Fiscal Year 2025 �Grant Guidance��Fiscal Section

Content

Section 2: Fiscal Management

• Budget and Budget Amendment KB
• Use of Funds
• Allowable Purchases KB
• Rental Costs of Real Property KB
• Non-Allowable KB
• Equipment & Supply Purchases MP
• Compensation MP
• Time and Effort Reporting MP
• Procurement MP
• Subcontractors AM
• Conflict of Interest AM
• Transportation Costs for Students AM
• Internal Controls AM

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Section 2: Fiscal Management

2.A: Budget and Budget Amendments

• The proposed budget submitted in the application is NOT the approved budget. Subgrantees must submit a detailed line-item Budget Form 208 each year of the 3-year grant cycle.
• Expenditures in the Budget Form 208 must align with the grant details.
• A Budget Amendment Form 209 is required when there are adjustments to your previously approved budget.
• The 21^st CCLC grant funds are made available on a reimbursement basis only.
• NCDPI requires applicants to have its own working capital to operate the 21^st CCLC program for approximately a three-month period.
• If it is discovered a subgrantee has been advancing 21^st CCLC funds, the advanced funds will result in a questioned cost and funds must be repaid to NCDPI.
• Additionally, the advancement of funds may result in the termination of the subgrantee’s 21^st CCLC grant award.

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2.C.1 Allowable Purchases

• Personnel and personnel benefits
• Staff development and training
• Transportation costs for students
• Approved food purchases
• Renting space to the extent that the rates are reasonable (2 CFR 200.465)
• Property Insurance related to equipment and furniture
• Teacher Substitutes
• Travel reimbursements
• 21^st CCLC program equipment and supplies, including computers and software
• Memberships in community, technical and/or professional organizations if the membership is in the name of the 21st CCLC Program
• Memberships to warehouse clubs if the membership is in the name of the 21st CCLC Program

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(Not an all-inclusive list)

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2 CFR 200.403

2.C.1 Allowable Purchases

Other expenditures that are allowable with conditions include:

• Educationally related field trips with pre-approval from NCDPI
• Leases/Contracted Service agreements with pre-approval from NCDPI
• All technology expenses with a per unit cost of $5,000 or more requires pre-approval from NCDPI
• Student incentives are limited to school supply type items with no value greater than $25

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2 CFR 200.403

2.C.4 Rental Costs of Real Property

• Allowable to the extent that the rate is reasonable considering factors such as:
• Rental costs of comparable property
• Market conditions in the area
• Available alternatives
• Rental costs under "less-than-arm's length" leases are allowable up to the cost of ownership and to the extent that they are allocable to the 21st CCLC program
• Cost of ownership must be determined on the basis of actual cost and may include depreciation, maintenance, taxes, and/or insurance. 
• Subgrantees and/or individuals affiliated with a "less-than-arm's length" transaction must not profit from the transaction. 
• Rental of any property owned by an individual or entity affiliated with the subgrantee for purposes of a home office or workspace is unallowable. 

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2 CFR 200.465(c)

2.C.6 Non-Allowable Purchases

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• Purchase of vehicles
• Costs for developing the proposal and grant writing services
• Food purchases for staff
• Fundraising costs
• Land acquisition
• Capital improvement and renovation costs
• Cost of conducting an audit if total of all federal grants received is less than $750,000
• Direct cash or gift cards in any amount for students or their parents

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• Field trip tickets purchased in advance for those who do not attend
• Entertainment or any costs associated with entertainment including diversions and social activities
• Charitable contributions
• Bonuses of any kind
• District level expenses not directly related to the program
• Activities that take place during the regular school day
• Lobbying
• Interest rates on credit cards
• Late fees and service fees

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(Not an all-inclusive list)

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2.C.6 Non-Allowable Purchases

• If NCDPI determines any costs to be unallowable, subgrantees are subject to repayment, including interest, of such cost. 2 CFR 200.410

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2.D Equipment & Supply Purchases

• In general, larger equipment purchases budgeted for in the final year of the grant cycle will not be approved.
• To manage 21^st CCLC equipment, all subgrantee’s must maintain property records, such as an Inventory.
• Inventory Listing Template in CCIP

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NOTES

• Equipment purchased with 21st CCLC funds must be made available to other federally funded programs, when not in use by the 21st CCLC program.
• If a cost benefits two or more projects or activities in proportions that can be determined without made undue effort or cost, the cost must be allocated to the projects based on the proportional benefit.
• Furniture, equipment, and computer devices with a per cost unit less than $5,000 must be inventoried as indicated in COA 5350-110-461 and 5350-110-462.

2 CFR 200.313

2.E Compensation

The costs of compensation are allowable to the extent they are:

• rendered during the period of performance of the Federal award and are for activities contributing and directly related to the 21^st CCLC program
• reasonable for the services rendered.

Compensation will be considered reasonable:

• to the extent that it is comparable to that paid for similar work in the labor market for employees with similar background and/or experience.
• when personnel necessary qualifications to perform the duties required for the position

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NCDPI recommends reviewing the following resources when considering 21^st CCLC Compensation:

• North Carolina Public School Salary Schedules
• NC May 2023 OEWS State Occupational Employment and Wage Estimates (bls.gov)
• The Finance Project and Public/Private Ventures on The Cost of Quality Out-of-School-Time Programs
• Wallace Foundation Cost Calculator which provides information on the overall price per student slot for OST programming.�

2 CFR 200.430 (a)(1)

2.E.1 Time and Effort Reporting

Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:

• Be supported by a system that provides assurance that charges are accurate, allowable, properly allocated
• Be incorporated into the official records of the subgrantee
• Reasonably reflect the total activity for which the employee is compensated by the subgrantee, not exceeding 100%
• Encompass all activities
• All 100% of effort must be recorded, regardless of whether time is spent on federal or non-federal activities
• Comply with established accounting policies and procedures of the subgrantee
• Support the distribution among specific activities or cost objectives

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2.E.1 Time and Effort Reporting

When the subgrantee’s records do not meet the standards described above, NCDPI may require other auditable time and effort documentation for all compensation, paid in part or whole from the 21st CCLC grant. This may include, but not limited to personnel activity reports (PARS), including prescribed certifications. 

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2.F Procurement

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2 CFR 200.218 – 200.327

2.F.1 Subtractors

• Subgrantees may not contract with any party which is debarred, suspended, excluded from or ineligible for participation in federal programs
• All personnel, including contracted staff, who interact with children must have cleared a criminal background check prior to providing services. 
• All contracts must be uploaded in CCIP for review and approval by NCDPI prior to seeking reimbursement.

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2 CFR 200.213

2.F.1 Subtractors

Contract Requirements:

• Name of Vendor (address).
• Nature of the purchase or service.
• Time period of the contract (frequency and duration).
• Total contract amount as well as sufficient cost details to facilitate invoice review.
• Specific deliverables that must be rendered and accepted prior to making payment.
• Deliverables must be quantifiable and measurable.
• Sanctions for non-performance, including an exit clause.
• Printed names, signatures, and dates for both parties.

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2 CFR 200.213

2.G Conflict of Interest

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Subgrantees must have written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award, and administration of contracts.

• Subgrantees must disclose in writing any potential conflict of interest to NCDPI

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Conflict of interest would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract.

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North Carolina General Statute (G.S. 115C-12.2) defines "immediate family member" as a spouse, parent, child, brother, sister, grandparent, or grandchild. The term also includes the step, half, and in-law relationships. 

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2 CFR 200.318

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Examples of conflict of interest within the 21^st CCLC program include but are not limited to:

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• Board members receiving payment from 21^st CCLC Grant funds.
• Making a business decision involving a company in which a board director or program employee has a financial interest or would receive a financial benefit. 
• Hiring an unqualified relative or friend to provide services to the program.
• Reporting to a supervisor who is also a close friend or family member. 
• Contracting with immediate family members or program employees for services.

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2.G Conflict of Interest

2 CFR 200.318

2.H Transportation Costs for Students

Reimbursement of transportation costs must be based on total miles driven daily, recorded on detailed mileage log, and multiplied by an approved mileage rate.

Approved Mileage Rates:

• District Yellow School Bus
• Up to the highest district rate of $4.52 per mile
• This rate is inclusive of fuel, oil, tires, repairs and maintenance, driver wages and benefits
• Organization owned/leased vehicles transporting 16 or more passengers (CDL required)
• Up to the highest district rate of $1.58 per mile
• This rate is inclusive of fuel, oil, tires, repairs, and maintenance. 
• Organization owned/leased vehicles transporting 15 or less (CDL not required)
• Current IRS rate 67 cents/mile
• This rate is inclusive of fuel, oil, tires, repairs, and maintenance. 

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2.H Transportation Costs for Students

Flat-fee transportation contracts are allowed and will be reviewed on a case-by-case basis. The flat-fee transportation contracts will only be allowed if the “regularly invoiced” amount is equal to or less than the approved mileage rate per vehicle type.

To enter in a flat-fee transportation contract, subgrantees must be able to provide the following evidence:

• Documentation of lesser rate to be charged versus the appropriate mileage rate per vehicle type
• Total daily mileage bus route
• Proposed amount to be charged. (In writing from Vendor)

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NOTES

• 21^st CCLC funds cannot be used to purchase vehicles.
• Separate costs for vehicle maintenance cannot be charged to the 21^st CCLC grant.
• All contracts must be uploaded into CCIP for review and approval by the fiscal team prior to any contracts going into effect (i.e. vendor payment).
• Personal vehicles should not be used to transport students.

2.J Internal Controls

The financial management system of each non-Federal entity must provide for the following (2 CFR 200.302):

• Identification of the Federal award received and all associated expenditures.
• Effective control and accountability must be maintained for all grant cash, real and personal property, and other assets. The non-Federal entity must adequately safeguard all such property and must assure that it is used solely for authorized purposes and protected against loss from unauthorized use or disposition.
• Comparison of actual expenditures with budget amounts for each Federal award.
• Adequate documentation for all transactions which may include authorizations, cancelled checks, paid invoices, payroll journals, time and attendance records, contracts, etc.
• While not all internal controls are required to be addressed in writing, the entity must still adhere to these requirements, and addressing the topics in writing helps ensure that all staff will consistently follow procedures and may reduce the risk of monitoring or audit findings.
• Refer to Grant Guidance 2.J.1 Required Fiscal Written Procedures

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2 CFR 200.302