicable to the Program/award
• Deduction alternative
• Addition alternative
• Cost Sharing/Matching alternative
• Combination alternative

60
 Prior Approval

Several changes to an award require O N C prior approval

• Changes of grantee organization
• Change in scope
• Transfer of substantive programmatic work if not previously approved
• Significant rebudgeting (lesser of 25% or $250K, cumulative)
• Other as defined by program office
• Changes in key personnel
• Carry over funds
• Indirect costs (if indirect costs not approved in initial budget)
Request from grantee, with written justification, should be 30 days from
when need approval

61
 Payments to Grantees

Grantees request funds from HHS’ Payment Management System (PMS)

• Payment requests may be made as often as needed: (daily, weekly, monthly,
etc.)
• No checks; electronic transfers only
• Also used to submit quarterly financial reports
• PMS is administered by HHS’ Division of Payment Management
• PMS Helpdesk: (877) 614-5533 or PMSSupport@psc.hhs.gov
Grantees must minimize time between draw and expenditure
• Cash Management Improvement Act (CMIA)
• Immediate needs basis; funds must be spent within three business days
What may impact a grantee’s ability to draw funds?
• No budget approval
• Late report submission
• Other restrictions

62
 Grantee Reporting Requirements
Report Required Frequency Reporting Period Due Date Submission Method

April 1 – June 30 July 10

American Recovery July 1 – September 30 October 10

and Reinvestment Quarterly Federalreporting.gov
Act (ARRA) Report October 1 – December 31 January 10

January 1 – March 31 April 10

April 1 – June 30 July 30

Federal Financial July 1 – September 30 October 30
Report (FFR) Federal Payment Management
Quarterly
Cash Transaction System (PMS)
Report (SF-425) October 1 – December 31 January 30

January 1 – March 31 April 30

Federal Financial Online Data Collection

Report (FFR) Federal Annually October 1 – September 30 December 30 System (OLDC)
(SF-425)

Program Progress Semi-

Determined by Program Office CRM, email, etc.
Report Annually

63
 Official Grant and Program Files

• Office of Grants Management files

• Official award file
• All award transactions, financial information, correspondence, approvals, etc
• Program information file
• Information for each program announcement
• Information related to all applications
• Institution file
• Contains information on a specific entity which receives multiple awards from
multiple programs
• Project officer files
• Documents project management activities from inception to closeout
• Record of that PO’s activities with respect to the award
• Auditor or reviewer will request to review for adequate documentation

64
 Sample Checklist

• Section 1
Applicant Submissions and Contacts – New Awards and Other Competing Awards

• Section 2
Review, Evaluation, and Negotiations – New Awards and Other Competing Awards

• Section 3
Award Notices and Restrictions/Special Conditions

• Section 4
Post-Award Prior-Approval Requests

• Section 5
Post-Award Monitoring and Closeout

• Section 6
Other

65
 Financial and Programmatic Monitoring

Financial Monitoring Programmatic Monitoring

• Evidence of expenditures show that • Programmatic Administration

purchases are necessary, reasonable,
allocable and allowable • Compare accomplishments to goals and
objectives
• Flow of Funds
• Reinforce priorities and policies
• Accounting System
• Adherence to project scope
• Internal Controls
• Performance according to Ops Plans
• Cash Management
• Progress (completion on time)
• A-133 Submission
• Objectives
• Interest accrual (as necessary)

66
 Financial Monitoring – Goals

The goals of financial monitoring include:

– To ensure that grant funds are used as intended and compliant
with regulatory requirements
– To ensure O N C is meeting the highest of management and
fiduciary standards
– To ensure grantee compliance with the terms and conditions of
the grant award
– To meet requirements imposed on O N C by law (A R R A)

67
 Financial Monitoring – Risk Factors

• General Selection Criteria

– New Grantee
– Dollar Amount of Award
– Multiple Awards
– Entity Type
– Subawards
– Reporting Findings (FSR, Audit, A R R A)
– Unobligated/Unexpended Balances
– Program Office Referral/Recommendations
– Samples

• The above general criteria was weighted based on various

factors

• Other risk factors not included above may also be considered

based on data analysis -out life of award
68
 Types of Financial Monitoring that OGM Conducts

• Desk-based Financial Monitoring

– Cash Analysis
– Desk Review

• On-Site Financial Monitoring

69
 Desk-based Monitoring – Cash Analysis

Cash analysis reviews:

– Recipient cash transactions
– Rate of draws
– Payment trends
– Unobligated balance
– Grant status
– Review of last program report

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 Desk-based Monitoring – Cash Analysis continued

During the O G M quarterly review, O G M and Project Officers discuss the

following :

• Has the grantee submitted timely performance reports?

• Is the grantee on target as outlined in their approved plan?
• Has contact been made with the grantee if not on target?
• If contact has been made, what corrective action has been discussed?

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 Desk-based Monitoring – Desk Reviews

• Limited verification of grantee compliance

– Federal regulations
– Terms and conditions
• Identifies potential issues
• Grants reviewed on a regular basis
• Core review of a grantee’s general management
practices
• May require further scrutiny - on-site financial
monitoring

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 On-Site Monitoring Visits

On-Site Monitoring Visits are performed at grantee location

• Ensure adequate internal controls, policies, processes, and systems exist
to appropriately manage awards
• Assess capability, performance and compliance against administrative
regulations and public policy requirements
• Report on the efectiveness of O N C grantees and grant programs and
the stewardship of public funds
• Collaboration with program office(s) is key to successful monitoring
– Joint site visits with program office when feasible
– Pre-site visit meeting with program staf

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 Common Issues Discovered During Financial Monitoring

• No written policies and/or procedures

• Inadequate procurement standards
• Lack of documentation
• Inadequate/untimely submission of reports
• Inadequate Subaward Monitoring
• Inadequate time and efort records
• Lack of competition during procurement
• Conflicts of interest
• Questioned expenditures
• Excess Cash on Hand
• Commingling of funds

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 Monitoring vs. Auditing

• Monitoring is preventative
– Performed by grants and program staf
– Resolve before audits

• Auditing is corrective / curative

– Performed by auditors
– In the record books

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 Audits – What is a Statewide Single Audit (A-133)?

• Required for Entities that Expend $500K or More in Federal

Funds during their Fiscal Year
• Review of All Federal Grant Programs and Requirements
• Audit Report Is Due 9 Months after the End of the Fiscal Year
• Submit the Audit Package to the Federal Audit Clearinghouse
(FAC)
– http://harvester.census.gov/fac/collect/ddeindex.html

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 A-133: Most Common Audit Findings

• Unallowable activities
• Unallowable costs
• Poor cash management
• Inadequate equipment and real property management
practices
• Expending funds outside of the period of availability of funds
• Inadequate procurement standards
• Untimely and inaccurate reporting
• Lack of subrecipient monitoring

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 Audit Resolution

• Health and Human Services

– ASFR, Division of Systems Policy, Payment Integrity,
and Audit Resolution (DSPPIAR) is responsible for A-
133 audit resolution
• OGM will assist in resolution of audit findings only as
requested by DSPPIAR
– ASFR also serves as a liaison with O M B, the O P D I
Vs, and the OIG on grant-related audit issues

• Recipient responsibilities
– Resolve audit findings of subawards
• Most O N C programs have a large number of subs

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 Audit Resolution

• Corrective Action Plan (C A P)

should include:
– Description of each finding
– Specific steps to be taken to implement
the recommendation
– Timetable for performance of each
corrective action
– Description of monitoring to be
performed to ensure implementation
of the C A P

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 HHS Office of the Inspector General (OIG) Performance Audits

• Evaluates HHS Goals and Objectives with grantee activities

• Rotating schedule of states and programs
• Annual audit plan
– Identifies key issues
– Implementation plan
• Conducted by OIG staf
• Compares expenditures to program impact
• Reports posted on OIG website (http://oig.hhs.gov/reports.asp)

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 Examples of Inspector General Audit Findings

• No measurable program goals and objectives

• Lack of monitoring and oversight
• Untimely/incorrect financial reporting
• Questioned costs
• Inadequate procurement practices
• Inadequate personal property controls

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 Grants Management Lifecycle – Closeout
ESTABLISH APPLY REVIEW AWARD MANAGE CLOSEOUT
Evaluate Final
Performance Reports
Review
Closeout Package
Conduct Final
Financial Reconciliation
Establish Disposition
of Funds
Notify Grantee of
Closeout

Retain Records

Legend:
Other Federal/HHS
Program Office Grantee
PHASE Entities
Office of Grants
Management ONC Budget PO/GMO Joint
 Recipient Closeout

• Due within 90 Days after End of Award

• Final Progress Report
• Final SF-269 Financial Status report
– Unobligated funds balance
– No unliquidated obligations
– Final drawdown
– Return excess funds
• Invention Disclosure (if applicable)
• Federally Owned Property Control (if applicable)

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 Retention of Records – Grantees

• Grantee Requirements (45 CFR 92.42 and 74.53)

• At least 3 years from the date of submission of the final
expenditure report
• If litigation, claim or an audit is initiated prior to the
expiration of the 3 year period, records must be retained
until completion of the action and resolution of issues or
the end of the 3 year period, whichever is later
• Records may be retained in an electronic format

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 Retention of Records – ONC

• Office of Grants Management

• 1 year unsuccessful applications
• 6 years 3 months official files
• If open audit, litigation, administrative proceeding
retention may be longer

• Project Officer files

• 2 years after closeout
• If open audit, litigation, administrative proceeding
retention may be longer

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 Grants Management Lifecycle
ESTABLISH APPLY REVIEW AWARD MANAGE CLOSEOUT
Create Notice of Grant Conduct Programmatic Evaluate Final
Authorizing Statute Establish Commitments Objective Review
Award Monitoring Performance Reports
Assess Review Review
Appropriation Assist Applicants Obligate Funds Closeout Package
Fiscal Integrity Performance Reports
Set Up Congressional Review /Recommend Conduct Final
OMB Apportionment Develop Funding Memo
Notification in System Post-Award Actions Financial Reconciliation
Establish Disposition
Conduct Review Application Release Funds Review Audits of Funds
Appropriations Analysis
Perform Conduct Notify Grantee of
Notify Grantee of Award Closeout
Allocate Funds Budget Review Financial Monitoring
Assess Review
Develop Retain Records
Funds Availability Financial Reports
Funding Opportunity
Announcement (FOA) Review and Approve Post-
Award Actions
Release FOA

Program and Grants Management Training and Technical Assistance

Review Award Complete

Review FOA Submit Application Revise Application Drawdown Funds
Package Drawdown of Funds
Submit Generate Final
Accept Award
Performance Reports Performance Reports
Submit Generate Final
Financial Reports Financial Reports
Legend:
Submit Submit
Other Federal/HHS Post-Award Requests Closeout Package
Program Office Grantee
PHASE
Entities
Office of Grants Ensure Audit is Complete Retain Records
Management ONC Budget PO/GMO Joint
 Critical Reference Documents

American Recovery and Reinvestment Act of 2009 (Recovery Act)

• What does the law say
• Statute is highest in order of precedence

45 CFR Part 74 and Part 92 - Administrative Requirements

• Part 92 – Government organizations (Including Tribal)
• Part 74 – NGO
• Uniform administrative rules when implementing Federal grant programs

Cost Principles
• 2 CFR Part 220 – Educational Institutions
• 2 CFR Part 225 – Government Organizations (Including Tribal)
• 2 CFR Part 230 – Non-Profit Organizations
• FAR 31.2

OMB Circular A-133 - Audits of States, Local Governments, and Non

Profit Organizations

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 Critical Reference Documents – continued

• HHS Grants Policy Statement (GPS)

– Grants policy for recipients
– Incorporated as a term in NGA
– Dos and Don’ts
– ONC staf should also know the GPS in order to provide support to grantees
– http://dhhs.gov/asfr/ogapa/grantinformation/hhsgps107.pdf

• Funding Opportunity Announcement (F O A)

• Notice of Grant Award (NGA) with Award Terms and Conditions
• Grants Management Advisories (GMAs)
• Grants Management Memorandum (GMM)
• Program Information Notices (P I Ns)
• Program Assistance Letters (P A Ls)

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 Critical Reference Documents – continued

• Grants Management Advisories (GMAs) – technical assistance resource which will

provide additional information in specific grants management areas for Grantees
– O N C-GMA-2010-01 Roles and Responsibilities Grants and Cooperative Agreements
– O N C-GMA-2010-02 Review of Proposed Subawards and Procurement Contracts Under
Grants
– O N C-GMA-2011-01 Matching and Cost Sharing
– O N C-GMA-2011-02 Use of Unobligated Balances under Grants and Cooperative
Agreements
– O N C-GMA-2011-03 Allowability of Food Costs
– O N C-GMA-2011-04 Program Income
– O N C-GMA-2011-05 Subrecipient Monitoring
– O N C-GMA-2011-06 Allowability of Payments to Uniformed Services and Civilian Federal
Employees

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 Training and Technical Assistance Plan

ONC Office of Grants Management has a Training and Technical

Assistance (T A) Plan based on three diferent levels of assistance:
•Level I: Guidance and Information Sharing – Consists of the daily technical
assistance of grants administration.
•Level II: Sample Protocols, Templates and Models – Targeted telephone and
electronic assistance involves assisting recipients in the development of protocols and
templates, as well as other specific needs, as requested by a recipient.
•Level III: Targeted Training Deliveries and Direct On-Site Assistance – Includes
targeted internal and external training sessions.

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 Office of Grants Management – TA Requests

Grants Management T A
request form
– Please use this form to
request Training and
Technical Assistance from the
ONC Office of Grants
Management
– Completed forms are
available from, and should
be submitted to
ONCGrants@hhs.gov

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Grants Management Questions

ONCGrants@hhs.gov

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