The Early Learning Coalition of Flagler and Volusia Counties, Inc. COST ALLOCATION PLAN Effective July 1, 2014September 1, 2015, until amended
Table of Contents SECTION PAGE I Attestation Certificate of Cost Allocation Plan II Introduction A. Purpose/Goal... 4 B. Definitions/Acronyms... 4 C. Applicable Guidance... 8 III Organization Structure A. Overview of ELC Flagler and Volusia Counties Organizational Structure... 8 B. Program(s) Administred/Managed by ELC Flagler and Volusia Counties... 9 C. Service Model to deliver program services to target population... 9 IV Description of Costs and Allocation Methods A. Types of Operating Costs... 10 B. Personnel Activity Reports (PARs)/Time Reporting Practices... 12 C. Support for Salary Allocations... 12 D. Allocations for Other Salary-related Costs... 13 E. Summary for Shared System Costs... 13 F. ELC Flagler and Volusia Counties Cost Pools... 14 G. Illustrative Example Allocations for ELC Flagler and Volusia Counties Cost Pools... 15 V Resource Sharing Agreements A. Entity Approach to Resource Sharing Agreements... 19 VI - Other Applicable Guidance/Instructions A. ELC Flagler and Volusia Counties Cost Objectives/Explanation of Funding Decisions... 19 B. Analysis of Future Fluctuations in ELC Flagler and Volusia Counties Operations... 20 C. Uniform Chart of Accounts/Cost Category Guide... 20 D. Applicable Other Cost Accumulator (OCA) Codes... 20 APPENDIX A Organization Chart for ELC Flagler and Volusia Counties... 21 APPENDIX B Overview of ELC Flagler and Volusia Counties Operating Model for Delivery of Services... 22 APPENDIX C List of Offices/Satellite Locations... 23 APPENDIX D Personnel Activity Reports (PARs) /Timesheet Template... 24 APPENDIX E Staff Instructions for PARs/Time Reporting... 26 APPENDIX F Uniform G/L Account Instructions... 28 APPENDIX G - Other Cost Accumulators (OCA) Codes... 28
Section I - Attestation Certificate of Cost Allocation Plan OMB A-122OMB A-81 CERTIFICATE OF COST ALLOCATION PLAN This is to certify I have reviewed the cost allocation plan submitted herewith and to the best of my knowledge and belief: This cost allocation plan has been prepared and implemented to allocate costs in accordance with the requirements of Generally Accepted Accounting Principles and OMB Circular A-122A- 81, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards., Cost Principles for Non-Profit Organizations. All costs included in this proposal are properly allocable to Federal awards on the basis of a beneficial or causal relationship between the expenses incurred and the agreements to which they are allocated in accordance with applicable requirements. Similar types of costs have been accounted for consistently and the State will be notified of any accounting changes affecting calculations. I declare the foregoing is true and correct. Organizational Unit: The Early Learning Coalition of Flagler and Volusia Counties, Inc. Signature: Name of Official: (Print or type) Title: DJ Lebo Executive Director Date of Execution: July 1, 2014September 1, 2015 Final Date of Submission: June 30, 2014September 1, 2015
Section II Introduction Purpose/Goal Cost Allocation is a method to identify and assign indirect costs to a cost object without arbitrary apportionment. Costs can be allocated where the amount to be assigned can be determined accurately. Direct costs are costs from activities identified to benefit a specific grant program or cost objective. Such costs are directly charged by the ELC of Flagler and Volusia Counties when incurred. Costs from other activities providing benefits to more than one grant program or cost objective may occur. The costs for these blended/shared activities must be identified in order to allocate the charges to the program(s) they benefit in a cost-effective and efficient way. This Cost Allocation Plan describes our approach to this process. Definitions/Acronyms As used in The Early Learning Coalition of Flagler and Volusia Counties, Inc. (ELCFV) Cost Allocation Plan Administrative Costs: Administrative costs are costs associated with the overall management and administration of a program not related to the direct provision of early education program services or otherwise allocable to the program cost objectives/categories. These costs can be from both personnel and non-personnel activities. Administrative costs include both the direct and shared costs associated with the management of the programs provided by an early learning coalition. Allocation Basis: An allocation basis is the calculation or measure best determining the benefits provided to a cost objective or program with minimal distortion; for example: square footage of building used, number of participants served. CAP: Cost Allocation Plan. Cost Pool: A cost pool is a collection of costs necessary to an entity s operation and which benefit more than one program or cost objective. Costs in a cost pool require further allocation in order to be charged to the final cost objectives based upon the relative benefits received. Costs in a cost pool may only be allocated to the cost objectives actually receiving a benefit. They may not be co-mingled with costs allocable to other cost objectives not receiving any benefit from the costs. Direct Costs: Direct costs are those specifically identified with a particular final cost objective, i.e., a particular award, project, service, or other direct activity of an organization. The Early Learning Coalition of Flagler and Volusia Counties, Inc. (ELCFV): Early Learning Coalitions are not-for-profit organizations tasked with administering the state s early education programs at the local level. There are 301 ELCs. The Flagler County School Readiness Coalition 4
and Volusia County School Readiness Coalition were originally authorized under s. 411.01 1002.81, F.S. On July 1, 2005, the Flagler County School Readiness Coalition merged into the Volusia County School Readiness Coalition and was renamed The Early Learning Coalition of Flagler and Volusia Counties, Inc. (ELCFV). ELCFV provides oversight and policy for all Early Learning programs (School Readiness and VPK). The current service area is Flagler and Volusia counties and includes all eligible School Readiness and VPK children who enroll for services within those counties. Early Learning Information System (ELIS)/Enhanced Field System (EFS): The Enhanced Fields System is a statewide centralized technology system to provide critical information to early learning parents, partners and providers. The anticipated benefits of EFS include, but may not be limited to, the following: (1) streamlined administrative processes for attendance tracking, eligibility processing and provider payments, (2) data sharing opportunities for educators, parents, providers and state agencies, and (3) easy on-line access to child care resources and referral information for early learning programs. Enhanced Fields System (EFS): A centralized statewide information system is in place to provide critical information to early learning parents, partners and providers. The uses of EFS include, but may not be limited to, the following: (1) administrative processes for attendance tracking, eligibility processing and provider payments, (2) eligibility determination and enrollment, (3) generating child care resource and referral information for parents and guardians. Florida Office of Early Learning (OEL): ELCFV s oversight agency for federal and/or state grant program funds received from the Department of Education, State of Florida. OEL is tasked with administering the state s early childhood development and education programs (i.e., School Readiness program and the Voluntary Pre-Kindergarten Program). Note: based on changes to state law enacted by SB 2156, effective October 1, 2011, OEL is a division of the Florida Department of Education. OEL was designated at that time as the lead agency for administration of the Federal Child Care and Development Fund, the school readiness system in accordance with s. 411.016M and the operational requirements of the Voluntary Pre- Kindergarten Education Program in accordance with part V of chapter 1002. Full Time Equivalent (FTE): A full time equivalent is a measurement of time paid to employees. One FTE is equivalent to 2,080 hours of time paid based on a 40 hour work week in an annual program year. Generally Accepted Accounting Principles (GAAP): GAAP are accounting rules and procedures established by authoritative bodies or conventions evolved through custom and common usage. GAAP has the meaning specified in generally accepted government auditing standards (GAGAS). [OMB Circular A-133] GAAP was issued by the American Institute of Certified Public Accountants (AICPA). [29 CFR 99.105] 5
In-Kind Contributions: In-kind contributions are donations from third parties. They are not to be confused with contributions by partnering programs of such things as space, equipment, staff or other goods and services for which the partnering program incurs a cost. Such partner contributions constitute the resources shared with the ELC to cover their proportional allocated share of blended/common costs. For more information and OEL guidance on this topic, please refer to the guidance paper link provided here: http://www.floridaearlylearning.com/sites/www/uploads/files/coalition/440.10%20match %20Reporting%20Guidance%202.25.pdf (insert new OEL link here, when available) In-Kind Contributions - Third-party: Third party in-kind contributions are the value of non-cash contributions provided by non-federal third parties. Third-party in-kind contributions may be in the form of real property, equipment, supplies, or other expendable property, and the value of goods and services directly benefiting and specifically identifiable to the project or program. OMB: The Executive Office of the President, Office of Management and Budget. The OMB issues authoritative guidance for federal grant programs called OMB Circulars. OMB A-122 (Now 2 CFR Part 230): This Circular establishes principles for determining costs of grants, contracts and other agreements with non-profit organizations. The principles are designed to provide the Federal Government bear its fair share of costs except where restricted or prohibited by law. OMB A-81 - consolidates and updates eight previous circulars including A-21 Cost Principles for Educational Institutions and A-110 Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations. The revisions become effective for new federal awards and new funding for existing awards on December 26, 2014. Other Cost Accumulator Code (OCA): OCA codes used to track expenditures and monitor awards of early education grant program funds in a uniform way to ensure OEL credits all expenditures of federal and state funds to the appropriate funding sources and benefitting programs. Personnel Activity Reports (PARs): Personnel Activity Reports reflect the distribution of activity of each employee and must be maintained for all staff members (professionals and nonprofessionals) whose compensation is charged, in whole or in part, directly to grant program awards. Prior Approval: Prior approval is the process of securing permission in advance from the ELC s oversight agency (i.e., OEL) to incur cost for those items designated as requiring prior approval by the OMB Circulars. For more information and OEL guidance on this topic, please refer to the guidance paper link provided here: http://www.floridaearlylearning.com/sites/www/uploads/files/coalition/240.05%20prior% 20Approval%20Guidelines.pdf(insert new OEL link here, when available) 6
Program: A grant, appropriation, or other designated fund whose activities, including costs, must be accumulated and reported to the funding sources. Examples of grant programs are: Child Care Development Block Grant Fund (CCDBG) Discretionary Funds, Temporary Assistance for Needy Families (TANF) and Voluntary Pre-Kindergarten (VPK) State General Revenues. Program Income: Program income is defined as additional revenues available for grant purposes earned as a result of a grant-funded activity or as a result of the grant agreement. Program income includes, but is not limited to, income from fees for services performed, the use of rental of real or personal property acquired under Federally funded projects, the sale of commodities or items fabricated under an award, license fees and royalties on patents and copyrights, and interest on loans made with award funds. Interest earned on advances of Federal funds is not program income. Except as otherwise provided in Federal awarding agency regulations or the terms and conditions of the award, program income does not include the receipt of principal on loans, rebates, credits, discounts, etc., or interest earned on any of them. School Readiness program (SR): The School Readiness program is part of the state s early childhood education development programs. Each ELC s School Readiness program should provide the elements necessary to prepare at-risk eligiblechildren for school, including health screenings/referrals and an appropriate educational program. SR services are provided on a full day, full-year, and full-choice basis to the extent possible in order to enable parents to work and be financially self-sufficient. The delivery of SR programs is comprised of child care providers and school-based sites operated by public and nonpublic schools. SR programs are funded through a mixture of federal and state funds. SR programs include, but are not limited to, the following elements: Developmentally appropriate, OEL approved curriculum; Appropriate staff-to-children ratio; and Parents making an informed choice of child care providers Shared/Joint/Common/Blended Costs: Shared costs are costs that cannot initially be charged to a single final cost objective. Costs such as rent, utilities, and phone, which cannot be readily assigned because they benefit multiple programs, service areas, or funding sources (for example, resource areas and conference rooms) may be considered shared/joint, common or blended costs. These accumulated costs are charged to an intermediate cost objective or cost pool and are periodically (usually on a monthly basis) allocated based on an agreed upon measure of benefit (time distribution, square footage, number of participants, etc.) Teen Parent Program: The Teen Parent program is part of an Agreement between The Early Learning Coalition of Flagler and Volusia Counties, Inc. and the School Board of Volusia County, FL (SBV). Those who are deemed eligible from the SBV will receive a referral for formal child 7
care services. The contracted award is set by the SBV with restrictions. All activity is referral based. Voluntary Pre-Kindergarten program (VPK): The Voluntary Pre-Kindergarten Education program is part of the state s early childhood development and education services delivery model. It provides every four-year-old child in Florida eligibility for a free, high quality prekindergarten learning opportunity that shall be voluntary and delivered according to professionally accepted standards. This program is designed to enhance each child s ability to make age appropriate progress in the development of language and cognitive capabilities through education in basic skills. The delivery system for the VPK program is comprised of private Pre-Kindergarten providers and of school-based sites operated by public and nonpublic schools. The VPK program is funded fully with state General Revenue (GR) funds. Applicable Guidance OMB Circular A-122 81 (2 CFR Part 200.300(2 CFR 230) (insert new OEL link here, when available) http://www.whitehouse.gov/sites/default/files/omb/assets/omb/fedreg/2005/083105_a122.pdf Florida State Auditor General www.myflorida.com/audgen Florida s School Readiness (SR) Act (s. 411.01, F.S.) http://www.leg.state.fl.us/statutes Florida s Voluntary Pre-Kindergarten Education Program (VPK) (ss.1002.52-1002.79, F.S.) http://www.leg.state.fl.us/statutes Florida Office of Early Learning www.floridaearlylearning.com Section III Organization Structure Overview of ELC of Flagler and Volusia Counties, Inc. and its Organizational Structure Early Learning Coalition Board Mission Statement ELCFV is committed to meeting the early learning needs of all children in our community. We focus on this work through our mission to Enhance children's School Readiness by providing opportunities for quality early learning while strengthening family stability for a healthy community. By effectively utilizing the resources available, we are able to offer opportunities to children and families focusing on the birth-to-five population to enhance their chances for education success by participating in quality school readiness and Voluntary Pre-Kindergarten programs better preparing them for school. Early Learning Coalition 8
The Flagler County School Readiness Coalition and Volusia County School Readiness Coalition were originally authorized under s. 411.01, 1002.81, F.S; now 6M. On July 1, 2005, the Flagler County School Readiness Coalition merged into the Volusia County School Readiness Coalition and was renamed The Early Learning Coalition of Flagler and Volusia Counties, Inc. (ELCFV). ELCFV provides oversight and policy for all Early Learning programs (School Readiness and VPK). The current service area is Flagler County and Volusia County and includes all eligible School Readiness and VPK children who enroll for services within those counties. ELCFV is responsible for the development, implementation, and oversight of the School Readiness and Voluntary Pre-Kindergarten programs and ensures children residing in Flagler and Volusia Counties have access to the service delivery system. For more information, please refer to Appendix A of this CAP, Organization Chart of ELC of Flagler and Volusia Counties, and refer to Appendix C of this CAP, List of Offices. Early Learning Coalition s Governing Board ELCFV s Board is comprised of at least 15, but not more than 30 members and is in compliance with s. 411.01(5)(a) 4-7 and 136M1002.81, F.S. ELCFV s membership is submitted to Florida s the Office of Early Learning for final approval and verification of membership statutory requirements. The Board is charged with the coordination of the early care and education system for ELCFV and is the local oversight body for ELCFV. The Board approves the CAP annually. Program(s) Administered/Managed by ELC of Flagler and Volusia Counties School Readiness (SR) Program ELCFV s School Readiness program provides the elements necessary to prepare at-riskeligible children for school, by promoting a quality learning environment, appropriately designed for the individual learning of each child. This includes several aspects, including health screenings/referrals and an appropriate educational program within the provider s programs. SR services are provided on a full day, full-year, and full-choice basis to the extent possible in order to enable parents to work and be financially self-sufficient. SR programs include, but are not limited to, the following elements: Appropriate staff-to-children ratio; Appropriate teacher-child interactions; Developmentally appropriate curriculum; and Parents are encouraged to make informed choices of child care providers. The delivery of SR programs is comprised of child care providers and school-based sites operated by public and nonpublic schools. SR programs are funded through a mixture of federal and state funds. 9
Voluntary Pre-Kindergarten (VPK) Program ELCFV s Voluntary Pre-Kindergarten program constitutionally provides every four-year-old child in Florida is eligibility for a free, high quality prekindergarten learning opportunity that shall be voluntary and delivered according to professionally accepted standards. The delivery system for the VPK program is comprised of private prekindergarten providers as well as school-based sites operated by public and nonpublic schools. The VPK program is funded fully with state General Revenue (GR) funds. Service Model to Deliver Program Services to Target Population ELCFV s service delivery system presently consists of five functional components with shared functional responsibilities amongst the components. These components include: Resource and Referral Services, Child Care & Education Services, Service Provider Payments, IT & System Services and Comprehensive Services. A brief description of these components is included in the service delivery system chart in Appendix B of this CAP, Overview of ELC of Flagler and Volusia Counties Operating Model for Delivery of Services. Section IV Description of Costs and Allocation Methods ELCFV is required to track expenditures for the School Readiness and Voluntary Pre- Kindergarten programs by other cost accumulator codes (OCAs). These OCAs are used to document administrative services, non-direct services, quality services, and direct service costs. A comprehensive listing of OCA codes is included in Appendix G. The Florida Office of Early Learning (OEL) provides the listing of available OCA codes to ELCFV. The CAP is based on the listing of OCA codes in effect and approved by OEL for use. All shared costs have been identified and estimated dollar values have been provided for illustrative purposes only. A description of each identified shared activity, cost item, or cost pool is provided, including function and benefit statements and the allocation methodology used. Narrative descriptions of all costs and any applicable funding limitations are also provided as are the relevant definitions of program and administrative costs. Only allowable OCAs will be included in the shared cost when the cost pool is generated. ELCFV records shared expenses and revenues using a two-segment method. The first segment defines which county, Flagler or Volusia, and the grant; for example SRF for School Readiness Flagler. The second segment defines which types of OCA services are being completed; for example 97BBA. This is accomplished by using the PARs to allocate the expenses in ELCFV s cost pool. ELCFV also expenses some items directly to the appropriate county, grant and OCA code. Once all expenses are coded, Revenue and Expenditure Reports are used to calculate the amounts of reimbursable expenses and OEL reimbursement worksheets are completed. The revenue is recorded to the appropriate county, grant and OCA code. ELCFV analyzes the ratio of children served by county and/or by funding grant and as appropriate on quarterly basis and 10
applies previous quarter s ratio to the quarter immediately following. calendar: Sample allocation For Expense Period Use Ratio Period July 1, 20153 Sept 30, April 1, 20153 June 30, 20153 20153 Oct 1, 20153 Dec 31, 20153 July 1, 20153 Sept 30, 20153 Adjustments will be made if % adjustment is more than 2%, final % from fiscal year will be used effective for the new fiscal year regardless of % change. Types of Operating Costs ELCFV is required to track expenditures by other cost accumulator codes (OCAs). OEL provides the list of available OCA codes to ELCFV. The CAP is based on the list of OCA codes in effect and approved by OEL for use. The full document is available on the following state website. For more specific instruction, please refer to Appendix G, Other Cost Accumulator Codes (OCAs). http://www.floridaearlylearning.com/sites/www/uploads/files/coalition/documents/250.0 1%20OCA%20Working%20Definitions.pdf(insert new Share Point Coalition Zone site link here, when available) ELCFV tracks expenditures for the School Readiness and Voluntary Pre-Kindergarten programs by other cost accumulator codes (OCAs). These OCAs are used to document the following categories of expenditures: Direct services costs; Quality Services; Non-direct service costs; Administrative costs; and Outreach and Awareness costs. Direct Services Costs Direct service costs are those specifically identified with providing early education services to eligible children. Child care providers submit attendance verificationmonthly attendance reports forms to ELCFV. The monthly attendance reports attendance forms provide data on the children served under the various early education programs and are subsequently reconciled to actual attendance by ELCFV subsidy managementprovider services staff. Payments are made to the child care providers based on the attendance data. The Finance Department accumulates cost data by OCA code based on the services provided to each child. 11
Quality Services These costs are associated with enhancing the overall performance of the early education system. Examples include, but are not limited to: quality items as identified in 45 CFR 98.51, resource and referral services, inclusion services, and rate differential costs paid to providers who meet national accreditation standards. These costs are allocated 100% to the Child Care Development Fund grant. Reimbursements for this category of expenditures are subject to a minimum earmark percentage of 4% the total grant award. Non-Direct Service Costs Non-Direct service costs are related to child care services and early education expenditures not for direct child care. Examples include eligibility determinations, monitoring of placements, other monitoring (other than for increasing quality), social services, child care placement, recruiting providers, and program development. Reimbursement for this category is capped at 19% of total expenditures less the reimbursement for administrative costs. ELCFV produces monthly revenue and expenditure reports for each non-direct service. Administrative Costs Administrative costs are associated with the administration and oversight of the School Readiness programs by ELCFV. The expenses under this heading are those incurred for the overall general executive and administrative offices of the organization and other expenses of a general nature which do not relate solely to any major function. This category shall also include its allocable share of fringe benefit costs, operation and maintenance expense, depreciation and use allowances. They include items as identified in 45 CFR 98.52 and OMB A-122-OMB A- 81. Examples of Administrative Coalition costs include: fiscal and budgetary activities, contract management, Board expenses, Coalition Administrative costs also include allocated shared costs such as: advertising, audit fees, data system support, insurance, legal services, repair and maintenance costs, rent, office supplies, and utilities. On a minimum of a bi-weekly basis, employees of ELCFV are required to document their work activities through the use of PARS, which are available for review. Reimbursements for this category are capped at 5% of the grant award, unless OEL grants a waiver for School Readiness and 4% for VPK administrative, enrollment and monitoring costs. Outreach and Awareness Costs When Outreach and Awareness funds are made available to ELCFV for the VPK program to provide for planning and implementation expenditures at the local level, these expenditures include non-direct services costs not related to providing direct classroom training. Examples of these costs include: planning materials and activities, training materials and activities, and outreach activities associated with the initial registering of providers and children. Please refer to Appendix G for a list of outreach and awareness OCA codes. School Readiness and VPK Program Allowable Costs Overview Program - Program - School Voluntary Service Delivery Costs Readiness Pre-K 12
Direct Services (Also Quality for SR) 8081.00% 96.00% Quality Services (QI4, etc) 8.608.30% tbd Administrative OCA (97BBA, etc.) - maximum 5.00% 4.00% Non-Direct Services (97BBD, etc.) 6.405.7% tbd Total 100.00% 100.00% Personnel Activity Reports (PARs)/Time Reporting Practices PARs are completed by ELCFV Staff. All ELCFV staff complete biweekly PARs via PayChexthe Payroll Service Provider web clock in tool. These reports are an after-the-fact determination of the actual activity of each employee. Each report accounts for the total activity for which employees are compensated and which is required in fulfillment of their obligations to the organization. The reports are electronically approved by the individual employee, or by a responsible supervisory official having firsthand knowledge of the activities performed by the employee. The distribution of activity represents a reasonable estimate of the actual work performed by the employee during the periods covered by the report. Support for Salary Allocations Salary expenses for ELCFV staff are supported by ELCFV staff PARs detailing the hours per pay period each employee was engaged in activities attributed to a particular OCA or to the blended/shared activities time codes. The reports are electronically approved by the individual employee, or by a responsible supervisory official having firsthand knowledge of the activities performed by the employee. Time for blended or shared activities is allocated through the use of a cost pool. In instances where costs are attributable to multiple OCAs (e.g. hours), allocation is based on percentages derived by summarizing all staff s actual hours as reported on PARs in each OCA for the pay periods ending during specified month. PARs are completed electronically and submitted bi-weekly according to ELCFV s annual pay period schedule. Information captured on the PAR is used in the payroll preparation process. Payroll journals processed each pay cycle detail compensation allocations by OCA or program function. ELCFV management monitors amounts charged to the OCA codes to ensure activities are correctly classified, administrative spending caps are not exceeded, and to verify all other minimum program earmarks are met. Allocations for Other Salary-related Costs ELCFV Staff costs incurred for other salary-related costs, such as Federal Insurance Contributions Act (FICA) tax, Unemployment Compensation (UC), Worker s Compensation, health insurance, dental insurance, life & disability, as well as Paid Time Off (PTO, annual/sick leave and holidays) are allocated monthly based on the percentages of actual time an employee 13
has spent working on program-related tasks as reported in the monthly PARs for ELCFV staff. Summary for Shared System Costs Costs for activities benefitting a single grant program are allocated or directly charged to the program as incurred. Other costs providing a benefit to more than one grant program are shared costs ELCFV allocates to the appropriate OCAs or project codes based on (1) guidance from OEL on OCA working definitions (OEL Guidance 250.01) and (2) the cost allocation methodologies described in this CAP. A description of each identified shared activity, cost item, or cost pool is provided, including function and benefit statements and the allocation methodology used. The following charts and tables provide illustrative allocation examples of shared costs benefitting each early education program in ELCFV s early education system delivery model for program services. 14
Table 1 - Shared Systems Costs Table Monthly Shared Systems Costs (1&7) Amounts to be Allocated School Readiness OEL Voluntary Pre-K Programs: Local School District (2) Teen Parent (6) Salaries and Benefits (3) $50,000 X X X (7) Computer & IT $3,500 X X General & Administrative $6,000 X X Insurance $2,000 X X Legal & Professional $1,515 X X Outreach & Special Events $210 X X Space Rental & Maintenance $25,500 X X Telephone & Utilities $5,750 X X Travel & Training (4) $525 X X Total Costs (5) $95,000 Notes: (1) Direct Costs that can be are specifically assigned by OCA code and not included in shared costs. Such Direct Costs have already been charged by ELCFV to the benefitting program(s). (2) Based on analysis performed by ELCFV management, these costs represent allowable costs for activities benefitting the SR/VPK programs. Costs have been allocated on a proportional basis to SR. (3) Represents all shared/blended salary and benefit costs for ELCFV. (4) Travel and training relate to general quality activities for ELCFV benefitting both specific and all early education programs. (5) The amounts shown are for illustrative purposes only and do not reflect actual ELCFV spending levels. (6) All allowable and direct charged as activity is billed. (7) Based on analysis performed by ELCFV management, these costs represent allowable costs for activities benefitting the SR program. Costs have been allocated on a proportional basis to SR. These Administrative Funds received are credited to SR 97BBD Monthly. ELC of Flagler and Volusia Counties Cost Pool ELCFV has implemented a Coalition Shared Cost Pool to manage and allocate shared/blended costs incurred benefitting multiple early education programs on a routine basis. Included below is a brief narrative description for the listed cost pool(s) and illustrative example allocations of ELCFV s Sample Shared Costs to allowable OCA codes. Early Learning Coalition Shared Cost Pool Function & Benefit: This cost pool accumulates all ELCFV costs not directly attributable to a particular grant program. These costs may include all governing board administrative costs (travel, copy costs), ELCFV administrative costs (salaries, travel supplies, copier, etc.) and costs incurred by program staff benefitting multiple early education program activities. ELCFV and its governing board s administrative oversight and guidance benefits all the early education programs. The described methodology best reflects the proportionate share of the benefit received by each benefitting grant program. 15
Allocation Method: Basis: Costs are distributed based on ELCFV staff s bi-weekly direct hours worked as reported on the PARs distribution summary for the current month. PARs are compiled per pay period on actual direct-charged staff time distributed to each program and the percentages charged to each program are used to allocate all costs accumulated in ELCFV s Shared Cost Pool. Justification: ELCFV and its governing board s administrative oversight and guidance benefit all the early education programs. The described methodology best reflects the proportionate share of the benefit received by each benefitting grant program. Frequency in which underlying data will be updated: ELCFV s cost pool distributions will be based on the compiled bi-weekly PARs submitted by Coalition staff. The cost pool allocation percentages will be updated per pay period based on the PARs prepared. The payroll process includes the hours allocation file which is reviewed each pay period in order for the calculations to be prepared. o The allocable split between counties is reviewed quarterly and updated as needed based on the number of children served and on the waitlist in each county. o The allocable split between quality OCA s requiring a separation between ages of children is reviewed quarterly and updated as needed, based on the percentage of age categories. o Only allowable OCAs will be included in the shared cost when the cost pool is generated. o Supporting Documentation: PARs will be maintained to support the percentage distributions to all grant programs. 16
Illustrative Example Allocations for ELC of Flagler and Volusia Counties Cost Pool The following chart is an illustrative example of direct-charged staff work hours for a month. These percentages will be used to allocate shared/blended costs from ELCFV s cost pool to benefitting grant programs. Table 2 Preliminary Cost Allocation Percentages Table Program Funder Direct-Charged Hours Data Total Program Staff Hours (1) Percentage (based on total) Shared Costs % s Total Program Staff Percentage (4) Hours (4) (based on total) SR Flagler (2) OEL 843900 12.04%12.86% 840900 12%12.86% SR Volusia (2) OEL 5,1555,100 73.64%72.86% 5,1805,120 74%73.14% VPK Flagler (2) OEL 140147 2.10% 140 2.10% VPK Volusia (2) OEL 840833 11.902% 840 1211.90% (3) (3) Teen Parent (5) School District 202 0.3228% Total 7,000 100% 7,000 100% Notes: (1) Hours are distributed based on the actual distributions from the month s PARs, based on hours and allocations of job tasks.. (2) Represents a roll up of OCAs for the program. Costs are allocated at the OCA level. See Tables 3 and 4 for details. (3) Based on analysis performed by ELCFV management, these costs represent allowable costs for activities benefitting the SR program. Costs have been allocated on a proportional basis to SR. These Administrative Funds received are credited to SR 97BBD Monthly. (4) Represents the revised calculated percentages for shared costs based on information in item #3 above. (5) Volusia County Only. Tables 3 and 4 OCA Allocation Percentages illustrative partial* details of monthly direct hours charged from ELCFV Staff PARs and/or monthly direct services expenditures *Full disclosures for SR are optional. Table 3 OCA Allocation Percentages Table - SR Monthly OCA Allocation Percentages for ELCFV Staff School Readiness (SR) Administrative Non-Direct Quality Direct Services SR Percentages 5% 6.45.7% 8.68.3% 810% Table 4 OCA Allocation Percentages Table - VPK Monthly OCA Allocation Percentages for ELCFV Staff Voluntary Pre-K (VPK) Administrative Enrollment Monitoring Direct Services VPK Percentages 1.81% 1.72% 0.51% 96% 17
Based on the percentages shown above in Tables 2-4, shared/blended costs in ELCFV s Cost Pool are allocated to benefitting grant programs as demonstrated by the following tables: Table 5 Summary Cost Allocation - All Programs (See footnotes on pages 18) Shared Systems Costs Amounts to be Allocated School Readiness Flagler OEL School Readiness Volusia Programs: Voluntary Pre-K Flagler Voluntary Pre-K Volusia Local School District (2) Teen Parent Allocation Percentages 12.0412.86% 73.6472.86% 2.10% 1211.90% 0.3228% Salaries and Benefits $50,000 $6,020 430 $36,820430 $1,000050 $6,0005,950 $160 140 Percentages after Funding Decisions 12.0412.86% 74.6473.14% 2.10% 1211.90% 0% Computer & IT $3,50024 $421450 $2,6122,560 $7074 $420416 $0 General & 6,00041 722772 4,4784,388 120126 720714 0 Administrative Insurance 2,00014 241257 1,493463 4042 240238 0 Legal & 1,51525 182195 1,1311,108 3032 182180 0 Professional Outreach & 2101 2527 157154 4 25 0 Special Events Space Rental & 25,500673 3,070,3,279 19,03318,651 53510 3,03560 0 Maintenance Telephone & 5,75089 692739 4,2924,206 12015 68590 0 Utilities Travel & 5259 6368 392384 11 623 0 Training (4) Total Costs (5) $95,000306 $11,43612,217 $70,40869,344 $1,900994 $11,400 305 $160 140 Table 6 Monthly Allocation of Shared Costs by OCA SR Monthly Shared Systems Costs - Amounts (7) OCAs SR to be Administrative (6) Non-Direct Quality Direct Allocated (2) Services (1) Allocation Percentages across all OCA 5% 6.45.7% 8.68.3% 8081% Percentages after Funding Decisions (8) 2029% 32% 4839% 0% Salaries and Benefits (3) $42,7604 $8,55212,429 $13,68313, $20,52516 $0 2,860 716,715 Computer & IT 3,010 602873 963963 1,4451,17 0 4 General & Administrative 5,160 1,0321,496 1,6511,651 2,4772,01 0 3 Insurance (9) 1,720 1,720 0 0 0 Legal & Professional (9) 1,303 1,303 0 0 0 Outreach & Special Events 181 3652 5858 7187 0 18
Space Rental & Maintenance 21,930 4,3866,360 7,0187,017 10,5268,5 0 53 Telephone & Utilities 4,945 9891,434 1,5821,582 2,3741,92 0 9 Travel & Training (4) 451452 90131 144145 217176 0 Total Costs (5) $81,4605 61 $18,71025,79 8 $25,09925, 132 $37,65130,631 $0 Table 7 Monthly Allocation of Shared Costs by OCA - VPK Monthly Shared Systems Costs - VPK Amounts to be Allocated (6) OCAs Administrative (6) Enrollment (6) Monitoring (6) Direct Services (1) Allocation Percentages across all OCA 1.81% 1.72% 0.51% 96% Percentages after Funding Decisions (8) 3623% 4852% 1625% 0% Salaries and Benefits (3) $7,000 $2,5201,610 $3,3603,640 $1,1201,7 $0 50 Computer & IT 490 177113 25535 78122 0 General & Administrative 840 193303 403437 134210 0 Insurance (9) 280 280 0 0 0 Legal & Professional (9) 212 212 0 0 0 Outreach & Special Events 29 107 1415 57 0 Space Rental & Maintenance 3,570 1,285821 1,7141,856 571893 0 Telephone & Utilities 805 290185 418386 129202 0 Travel & Training (4) 7473 2617 3638 1218 0 Total Costs (5) $13,300 299 $5,1033,438 $6,1486,659 $2,0493,2 02 $0 Notes for Tables 5, 6 and 7: (1) Direct Costs that can be are specifically assigned by OCA code and not included in shared costs. Such Direct Costs have already been charged by ELCFV to the benefitting program(s). Only costs incurred for direct services can be charged to this OCA. (2) Based on analysis performed by ELCFV management, these costs represent allowable costs for activities benefitting the SR program. Costs have been allocated on a proportional basis to SR and minimal benefits receives therefore rollup to Salaries & Benefits. (3) Represents all shared/blended salary and benefit costs for ELCFV. (4) Travel and training relate to general quality activities for ELCFV benefitting both specific and all early education programs. (5) The amounts shown are for illustrative purposes only and do not reflect actual ELCFV spending levels. (6) ELCFV management monitors amounts charged to the various OCA costs (a) to ensure administrative spending caps are not exceeded and (b) to verify all other minimum program funding objectives are met. (7) Costs have been allocated on a proportional basis to SR. (8) The percentages shown represent a rollup of all OCA categories, excluding direct OCAs, based on ELCFV staff biweekly direct hours worked as reported on the PARs distribution summary. (9) OCA guidance provides these costs are generally administrative in nature and restricted to 97BBA/VPADM; however, the ELC may infrequently incur individual transactions in these cost categories resulting in allocations to other OCAs. Adequate documentation to support any such transactions will be maintained at ELCFV level and will be available for review upon request. Additional Comments/Instructions: 19
A cost is allocable to a particular OCA if the costs of goods or services are chargeable or assignable to such OCA in accordance with relative benefits received. For example, a telephone may be used by a staff member to provide both administrative and eligibility services for ELCFV. The employee s time working in these areas of responsibility (administrative and eligibility services) will determine the allocation of the cost of this equipment. Section V Resource Sharing Agreements Entity Approach to Resource Sharing Agreements ELCFV does not have any active resource sharing arrangements. ELCFV has no shared resources or common/shared activities with entities that are not under the ELCFV s or under OEL s funding control. ELCFV management routinely reviews operations on at least a quarterly basis to identify changes to ELCFV resources or activities, including resource sharing arrangements. Note: ELCFV management asserts that if such activities are identified in future periods, management decisions will be made on a case-by-case basis to initiate any required changes to the cost allocation processes described in this CAP. Factors management will use in this process will include the significance of any resource sharing activities identified and the anticipated cost/benefit results from such revisions. Section VI - Other Applicable Guidance/Instructions ELC of Flagler and Volusia Counties Cost Objectives/Explanation of Funding Decisions ELCFV has structured this CAP in accordance with OMB Circular guidance. It should be noted the OMB Circulars provide a distinction between cost allocation and funding allocations. Our management is aware of this distinction and makes funding decision modifications as needed. A brief description is included as follows for these two processes. EXAMPLE OF COST ALLOCATION DECISIONS: A function or activity within the ELCFV benefitting two or more programs may be set up as a single cost objective. Costs allocable to cost objective are allowable to any of the involved programs benefitting from these activities/costs. In addition, ELCFV can make a funding decision regarding what combination of funds made available under these programs would be applied to this cost objective. EXAMPLE OF FUNDING ALLOCATION DECISIONS: Based on program guidelines and restrictions, the costs for classroom materials for three-yearolds are allowable and can be funded by the School Readiness Programs (1), so ELCFV s funding decisions reflect this. However, the Voluntary Pre-Kindergarten program cannot fund these costs because they are not eligible or allowable under this program. 20
The costs for classroom materials for four-year-olds are allowable and can be funded by the Voluntary Pre-Kindergarten Program (2). However, these costs are also eligible and allowable under the School Readiness Program (3), so ELCFV s funding decisions may reflect this adjustment. 21
School Readiness OCAs VPK OCA Cost Category OCA 97POO OCA 97QOO OCA 97QVP OCA VPPRS Training materials four-year-olds Not Allowable Allowable (3) Allowable (3) Not Allowable (2) Training materials three-year-olds Not Allowable (1) Allowable Not Allowable Not Allowable Program services four-year-olds Allowable Not Allowable Not Allowable Allowable Notes: (1) The School Readiness OCAs are structured to track specific types of costs. OCA 97POO is a direct service cost OCA used only for tracking the cost of classroom slots for children; classroom materials cannot be charged to this OCA. (2) The VPK OCAs are structured to track specific types of costs. OCA VPPRS is a direct service cost OCA used only for tracking the cost of classroom slots for children; classroom materials cannot be charged to this OCA. (3) OCA 97QVP is a direct service cost OCA established to track the cost of VPK training materials paid for with School Readiness funds; OCA 97QOO is a direct service cost OCA may be used to track other costs of training materials for four-year-olds. Discretion over funding decisions belongs to the ELCFV. However, the ability to make these funding decisions cannot change the basic nature of the costs being allocated. If such costs are unallowable according to the OMB Circulars or program regulations, they will remain unallowable. Analysis of Future Fluctuations in ELC of Flagler and Volusia Counties Operations Future Fluctuations in Operations ELCFV has structured the allocation methods implemented by this CAP to allow for future fluctuations in operations and to reduce the need for filing unneeded CAP revisions. It is ELCFV s intent to apply the allocation methods described in this CAP to future operating activities. The ELCFV will submit a CAP revision for future fluctuations in operations if there is any change in allocation methodologies applied. Changes initiating CAP revisions include, but may not be limited to: (1) changes in ELCFV s operating model, (2) changes in the allocation methods applied, (3) additions/deletions of the cost allocation pools used, and (4) material additions/deletions to early education programs or other grant programs administered/managed by ELCFV. Uniform Chart of Accounts/Cost Category Guide As of October 2012July 2014, OEL Instructions to ELCs are pending; updates will be provided as work onimplemented the State s Uniform Chart of Accounts Project proceeds. The uniform chart of accounts became effective as of July 1, 2014, and helps align the ELC s cost reporting with additional Coalition Plan disclosure requirements outlined in section 1002.85(2), F.S. The ELC s chart of accounts numbering system is now identical to the uniform chart of account guidance from OEL and no bridging worksheet is required. Template reports from OEL 22
for budget, revenues and expenditures are also completed annually. A link to this guidance has also been provided here. http://oelsharepoint/sites/coalitionszone/201415%20grant%20agreement%20documents/forms/allite ms.aspx Note: additional language may be needed above if an ELC did not change the numbering in the existing chart of accounts as of July 1, 2014. OEL accepted this practice as long as the ELC can map their chart of accounts to the uniform chart of accounts (using a bridging worksheet/spreadsheet), and report activities based on the requirements described. Each ELC should indicate what practice has been adopted as of July 1, 2014. Applicable Other Cost Accumulator Codes Please see Appendix G for more information. 23
APPENDIX A Organization Chart for ELC of Flagler and Volusia Counties Effective Date = March 2012September 2015 Executive Director Human Resources Deputy Director Executive Asst Finance Provider Services Outreach Family Services Accounting and Reporting Business Center (Inc. IT) Provider Operations Provider Programs Eligibility and R&R Child Screening 24
APPENDIX B Overview of ELC of Flagler and Volusia Counties Operating Model for Delivery of Services Eight Functional Components Effective Date = March 2012September 2015 Federal Funding State Funding Local Funding Resource & Referral Services Eligibility determination Enrollment Technical assistances Outreach Inclusion Child Care & Early Education Services Child screening & assessment Professional development Program & curriculum support Family engagement Administrative Support Services IT services, including data base management, website updates and help desk Contracting, compliance reviews Provide finance and accounting information HR services Service Provider Payments Reimbursement of child care provider services Support for payment adjustments Support for monitoring accuracy of payments Direct Services School Readiness Teen Parent Voluntary Pre-Kindergarten 25
APPENDIX C List of Offices Effective Date = March 2014September 2015 ELCFV Facilities ELCFV maintains four offices within the service area as described as follows: ELCFV Hours Location Phone Facilities Daytona Monday - Thursday 7:30AM to 135 Executive Circle, Suite 386-323-2400 Beach 5:00PM Fridays 8:00AM to 4:30PM 100 Daytona Beach, FL 32114 DeLand Monday - Thursday 7:00AM to 1205 S. Woodland Blvd., 386-736-5010 6:00PM; CLOSED 1-2 PM Daily Fridays: CLOSED Suite 1, DeLand, FL 32720 Deltona Thursday: By appointment only 935 Howland Blvd. Deltona, 386-736-5010 FL 32738 Flagler MondayTuesday, Wednesday, and Thursday Friday 8:300AM-54:030PM 800 E. Howe Bunnell, FL 321101000 Belle Terre Blvd, Palm Coast, FL 32164 386-437- 8236323-2400 By appointment only. 26
APPENDIX D - Personnel Activity Reports (PARs) /Timesheet Template Allocation Spreadsheet Sample EMPLOYEE NAME SITE/DEPT FUND OCA BG PERCENTAGE FRESHOUR, BETH Family Services SRF 97BDE ELIGF 1.60% FRESHOUR, BETH Family Services SRV 97BDE ELIGDAY 8.40% FRESHOUR, BETH Family Services SRF 97BBD ELIGF 4.80% FRESHOUR, BETH Family Services SRV 97BBD ELIGDAY 25.20% FRESHOUR, BETH Family Services SRF 97QI4 RRF 2.56% FRESHOUR, BETH Family Services SRV 97QI4 RRDAY 13.44% FRESHOUR, BETH Family Services SRF 97QCS ELIGF 1.44% FRESHOUR, BETH Family Services SRV 97QCS ELIGDAY 7.56% FRESHOUR, BETH Family Services SRF 97ICS ELIGF 0.96% FRESHOUR, BETH Family Services SRV 97ICS ELIGDAY 5.04% FRESHOUR, BETH Family Services SRF 97BBA ELIGF 1.60% FRESHOUR, BETH Family Services SRV 97BBA ELIGDAY 8.40% FRESHOUR, BETH Family Services VPKF VPENR ELIGF 2.24% FRESHOUR, BETH Family Services VPKV VPENR ELIGDAY 11.76% FRESHOUR, BETH Family Services VPKF VPADM ELIGF 0.80% FRESHOUR, BETH Family Services VPKV VPADM ELIGDAY 4.20% Sample Allocations within Paychexthe current Payroll Service Provider* *Includes updated allocation due to difference identified as a result of verification of activity performed in pay period. 27
Additional Tools Time Study (Additional verification of allocations performed semi-annually) 28
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