FINANCIAL/ADMINISTRATIVE PROCEDURES MANUAL GUIDANCE

Transcription

1 FINANCIAL/ADMINISTRATIVE PROCEDURES MANUAL GUIDANCE LOGISTICS OF GRANTS INTERNAL CONTROLS (LOGIC) Education Service Center, Region 20 Denise Dusek (210)

2 DEFINITIONS Policy: A set of policies are principles, rules, and guidelines formulated and adopted by an organization to reach its longterm goals and typically published in a booklet or other form that is widely accessible. Business Dictionary.com Accessed 5/28/15 EDUCATION SERVICE CENTER, REGION 20 LOGIC 2

3 DEFINITIONS Procedure: Procedures are the specific methods employed to express policies in action in day-to-day operations of the organization. Business Dictionary.com Accessed 5/28/15 EDUCATION SERVICE CENTER, REGION 20 LOGIC 3

4 Policies and Procedures: DEFINITIONS Policies and procedures are designed to influence and determine all major decisions and actions, and all activities take place within the boundaries set by them Together, policies and procedures ensure that a point held by the governing body of an organization is translated into steps that result in an outcome compatible with that view. Business Dictionary.com Accessed 5/28/15 EDUCATION SERVICE CENTER, REGION 20 LOGIC 4

5 DEFINITIONS Policy = Law, Requirement Goal of the organization Procedures = How implemented at local level Steps to achieve goals EDUCATION SERVICE CENTER, REGION 20 LOGIC 5

6 WHY IMPORTANT Effective Internal Control System Required of EDGAR (Education Department General Administrative Regulations) Evidence of compliance Maintains consistency Training tool EDUCATION SERVICE CENTER, REGION 20 LOGIC 6

7 GETTING STARTED Begin the dialogue Use the templates to develop a framework to provoke thoughtful, deliberate analysis of: What you do, How you do it, and How to implement Federal and State requirements at the local level Consider how things connect business side, program side Collaborative effort consider creating workgroups EDUCATION SERVICE CENTER, REGION 20 LOGIC 7

8 THE JOURNEY Consider the manual a work in progress Revise as needed, based on: TEA guidance USDE guidance Results of audits Changes in local policy and processes EDUCATION SERVICE CENTER, REGION 20 LOGIC 8

9 CONTINUOUS CYCLE DEVELOP Include stakeholders, staff members who perform the tasks Include both fiscal and programmatic personnel AGREE Buy-in from those who will use the policies and procedures Formally adopt, according to local policy IMPLEMENT Train staff MONITOR & REVIEW Ensure proper implementation Review annually or whenever new guidance is released Determine if revisions needed UPDATE (Include effective date on each updated version) EDUCATION SERVICE CENTER, REGION 20 LOGIC 9

10 What to call the manual? LOCAL DECISIONS Financial Procedures? Administrative Procedures? Financial/Administrative Procedures? One manual or several, separate manuals? Financial/Administrative Procedures Procurement Procedures Travel Procedures EDUCATION SERVICE CENTER, REGION 20 LOGIC 10

11 LOCAL DECISIONS Policies and procedures together in one manual? OR Separate manual for policy and separate manual for procedures? EDUCATION SERVICE CENTER, REGION 20 LOGIC 11

12 LOCAL DECISIONS Federal Program Procedures/Program Operating Guidelines vs Financial/Administrative Procedures Include fiscal-related program requirements in both? OR Include fiscal-related program requirements in the Financial/Administrative Procedures manual and make reference to these in your Program Manual? EDUCATION SERVICE CENTER, REGION 20 LOGIC 12

13 IMPORTANT CONSIDERATIONS Compliant with federal and state requirements Must not conflict with local policy Local policy must not conflict with federal and state requirements Follow most restrictive requirement: EDGAR (cross-cutting, applies to all federal education grants) Program-Specific Statute/Regulations State Rules and Regulations Local Policy EDUCATION SERVICE CENTER, REGION 20 LOGIC 13

14 IMPORTANT CONSIDERATIONS Address all requirements that apply to federal and state grants Consistently treated Applicable to all federal programs (cross-cutting) Include program-specific fiscal requirements and procedures, when applicable Example: Indicate the fiscal compliance requirements of IDEA- B, such as Excess Cost calculation and MOE analysis EDUCATION SERVICE CENTER, REGION 20 LOGIC 14

15 IMPORTANT CONSIDERATIONS Effective Date indicated on manual Procedures describe the process adequately, but not overly prescriptive (auditors will look for implementation) Develop flowchart (optional); Auditors like this! If a certain element/topic is not applicable, don t remove the topic from your manual. Instead, state N/A Example: If you don t use credit cards, have a section where you state that your LEA does not use credit cards EDUCATION SERVICE CENTER, REGION 20 LOGIC 15

16 IMPORTANT CONSIDERATIONS Training is critical Employees need to know and understand the policies and procedures Employees need to understand the reasoning behind the procedure Example: why time and effort reporting? Auditors may ask an employee to describe how and why they carry out a certain task Common audit finding: Written procedure is not being implemented EDUCATION SERVICE CENTER, REGION 20 LOGIC 16

17 ABOVE ALL, CUSTOMIZE! Must be localized, customized Use caution if using a template with standard procedures, or adopting a manual from another LEA Not a plan in a can EDUCATION SERVICE CENTER, REGION 20 LOGIC 17