NSP Administrative Requirements

Transcription

1 U.S. Department of Housing and Urban Development NSP Administrative Requirements Accounting, Recordk dkeeping and Monitoring June 17, 2010 U.S. Department of Housing and Urban Development Community Planning and Development 1 1

2 Welcome! Webinar Information All callers will be muted. To ask a question, click on the hand button and you will be recognized at the appropriate time. We will allow for questions after each section and at the end of the session. We are not taking Chat questions. If you are only listening to the Audio portion of the Webinar, you may your question to mbennett@tdainc.org. U.S. Department of Housing and Urban Development Community Planning and Development 2 2

3 Speakers Today Dionne Roberts Training & Development Associates, Inc. William Woodring Training & Development Associates, Inc. Paul Webster HUD U.S. Department of Housing and Urban Development Community Planning and Development 3 3

4 This Session Covers Financial i Management & Accounting Recordkeeping Monitoring U.S. Department of Housing and Urban Development Community Planning and Development 4 4

5 U.S. Department of Housing and Urban Development NSP Administrative Requirements Financial Management NSP & Accounting & Procurement U.S. Department of Housing and Urban Development Community Planning and Development 5 5

6 First the Context All recipients of Federal grants must follow Uniform Administrative Requirements They set common rules or standards for running programs Issued in OMB Circulars and HUD regulations In addition, grantees must follow other OMB Circulars U.S. Department of Housing and Urban Development Community Planning and Development 6 6

7 Applicability Area of Program Management State and Local Governments Not-for-Profits Uniform Administrative Requirements OMB Circular A CFR Part 85 OMB Circular A CFR Part 84 Cost Principles OMB Circular A-87 (2 CFR Part 225) OMB Circular A-122 (2 CFR Part 230) U.S. Department of Housing and Urban Development Community Planning and Development 7 7

8 Guidance on Financial Management Establish minimum standards for managing grants Control and account for funds, property, other assets (internal controls) Identify source and use of all Federal funds (accounting system) Allow accurate, timely and complete financial reporting (budgets and reports) Minimize time in transfer of funds between Federal government and grantee (cash management) U.S. Department of Housing and Urban Development Community Planning and Development 8 8

9 Internal Controls Combination of polices, procedures, job responsibilities, personnel and records that create accountability Ensures funds are used and managed properly U.S. Department of Housing and Urban Development Community Planning and Development 9 9

10 Accounting System System of tracking sources and uses of funds or fund accounting -- method that groups resources into funds Ensures that program costs are Incurred for proper period Actually paid Expended on eligible items Expended from appropriate grant Approved by appropriate officials U.S. Department of Housing and Urban Development Community Planning and Development 10 10

11 Accounting System (cont d) Accounting system should include Chart of accounts Cash receipts journal Cash disbursements journal Payroll journal General ledger U.S. Department of Housing and Urban Development Community Planning and Development 11 11

12 Example: Fund Accounting Revenue Grants Appropriations Collections Total Revenue Expenses Projects/Activities Administration Total Expenses Excess Revenue CDBG HOME NSP General Fund Fees Total U.S. Department of Housing and Urban Development Community Planning and Development 12 12

13 Budgets Records that compare and control expenditures Keep records on budgeted amounts Compare obligations and expenditures to planned budgets and accomplishments Report deviations from budgets and plan Ensures that grantee performs and is held accountable for results U.S. Department of Housing and Urban Development Community Planning and Development 13 13

14 OMB Cost Principles Cost principles referenced in Financial Management Standards Three components further explained in two separate OMB Circulars Cost allowability Cost reasonableness Cost allocation U.S. Department of Housing and Urban Development Community Planning and Development 14 14

15 Determining Costs Costs are only eligible if they Are associated with an eligible client Pay for eligible activities Are delineated in grantee application Have adequate source documentation Meet OMB standards for being Allowable Reasonable Allocable U.S. Department of Housing and Urban Development Community Planning and Development 15 15

16 Cost Allowability In general, cost must be Necessary and reasonable Allocable to program Auth orized or not prohibited Conform to rules and requirements Not charged to any other program U.S. Department of Housing and Urban Development Community Planning and Development 16 16

17 Cost Allowability (cont d) Refer to list of allowed costs in OMB Circular Discusses what s allowed and what s not allowed Specifies circumstances Offers examples l For grantees, 43 selected items of cost U.S. Department of Housing and Urban Development Community Planning and Development 17 17

18 Cost Reasonableness Costs charged to Federal award must be necessary, reasonable and directly related to the grant Look at following Whether cost is ordinary and necessary Market prices for comparable goods and services Benefit to individuals involved Significant deviations from established practices of grantee may present unreasonable cost U.S. Department of Housing and Urban Development Community Planning and Development 18 18

19 Cost Allocation A cost is allocable to HUD program if Treated consistently with other similar costs Incurred specifically for program Benefits program or can be distributed based on a reasonable proportion Necessary to operations U.S. Department of Housing and Urban Development Community Planning and Development 19 19

20 Direct and Indirect Costs Direct costs can be identified with specific program or activity Indirect costs are incurred for common/joint purpose benefiting more than one program or activity Administrative salaries Accounting expenses Facility maintenance U.S. Department of Housing and Urban Development Community Planning and Development 20 20

21 U.S. Department of Housing and Urban Development NSP Administrative Requirements Recordkeeping U.S. Department of Housing and Urban Development Community Planning and Development 21 21

22 Time Requirements Documents have to be kept for 3 years from the date of submission of final expenditure report Financial records Supporting documents Statistical records All other records pertinent to an award U.S. Department of Housing and Urban Development Community Planning and Development 22 22

23 Exceptions to 3-year Rule If any litigation, claim, or audit is started before the expiration of the 3-year period, the records shall be retained until all litigation, claims or audit findings involving the records have been resolved and final action taken. Records for real property and equipment acquired with Federal funds shall be retained for 3 years after final disposition. Indirect cost rate proposals and cost allocati on plans have separate requirements U.S. Department of Housing and Urban Development Community Planning and Development 23 23

24 U.S. Department of Housing and Urban Development NSP Administrative Requirements Monitoring U.S. Department of Housing and Urban Development Community Planning and Development 24 24

25 Why Monitor? HUD reviews (monitors) grantees Annual review Issues with subrecipients and other entities will result in concerns or findings for grantee If problems not resolved, sanctions may be imposed U.S. Department of Housing and Urban Development Community Planning and Development 25 25

26 Grantee Responsibilities Grantees responsible for ensuring that subrecipients and other entities Comply with all applicable requirements Achieve their objectives within schedule and budget Monitoring should offer ongoing support and assistance (TA) U.S. Department of Housing and Urban Development Community Planning and Development 26 26

27 Monitoring Visit (cont d) Step 1 Preparation Prepare for visit by brushing up on rules and reviewing materials (agreements, reports, audits) Step 2 Conducting visit Send notice of date, scope and focus of review Hold entrance conference with chief official Document, gather and analyze information (use checklists and make notes) Hold exit conference to report results, hear reaction and form conclusions U.S. Department of Housing and Urban Development Community Planning and Development 27 27

28 Monitoring Visit (cont d) Step 3 Follow-up Send letter that both praises and raises finding/concerns Set deadlines for response or action U.S. Department of Housing and Urban Development Community Planning and Development 28 28

29 Key Documents for Monitoring Regulations and notices Written agreement Forms/checklists Subrecipients and other entities informa tion Project files Payment requests/vouchers Past monitoring files U.S. Department of Housing and Urban Development Community Planning and Development 29 29

30 HUD s Monitoring Handbook HUD s Monitoring Handbook, Chapter 8 covers NSP topics Offer best guidance for documenting compliance Grantees Subrecipients i and other entities titi handbook.cfm U.S. Department of Housing and Urban Development Community Planning and Development 30 30

31 Contents ECONOMIC RECOVERY PROGRAMS CHAPTER APPLICABILITY 8-2 REVIEW OBJECTIVES 8-3 MONITORING THE HOMELESSNESS PREVENTION AND RAPID RE-HOUSING PROGRAM (HPRP) 8-4 MONITORING THE NEIGHBORHOOD STABILIZATION PROGRAM 1 (NSP-1) 8-5 MONITORING THE NEIGHBORHOOD STABILIZATION PROGRAM 2 (NSP-2) 8-6 MONITORING THE COMMUNITY DEVELOPMENT BLOCK GRANT RECOVERY PROGRAM (CDBG-R) U.S. Department of Housing and Urban Development Community Planning and Development 31 31

32 Contents (cont d) EXHIBIT 8-10 Guide for Review of NSP-1 Program Progress EXHIBIT 8-11 Guide for Review of NSP-1 National Objective of Benefit to Low-, Moderate-, and Middle-Income Persons EXHIBIT 8-12 Guide for Review of NSP-1 Cooperative Agreements EXHIBIT 8-13 Guide for Review of NSP-1 State Requirements EXHIBIT 8-14 Guide for Review of NSP-1 Continued Affordability EXHIBIT 8-15 Guide for Review of NSP-1 Eligible Use C: Establish Land Banks EXHIBIT 8-16 Guide for Review of NSP-1 Fair Housing and Equal Opportunity Requirements EXHIBIT 8-17 Guide for Review of NSP-2 Program Progress U.S. Department of Housing and Urban Development Community Planning and Development 32 32

33 How to Use the Guide As monitor, complete during review Check-off items when evidence provided by subrecipients and other entities When being monitored, use to prepare Self-check presence of file documentation If a monitor can t check Yes next to rule citation, it is a finding of non-compliance U.S. Department of Housing and Urban Development Community Planning and Development 33 33

34 Corrective Actions 3 increasingly serious levels Low-level Identify problem and corrective action Plan strategy t with more reports/monitoring i Moderate-level Restrict payments Disallow expenses or require repayment Impose probation U.S. Department of Housing and Urban Development Community Planning and Development 34 34

35 Corrective Actions High-level Suspend organization Do not renew Terminate activity Initiate legal action U.S. Department of Housing and Urban Development Community Planning and Development 35 35

36 Results End result of monitoring should foster Production/accountability Compliance with requirements Responsiveness to communit ity needs Effective use of resources Good organizational performance U.S. Department of Housing and Urban Development Community Planning and Development 36 36

37 U.S. Department of Housing and Urban Development NSP Administrative Requirements For more help, go to: Give us your feedback: Thank You! U.S. Department of Housing and Urban Development Community Planning and Development 37 37