FAQ Update: More Fiscal Information

The Office of Head Start recently updated the FAQ list with specifically fiscal information. This text is directly from their website:

Fiscal FAQs

• 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.

Waiver

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:

1. A  new Head Start grantee or delegate agency is being established;
2. Services  are being expanded by an existing grantee or delegate agency;
3. Delivery  of component services to children and families is delayed until program  development and planning is well underway or completed; and
4. 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.

• What types of  costs are considered program costs?

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:

1. Personnel and non-personnel costs directly related  to the provision of program services and component training and transportation  for staff, parents, and volunteers;
2. Costs of the functions directly associated with the  delivery of program services through the direction, coordination, or  implementation of a specific component;
3. Salary costs for program coordinators and staff,  janitorial staff, and transportation staff involved in program component  efforts.
4. Costs associated with parent involvement and volunteer  services; and
5. 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.

• What is “federal  interest” and when is it established in a facility?

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.

When real property, equipment, and  supplies are acquired or improved with federal funds, the federal interest is  established, per 45  CFR Parts 74.32–74.35 and 1309.21(a).

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.

 

• How do you categorize and allocate  facilities costs?

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.

 

Thank you.

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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].