Policies and Procedures Under the Uniform Guidance

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1 Policies and Procedures Under the Uniform Guidance Maribel Langas Miller Director, Division of Policy and Oversight Office of Grants and Financial Management National Institute of Food and Agriculture Department of Agriculture

2 Perspective Alaska Local Government/School District, Kodiak Alaska Regional Office, Department of the Interior (DOI) Bureau, U.S. Fish and Wildlife Service (FWS) DC Headquarters Office, FWS DC Departmental Office, DOI White House, Executive Office of the President, OMB

3 Free Training for Federal Employees and Grantees

4 National Institute of Food and Agriculture and Our Partners

5 Enterprise Risk Risks and Uncertainty Strategic Operational Reputational Financial Etc. Strategic Decisions (OMB A-11) Budget Decisions (OMB A-11) Mission/Vision Goals/Objectives Strategic Reviews Policy President s Budget Congressional Justification Program Management (OMB A-11) Agency Priority Goals Cross Agency Priority Goals Strategic Review CXO/Operations Support (OMB A-123) Operational Control Objectives Reporting Control Objectives Compliance Control Objectives

6 USDA s Annual Financial Report to inform Congress, the President, and the American people how USDA has used Federal resources entrusted to the Department in FY USDA strives to do the following: remove obstacles in order to give farmers, ranchers, foresters, and producers every opportunity to prosper; prioritize customer service every day for American taxpayers and consumers; ensure that the food we put on the table to feed our families meets the strict safety standards we have established; and be good stewards of the land to leave it better than we found it. USDA has demonstrated good stewardship of taxpayer resources by putting in place well-controlled and wellmanaged business lines and financial management systems and processes.

7 The President s Management Agenda

8 The President s Budget

9 Data

10 Data

11 Data

12 Data

13 The Pyramid of Grant Requirements Authorizations and Appropriations Government Wide Program Statutes & Appropriations OMB Uniform Guidance Government Wide Lobbying Drug Free Workplace Suspension Debarment Davis Bacon Act Agency & Programs Program Regulations NIFA Policy Guide; other guidance RFAs Terms and Conditions 13

14 2 CFR 200 Internal Control Emphasis 2 CFR Policy Guide for Cost Principles Sound Management Practices Uniform Guidance 2 CFR Internal Controls Requirement 2 CFR Definition - Internal controls 2 CFR Definition - Internal Control over Compliance Requirements

15 2 CFR , Subpart E, Cost Principles, Policy Guide Non-Federal entity is responsible for efficient and effective administration of award through use of sound management practices, and administering Federal funds in compliance with agreements, program objectives, and the terms and conditions of Federal award.

16 2 CFR , Financial System Standards Identify all Federal receipts and expenditures Accurate, current, and complete disclosure Comparison of expenditures to budgets Written procedures for payments Records that identify source and application of funds Written procedures for allowable costs Effective control over and accountability for assets

17 2 CFR Internal controls Have effective internal controls over Federal awards that provide reasonable assurance of compliance Comply with Federal statutes, regulations, and grant terms and conditions Evaluate and monitor compliance Take prompt action when instances of noncompliance are identified Safeguard protected personally identifiable information (PII) and other sensitive data.

18 Establishing Policies & Procedures Effective Controls Sound management practices

Requirements for Written Policies and Procedures Required written policies and procedures: Payments 200.302 (b)(6), and 305 Procurement 200.318 Competition 200.

19 Requirements for Written Policies and Procedures Required written policies and procedures: Payments (b)(6), and 305 Procurement Competition Method for evaluation and selection Allowable costs (b)(7) Compensation Fringe Benefits Employee relocation costs Travel costs Put these into clearly written policies and procedures All relevant parties should have copies

20 Recommended Policies and Procedures Accounting System Budget Controls and Modifications Chart of Accounts Receivables Payables Approvals Documentation Audits and Resolution Small Purchase Process Credit Card, Petty Cash Drawdowns and Cash Management

Recommended Policies and Procedures Bank Reconciliation Program Income Interest Income Human Resources hiring and selection Compensation and

21 Recommended Policies and Procedures Bank Reconciliation Program Income Interest Income Human Resources hiring and selection Compensation and Fringe Benefits Complaints/Grievances Cost Policies - Allowable Costs, Indirect Costs Staff Travel Participant/Program Services Purchasing Procurement

and Leveraged Resources Reporting (Financial and Performance)

22 Recommended Policies and Procedures Monitoring Incident Reporting Property/Equipment Management Record Retention Match and Leveraged Resources Reporting (Financial and Performance) Internal Controls, Segregation of Duties Policies and Procedures for the Board

Subrecipient Monitoring &Oversight Ensure subawards appropriately identified Specify required information for each award Include FAIN and DUNS numbers

23 Subrecipient Monitoring &Oversight Ensure subawards appropriately identified Specify required information for each award Include FAIN and DUNS numbers Evaluate risk of non-compliance Monitor subaward activities Verify audit coverage CFDA Number and dollar amount of each Honor ICRs or de minimis rate 24

24 Effective Policies and Procedures Compliant With rules and regulations Clear Precise, easy to understand, unambiguous Complete Addresses the process flow; appropriate level of detail; does not leave major unanswered questions Current Regular review, modify if needed

25 The Goal

GRANT AWARD NOTIFICATION

GRANT AWARD NOTIFICATION 1 RECIPIENT NAME 2 AWARD INFORMATION PR/AWARD NUMBER ACTION NUMBER 0 ACTION TYPE AWARD TYPE Discretionary 3 PROJECT STAFF RECIPIENT PROJECT DIRECTOR 4 PROJECT TITLE 84.250_ EDUCATION PROGRAM CONTACT EDUCATION