Various provisions of the CSP grant can be found in the non-regulatory Guidance posted on the NYSED Charter School Office website at: http://www.p12.nysed.gov/psc/grants.html. Section A-3 of that guidance states that: “…recipients of funds under this program should be aware of the following significant statutory requirements in addition to those in title V, part B, subpart 1 of the ESEA:…(i) The Education Department General Administrative Regulations (EDGAR), parts 74, 75, 76, 77, 79, 80, 81, 82, 84, 85, 86, 97, 98, and 99)…”
EDGAR information can be found at: http://www2.ed.gov/policy/fund/reg/edgarReg/edgar.html. Specific to the EDGAR requirements, the NYS Education Department’s Office of Grants Finance provides guidance on its website to all recipients of federal funds. This guidance can be found at: http://www.oms.nysed.gov/cafe/guidance/.
Three areas of EDGAR that we would like to highlight for you, which are also found on the
Grants Finance website are pertinent to your 20% initial payment (http://www.oms.nysed.gov/cafe/guidance/guidelines.html#forms), cash management procedures (http://www.oms.nysed.gov/cafe/guidance/payments.html), and interest (http://www.oms.nysed.gov/cafe/guidance/interest.html).
Grants Finance provides the following information:
- For those grant programs that permit payment on anticipated expenditures, payments are allowed only when a local agency can demonstrate willingness and ability to maintain appropriate procedures that minimize the time between receipt and disbursement of the funds.
- Local agencies may only request as much cash as is necessary to meet the immediate needs of a grant project and must minimize the time between receipt of the funds and disbursing them for grant activities.
- For those grant programs that permit payment on anticipated expenditures, payments are allowed only when a local agency can demonstrate willingness and ability to maintain appropriate procedures that minimize the time between the receipt and the disbursement of grant funds. To meet that requirement, local agencies are strongly urged to:
- coordinate the timing of cash requests closely with internal approvals for payment, so that cash received from SED does not stay in a bank account for an extended period of time;
- pay out grant funds for project activities as soon as possible after receiving cash from SED;
- plan carefully for cash flow during the budget period and review project cash requirements before each drawdown; and
- monitor cash receipts and payments regularly
- Part 80 of EDGAR establishes uniform administrative requirements for State and local governments including school districts. Section 80.21(i) states …[G]rantees and subgrantees shall promptly, but at least quarterly, remit interest earned on advances to the Federal agency. The grantee or subgrantee may keep interest amounts up to $100 per year for administrative expenses.
- Part 74 of EDGAR establishes the uniform administrative requirements for institutions of higher education, hospitals and other non-profit organizations. The requirements in Section 74.22(l) are similar to those in Part 80, with the provision that these agencies may retain up to $250 per year for administrative expenses.
Interest exceeding the $100 or $250 allowable for administrative expenses must be returned to the federal government. It cannot be retained to offset any direct or indirect program costs. State and local governments, including school districts, must return any interest owed to the U.S. Department of Education, P.O. Box 979053, St. Louis, Missouri 63197-9000. Institutions of higher education, hospitals and other non-profit organizations must remit to the U.S. Department of Health and Human Services, P.O. Box 6120, Suite 1133, Rockville, Maryland 20852. Any remittance should be accompanied by a letter stating that it is for "interest earned on federal funds" and include the agency's DUNS number. A copy of the letter should also be sent to Grants Finance.