daf-1_administration_of_federal_grants_-_allowability
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daf-1_administration_of_federal_grants_-_allowability [2026/03/05 16:58] sau47 |
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| **Policy DAF-1** \\ | **Policy DAF-1** \\ | ||
| **Administration of Federal Grants - Allowability** \\ | **Administration of Federal Grants - Allowability** \\ | ||
| - | **School Board Approved: December 2, 2024** \\ | + | **School Board Approved: August 17, 2026** \\ |
| The Superintendent is responsible for the efficient and effective administration of grant funds through the application of sound management practices. Such funds shall be administered in a manner consistent with all applicable Federal, State and local laws, the associated agreements/assurances, program objectives and the specific terms and conditions of the grant award.\\ | The Superintendent is responsible for the efficient and effective administration of grant funds through the application of sound management practices. Such funds shall be administered in a manner consistent with all applicable Federal, State and local laws, the associated agreements/assurances, program objectives and the specific terms and conditions of the grant award.\\ | ||
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| iii. there is an educational benefit associated with the cost;\\ | iii. there is an educational benefit associated with the cost;\\ | ||
| - | iv. the cost aligns with identified needs based on results and findings from a needs assessment; and/or | + | iv. the cost aligns with identified needs based on results and findings from a needs assessment; and/or\\ |
| v. the cost addresses program goals and objectives and is based on program data.\\ | v. the cost addresses program goals and objectives and is based on program data.\\ | ||
| Line 56: | Line 57: | ||
| b. in the case of other costs, all receipts and other invoice materials shall be retained, along with any documentation identifying the need and purpose for such expenditure if not otherwise clear.\\ | b. in the case of other costs, all receipts and other invoice materials shall be retained, along with any documentation identifying the need and purpose for such expenditure if not otherwise clear.\\ | ||
| - | B. Selected Items of Cost: | + | **B. Selected Items of Cost:**\\ |
| The District shall follow the rules for selected items of cost at 2 CFR Part 200, Subpart E when charging these specific expenditures to a Federal grant. When applicable, District staff shall check costs against the selected items of cost requirements to ensure the cost is allowable. In addition, State, District and program-specific rules, including the terms and conditions of the award, may deem a cost as unallowable and District personnel shall follow those rules as well.\\ | The District shall follow the rules for selected items of cost at 2 CFR Part 200, Subpart E when charging these specific expenditures to a Federal grant. When applicable, District staff shall check costs against the selected items of cost requirements to ensure the cost is allowable. In addition, State, District and program-specific rules, including the terms and conditions of the award, may deem a cost as unallowable and District personnel shall follow those rules as well.\\ | ||
| - | C. Cost Compliance: | + | **C. Cost Compliance:** |
| The Superintendent shall require that grant program funds are expended and are accounted for consistent with the requirements of the specific program and as identified in the grant application. Compliance monitoring includes accounting for direct or indirect costs and reporting them as permitted or required by each grant.\\ | The Superintendent shall require that grant program funds are expended and are accounted for consistent with the requirements of the specific program and as identified in the grant application. Compliance monitoring includes accounting for direct or indirect costs and reporting them as permitted or required by each grant.\\ | ||
| - | D. Determining Whether A Cost is Direct or Indirect:\\ | + | **D. Determining Whether A Cost is Direct or Indirect:**\\ |
| 1. “Direct costs” are those costs that can be identified specifically with a particular final cost objective, such as a Federal award, or other internally or externally funded activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy.\\ | 1. “Direct costs” are those costs that can be identified specifically with a particular final cost objective, such as a Federal award, or other internally or externally funded activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy.\\ | ||
| - | These costs may include: salaries and fringe benefits of employees working directly on a grant-funded project; purchased services contracted for performance under the grant; travel of employees working directly on a grant-funded project; materials, supplies, and equipment | + | These costs may include: salaries and fringe benefits of employees working directly on a grant- funded project; purchased services contracted for performance under the grant; travel of employees working directly on a grant-funded project; materials, supplies, and equipment |
| purchased for use on a specific grant; and infrastructure costs directly attributable to the program (such as long distance telephone calls specific to the program, etc.).\\ | purchased for use on a specific grant; and infrastructure costs directly attributable to the program (such as long distance telephone calls specific to the program, etc.).\\ | ||
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| The salaries of administrative and clerical staff should normally be treated as indirect costs. Direct charging of these costs may be appropriate only if all the following conditions are met:\\ | The salaries of administrative and clerical staff should normally be treated as indirect costs. Direct charging of these costs may be appropriate only if all the following conditions are met:\\ | ||
| - | |||
| a. Administrative or clerical services are integral to a project or activity.\\ | a. Administrative or clerical services are integral to a project or activity.\\ | ||
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| d. The costs are not also recovered as indirect costs.\\ | d. The costs are not also recovered as indirect costs.\\ | ||
| - | Where a Federal program has a specific cap on the percentage of administrative costs that may be charged to a grant, that cap shall include all direct administrative charges as well as any recovered indirect charges. Effort should be given to identify costs as direct costs whenever practical, but allocation of indirect costs may be used where not prohibited and where indirect cost allocation is approved ahead of time by NHDOE or the pass-through entity (Federal funds subject to 2 C.F.R Part 200 pertaining to determining indirect cost allocation).\\ | + | Where a Federal program has a specific cap on the percentage of administrative costs that may be charged to a grant, that cap shall include all direct administrative charges as well as any recovered indirect charges.\\ |
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| + | Effort should be given to identify costs as direct costs whenever practical, but allocation of indirect costs may be used where not prohibited and where indirect cost allocation is approved ahead of time by NHED or the pass-through entity (Federal funds subject to 2 C.F.R Part 200 pertaining to determining indirect cost allocation).\\ | ||
| **E. Timely Obligation of Funds:**\\ | **E. Timely Obligation of Funds:**\\ | ||
| - | Obligations are orders placed for property and services, contracts and subawards made, and similar transactions during a given period that require payment by the recipient or sub-recipient during the same or a future period.\\ | + | Obligations are orders placed for property and services, contracts and sub-awards made, and similar transactions during a given period that require payment by the recipient or sub-recipient during the same or a future period.\\ |
| - | The following are examples of when funds are determined to be “obligated” under applicable regulation of the | + | The following are examples of when funds are determined to be “obligated” under applicable regulation of the U.S. Department of Education:\\ |
| - | U.S. Department of Education:\\ | + | |
| When the obligation is for:\\ | When the obligation is for:\\ | ||
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| **F. Period of Performance:**\\ | **F. Period of Performance:**\\ | ||
| - | All obligations must occur on or between the beginning and ending dates of the grant project. This period of time is known as the period of performance. The period of performance is dictated by statute and will be indicated in the Grant Award Notification (“GAN”). As a general rule, State-administered Federal funds are available for obligation within the year that Congress appropriates the funds for. However, given the unique nature of educational institutions, for many Federal education grants, the period of performance is twenty-seven (27) months. This maximum period includes a fifteen (15) month period of initial availability, plus a twelve (12) month period of carry over. For direct grants, the period of performance is generally identified in the GAN.\\ | + | All obligations must occur on or between the beginning and ending dates of the grant project. This period of time is known as the period of performance. The period of performance is dictated by statute and will be indicated in the Grant Award Notification (“GAN”). As a general rule, State- administered Federal funds are available for obligation within the year that Congress appropriates the funds for. However, given the unique nature of educational institutions, for many Federal education grants, the period of performance is twenty-seven (27) months. This maximum period includes a fifteen (15) month period of initial availability, plus a twelve (12) month period of carry over. For direct grants, the period of performance is generally identified in the GAN.\\ |
| - | Pre-award costs are those incurred prior to the effective date of the Federal award or subaward directly pursuant to the negotiation and in anticipation of the Federal award where such costs are necessary for efficient and timely performance of the scope of work. Such costs are allowable only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the initial Federal awarding agency or of the NHDOE or other pass-through entity.\\ | + | Pre-award costs are those incurred prior to the effective date of the Federal award or sub-award directly pursuant to the negotiation and in anticipation of the Federal award where such costs are necessary for efficient and timely performance of the scope of work. Such costs are allowable only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the initial Federal awarding agency or of the NHED or other pass-through entity.\\ |
| For both State-administered and direct grants, regardless of the period of availability, the District shall liquidate all obligations incurred under the award not later than forty-five (45) days after the end of the funding period unless an extension is authorized. Any funds not obligated within the period of performance or liquidated within the appropriate timeframe are said to lapse and shall be returned to the awarding agency. Consistently, the District shall closely monitor grant spending throughout the grant cycle.\\ | For both State-administered and direct grants, regardless of the period of availability, the District shall liquidate all obligations incurred under the award not later than forty-five (45) days after the end of the funding period unless an extension is authorized. Any funds not obligated within the period of performance or liquidated within the appropriate timeframe are said to lapse and shall be returned to the awarding agency. Consistently, the District shall closely monitor grant spending throughout the grant cycle.\\ | ||
| **District Policy History:**\\ | **District Policy History:**\\ | ||
| - | First reading: November 4, 2024\\ | + | First reading: August 3, 2026\\ |
| - | Second reading: November 18, 2024\\ | + | Second reading: August 17,2026\\ |
| - | Third reading/adopted: December 2, 2024\\ | + | **District revision history:** Approved April 19, 2021; Revised December 2, 2024\\ |
| - | **District revision history:** Approved April 19, 2021\\ | + | |
| {{policy_daf-1.pdf |Download}}\\ | {{policy_daf-1.pdf |Download}}\\ | ||
| [[section_d|Section D]]\\ | [[section_d|Section D]]\\ | ||
| [[start|Policy Manual]] | [[start|Policy Manual]] | ||
daf-1_administration_of_federal_grants_-_allowability.txt · Last modified: 2026/08/31 20:39 by sau47
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