Do you know what your obligations are related to indirect costs as a pass-through entity of federal funds?  Did you know that Title 2 of the Code of Federal Regulations (CFR) part 200.332 requires that pass-through entities accept a subrecipients federally approved Indirect Cost Rate, allow for use of the de minimis, or must negotiate an Indirect Cost Rate if requested by the subrecipient? Do you want to know how to develop a cost allocation plan so that the true costs of delivering services are captured? Do you want more clarity on the different methodologies for establishing an indirect cost rate?   

This training is designed for SAAs and subrecipients who want to gain foundational knowledge and the skills to successfully create a cost allocation plan and negotiate an indirect cost rate agreement.

At the end of this training participants will:

·     Understand 2 CFR 200 requirements related to indirect costs,

·     Know the necessary components of an IDC proposal packet and cost allocation plan,

·     Be able to articulate why it’s important to charge indirect costs to cover all costs for services provided,

·     Understand the various types of indirect cost rates and methodologies for determining each one,

·     Recognize when it might be best to apply the de minimis rate,

·     Know what goes into building a cost allocation plan and indirect cost rate proposals, and

·     Know where to go for additional helpful tools and resources to develop cost allocation plans and indirect cost rates.

Session 1: Introduction to Cost Allocation Plans and Indirect Cost Rates will address an introduction to cost allocation plans and the development of an indirect cost rate packet. This session will go through the key definitions, what a cost allocation plan and indirect cost rate proposal includes, and provides clarification regarding the requirements under the Uniform Guidance (2 CFR 200). During this session, participants will take a deeper look at the different types and methodology for allocating costs including direct costs, shared costs, indirect costs, and administrative costs how those costs factor into the indirect cost rate proposal process.

Session 2: How to Develop a Cost Allocation Plan– will look at what’s included and how to go about developing a cost allocation plan.  Participants will learn how cost allocation plans differ for institutes of higher education, nonprofits, and states and local governments. Participants will learn how to take various agency expenses to create a cost allocation plan that will ultimately outline and substantiate an organization’s methodology for allocating costs. 

Session 3:  How to develop an indirect cost rate enables participants to build on the previous session and review a cost allocation to determine and develop an indirect cost rate that ensures a fair and equitable allocation of essential costs. During this session, participants will review the various types of indirect cost rates and examine the required documentation for developing an indirect cost rate proposal package. Participants will also gain an understanding of the process and time frames for negotiating an indirect cost rate with their cognizant agency. 

About the presenter:  Wendy Heath, CFE, is the Assistant Director of the Fiscal Unit for the State of Tennessee, Office of Criminal Justice Programs.  Ms. Heath has worked for State Government for 22 years and for the vast majority of those years, has been in the audit field. Her audit experience goes back to being an auditor for the State of Tennessee Comptroller of Treasury Office. During her years as an auditor, she gained a lot of experience with federal grants and performing single audits. After 16 years, she took a position as the Finance Director for the Tennessee Department of Education. Her main function was to over see the Achievement School Districts budget. In this position she managed federal funding and all expenses for the school district. She held that position for a few years and moved to her current position. This position is the perfect fit for Ms. Heath’s combination of audit and finance experience. Ms. Heath has the primary responsibility for developing OCJP’s IDC rate. Through years of training and other lessons learned, Ms. Heath has become well versed in creating indirect cost plan proposals and reviewing subrecipient indirect cost rate proposals, as well as communicating with their federal cognizant agency during the process. She has a passion for this work and looks forward to bringing her knowledge to help others develop their own process.

This on-demand virtual training package provides grant managers with everything they need to know to successfully meet their responsibilities as a recipient and administrator of federal grant funding. The training includes essential information, tools and resources.

Who: This training is designed for grant managers who administer Edward Byrne Memorial Justice Assistance Grant (Byrne JAG) funding, but will also benefit those who administer federal criminal justice grant funds including Residential Substance Abuse Treatment (RSAT), Coverdell Forensic Science Improvement, (Coverdell), Sexual Assault Services Formula Grants (SASP), Coronavirus Emergency Supplemental Funding (CESF) and American Rescue Plan (ARPA).

What: This training package includes ten self-paced modules.

Session 1, 3 modules:  focused on Grant Management Responsibilities of the SAA and Direct Receipients at the Pre-Award Phase

Session 2, 3 modules focused on Grant Management Responsibilities of the SAA and Direct Recipients at the Award and Post-Award Phase

Session 3, 4 modules focused on Grant Management Responsibilities of the SAA and Direct Recipients as Pass-Through Entitles

 Participants will:

·       Examine programmatic and financial components for managing federal funds from pre-award through close out,

·       Understand the legal hierarchy and precedence involved in the appropriations and authorizations processes for federal funding,

·       Examine requirements of 2CRF Part 200, the DOJ Financial Guide, Award Conditions and what they mean for your agency,

·       Understand important components of internal controls and how to enhance prevention of fraud, waste and abuse of federal funds,

·       Clarify the roles and responsibilities of Federal Grant Points of Contact (POCs); Agency Administrators, Grant Managers and Financial Points of Contact (FPOC),

·       Learn how to address and comply with universal and special conditions linked to awards and reconcile those with state priorities,

·       Understand the grant manager’s role as “Coach” and best practices for delivering technical assistance for subgrantee success,

·       Learn and apply recipient and subrecipient risk management and monitoring tools and techniques,

·       Understand reporting requirements, timelines and systems,

·       Learn how to prepare for audits and develop and monitor for corrective actions plans, and

·       Locate and access ongoing grant management resources, including free resources to improve your policies and procedures and enhance equity in your grant making processes.

The two-part virtual training is designed to provide Byrne Justice Assistance Grant SAAs and subrecipients with the knowledge and skills to meet subgrant monitoring responsibilities as pass-through agents of federal grant funds.

In this series, participants will understand the importance, purpose, expectations and requirements for subgrant monitoring. Further, participants will learn about subgrant management processes, tools, techniques, and training that can support successful grant management and subgrant monitoring outcomes. Using and applying the knowledge gained will allow participants to assess their agency’s subgrant monitoring practices to identify both best practices and areas for potential improvement that will lead to more efficient and effective processes.

After completing this series, participants will be able to:

• Understand the importance and recognize the purpose of grant monitoring as a pass-through entity of federal funds.
• Employ grant practices to assist the SAA and subgrantees to achieve grant monitoring outcomes.
• Employ an appropriate type of monitoring that matches the assessed level of risk of subgrantees.
• Recognize indicators of grant fraud, waste and abuse and how to address them.
• Examine the components of financial grant monitoring.
• Differentiate between programmatic and financial grant monitoring and examine the components of each.
• Know where to access tools and techniques that support successful grant management and subgrant monitoring outcomes.
• Use and apply the knowledge gained to assess their agency’s subgrant monitoring practices and to identify both best practices and areas for potential improvement that will lead to more efficient and effective processes.

Topics covered include:

• What is the purpose of subgrant monitoring?  
• What are the expectations of federal partners regarding SAA subgrant monitoring?
  • Office of Justice Program/Bureau of Justice Assistance
  • Byrne JAG Special Conditions
  • DOJ Financial Guide
  • Code of Federal Regulations (2 CFR 200)
• State (SAA) Monitoring Responsibilities
• Resources that a state should have on hand (Grant Management Policies & Procedures, Grant Administrative Guide)
• Where, When and How to Begin Addressing Subgrant Monitoring
  • Role of the subgrant application process in subgrant monitoring; how can your subgrant application give you the information you will need for later subgrant monitoring?
  • Subgrant application reviews
  • Financial Management Questions
  • Financial Audits
• Establishing a subgrant application process that ensures applicants make an informed decision about their capability for compliance with federal expectations
  • General Grant Condition expectations
  • Special Conditions
  • Program and/or Grant-Specific Conditions
  • Financial Requirements
• Using a Risk-Based Approach in Grant Monitoring
  • Indicators of Risk from application through close-out
  • Administrative and Programmatic Application Reviews
  • Budget/Financial Application Reviews
  • Financial Management Questions
  • Examples of Low, Medium and High Risk Considerations
  • Examples of How to Mitigate Risk
• Different Levels of Monitoring and What is Involved in Each
  • Desk Monitoring
  • Enhanced Desk Monitoring
  • Structured Desk Monitoring
  • Comprehensive Planned On-site