4. Operations and Processes

Annual Financial Report (AFR)

An Annual Financial Report (AFR) is due after the fiscal year ends (see the At-a-Glance for specific dates). The AFR is part of the budget template and must show the actual expenditures for that fiscal year. Various components are reviewed by AEI for accuracy, including match, admin percentage, and expenditure versus budgeted variance.

Audits

It is best practice for organizations to document what the organization’s audit schedule is. This may be requested by CDE.

AEFLA

A single audit is required if an organization has collectively spent $750,000 or more in federal funds in the previous fiscal year.

CDE receives single audit reports automatically from school districts and Institutions of Higher Education.

Non-profit organizations will need to fill out a “Non-Profit Audit Inquiry Form” for CDE Grants Fiscal at the beginning of each grant cycle. The purpose of this document is to ensure the organization is in compliance with Uniform Grant Guidance requirements.

Budget Preparation

CDE Grants Fiscal provides grantees with Excel budget templates created to gather planned program expenditure information for the grant.

The planned expenditures captured in the budget requires significant vetting by program and fiscal staff at the local agency before it is entered into the worksheet. Make sure to provide an appropriate level of detail in the budget spreadsheet: See the first tab of the budget template for specific instructions.:

Budget Revisions

A budget revision includes any changes to funding in the budget line items. Budget revisions must remain within the purpose of the grant program.

The 10% Rule

Within a fiscal year, a budget line may be realigned without prior written approval from AEI and CDE Grants Fiscal if the cumulative amount of the transfers does not exceed 10% of the total budget during a single fiscal year, is not a change to Program Income, Match or Infrastructure, and is not a salary or equipment cost. No matter the scope of the change, please describe the revision in the notes column of the budget detail.

Budget Revision Process

Budget revision requests are required any time the transfer exceeds 10% of the total budget, any time changes are made to salary or equipment, anytime out-of-state travel is added to the budget, and anytime changes are made to Match, Program Income or Infrastructure Contributions to the local One-stop Center. Requests must be received at least 30 days before the change takes place as it requires review from AEI and Grants Fiscal. Budget revision notifications will not be accepted or considered after April 30 of each fiscal year.

The budget revision process is as follows:

Grantee submits an updated budget to their AEI Program Coordinator. Changes are reflected in the appropriate budget revision column and are described in the notes column in the budget detail.
- If the changes include a change of address or changes to the grant application cover page details, the grantee will submit additional Grantee Information Updates to their AEI Program Coordinator.
- Verify the match does not exceed the 40% requirement.
The request will be reviewed for programmatic impact, specifically with regard to the grantee’s ability to meet goals described in the grant application and for fiscal impact to ensure the request is allowable.
If there are any concerns or questions, AEI will email the grantee and request a revised narrative or clarifications.
The primary and secondary grant contacts and fiscal contact will receive an official memo from AEI approving or denying the revision. The AEI director will be copied on the official memo.
A copy of any approved revised budgets and each AEI memo will be kept at AEI and with the grantee.

Competitive Bidding (AELA)

Grantees must follow their local procurement policies for cost thresholds that require competitive bidding.

DUNS Number (AEFLA)

The organization’s DUNS number is required and your agency must be active on SAM.gov to receive federal funds. For more information about a grantee’s DUNs number, use the “Search Records” feature on SAM.gov.

Fiscal Contact Communication

The fiscal contact is the person in charge of the accounting system. Note: this is not necessarily the person who submits the request for funds document to CDE Grants Fiscal.

Any communication that could have a fiscal impact on the program will include the primary, secondary and fiscal grantee contacts.

Fiscal Tracking

AEFLA

Maintain separate fund accounting and management of grant, match and program income dollars directly associated with this grant.
Track money as adult education funds in accounting system so it is clear the grantee is not supplanting funds.
Use clearly defined fiscal procedures and processes. The Uniform Grant Guidance requires all recipients of federal funds to have fiscal procedures and processes, as well as internal control policies that satisfy the Uniform Grant Guidance requirements and 2 CFR 200.303. Remember to include procurement policies and also satisfy 2 CFR 200.317-326.
Maintain accurate records of funds received and disbursed. The Uniform Grant Guidance does allow recipients of federal funds to maintain their program and financial records electronically.
Keep documentation supporting all expenditures paid for by the AEFLA grant. This includes an inventory of all supplies and an itemized inventory of all equipment that are current and being used by the grantee per 2 CFR 220.313-314.

AELA

Maintain separate fund accounting and management of the AELA Grant.
Track money as adult education funds in accounting system so it is clear the grantee is not supplanting funds.
Use clearly defined fiscal procedures and processes.
Maintain accurate records of funds received and disbursed.
Keep documentation supporting all expenditures paid for with AELA grant funds.

Grant Award Letter

AEFLA

Once the State has received official notification of allocation, grantees will receive a Grant Award Letter (GAL) from the CDE Office of Grants Fiscal. GALs will be saved at the AEI office and with the grantee.

The Grant Award Letter must be wet signed by all standalone non-profits (not school districts nor community colleges) prior to officially releasing the funds.

AELA

Funding for the AELA can be found in the annual Colorado Legislature Long Appropriation Act, usually signed by the governor in May.Typically, grantees will receive a Grant Award Letter (GAL) and payment from the CDE Grants Fiscal Office by August 31st. GALs will be saved at AEI and with the grantee

Interim Financial Reports (IFR)

Interim Financial Reports are required at specific intervals during the fiscal year (see the At-a-Glance for specific dates). Grantees provide an expenditure report from their accounting system showing the total budget, as well as a detailed itemization of expenditures to include amount, date description, etc. of the expenditures to date and the and the remaining balance.

Paying Contractors

The grantee is ultimately responsible for ensuring grant requirements are carried out, even if the grantee sub-contracts some of the grant deliverables.

Paying Staff for Supplemental Activities

Supplemental funds are awarded to grantees when they have the opportunity to participate in an activity which grantees were not aware of at the time their original budget was submitted for the fiscal year. These activities are necessary in order to meet the requirements of WIOA and increase the effectiveness of adult education programming.

The grantee will need to ensure staff are not paid from the initial AEFLA budget but instead, from the supplemental funds. Adherence to this requirement is mandatory to assure staff are not receiving compensation from the same federal source for time that is charged to the federal grant.

Per Pupil Revenue (PPR) Funding

Adult education programs may enter into contracts with school districts to serve learners. Sometimes Per Pupil Revenue (PPR) funding received by the district is used to provide services to learners in an adult education program. If school districts use PPR funding for learners to receive adult education services, they must follow the requirements outlined in the most recently published “Student October Count Audit Resource Guide” located on CDE’s Pupil Count page. Learners who receive services through this funding are not counted in reporting for either the federally-funded AEFLA or the state-funded AELA grants.

Program Name Change

If a grantee plans to change its name, it must receive approval from the organization’s board. Once approved, send the resolution or board minutes to the AEI program coordinator and Grants Fiscal contact. The grantee will also need to need submit a new W-9 to be processed by the CDE Accounting Office and the State Controller’s Office.

AEFLA

The grantee must also change the program name on Sam.gov if it would like the program name to show on any forthcoming GANs.

Request for Funds (RFF) (AEFLA)

AEFLA/IELCE is a reimbursement grant, meaning that funds must be spent from existing general funds prior to a grantee’s request for funds. Grantees will submit the Request for Reimbursement electronically, utilizing the FormSite tool (information can be found on the Grants Fiscal webpage on CDE website). The RFF form should be filled out with the total allocation, expenditures to date, less reimbursements to date. In addition, attachment should be submitted detailing the program income and match incurred to date. If match is not distributed on a monthly basis within the organization, please note the time period the match amount refers to in each RFF attachment. Program income may not be expended on a month-to-month basis since funds may be used in chunks for specific purposes, so the “Program Income Expended Year-to-Date” amount may appear to be the same for multiple RFFs. The intention of including the program income detail attachment to the RFF is to ensure that program income funds are spent down in the year the same fiscal year that they are collected. If a grantee is not collecting Program Income and the approved budget reflects $0 for this category, no further action is required for the program income portion of the RFF.

An RFF must be submitted at least once every quarter according to the schedule below, with a maximum of once a month (If a date falls on a weekend or a holiday, the date will be the next business day):

Q2: (Oct, Nov, Dec) Due prior to January 15th
Q3: (Jan, Feb, Mar) Due prior to April 15th
Q4: (Apr, May, June) Due prior to September 15th

Requests for reimbursement are due to the CDE Office of Grants Fiscal by the 15th of each month. Grantees typically receive payment within 30 business days from the 15th processing date. It is important to ensure appropriate documentation is maintained at the local level for federal expenditures as well as match and program income (if applicable). Grantees do not, however, submit that documentation with RFFs unless otherwise directed by AEI or CDE Grants Fiscal. It should be noted that expenditure support and/or fiscal reports/documentation can be requested at any time by Grants Fiscal.

Funds must be obligated by June 30. Please remember, goods or services are required to be received by June 30, in order to indicate funds are obligated. A fiscal report/general ledger will be reviewed to ensure the funds are obligated within the grantees financial system. Funds not spent by June 30 will revert back to CDE.

Support and Contact Information

Fiscal guidance presentations are offered to grantees throughout the year based on need. AEI and CDE Grants Fiscal are also available to provide targeted technical assistance to grantees during staff transition or for unique issues, questions or concerns. Please reach out to your AEI Program Coordinator to discuss further.

For fiscal related issues, technical assistance or questions, feel free to contact Marti Rodriguez, Grants Fiscal Analyst, 303-866-6769 or [email protected]; as well as Jennifer Austin, Grants Fiscal Management Unit Director, 303-866-6689 or [email protected].