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How to Stay Out How to Stay Out of of

[the Grant Officer’s [the Grant Officer’s Overview]Overview]

2009 New Grantee Conference - Chicago - May 15th2009 New Grantee Conference - Chicago - May 15th

TT..RR..OO..UU.. BB..LL..EE!!

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TThanks for being

our Grantee!

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What we expect from you…What we expect from you…

- Be responsible stewards of Federal funds.

- Use grant dollars for their intended purpose.

- Account for costs & justify expenditures.

- Report back to ETA

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- Design a program focused on customer needs

- Address those needs

- Meet the requirements of Federal law & regulation

What we expect from you…What we expect from you…

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- money

- guidance (rules & regulations)

- modification flexibility

- on-site technical assistance & monitoring

What you can expect from us…What you can expect from us…

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4 ways to get into

eally big trouble…

RR

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- Embezzlement

- Theft or Bribery

- False Statements or Claims

- Mail & Wire Fraud

Four Flavors of Fraud…Four Flavors of Fraud…

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- Grant recipients, company officers, business partners, board members & managers

- Bookkeepers, financial staff & other employees

- Contractors & subcontractors

- Consultants

Who Commits Grant Fraud…Who Commits Grant Fraud…

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- Charging personal expenses as business expenses

Common Grant Fraud Scenarios…Common Grant Fraud Scenarios…

- Charging costs which have not been incurred, e.g. labor costs for fictitious employees, contractors, or consultants

- Charging for inflated costs or hours

- Kickbacks or other abuses of Quid pro quo

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http://www.usdoj.gov/criminal/npftf/

http://www.contractormisconduct.org/

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OObligations you take on with your grant…

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- that WE will provide the funds

- that YOU will comply with Every-Part-of-the-Agreement

Any sub-award relationships are governed by OMB Circulars. You are responsible for all sub-award relationships.

The Grant Agreement certifies…The Grant Agreement certifies…

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The Salary Cap…The Salary Cap…

- Pub.L. 109-234

- Guidance in TEGL 5-06: http://wdr.doleta.gov/directives/attach/TEGL/TEGL05-06.pdf

- Limits salary & bonus payments to individuals

2009 Limit: http://www.opm.gov/oca/09tables/pdf/ex.pdf

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- Accounting, financial & cash management

- Procurement

- Property management

- Personnel management & payroll

- Audit functions

- General legal services

Administrative Costs are…Administrative Costs are…

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- Get a Federally-approved rate if…

- 90-day timeframe

- It’s not the same as Admin!

The Indirect Cost Rate Agreement…The Indirect Cost Rate Agreement…

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- How to establish a Direct Deposit Account: http://www.dpm.psc.gov/grant_recipient/new_grantee_information/nonhhs_1199a.aspx?

- How to access funds: http://www.dpm.psc.gov/

- How to access on-line electronic reporting:http://www.etareports.doleta.gov/CFDOCS/grantee_prod/reporting/index.cfm

Your Grant Award letter tells you…Your Grant Award letter tells you…

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with any change to the Eight P’s:

- Partner- Personnel- Place- Purpose- Performance- Period- Parts- Price

Request a modification…Request a modification…

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- Quarterly Narrative Program Report

- On-line Financial reporting - ETA 9130

- All reports due 45 days after quarter end

- YOU certify it

Reporting…Reporting…

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nallowable activities

prohi itions

imitations

UU

BB

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- Not grant-related

- Fundraising

- Alcohol

- Entertainment

- Bad debt

OMBOMB says it’s Unallowable… says it’s Unallowable…

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- Legal expenses for claims against the government

- Audit appeals

- Real property or Construction (except for ADA compliance)

WIAWIA says it’s Unallowable… says it’s Unallowable…

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- Charging fees for placement or training

- Public service employment

- Sectarian activities

WIAWIA says it’s Unallowable… says it’s Unallowable…

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WIA Section 181

- Business relocation

- Customized training which facilitates relocation

- Employment generating activities

- Economic development activities

Statutory Prohibitions…Statutory Prohibitions…

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WIA Section 181

- Revolving loan funds

- Capitalization of businesses

- Contract bidding resource centers

- Foreign travel

Statutory Prohibitions…Statutory Prohibitions…

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-0-% Limitations - Pre-award, legal, real property

The Four Cost Limitations…The Four Cost Limitations…

10-15% Limitations - Administrative costs

20% Limitations - Budget realignments

100% Limitations – Expend all your grant funds!

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EEverything will be OK!

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- Main point of contact

- Conduit for all formal Grantee-ETA communications

- Advises & assists on paperwork sufficiency

- Technical Assistance

- Oversight

Your “Friendly” Project Officer…Your “Friendly” Project Officer…

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… allegations of fraud can & should be made directly to DOL’s OIG - Office of Investigations, or a designated Telephone Hotline

…AND tell your FPO

ETA v. Office of the Inspector General…ETA v. Office of the Inspector General…

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U.S. Department of Labor National Call Center

[OIG Hotline]

866-4-USA-DOL866.487.2365

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- Are my costs necessary & reasonable?

- Does ETA get a proportional share of the costs & benefits received?

Ask Yourself…Ask Yourself…

What would a Prudent Person do?

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Tom Coyne312.596.5435

coyne.tom@dol.gov

Questions/Comments?Questions/Comments?