Grant Management & Fiscal Responsibility of VR Cases

Twenty Questions

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1. The tribal wisdom of the Lakota, passed on from generation to generation, says that when you discover that you are riding a dead horse, the best strategy is?

“Dismount”

2. Name one government cure for riding a dead horse?

1. Buying a stronger whip.2. Asserting “This is the way we always have ridden this horse.”3. Arranging to visit other sites to benchmark how they ride dead horses.4. Providing additional training to increase riding ability.5. Outsourcing to private contractors to see if they can ride the dead horse

cheaper. 6. Harnessing several dead horses together to increase the speed.7. Declaring that, as the dead horse does not have to be fed, it is less

costly, carries lower overheads, and therefore contributes substantially more to the bottom line of the economy than do some other horses.

8. Commissioning a study to identify ways to improve dead horses through incremental enhancements, such as adding wheels.

9. Rewriting the expected performance requirements for all horses.10. Promoting the dead horse to a supervisory position.

3. What are Personnel Activity Reports?

Personnel Activity Reports are documents that reflect an after-the-fact distribution of the actual activity of each employee which is compensated by a federal grant program.

4. True or False? In purchases of services for clients if there is no law against it therefore there was nothing unethical about it.

False much that is unethical is not illegal. Ethics is good conduct as determined by the values and customs. Professions promulgate codes of ethics precisely because the law cannot proscribe all inappropriate or harmful behavior. Lying, betrayal, nepotism, services to family members and many other kinds of behavior.

5. Client Services in the responsibility of ?

No set of rules will apply in all situations, however compliance with rules, regulations and laws regarding services to clients is everyone's responsibility. This would include the VRC; Program Director; Fiscal Staff; other TVR Staff, the program evaluator and RSA.

6. Name one control environment factors?

1. Integrity; 2. Ethical values and competence of the entity's people; 3. Management's philosophy and operating style; 4. The way management assigns authority and

responsibility, and organizes and develops its people; and 5. The attention and direction provided the Program and

Tribe.

7. What are reasonable costs?

A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost.

8. The question of reasonableness is particularly important when federally funded. In determining reasonableness of a given cost, consideration shall be given to?

8 Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the governmental unit or the performance of the federal award. The restraints or requirements imposed by such factors as: sound business practices; arms length bargaining; Federal, State and other laws and regulations; Tribal policy and procedures and, terms and conditions of the Federal award. Also, market prices for comparable goods or services. Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to their clients and significant deviations from the established practices of which may unjustifiably increase the Federal award's cost.

9. What would be a sign of weak internal controls for client services?

Encumbrances (purchase orders) not in place in order to set aside budget for purchases;

The VRC who requested the encumbrances approves the encumbrance?

Encumbrances not directly related to an IPE or related grant activities.

No record of receipt of goods and services in client files or recorded with fiscal.

10. What are Allocable Costs?

A cost is allocable to a particular cost objective if the goods or services involved are chargeable or assignable to such cost objective in accordance with relative benefits received.

11. What are Allowable Costs?

Be necessary and reasonable for proper and efficient performance and administration of Federal awards.

Be allocable to Federal awards. Be authorized or not prohibited under State or local laws or

regulations. Conform to any limitations or exclusions set forth in these principles,

Federal laws, terms and conditions of the Federal award, or other governing regulations as to types or amounts of cost items.

Be consistent with Tribal policies, regulations, and procedures that apply uniformly to both Federal awards and other activities of the governmental unit.

12. Does a grant program need approval from RSA to replace the VRC?

It depends. EDGAR § 80.30 (applicable to state, local, and tribal governments) requires that a grantee obtain prior approval from ED for changes to key persons identified in the application and for changes in the project director or principal investigator in research projects regardless of whether those individuals were identified in the application.

13. Why are internal controls important?

Effectiveness and efficiency of operations.Reliability of financial reporting.Compliance with applicable laws and

regulations.

14. How is a Vocational Rehabilitation Counselor (VRC) a part of internal controls?

Purchased services are approved by supervisors and financial staff based on VRC recommendations. The VRC jointly develop a plan of services with eligible individuals to achieve quality successful employment as stated at 34 CFR 361.45(c)(1), and 361.46(a)(1). They ensure each service is “appropriate to the vocational rehabilitation needs of each individual and consistent with each individual’s informed choice…to assist the individual with a disability in preparing for, securing, retaining, or regaining an employment outcome that is consistent with the individual’s strengths, resources, priorities, capabilities, interests, and informed choice” (34 CFR 361.48) and meets the goals of the Individualized Plan for Employment. Collaborative relationships are developed with consumers to increase the likelihood of successful outcomes.

15. What are Internal Controls in relationship to Client Services?

Oversight and approvals policy and procedures to ensure federal money is spent correctly on vocational rehabilitation clients and personnel needed to support those services.

-Transactions properly recorded and accounted for- Personnel expenses documented with PARs and key personnel changes approved by RSA

Able to prove federal money is spent correctly -Transactions are executed in compliance with laws, regulations, and provisions of contracts or grants

Safeguard and document property and services purchased with federal money

-Funds, property, and other assets purchased for clients are safeguarded against loss from unauthorized use or disposition

16. Can a TVR grant program reduce the number of clients to serve or to obtain employment?

16. EDGAR §§ 74.25 and 80.30 appear to give ED program officials the authority to review and approve requests to change the scope or objectives of a discretionary grant. However, ED does not permit changes to the scope or objectives of a grant except in rare cases where the competition for the grant was not truly competitive.

17. How is Separation of duties important for grants management and client services?

Best practice is to have different people: • Approve purchases• Receive ordered materials and other client purchases• Approve invoices for payment• Review and reconcile financial records• Perform inventory counts

• Potential consequences if duties are not separated: • Unauthorized or unnecessary purchases made• Improper charges made to department budgets• Excessive costs incurred• Goods purchased for personal use or from phoney vendors

18. What are deficiencies in internal controls?

Noncompliance with laws and regulations• Unallowable costs• Undocumented costs• Unapproved costs• Unreasonable costs

19. What is one objective of the CRC Code of Ethics related to purchases of services?

The basic objectives of the Code are to: (1) promote public welfare by specifying ethical behavior expected of rehabilitation counselors; (2) establish principles that define ethical behavior and best practices of rehabilitation counselors; (3) serve as an ethical guide designed to assist rehabilitation counselors in constructing a professional course of action that best serves those utilizing rehabilitation services; and, (4) serve as the basis for the processing of alleged Code violations by certified rehabilitation counselors.

20. How does TVR grant personnel support client services?

TVR grants should be client-focused; should have clear objectives serving clients, definitive timelines and measurable outcomes; and should be part of a larger effort of leveraging funds with State VR and/or filling resource gaps with other funding sources.