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POST-AWARD REFERENCE GUIDE POST-AWARD REFERENCE GUIDE Earmark Grants June, 2007 Employment and Training Administration United States Department of Labor About This Guide This post-award reference guide is designed to provide a comprehensive overview of the terms, conditions, and performance expectations associated with Earmark grants. It is designed to be a resource to the Earmark grantees as well as to their Federal Project Officers. The guide is divided into two major sections. The first section examines each element of the Grant Award Face Sheet and the Grant Award document. Particular attention is paid to the statutory, regulatory, and administrative provisions which are applicable to these grants. The second section of the guide is an addendum which provides in-depth information on particular aspects of grant management which frequently raise questions. This section also provides related websites, sample forms, and other useful resources. A table of contents for the guide is on the next page. Earmark Post-Award Guide i ii Earmark Post-Award Guide Earmark Post-Award Guide Table of Contents I. GRANT AWARD AGREEMENT & REQUIREMENTS OVERVIEW Grant Agreement Face Sheet GRANT PERIOD OF PERFORMANCE 1 TOTAL GOVERNMENT FINANCIAL OBLIGATION 1 UNIFORM ADMINISTRATIVE REQUIREMENTS 1 COST PRINCIPLES 1 OTHER REQUIREMENTS 2 WORKFORCE INVESTMENT ACT; FINAL RULES 4 Grant Award Document PART I: STATEMENT OF WORK 7 PART II: BUDGET INFORMATION 7 PART III: ASSURANCES/CERTIFICATIONS 7 PART IV: SPECIAL CLAUSES/CONDITIONS 8 II. ADDENDUM Vision for a WIRED Workforce Investment System A-1 Grant Agreement Transmittal Letter A-3 Grant Modification Procedures A-5 Earmark Grantees’ Reporting Information A-7 Financial Status Reporting Instructions A-9 Subrecipient Reporting A-15 Tuition and Fee Income A-17 Cost Principles/Selected Items of Cost A-19 Administrative and Program Costs A-25 Procurement A-27 ETA’s Performance Accountability System A-31 Equipment A-33 Salary and Bonus Limitations A-35 Websites Guide A-39 Cross Reference of Administrative Requirements A-45 Records Retention A-47 Forms and Other Documents A-49 Attachments Earmark Post-Award Guide iii iv Earmark Post-Award Guide Earmark Grants Post-Award Guide: Part I Grant Award Agreement & Requirements Overview Earmark Post-Award Guide v vi Earmark Post-Award Guide Part I Table of Contents Grant Agreement Face Sheet GRANT PERIOD OF PERFORMANCE 1 TOTAL GOVERNMENT FINANCIAL OBLIGATION 1 UNIFORM ADMINISTRATIVE REQUIREMENTS 1 COST PRINCIPLES 1 OTHER REQUIREMENTS 2 Single Audit Act 2 Lobbying Certification 2 Non-Discrimination and Equal Opportunity Requirements 3 Drug-Free Workplace 4 Debarment and Suspension 4 WORKFORCE INVESTMENT ACT; FINAL RULES 4 Grievance Procedures 5 Administrative Costs 5 Grant Award Document PART I: STATEMENT OF WORK 7 PART II: BUDGET INFORMATION 7 PART III: ASSURANCES/CERTIFICATIONS 7 Access to Records 7 Conflict of Interest/Personal Gain Safeguards 7 Statement of Work 7 Non-Discrimination and EEO 7 Hatch Act 7 PART IV: SPECIAL CLAUSES/CONDITIONS 8 Special Clauses 8 Budget Line Item Flexibility 8 Indirect Cost Rate and Cost Allocation Plan 8 Conditions 12 Federal Project Officer 12 Equipment 12 Program Income 12 Pre-Award Costs 13 Reports 13 Consultant Fees 14 Rebates 14 Publicity 14 Public Announcements 14 Executive Order 12928 15 Procurement 15 Veteran’s Priority: Jobs for Veterans Act, PL 107-288 15 Salary and Bonus Limitations 16 Earmark Post-Award Guide vii viii Earmark Post-Award Guide Grant Agreement Face Sheet GRANT PERIOD OF PERFORMANCE Grant costs incurred as of the start date of the grant can be charged to the grant even if the grant was executed by the Grant Officer (GO) after that date. Startup or pre-award costs can be charged to the grant ONLY with prior GO approval. No costs can be charged to the grant after the period of performance end date. TOTAL GOVERNMENT FINANCIAL OBLIGATION Costs charged to the grant cannot exceed the total amount of the grant award. The Department of Labor (DOL) uses the Payment Management System (PMS) for the disbursement of funds to recipients. The cover letter on your grant agreement provides information on how to establish an account and access the system. Please note that the password and PIN issued for PMS are distinct and different from the password and PIN associated with the online grantee reporting system. Payments can be automatically drawn down through the system for immediate needs. It is expected that these funds will be disbursed shortly after being drawn down. The addendum to this guide provides a sample grant agreement transmittal letter with information about how to establish the PMS account. UNIFORM ADMINISTRATIVE REQUIREMENTS Establish requirements for all grants awarded by the Department of Labor. Include standards for financial management, modifications, property standards, procurement standards, and reporting. Require that there be written policies and procedures for determining the reasonableness, allocability, and allowability of costs. 29 CFR Part 95 These requirements apply to Institutions of Higher Education, Hospitals, Non-Profit Organizations, Commercial Organizations, Organizations under the Jurisdiction of Foreign Governments, and International Organizations. 29 CFR Part 97 These requirements apply to State, Local, and Indian Tribal Governments. COST PRINCIPLES Establish principles and standards for determining costs applicable to grants, contracts, and other agreements. Include guidance on reasonable, allowable, and allocable costs. OMB Circular A-21 Cost Principles for Educational Institutions Earmark Post-Award Guide 1 OMB Circular A-87 Cost Principles for State, Local, and Indian Tribal Governments OMB Circular A-122 Cost Principles for Non-Profit Organizations 48 CFR Part 31 Contract Cost Principles and Procedures for Commercial Organizations OTHER REQUIREMENTS Single Audit Act OMB Circular A-133: Single Audit Act 29 CFR Part 96: Audit Requirements For Grants, Contracts, and Other Agreements 29 CFR Part 99: Audits of States, Local Governments, and Non-Profit Organizations Parts 96 and 99 identify the audit requirements for recipients and subrecipients of DOL funds and contain DOL’s procedures for the resolution of audit findings. These requirements apply to all grants and contracts and other Federal awards provided by or on behalf of the DOL. Every grant recipient and subrecipient organization that expends $500,000 or more in Federal funds (received from all Federal sources combined) during its fiscal year to operate one or more programs must undergo an independent organization-wide financial or compliance (single) audit. Any entity that expends $500,000 or more under only one Federal program that is not subject to a requirement for a financial statement audit may elect to have a program-specific audit. There are no audit requirements for an entity that spends less than $500,000 in Federal awards in a fiscal year, or any entity that receives Federal funds exclusively as a vendor, regardless of funding level. 29 CFR Part 93: Lobbying Certification As part of the grant award, the grantee certifies that it will not use Federal dollars to influence an officer, employee of any agency, or employee or member of Congress in conjunction with any Federal action, e.g. to procure a grant award. Grantees who use their own funds to do so must complete the lobbying disclosure form (SF LLL) and submit it to the Grant Officer (GO) through the Federal Project Officer (FPO). Any entity receiving a subgrant of $100,000 or more is required to submit a lobbying certification to the grantee. If a subgrantee is using non-appropriated funds to lobby, it must also complete the disclosure form and forward it to the GO through the grantee and FPO. 2 Earmark Post-Award Guide 29 CFR Part 37: Non-Discrimination and Equal Opportunity Requirements These regulations implement the nondiscrimination and equal opportunity provisions of the Workforce Investment Act and are applicable to this grant program. Discrimination is prohibited on the basis of race, color, religion, sex, national origin, age, disability, political affiliation, and citizenship/status as a lawfully admitted immigrant authorized to work in the United States. Please note, §37.4 defines discrimination on the ground of citizenship as “a denial of participation in programs or activities financially assisted in whole or in part under Title I of WIA to individuals on the basis of their status as citizens or nationals of the United States, lawfully admitted permanent resident aliens, refugees, asylees, and parolees, or other immigrants authorized by the Attorney General to work in the United States.” It is the grantee’s responsibility to establish a policy regarding those individuals not lawfully permitted to work in the United States or those not lawfully in the United States. In some jurisdictions, State law may determine the policy. Grantees are required to comply with all sections in 29 CFR Part 37. Below is a summary of some, but not all, of the Equal Opportunity requirements. Equal Opportunity Notice Dissemination, (§37.29): Grantee must provide initial and continuing notice that it does not discriminate on any prohibited ground. This notice must be provided to applicants for grant services, participants, applicants for employment and employees, unions, or professional organizations that hold collective bargaining or professional agreements with the grantee, subgrantee/contractors under the grant, and members of the public including those with impaired vision or hearing. Equal Opportunity Notice Content (§37.30): The referenced section provides the wording that must be contained in the required EO notice. The required wording provides a complainant the opportunity to file a complaint either with the grantee’s equal opportunity officer or directly with the U.S. Department of Labor Civil Rights Center in Washington, DC. Equal Opportunity Notice Communication (§37.31): The EO notice must be posted prominently in reasonable numbers and places; disseminated in internal communications; included in handbooks and manuals; and be made available to each participant and be part of each participant’s file. Equal Opportunity Wording in Publications and other Communications (§37.34): All program brochures, outreach materials, job announcements, and other materials must contain the wording that the program is an “equal opportunity employer/program” and that “auxiliary aides and services are available upon request to individuals with disabilities.” Services and Information in Languages other than English (§37.35): If a significant number or proportion of the population eligible to be served by the program may need services or information in a language other than English, the grantee should take reasonable steps to provide services and information in appropriate languages. Earmark Post-Award Guide 3 EEO Data/Requirements (§37.37): Each recipient must record the race/ethnicity, sex, age, and where known, disability status, of every applicant, registrant, eligible applicant/registrant, participant, terminee, applicant for employment, and employee. An individual has the right to refuse to provide any part or all of the data. Such a refusal cannot result in a denial of service. The grantee may not furnish the data on behalf of the individual. Information on an individual's ethnicity must be collected before information on race. At a minimum, the following information should be collected on ethnicity/race: Ethnicity: Race: Hispanic of Latino Yes No American Indian or Alaska Native Asian Black or African American Hawaiian Native or other Pacific Islander White 29 CFR Part 94: Drug-Free Workplace By signing the grant agreement, grantee certifies that it will maintain a drug-free workplace by publishing a statement that notifies its employees that it is unlawful to manufacture, dispense, process, or use a controlled substance in the workplace. The grantee also certifies that it will maintain a drug awareness program which informs employees about the dangers of drug abuse in the workplace; the grantee’s drug-free workplace policy; any available drug counseling; and the penalties for drug abuse violations in the workplace. 29 CFR Part 98: Debarment & Suspension By signing the grant agreement, grantee certifies that it is not debarred from doing business with the Federal Government and that it has not had a Federal contract terminated for cause or default within the last three years. The grantee must verify that all subrecipients and contractors funded by $100,000 or more are not debarred or suspended from doing business with the Federal Government. The General Services Administration (GSA) Website provides access to the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” at http://epls.arnet.gov. WORKFORCE INVESTMENT ACT; FINAL RULES 2 0 C FR P a r t 6 5 2 E t A l . Earmark grants are subject to the provisions of the Workforce Investment Act (WIA) and the WIA Final Rules (Regulations). In addition, Congressionallymandated earmark grants may have additional (or fewer) special requirements required by Congress as laid out in the legislation or associated documents authorizing the awards, e.g. a conference report. An example of this is the requirement for grantees in several years’ conference reports to coordinate with 4 Earmark Post-Award Guide the local Workforce Investment Board. Two of the most notable regulations are expanded on below. Grievance Procedures Recipient is required to establish and maintain a procedure for dealing with participant and other interested parties’ grievances and complaints. The procedure must provide an opportunity for an informal resolution and a hearing to be completed within 60 days of the filing of the grievance or complaint. The recipient is responsible for providing information about the content of the grievance and complaint procedures to all participants and other interested parties. Reasonable efforts to assure that all individuals, including youth and those with limited-English speaking skills, understand the procedures must be made. The provisions of this section on grievance procedures that do not apply to discrimination complaints brought under WIA section 188 and/or 29 CFR Part 37. Such complaints must be handled in accordance with the procedures set forth in that regulatory part. Administrative Costs Definition: The definition of administrative costs used by the Employment and Training Administration (ETA) is different from the facilities and administrative costs referred to in OMB Circular A-21. ETA’s definition of administrative costs is found at 20 CFR 667.220 (b) and (c) and is incorporated into the grant award. ETA uses a function-based definition of administrative costs, which means costs associated with administrative functions, such as accounting, procurement, etc. are considered administrative costs. Program costs are those related to the direct provision of workforce investment services, including services to participants and employers. An individual, such as a program director, can incur both program and administrative costs depending on the function which is being performed. Indirect costs can be either program or administrative, based on ETA’s definition. More information about program and administrative costs can be found in the Addendum section of this document. Limitation: Administrative costs for this grant are limited to 10 per cent. The administrative limit applies to the total award amount and includes both direct administrative costs and indirect administrative costs. Not all indirect costs are administrative costs under the ETA definition. That portion of indirect costs that are administrative costs, plus any direct administrative costs, cannot exceed the 10 per cent limitation. The Grant Officer may approve additional administrative costs up to a maximum of 15 per cent of the total award amount if adequate justification is provided by the grantee at the time of the award. Reporting: Grantees need to have a system in place to track the administrative cost expenditures. The amount and percentage of administrative costs should be reported quarterly on the Financial Status Report, SF 269, in Item 12, Remarks. Earmark Post-Award Guide 5 6 Earmark Post-Award Guide Grant Award Document The grant award document consists of 4 parts: Part I: Statement of Work Part II: Budget Information Part III: Assurances and Certifications Part IV: Special Clauses and Conditions PART I: STATEMENT OF WORK Contains the project description of the grant, timelines, outcomes, and deliverables. PART II: BUDGET INFORMATION Contains the SF 424A, which provides a line item budget for the grant program. PART III: ASSURANCES/CERTIFICATIONS The grantee should review all of the assurances under this part of the Grant Agreement. Among them are: (1) Access to Records The grantee will give the awarding agency, the Comptroller General of the US, and if appropriate, the State, through any authorized representative, access to, and the right to examine, all records, books, papers, or documents related to the award; and will establish a proper accounting system in accordance with generally accepted accounting standards or agency directives. (2) Conflict of Interest/Personal Gain Safeguards The grantee will establish safeguards to prohibit employees from using their positions for a purpose that constitutes or presents the appearance of personal or organizational conflict of interest or personal gain. (3) Statement of Work The grantee will initiate and complete all work within the grant period of performance. (4) Non-Discrimination and EEO Assures compliance with all Federal statutes relating to nondiscrimination. (5) Hatch Act Limits the political activities of employees whose principal employment activities are funded in whole or in part with Federal funds. Earmark Post-Award Guide 7 PART IV: SPECIAL CLAUSES/CONDITIONS Special Clauses 1. Budget Line Item Flexibility Any change in the amounts budgeted for wages, salaries, fringe benefits, and/or indirect costs must receive prior approval from the Grant Officer (GO). A change in mix or match of personnel reflected on the wages and fringe benefits line items does not require a modification. However, these changes must be reviewed by the Federal Project Officer (FPO) prior to implementation. A cumulative increase or decrease of more than 20 per cent to any other single line item during the grant period also requires Grant Officer approval. It is the grantee’s responsibility to periodically compare line item expenditures with the budget in order to ensure that this requirement is being met. The grantee should ensure the budget is in line with actual needs. Any requests to modify the budget should be made when the need is identified and prior to implementing the change, not after the fact. 2. Indirect Cost Rate and Cost Allocation Plan Clause #2 lists 2 options: A. Applies to a grantee that submitted with the grant application a current Indirect Cost Rate (ICR) Agreement or Cost Allocation Plan (CAP) approved by the cognizant Federal agency. Regarding the ICR agreement, the grantee may be asked to provide the indirect rate approved; type of indirect cost rate (provisional/fixed); allocation base; and/or current period of applicable to rate. B. Applies to a grantee who does not have an approved ICR or CAP. A temporary billing rate or amount is provided in option B for those grantees who have indicated on the Budget Information Form (SF 424A) that they are charging indirect costs to the grant. These grantees are required to submit an acceptable indirect rate cost proposal or CAP to their cognizant agency within 90 days of grant award. (Generally, the Federal agency providing the preponderance of funds to the organization is the cognizant agency). If the proposal is not submitted within the 90-day period, reimbursement for the temporary billing rate or amount may be suspended by DOL. The Department of Health and Human Services is the cognizant agency for most small colleges. DHHS has included in Chapter 6-160 of its Grants Administration Manual its general policy that limits indirect costs on training grants awarded to institutions of higher education, hospitals, and other non-profit institutions to 8 per cent of total direct costs. The Department of Education has also established a similar general policy that limits indirect costs for Department of Education training grants awarded to small colleges who have no formal indirect cost rate agreement approved by a federal agency to an amount up to 8 per cent of modified total direct costs [i.e., total direct costs minus the costs of equipment, subcontracts, and stipends]. Because of this, DHHS, which is the cognizant agency for cost negotiation for small colleges, will not negotiate an indirect cost 8 Earmark Post-Award Guide rate with individual grantees who are awarded training grants that are limited to an 8 per cent indirect cost rate. Grantees are required to maintain documentation on file, subject to audit, which supports its actual indirect costs incurred and demonstrate that the 8 per cent (or lower) indirect cost rate charged to training grants does not exceed actual indirect costs incurred. There is no similar cap on indirect costs for grants awarded by ETA. The ETA 10 per cent cap on administrative costs does not translate to a cap on indirect costs. However, if a DOL grantee has a letter from the DHHS stating that it is authorized to utilize an 8 per cent indirect cost rate, and the grantee is willing to apply that rate to its DOL grant, the U.S. Department of Labor will honor a rate of 8 per cent of modified total direct costs subject to the conditions in the above paragraph. Alternatively, if the grantee desires to submit an indirect cost proposal to DHHS for a rate to apply to its DOL grant, DHHS has indicated that its cost negotiators will negotiate the rate. If DOL is your cognizant agency, the proposal should be sent directly to the Division of Cost Determination at the applicable address below. Cost negotiation for most community colleges is handled by the Department of Health and Human Services DHHS. The addresses for DHHS cost negotiators are also provided below. U.S. Department of Labor Cost Negotiators WASHINGTON, D.C. METROPOLITAN AREA U.S. Department of Labor Division of Cost Determination 200 Constitution Avenue, N.W., S-1510 Washington, D.C. 20210 Phone: 202-693-4100 Fax: 202-693-4099 Victor M. Lopez, Chief lopez.victor@dol.gov Phone: 202-693-4106 Damon Tomchick, Cost Negotiator tomchick.damon@dol.gov Phone: 202-693-4105 Casey Carros, Cost Negotiator carros.casimer@dol.gov Phone: 202-693-4107 Margie Merced, Cost Negotiator merced.margie@dol.gov Phone: 202-693-4105 ATLANTA REGION Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee Earmark Post-Award Guide Phil Zahnd Cost Negotiator 111 Zahnd Way Florence, AL 95634 Phone: 256-272-0075 Fax: 256-272-0085 zahnd.phil@dol.gov 9 CHICAGO REGION Illinois, Indiana, Iowa, Kansas, Michigan, Minnesota, Missouri, North Dakota, Nebraska, Ohio, South Dakota, Wisconsin Ronald Goolsby Cost Negotiator 230 South Dearborn Street, Room 1016 Chicago, IL 60604-1505 Phone: 312-886-5247 Fax: 312-353-0127 goolsby.ronald@dol.gov DALLAS REGION Arizona, Arkansas, Colorado, Kentucky, Louisiana, Nevada, New Mexico, Oklahoma, Texas, Wyoming Carol McKone Cost Negotiator P.O. Box 821067 Ft. Worth, TX 76182 Phone: 817-281-1503 Fax: 817-281-1530 mckone.carol@dol.gov PHILADELPHIA REGION Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Puerto Rico, Rhode Island, Vermont, Virgin Islands, Virginia, West Virginia. Stephen Cosminski Cost Negotiator P.O. Box 509 Perkasie, PA 18944 Phone: 215-257-8712 Fax: 215-257-8994 cosminski.stephen@dol.gov SAN FRANCISCO REGION Alaska, California, Hawaii, Idaho, Montana, Oregon, Utah, Washington 10 Arthur Campbell Cost Negotiator P.O. Box 3433 Renton, WA 98056 Phone: 425-271-3848 Fax: 4425-271-5295 campbell.arthur@dol.gov Earmark Post-Award Guide If the Department of Health and Human Services is your cognizant agency, the proposal should be sent to the applicable address below. DHHS negotiates indirect rates for most community colleges. U.S. Department of Health and Human Services Cost Negotiators NATIONAL OFFICE Daryl Mayes National Director Division of Cost Allocation Financial Management Service, PSC Cohen Building, Room 1067 330 Independence Avenue, SW Washington, DC 20201 Phone: 202-401-2808 MID-ATLANTIC FIELD OFFICE Alabama, Delaware, District of Columbia, Florida, Georgia, Kentucky, Maryland, Mississippi, North Carolina, Pennsylvania, South Carolina, Tennessee, Virginia, West Virginia Daryl Mayes Director Division of Cost Allocation Financial Management Service, PSC Cohen Building, Room 1067 330 Independence Avenue, SW Washington, DC 20201 Phone: 202-401-2808 NORTHEASTERN FIELD OFFICE Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, Vermont Includes: Puerto Rico, Virgin Islands, Canada, Europe Robert Aaronson Director 26 Federal Plaza Room 41-122 New York, NY 10278 Phone: 212-264-2069 CENTRAL STATES FIELD OFFICE Arkansas, Illinois, Indiana, Iowa, Kansas, Louisiana, Michigan, Minnesota, Missouri, Nebraska, New Mexico, Ohio, Oklahoma, Texas, Wisconsin Henry Williams Director 1301 Young Street Room 732 Dallas, TX 75202 Phone: 214-767-3261 WESTERN FIELD OFFICE Alaska, Arizona, California, Colorado, Hawaii, Idaho, Montana, Nevada, North Dakota, Oregon, South Dakota, Utah, Washington, Wyoming Wallace Chan Director 90 7th Street, Suite 4-600 San Francisco, CA 94103 Phone: 415-437-7820 Includes: Pacific Rim, Asia, Australia Earmark Post-Award Guide 11 Conditions 1. Federal Project Officer The Federal Project Officer (FPO) is identified in the grant agreement. The FPO is the primary U.S. Department of Labor (DOL) point of contact for the grantee. However, the FPO is not authorized to make any changes to the terms or conditions of the grant. Such changes, if any, will be accomplished by the Grant Officer (GO) using a properly executed grant/agreement modification submitted through the FPO. 2. Equipment Prior approval from the DOL/ETA GO must be obtained for the purchase and/or lease of any equipment with a per unit acquisition cost of $5,000 or more and a useful life of more than one year. This includes the purchase of Automatic Data Processing (ADP) equipment. A detailed description of the equipment to be purchased should be included in the proposal. If it is not, the grantee should submit to the GO, through the Federal Project Officer, a detailed list of the equipment to be purchased, the estimated cost of each piece of equipment including price quotes, and an explanation of how the purchase of the equipment will contribute to meeting the grant goals and objectives. However, merely listing the equipment in the proposal does NOT constitute prior approval, which must be specifically requested. 3. Program Income Program income is defined as gross income received by the grantee or subgrantee directly generated by a grant-supported activity, or earned only as a result of the grant agreement during the grant period. The grantee is required to utilize the addition method if any program income is generated throughout the duration of the grant/agreement. This means the funds may be used in addition to the grant funds for the purposes specified in the grant award. The grantee is allowed to deduct costs incidental to generating Program Income to arrive at the net Program Income [29 CFR Part 95.24 (c) or 29 CFR Part 97.25(c)(g)(2)] ETA requires program income to be wholly expended within the period of performance specified in the grant agreement. The income can be spent on grant activities by the organization that earned it for otherwise allowable costs, based upon the grant agreement, regulations, and the OMB Cost Principles. Any program income funds remaining at the end of the grant period of performance will be used to reduce the reported grant expenditures at closeout. Grantees should use program income before drawing down additional federal funds. The grantee is not accountable to the federal government for program income earned after the expiration of the grant. Note: Specific guidance regarding the question of tuition payments and fees counting as program income is contained in the Addendum of the guide, on page A-17. 12 Earmark Post-Award Guide 4. Pre-Award Costs Allowable costs incurred prior to the Department’s obligation of funds will not be approved by the Grant Officer. 5. Reports a. Quarterly Financial Status Report (SF 269) – Please note that a new financial status report format approved by the Office of Management and Budget is scheduled to be in place for all financial reporting with the quarter ending September 30, 2007. Grantees will be provided updated reporting instructions when the new reporting format goes into effect. Reports must be submitted through ETA’s online Grantee Reporting System. The letter that transmitted the grant agreement provides information on how to utilize and obtain access to the Grantee Reporting System. Please review this letter thoroughly. Each recipient must identify a primary contact, responsible for certifying the accuracy of the data submitted in the report, and a secondary contact, responsible for data entry. DOL will provide you with a password to enable data entry and a PIN to enable data certification. If the Grantee Reporting System is not available, the grantee should contact the e-Grants help desk for immediate assistance and inform their FPO. The e-Grants help desk phone number is (202) 693-2644; the email address is e-grants.help@dol.gov. The addendum to this guide provides a sample grant agreement transmittal letter containing the Grantee Reporting System information. The grantees are required to report expenditures on an accrual basis. i. Accrued Expenditures, or Total Outlays, are reported on line 10a and should include the total cumulative accrued expenditures of the grantee and all of its subrecipients. Accrued expenditures include the value of all goods and services received, and the share of indirect costs to date (if applicable), regardless of whether or not the costs have been billed or payments have been made. For instance, the cost of salaries of employees for the time worked during the reporting period, even though payment of payroll costs does not occur until the following reporting period, are reported as part of the total outlays for the grantee. If the entity has subrecipients that have not submitted a cost report for the quarter, the grantee should include estimated costs for that subrecipient. Each quarter, the cumulative costs should increase in comparison to the prior quarter. If the grantee is including an adjustment to previously reported costs, a note to that effect should be included in the Remarks section of the report. For example, costs may decrease if expenditures are shifted to a different funding stream or grant. If so, an explanation of this adjustment should be provided in the report. ii. Unliquidated obligations are reported in lines 10k through 10n. An example of an unliquidated obligation is the difference between the Earmark Post-Award Guide 13 total amount of an executed subcontract and the outlays reported under that subcontract. iii. Program income generated and expended during the quarter is reported in lines 10q-t. iv. Report the amount and percent of administrative costs on line 12, Remarks. Line-by-line instructions for completing the financial status report are included in the addendum to this guide. b. Quarterly Progress Report – A suggested format for quarterly reporting can be found in the Attachments section of this guide. c. Final Report – The final narrative report is due no later than 90 days after the grant expires. Grant funds cannot be used to write the report after the grant has expired. Therefore, it is recommended that the final report be completed as far as possible during the life of the grant. d. Final Financial Report – The report for the last quarter of the grant period of performance, due 30 days after the end of that quarter, should be marked as “final”. This will trigger the electronic transmission of a closeout package to the grantee and will make the closeout financial status report window available in the grantee reporting system. The closeout report is due 90 days after the end of the period of performance or 90 days after all funds have been expended, whichever occurs first, unless an extension is granted by the closeout unit. 6. Consultant Fees The limit is $500 per day. Grant Officer approval is needed for higher fees. 7. Rebates The grantee must advise the Grant Officer, in writing, of any forthcoming income resulting from lease/rental rebates or other rebates, interest, credits, or any other monies or financial benefits to be received directly or indirectly as a result of, or generated by, grant funds. Appropriate action must be taken to ensure that the Government is reimbursed proportionally from such income. Rebates must also be reported on the quarterly SF 269 on line 10b. 8. Publicity No funds provided under the grant can be used for publicity or salaries to support or defeat legislation or appropriations pending before congress 9. Public Announcements When issuing statements, press releases, requests for proposals, bid solicitations, and other documents describing projects, or programs funded in whole or in part by Federal funds, the grantee shall clearly state: (1) the percentage of the total cost of the program or project which will be financed with the Federal money and (2) the dollar amount of Federal Funds for the project or program. 14 Earmark Post-Award Guide 10. Executive Order 12928 The grantee is strongly encouraged to provide subgranting opportunities to Historically Black Colleges and Universities and other minority institutions, such as Hispanic Serving Institutions and Tribal Colleges and Universities, and to Small Businesses Owned and Controlled by Socially and Economically Disadvantaged Individuals (SDBs). 11. Procurement The grantee is responsible for following the procurement standards for partners specified in the grant agreement, as well as service providers procured after grant award. OMB circulars and administrative requirements require an entity’s procurement procedures to be conducted, as practical, to provide open and free competition. In the case where partners in the grant are not selected through competition, the procurement standards still require that there be a record of the procurement history for each procurement providing the basis for the contractor selection and, if applicable, justification for lack of competition as well as the basis for the award cost or price. Some form of cost or price analysis must be performed and documented for every procurement action. There are also requirements for contract administration, contract provision, codes of conduct, and procurement procedures. To qualify as a partner under this grant program, the partner organization needs to have been part of the proposal development, has to have brought some resources into the program, and needs to be an integral part of the project’s scope of work. The involvement of the partner organization in these activities needs to be adequately documented in the procurement record. The following criteria may be used to determine if an entity providing services under the grant is a service provider or a partner: SERVICE PROVIDER OR PARTNER? SERVICE PROVIDER Performs in accordance with specifications PARTNER Part of a joint proposal for funding Usually procured through an RFP Contributes resources to the program May be a subrecipient or a vendor Integral part of scope of work One partner receives grant award on behalf of the partnership Maintain documentation regarding the partnership formation 12. Veteran’s Priority: Jobs for Veterans Act, PL 107-288 Of those individuals who meet the eligibility requirements established by the grantee for participation in the project, priority of service must be given to veterans and spouses of certain veterans for the receipt of employment, training, and placement services in DOL-funded programs. Earmark Post-Award Guide 15 Grantees are responsible for developing and implementing priority of service procedures. Each recipient must track the number of veterans and spouses served. Outcomes of veterans and spouses should be tracked as well. The number of veterans served must be reported in the Quarterly Progress Report. The categories of spouses which must get priority are as follows: The spouse of any veteran who died of a service-connected disability; The spouse of any member of the Armed Forces who is currently and has been more than 90 days listed as: o o o missing in action, captured in the line of duty by a hostile force, or Forcibly detained or interned in the line of duty by a foreign government or power; The spouse of any veteran who has a total disability resulting from a service-connected disability; and The spouse of any veteran who died while a disability so evaluated was in existence. 13. Salary and Bonus Limitations Grant funds may not be used to pay the salary and bonuses of an individual, either as a direct or indirect cost, at a full time rate in excess of the salary of an Executive Level II in the federal government. A salary table providing this rate is listed on the Federal Office of Personnel Management website [www.opm.gov] under Federal salaries and wages and is adjusted annually. In 2007, the maximum is $168,000. Wages and cash bonuses are included in calculating compensation subject to the limitation. Fringe benefits and non-monetary compensation are not included. The limitation is applied proportionately to individuals whose full-time salary is not charged to the grant. For instance, if in 2007, 25 per cent of an employee’s time is attributable to work performed under the grant, no more than $42,000 can be charged to the grant during the year (i.e. 25 per cent of the $168,000 limitation). Training and Employment Guidance Letter 5-06, issued by the Employment & Training Administration on August 15, 2006 provides implementation guidance and is included in the addendum to this guide. 16 Earmark Post-Award Guide Earmark Grants Post-Award Guide: Part II Addendum Earmark Post-Award Guide Addendum A-i A-ii Earmark Post-Award Guide Addendum Part II Table of Contents Vision for a WIRED Workforce Investment System A-1 Grant Agreement Transmittal Letter A-3 Grant Modification Procedures A-5 Earmark Grantees’ Reporting Information A-7 Financial Status Reporting Instructions A-9 Subrecipient Reporting A-15 Tuition and Fee Income A-17 Cost Principles/Selected Items of Cost A-19 Administrative and Program Costs A-25 Procurement A-27 ETA’S Performance Accountability System A-31 Equipment A-33 Salary and Bonus Limitations A-35 Websites Guide A-39 Cross Reference of Administrative Requirements A-45 Records Retention A-47 Forms and Other Documents A-49 Attachments We Believe in Equal Opportunity (Poster) A-53 Equal Opportunity is The Law (Form) A-55 Lobbying Certification and Disclosure of Lobbying Activities A-57 Disclosure of Lobbying Activities (SF-LLL) A-59 R6 Quarterly Earmark Program Narrative Report (Suggested Template) A-61 Earmark Post-Award Guide Addendum A-iii Vision for a WIRED Workforce Investment System The forces of globalization are causing massive shifts and transitions in the world’s economy. While globalization creates significant challenges and opportunities at the international and national levels, innovative responses and solutions must be developed regionally, at the level where diverse strategic partners with a shared vision for achieving economic competitiveness and prosperity come together, aligning their talents and resources in support of fostering innovation in the global marketplace. A key component of fostering regional innovation in the global marketplace is transforming the way we have traditionally approached workforce preparation. The 21st Century economy demands a workforce with postsecondary education credentials, comfort in rapidly evolving, high-technology environments, and the adaptability to respond immediately to changing economic and business needs. The public workforce system must play a leadership role in meeting these demands, catalyzing the implementation of innovative talent development and lifelong learning strategies that will enable American workers to advance their skills and remain competitive in the global economy. The U.S. Department of Labor (DOL) Employment and Training Administration (ETA) supports a broader national strategy to support the workforce system in driving talent development and lifelong learning in regionally based economies. The Workforce Innovations In Regional Economic Development Initiative (WIRED), begun in 2006 as a Federal funding investment in regional economic models, represents a larger strategic approach by which all regional economies across the country can respond to the evolving dynamics and demands of the global economy. The foundation of the WIRED framework is evidence that three critical “pillars” must be in place and linked in order for regional economies to successfully innovate: An environment that supports and nurtures capital investment and entrepreneurship; A world-class infrastructure, which includes both physical and technological/virtual assets; and, most importantly; Talent development systems and strategies that give workers the skills needed to succeed in a 21st Century economy and continuously provide a lifetime of learning and education opportunities. To link these three pillars, the WIRED framework calls for the strategic partnership of multiple regional stakeholders, many of them relatively nontraditional allies of the workforce system - philanthropists and foundations, capital investors and angel networks, research and development institutions – along with the entire continuum of education partners, economic development entities, business and industry association representatives, regional infrastructure stakeholders, community leaders, and others. The framework articulates the critical success factors regions must pursue to ensure economic transformation and competitiveness, such as a strongly-articulated and understood regional identity and a shared commitment to the leveraging and alignment of resources or Earmark Post-Award Guide Addendum A-1 investments. To support the achievement of these success factors, the WIRED framework outlines concrete steps that regional economies must take in order to achieve economic prosperity, such as forming an empowered core leadership group and conducting a comprehensive regional asset and gap analysis. These success factors, and the “transformation steps” that support them, must be jointly owned by all partners and stakeholders in regional economies. However, within the WIRED framework, particular regional leaders may have greater roles than others, and greater expertise or assets to bring to bear, at particular times during the ongoing transformation process. The workforce system’s strengths and assets obviously reside in talent development and education, the most important pillar of a competitive regional economy. It is ETA’s intent to support broader and longer-term efforts to help implement the WIRED framework throughout the entire workforce system, and to further the understanding of what this framework means, practically and operationally, for state and local workforce system partners. The framework supports the broad vision for the workforce system’s role in pursuing talent development as the key component of regional economic competitiveness. ETA is committed to making this vision more and more concrete through continuous dialogue with workforce system partners, communication, and learning opportunities such as Webinars, policy development and clarification, technical assistance, and the sharing of WIRED strategies and successes as they evolve. Regional economic transformation – and the transformation of the workforce system that supports it – is a mutual, collaborative process. ETA looks forward to ongoing opportunities to engage with workforce system leaders and their partners to support their efforts in the WIRED framework and to learn from their successes and achievements. For more information on the WIRED framework and other tools developed under the WIRED initiative, please visit www.doleta.gov/WIRED. For more policy guidance from ETA, please visit www.doleta.gov/directives. A-2 Earmark Post-Award Guide Addendum Grant Agreement Transmittal Letter A grant agreement transmittal letter is sent to the newly awarded grantees by the Grant Officer as part of the executed grant agreement package. The letter explains how to access funds via the Payment Management System (PMS), and how to obtain access to the U.S. Department of Labor, Employment and Training Administration’s on-line Grantee Reporting System to report on the required Standard Form (SF) 269, Financial Status Report. Employment & Training Administration 200 Constitution Avenue, N.W. Washington, D.C. 20210 U.S. Department of Labor Grant Number: Enclosed is an executed copy of your recently awarded grant or agreement with the U. S. Department of Labor, Employment and Training Administration (ETA). This copy is being forwarded for your files. This letter is also to advise you how to access funds via the Payment Management System (PMS), and how to obtain access to ETAs on-line Grantee Reporting System to report on the required SF 269, Financial Status Report. These are two separate systems and require separate passwords/PINs. Please complete the following two steps. A. If you currently use PMS (Smart-Link) for other ETA grants, the funds awarded under this new grant agreement will be available under your current Account Number (PIN) in a separate subaccount. The contacts for subaccounts for ETA are Lanisha White (202) 693-2831 and Julia Murray (202) 693-2821. If you need to establish a PMS account, you must submit (preferably by overnight mail) a Direct Deposit Sign-up Form (SF 1199A) to: Ms. Pamela Wilkerson U.S. Department of Labor/ETA OFAM/Office of Comptroller 200 Constitution Avenue, NW - N4702 Washington, D.C. 20210 Telephone (202) 693-2602 Enclosed are the SF1999A with instructions and a sample of a completed form. If you have designated a separate entity to be the fiscal agent to access and disburse your grant funds, please submit a letter to DOL with that entity's name, address and EIN (Employer Identification Number). Along with the letter, also submit a SF 1199A from your fiscal agent. Upon receipt of your SF 1199A and the fiscal agent SF 1199A, you will be provided with PIN and Password to access the PMS. B. Once the SF 1199A is completed, the next step is to request a password and PIN to enable on-line access to the Grantee Reporting System for the required SF Earmark Post-Award Guide Addendum A-3 269, Financial Status Report. Two individuals in your organization must be identified who will be responsible for financial reporting. One individual should be the primary contact and responsible for certifying the accuracy of the data submitted by entering the PIN. The PIN is an electronic signature. The secondary individual should be the person responsible for the data entry. Please provide the grant agreement number, names and telephone numbers for both individuals, and an e-mail address for only the primary contact to: Shantay Logan at Logan.Shantay@dol.gov and Elizabeth Norris at Norris.Elizabeth@doI.gov. An on-line request form to receive the Password/PIN is also available at http://www.doleta.gov/sga/pdf/FSR-e-form.pdf which can be submitted by email if desired. Questions concerning the SF 269 form should be directed to your Federal Project Officer (FPO) or Thomas Martin (202) 693-2989. Questions concerning your grant agreement should be directed to your FPO identified in Part IV of your grant agreement. All communications should include your specific grant or agreement number as assigned. Sincerely, /signature/ Eric D. Luetkenhaus Grant/Contracting Officer Enclosures A-4 Earmark Post-Award Guide Addendum Grant Modification Procedures The U.S. Department of Labor (DOL) Employment and Training Administration (ETA) grant recipients are required to request prior written approval for budget and/or program plan revisions. Modification requests must be submitted to the Grant Officer (GO) through the Federal Project Officer (FPO) if there is: A change in the scope or the objective of the project/program (even if there is no associated budget revision requiring prior written approval); A change in a key person specified in the application or award document; The absence for more than three months, or a 25 per cent reduction in time devoted to the project, by the approved project director or principal investigator; The transfer of amounts budgeted for indirect costs to absorb increases in direct costs, or vice-versa; The inclusion of costs that require prior approval by the grant officer. For institutions of higher education, these costs are listed OMB Circular A-21, attachment J; The purchase of equipment defined as tangible, nonexpendable personal property having a useful life of more than one year and an acquisition cost of $5,000 or more per unit; The transfer of funds allotted for training allowances (direct payment to trainees) to other categories of expense; Unless described in the application and funded in the approved award, the subaward, transfer, or contracting out of any work under an award. This provision does not apply to the purchase of supplies, material, equipment, or general support services; or A need to extend the grant period of performance. Special Clause #1 to the grant agreement outlines additional circumstances requiring a budget modification: Any change in the amounts budgeted for wages, salaries, fringe benefits, and indirect costs must receive prior approval from the GO. An increase or decrease of more than 20 per cent to any other single line item also requires GO’s approval. The 20 per cent rule applies to cumulative changes made during the life of the grant. All modification requests must be accompanied by a cover letter explaining and justifying the changes requested. The cover letter should be signed by a grantee official who has the authority to enter into a modification to the grant with the Earmark Post-Award Guide Addendum A-5 Department of Labor. Where applicable, revised portions of the statement of work should be submitted. When requesting a modification to the budget, grantees shall use the budget forms that were used in the application. A budget breakout and narrative should accompany the revised budget form. A-6 Earmark Post-Award Guide Addendum Earmark Grantees’ Reporting Information To capture grantee learning and achievement as it happens and to ensure that grantees remain on track to meet the outcomes listed in their grant’s statement of work, the U.S. Department of Labor, Employment and Training Administration (ETA) requires grantees to report, on a regular basis, the progress made in meeting the goals and objectives of their grants. These reports are the primary means for ETA staff to understand the significant innovations and successes resulting from the grant for accountability and dissemination purposes, as well as to identify challenges encountered, learn about grantee strategies for resolution, track project expenditures, and develop a better understanding of the technical assistance needs of the grantee. TYPES OF REPORTS AND FREQUENCY OF REPORTS Earmark grantees are expected to submit to ETA two types of reports each quarter, financial and programmatic, as well as financial and programmatic final reports at the completion of their grant. All reports are described in more detail below. Quarterly Narrative Reports A Quarterly Narrative Report provides a detailed account of activities undertaken that quarter and serves as a regular communication between the grantee and the Federal Project Officer (FPO) about the progress of the project. While there is no agency-prescribed format, an example that has been used can be found in the Attachments. Once prepared and finalized, the report should be forwarded to the FPO no later than 30 days after the end of each calendar year quarter (see Quarterly Reporting Schedule section below). Financial Quarterly Reports Earmark grantees are also required to submit quarterly Financial Status Reports (SF 269) until the grant’s period of performance has expired. Financial Status Reports are used to track the cumulative amount of grant funds that have been expended. The form used for this report, the SF 269, is the same form required by many other Federal grant programs and may already be familiar to you. As shown in the chart, financial reports are required to be submitted to ETA no later than 30 days after the end of each calendar year quarter. To help simplify the process, an On-Line Electronic Grantee Reporting System has been developed for submitting these reports at the following URL: http://www.etareports.doleta.gov. Additional information can be found at http://www.whitehouse.gov/omb/grants/sf269.pdf. Earmark Post-Award Guide Addendum A-7 Quarterly Reporting Schedule Grantees are encouraged to provide frequent updates as the need arises; however, at a minimum, grantees should plan to update ETA on their progress four times a year through Financial and Progress Reports, as shown below: QUARTER PERIOD COVERED DUE DATE TO FPO 1 January 1 – March 31 April 30 2 April 1 – June 30 July 30 3 July 1 – September 30 October 30 4 October 1 – December 31 January 30 Please note that should the due date of the report fall on a Saturday or Sunday, the report is due the Friday before. Final Narrative Report and Evaluation Earmark grantees must submit a Final Project Narrative Report (evaluation of the project) no later than 90 days after completion of the grant. The final report serves a three-fold purpose: (1) communicates the grantee’s success in meeting the goals and objectives in the grant agreement as well as thoroughly documenting the solution approach; (2) summarizes project activities, employment outcomes, impacts and related results of the demonstration; and (3) serves as an essential source of information for communicating achievement and outcomes to the public workforce system, industry leaders, other stakeholders, and the education and training community. Please note that although the final report is a comprehensive summary of grant activities, there is an expectation that grantees will notify their FPO as effective approaches, models, and/or products from the project become available. ETA suggests grantees work on the Final Project Narrative Report (evaluation) throughout the grant’s lifetime. By accurately documenting the progress of the grant throughout its lifetime, grantees can ensure the final report is complete. Planning ahead also will make the job of organizing and writing the final report easier. Grantees may even wish to forward a draft copy 30-60 days before the grant ends to the FPO who can review it and help to ensure its completeness. Final Financial Report The report for the last quarter of the grant period of performance, due 30 days after the end of that quarter, should be marked as “final”. This will trigger the electronic transmission of a closeout package to the grantee and will make the closeout financial status report window available in the grantee reporting system. The closeout report is due 90 days after the end of the period of performance or 90 days after all funds have been expended, whichever occurs first, unless an extension is granted by the closeout unit. A-8 Earmark Post-Award Guide Addendum Financial Status Reporting Instructions GENERAL INSTRUCTIONS Please note that a new financial status report format approved by the Office of Management and Budget is scheduled to be in place for all financial reporting with the quarter ending September 30, 2007. Grantees will be provided updated reporting instructions when the new reporting format goes into effect. The Financial Status Report (FSR), Standard Form (SF) 269, is the required mechanism for U.S. Department of Labor (DOL), Employment and Training Administration (ETA) grantees to report program outlays (expenditures) and program income on an accrual basis. DOL mandates utilization of the FSR, SF 269, Long Form, as opposed to the SF 269A, Short Form, so that line items are available for reporting all program income earned and disbursed under grant awards. The FSRs are to be submitted via the online Grantee Reporting System no later than 30 days after the end of each reporting quarter, until all grant funds have been expended or the period of funds availability has expired. LINE ITEM CLARIFICATIONS Identifying Information This section covers Items 1-9, which identifies the grantee and provides the specific grant number, fund source, and the year of the funds applicable to this grant. This information will be pre-entered into the electronic system. For the first reporting period the grantee must verify that all the pre-entered data is current. Items 1-5 Enter names and addresses of Federal funding agency and recipient organization, plus other identifying information. Item 6 Check only if submitting the final report for the grant. Item 7 Check accrual box, as program outlays (expenditures) and program income are required to be reported on an accrual basis. Item 8 Enter the “grant period” in this item. The “from” box should reflect the beginning date of the grant award and the “to” box should reflect the ending date of the grant award. Item 9 Enter beginning and ending dates of period covered by this FSR. As the reports are cumulative, the beginning date in Item 9 will always be the beginning date of the grant, and the ending date is the last day of the quarter for which FSR is being submitted. Earmark Post-Award Guide Addendum A-9 Transactions Item 10 A-10 Columns I, II, and III show the effect of this reporting period’s transactions on the cumulative financial status. Amounts reported in Column I will generally be the same as Column III of the previous report in the same “grant period”. If this is the first or only report for the grant or funding period, only Column III should be filled in. Adjustments to amounts entered on previous reports should be reflected in Column I with a footnote and an attached explanation. a. TOTAL OUTLAYS (accrued expenditures) are the sum of actual cash disbursements for direct charges for goods and services, plus: − Amount of indirect expense incurred; − Value of in-kind contributions applied; and − Net increase or decrease in amounts owed by the recipient for goods and other property received for services performed by employees, contractors, subgrantees, and other payees; and other amounts becoming owed for which no current services or performance is required, i.e. annuities, insurance claims, and other benefit payments. b. REFUNDS, REBATES, or any receipt that is treated as a reduction of expenditures rather than as income, unless already netted out of outlay amount shown on line 10a. c. PROGRAM INCOME (earned/accrued, potential more than actual cash received) reported in accordance with the “deduction” alternative. There should be no entry on this line item, as DOL requires utilization of “addition” alternative. d. NET OUTLAYS are total outlays, line a minus line b. e. Recipient’s share of net outlays refers to “other” recipient funds expended or in-kind matching applied for the purposes of the grant, using resources other than those provided under this or other Federal grants. Basically, any cost sharing or matching outlays should be reported in this section. THIRD PARTY (IN-KIND) CONTRIBUTIONS. In-Kind contributions are made by a third party. A third party is an entity not receiving grant funds. For instance, a school which is not funded by the grant provides books for training, or an unpaid volunteer provides tutoring services to students. These are third party, inkind contributions. f. OTHER FEDERAL AWARDS AUTHORIZED TO BE USED TO MATCH THIS AWARD. Self-explanatory g. PROGRAM INCOME USED IN ACCORDANCE WITH THE MATCHING OR COST SHARING ALTERNATIVE. Not applicable to most DOL grants. h. ALL OTHER RECIPIENT OUTLAYS not shown on lines e, f, or g. i. TOTAL RECIPIENT SHARE OF NET OUTLAYS. Sum of lines e, f, g, and h. Earmark Post-Award Guide Addendum j. FEDERAL SHARE OF NET OUTLAYS is Net Outlays (line d) minus Recipient Share of Net Outlays (line i). If there are no entries on line i, line j should equal line d. k. TOTAL UNLIQUIDATED OBLIGATIONS are obligations incurred, but for which an outlay (expenditure) has not yet been recorded in the grantee’s books of account. This amount is additional to amounts reported on lines a and j and refers to unliquidated obligations of this award (as identified in funding/grant period), including unliquidated obligations to subgrantees and contractors. Obligations are defined as “amounts of orders placed, contracts and subgrants awarded, goods and services received, and similar transactions during a funding period that will require payment by the recipient or subrecipient during the same or future period.” On the final report, line k must be zero. Grantee has 90 days after all funds have been expended, or the period of availability has expired, to liquidate funds that were obligated during the period of performance. l. RECIPIENT’S SHARE OF UNLIQUIDATED OBLIGATIONS is additional to recipient’s outlays reported on line i, including obligations incurred for which outlay has not yet been recorded m. FEDERAL SHARE OF UNLIQUIDATED OBLIGATIONS is line k minus line l. In the final report, this line must be zero. n. TOTAL FEDERAL SHARE is the sum of line j (Federal Share of Net Outlays) and line m (Federal Share of Unliquidated Obligations). o. TOTAL FEDERAL FUNDS AUTHORIZED FOR THIS FUNDING/GRANT PERIOD refers to the total cumulative funds authorized for this grant. p. UNOBLIGATED BALANCE OF FEDERAL FUNDS is line o (Total Federal Funds Authorized) minus line n (Total Federal Share of Net Outlays plus Federal Share of Unliquidated Obligations). Program Income q. DISBURSED PROGRAM INCOME relates to lines c (“Deduction” alternative) and/or line g (“Matching or Cost Sharing” alternative). This line would be zero for DOL grants. r. DISBURSED PROGRAM INCOME USING ADDITION ALTERNATIVE should be reported for the grant as appropriate. s. UNDISBURSED PROGRAM INCOME is program income earned but not expended. t. TOTAL PROGRAM INCOME REALIZED is the sum of q (Disbursed under “Deduction” or “Matching” alternative), r (Disbursed under “addition” alternative), and s (Undisbursed Program Income). Earmark Post-Award Guide Addendum A-11 Item 11 Item 12 Indirect Expense. Requires information related to the indirect costs charged to the grant and included in the total outlays. a. TYPE OF RATE. Check type of indirect cost rate applied. This should be contained in the grant agreement or otherwise negotiated. b. RATE. Enter actual approved rate in effect during reporting period (as identified in item 8). c. BASE. Enter base dollar amount against which rate is applied. d. TOTAL AMOUNT. Multiply rate times base and enter total indirect amount. e. FEDERAL SHARE. Federal share is the indirect cost minus any portion paid out of recipient funds. This entry should equal d, if there is no non-Federal share. Remarks. This section provides space for any clarifying information. Here grantee is required to indicate the cumulative amount of the total outlays, both direct and indirect, classified as Administrative costs. ADDITIONAL FISCAL DEFINITIONS Obligation The amount of orders placed, contracts and subgrants awarded, goods and services received, and similar transactions during a given period that will require a payment by the grantee during the same or future period. [29 CFR 97.3 or 95.2] In the case of orders, contracts, and awards, this generally is in the form of an official document. Staff salaries and related costs, or other on-going internal operation costs, are generally obligated as they are incurred. Outlays Expenditures are charges made to the project or program. ETA requires outlays to be reported on an accrual basis. For reports prepared on an accrual basis, outlays are the sum of actual cash disbursements, the amount of indirect expense incurred, the value of in-kind contributions applied, and the amounts owed by the grant