Policies and Procedures

Under the Uniform

Guidance

Maribel Langas MillerDirector, Division of Policy and Oversight

Office of Grants and Financial Management

National Institute of Food and Agriculture

Department of Agriculture

PerspectiveAlaska Local Government/School District, Kodiak

Alaska Regional Office, Department of the Interior (DOI) Bureau, U.S. Fish and Wildlife Service (FWS)

DC Headquarters Office, FWS

DC Departmental Office, DOI

White House, Executive Office of the President, OMB

Free Training for Federal Employees and Grantees

National Institute of Food and Agriculture and Our Partners

Enterprise Risk

Strategic

Decisions

(OMB A-11)

Budget Decisions

(OMB A-11)

Program Management

(OMB A-11)

Operational Control Objectives

Reporting Control Objectives

Compliance Control

Objectives

Agency Priority Goals

Cross Agency Priority

Goals

Strategic Review

Policy

President’s Budget

Congressional

Justification

Mission/Vision

Goals/Objectives

Strategic Reviews

CXO/Operations Support

(OMB A-123)

Risks and Uncertainty

Strategic

Operational

Reputational

Financial

Etc.

USDA’s Annual Financial Reporthttps://www.usda.gov/sites/default/files/documents/usda-fy17-agency-financial-report.pdf

…to inform Congress, the President, and the American people how

USDA has used Federal resources entrusted to the Department in

FY 2017. USDA strives to do the following: remove obstacles in

order to give farmers, ranchers, foresters, and producers every

opportunity to prosper; prioritize customer service every day for

American taxpayers and consumers; ensure that the food we put

on the table to feed our families meets the strict safety standards

we have established; and be good stewards of the land to leave it

better than we found it. USDA has demonstrated good stewardship

of taxpayer resources by putting in place well-controlled and well-

managed business lines and financial management systems and

processes.

The President’s Management Agenda

The President’s Budget

Data

Data

Data

Data

The Pyramid of Grant Requirements

Suspension

Debarment Drug Free

Workplace

Lobbying

NIFA Policy

Guide; other

guidance

RFAs

Davis

Bacon Act

Terms and

Conditions

Program

Regulations

OMB Uniform

Guidance

Program Statutes

& Appropriations

Agency & Programs

Government Wide

Authorizations and Appropriations

Government Wide

13

2 CFR 200.400

Policy Guide for Cost Principles

“Sound Management Practices”

2 CFR 200.303

Internal Controls Requirement

2 CFR 200.61

Definition - Internal controls

2 CFR 200.62

Definition - Internal Control over

Compliance Requirements

Uniform

Guidance

2 CFR 200 Internal Control Emphasis

2 CFR 200.400, Subpart E, Cost

Principles, Policy Guide

Non-Federal entity is responsible for efficient

and effective administration of award through

use of sound management practices, and

administering Federal funds in compliance

with agreements, program objectives, and the

terms and conditions of Federal award.

Identify all Federal

receipts and

expenditures

Accurate, current, and

complete disclosure

Effective control over

and accountability for

assets

Comparison of

expenditures to budgets

Written procedures

for payments

Records that identify

source and application

of funds

Written procedures

for allowable costs

2 CFR 200.302, Financial System Standards

Have effective

internal controls

over Federal

awards that provide

reasonable

assurance of

compliance

Comply with

Federal

statutes,

regulations,

and grant terms

and conditions

Evaluate and

monitor

compliance

Take prompt

action when

instances of

noncompliance

are identified

Safeguard

protected

personally

identifiable

information (PII)

and other sensitive

data.

2 CFR 200.303 Internal controls

Establishing Policies &

Procedures

Sound management

practices

Effective Controls

Requirements for Written Policies

and Procedures

Payments 200.302 (b)(6), and 305

Procurement 200.318

Competition 200.319

Method for evaluation and selection

200.320

Allowable costs 200.302 (b)(7)

Compensation 200.430

Fringe Benefits 200.431

Employee relocation costs 200.464

Travel costs 200.474

• Put these into clearly

written policies and

procedures

• All relevant parties

should have copies

Required written policies and procedures:

• Accounting System

• Budget Controls and Modifications

• Chart of Accounts

• Receivables

• Payables

• Approvals

• Documentation

• Audits and Resolution

• Small Purchase Process – Credit Card, Petty Cash

• Drawdowns and Cash Management

Recommended Policies and Procedures

• Bank Reconciliation

• Program Income

• Interest Income

• Human Resources – hiring and selection

• Compensation and Fringe Benefits

• Complaints/Grievances

• Cost Policies - Allowable Costs, Indirect Costs

• Staff Travel

• Participant/Program Services

• Purchasing

• Procurement

Recommended Policies and Procedures

• Monitoring

• Incident Reporting

• Property/Equipment Management

• Record Retention

• Match and Leveraged Resources

• Reporting (Financial and Performance)

• Internal Controls, Segregation of Duties

• Policies and Procedures for the Board

Recommended Policies and Procedures

Evaluate risk of

non-compliance

CFDA Number and

dollar amount of each

Include FAIN and

DUNS numbers

Specify required

information for

each award

Ensure subawards

appropriately identified

Verify audit coverage

Monitor subaward activities

Honor ICRs or de minimis

rate

Subrecipient Monitoring &Oversight

24

• With rules and regulationsCompliant

• Precise, easy to understand, unambiguousClear

• Addresses the process flow; appropriate level of detail; does not leave major unanswered questions

Complete

• Regular review, modify if neededCurrent

Effective Policies and Procedures

The Goal