The Office of Head Start recently updated the FAQ list with specifically fiscal information. This text is directly from their website:
- What is the difference between the applicant’s Authorized Organization Representative (AOR) and Point of Contact (POC)?
The signature of the Authorized Organization Representative (AOR) is required on the original copy of the application submission. Consistent with the instructions from the SF-424, the individual(s) named by the applicant/recipient organization as the AOR is authorized to act for the applicant/recipient and to assume the obligations imposed by the federal laws, regulations, requirements, and conditions that apply to grant applications or awards.
Consistent with the instruction for Grants.gov for electronic submissions, the AOR is the person that uploads and electronically submits the application.
The Point of Contact (POC) (sometimes also known as the project director or principal investigator) is the person the applicant has assigned to oversee the project and should not be the same person identified as the AOR.
Consistent with the instruction on the SF-424, the POC is the person to be contacted on matters involving the application and must be available to answer questions pertaining to the application. This person should not be identified as the project director or the principal investigator.
Consistent with the instructions for electronic submission on Grants.gov, the POC is the E-Biz designee who provides credentials to the person that organization has designated to upload and electronically submit the application, also known as the AOR.
- Can a disallowance of federal funds be taken against a grantee agency if it exceeds the 15 percent administrative cost limitation?
Yes, a disallowance can be taken against the grantee agency for the amount of administrative costs that exceed the 15 percent limit. In addition, a disallowance may be taken on administrative costs that are considered excessive even if the administrative costs limitation is not exceeded.
Section 644(b) of the Head Start Act and Section 45 CFR 1301.32 of the Head Start Program Performance Standards limit the amount of funds that may be charged as development and administrative costs to 15 percent of the total cost of the program. Grantee agencies must have a system in place, including adequate procedures, to ensure that the 15 percent administrative cost limitation requirement is met to avoid non-compliance. However, there are some exceptions.
The Office of Head Start may grant a waiver of the 15 percent administrative costs limitation for a specified period of time not to exceed 12 months. The grantee agency should ensure that such approval is obtained in writing before proceeding.
There are certain conditions under which a waiver can be granted, such as when:
- A new Head Start grantee or delegate agency is being established;
- Services are being expanded by an existing grantee or delegate agency;
- Delivery of component services to children and families is delayed until program development and planning is well underway or completed; and
- Component services are disrupted or suspended in an existing Head Start program due to circumstances beyond the grantee agency’s control, such as fire, flood, or tornado.
- How do you allocate the costs of a staff member who serves as both the Head Start director and education coordinator in a small program?
This would be considered a dual benefit cost and should be appropriately allocated. Dual benefit costs relate to both administrative functions and program component services and can be designated as either personnel or non-personnel costs. Therefore, they must be allocated on a rational basis between administrative and program service delivery.
Program costs are those costs directly associated with the delivery of program services through the direction, coordination, or implementation of a specific component. Program components include education, disabilities, health, nutrition, parent involvement, social services, and transportation.
Program costs include, but are not limited to, the following:
- Personnel and non-personnel costs directly related to the provision of program services and component training and transportation for staff, parents, and volunteers;
- Costs of the functions directly associated with the delivery of program services through the direction, coordination, or implementation of a specific component;
- Salary costs for program coordinators and staff, janitorial staff, and transportation staff involved in program component efforts.
- Costs associated with parent involvement and volunteer services; and
- Expenses related to program staff functions, such as the allocable costs of fringe benefits; travel; transportation; training; food; center and classroom supplies and equipment; funds for parent activities; insurance; and the occupation, operation, and maintenance of the program facility, including utilities.
Section 45 CFR 1301.32 of the Head Start Program Performance Standards provides additional information related to program costs.
Federal interest is the acquisition of real property, equipment, or supplies under an award, whether paid by federal funds, or satisfying some or all of a matching cost sharing requirement. The dollar amount that is the product of the federal share of project costs multiplied by the current fair market value of the property.
The standard forms approved by the Office of Management and Budget (OMB) for recipient reporting of inventory for Tangible Personal Property and Real Property Status Report are SF-428 and SF-429 respectively.
Section 45 CFR Part 1309 of the Head Start Program Performance Standards outlines the application procedures for the purchase, construction, and major renovations of facilities. Grant applicants must determine the use of the facility. If the facility contains space for both administrative functions and program component functions, it would be classified as a dual benefit cost and the grantee agency must then allocate costs between administrative and program.
- The funding opportunity announcement references “indirect costs” in Phase Two. Is ACF referring to indirect costs for organizations with an indirect cost rate in place or is it also referring to allocated shared costs (such as Fiscal/HR Department costs) for organizations without an approved indirect cost rate?
“Indirect cost rate” in this context refers to the rate agreement established for the non-profit agency and approved by the cognizant Federal agency.
- Is ACF providing access to the Internal Control-Integrated Framework (COSO Report) as referenced in the Phase Two information?
The COSO Internal Control – Integrated Framework is referenced in the OMB Circular A-133 compliance supplement – Part 6. Applicants should visit http://www.whitehouse.gov/omb/circulars/a133_compliance_supplement_2011 to view Part 6 regarding the compliance supplement and the related framework.
- Must start-up costs be included in the Award Ceiling amount or may additional funds be requested in the proposal?
One-time start-up costs are in addition to the ongoing operational funds allocation in the announcement.
If your agency has activated a ‘trigger’ and is facing recompetition – you might want or need guidance. In most cases, we can help you get through this critical period and, if we can’t, we’ll certainly help you find the support you need.
If you think you have a legal issue OR want to prevent one through regulatory compliance and risk assessment, please do youself a big favor and call Ted Waters at [email protected] or Zoë Beckerman at [email protected], both with Feldesman Tucker Leifer Fidell LLP.
If you are a delegate agency thinking about responding to the upcoming RFP to continue to serve your children and families on your own, but are unsure about grant writing, give us a call.
If you are a community based, solid organization with your heart and management practices in the right place and think could do just as well or better on behalf of young children and their families, we can help you think that through and move forward if you’d like. Call us: 703-299-6570 or 703-299-6570 or email [email protected].