Program Instructions Nevada

PROGRAM INSTRUCTIONS – NEVADA

PINs

Revised and Adopted February 28, 2008

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PIN #	CURRENT PIN DATE	SUBJECT
1	10/1/00	Program Instructions
2	10/1/00 REV 8/28/07	Grantor Authority
3	10/1/00 REV 8/28/07	Grantee (Sponsor) Responsibilities
4	10/1/00 REV 2/15/07	Retention and Disposal of Project Documents
5	10/1/00 REV 8/28/07	Probationary Status
6	10/1/00 REV 8/28/07	Cost Sharing or Matching Requirements for Title III and Allowable Match
8	10/1/00 REV 8/28/07	Insurance Coverage
9	10/1/00 REV 10/1/03	Conflict of Interest and Nepotism
10	10/1/00 REV 8/28/07	Eligibility for Service Under the Older Americans Act
11	10/1/00 REV 8/28/07	Procedure for Collecting Program Income
12	10/1/00 REV 10/1/03	Collection of Donations and Fees at Nutrition Sites
14	10/1/00 REV 8/28/07	Use of Program Income
15	10/1/00 REV 8/28/07	Budget Transfers Between Title III-C1, III-C2 and III-B Grants
16	10/1/00 REV 8/28/07	Budget Transfers Between Budget Categories and Within the Same Entitlement for Categorical Grants
17	10/1/00	Leave Accrual for Categorical Grants
19	10/1/00 REV 8/28/07	Compliance with Single Audit Requirements
20	10/1/00 REV 8/28/07	Procedures for Fiscal Monitoring and Administrative Review
21	10/1/00 REV 8/28/07	Title/Usage of Equipment Purchased with Grant Funds
22	10/1/00 REV 8/28/07	Interest Bearing Checking Accounts
23	10/1/00	Food Inventories for Nutrition Programs
24	10/1/00 REV 8/28/07	Purchase of Equipment
25	10/1/00	Petty Cash
26	10/1/00 REV 1/15/04	Federal Cash on Hand
27	10/1/00	Overtime/Compensatory Time
28	10/1/00 REV 8/28/07	Allowability and Allocability of Costs to Division Grant Funds
29	10/1/00 REV 8/28/07	Internal and Accounting Controls for Recording Meal Counts and Fixed Fee Units of Service
30	10/1/00 REV 4/24/06	Sliding Fee Scale
31	10/1/03 REV 4/24/06	Travel Policies and Procedures
32	10/1/03 REV 2/15/07	Administrative Costs
33	10/1/03 REV 10/1/03	Change of Address and Key Personnel
34	5/25/07	Training Grants
35	11/26/07	Protection of Client Information
Appendix 1	10/1/03 REV 1/15/04	Appendix 1. General Principles for Determining Allowable Costs
Appendix 2	101/03	Appendix 2. Risk Assessment Criteria
Appendix 3	8/28/07 REV 2/28/08	Appendix 3. Cost Sharing

The Administrator of the Division for Aging Services (Division) reserves the right to issue program directives to grantees that receive funds from the Division. These program directives will be issued as Program Instructions-Nevada (PINs). Program Instructions-Nevada will be utilized by grantees in complying with the terms of the Notification of Grant Award.

Non-compliance of the PINs may cause the grantee to be terminated from receiving funds from the Division.

AUTHORIZED:

Carol Sala, Administrator Revised: 10/1/03
Revised: 8/28/07

Division for Aging Services PIN - 1
June 30, 1992
October 1, 2000

PROGRAM INSTRUCTIONS

The Administrator of the Division will issue program instructions, relative to financial management requirements, to grantees that receive funding from the Division. These program instructions are identified by the term PIN (Program Instruction-Nevada), followed by a consecutive number as they are issued. Program instructions may be modified at any time.

Programs who do not follow the requirements outlined in the PINs will jeopardize their receipt of funding through the Division.

Division for Aging Services PIN - 2
June 30, 1992
October 1, 2000
August 28, 2007

GRANTOR AUTHORITY

PROGRAM INSTRUCTION: This instruction conveys the role of the Division as grantor. The grantor cannot be limited in its rights by the grantee, as grantor rules and regulations will supersede grantee policies and procedures. If the grantee receives Title III Federal funds, then the Division, Assistant Secretary of the Administration on Aging, the Inspector General, the Comptroller General of the United States, or any of their duly authorized representatives have the right of timely and unrestricted access to any books, documents, papers, or other records of the sub-recipient that are pertinent to the award, in order to conduct audits, examinations, excerpts, transcripts and copies of such documents. Any entity that is not an agency of the State of Nevada, must allow the State Legislative Commission Auditor the same rights. For other Federal fund awards, the Division, the Inspector General, the Comptroller General of the United States has that right. Any non-state agency of the State of Nevada must also allow the State Legislative Commission Auditor access. For all other awards, the Division’s ability to evaluate the grant will not be denied or hindered. And for any non-state agency, the State Legislative Commission Auditor will have the ability to evaluate the grants. This includes access to any document or record that is pertinent to administering the program. This also includes the right to interview participants/clients, grantee personnel and program staff, in accordance with confidentiality regulations. When federal funds are disbursed to grantees, they must adhere and comply with the Federal Administrative Regulations of the Office of Management and Budget (OMB) Circulars. The applicability of administrative requirements varies by recipient, as listed below:
State and Local Governments	OMB Circular A-102 Uniform Administrative Requirements, 2 CFR Part 220 (OMB Circular A-87 Cost Principles), OMB Circular A-133 Audits
Non-Profits and Higher Institutions	OMB Circular A-110 Uniform Administrative Requirements, 2 CFR Part 230 (OMB Circular A-122 Cost Principles), OMB Circular A-133
Education Institutions	OMB Circular A-110 Uniform Administrative Requirements, 2 CFR Part 220(OMB Circular A-21 Cost Principles, OMB Circular A-133 Audits
For-Profit Organizations	48 CFR Part 31
Grantees are dependent upon technology to assist in managing programs and perform financial capability.

Division for Aging Services PIN - 3
June 30, 1992
October 1, 2000
August 28, 2007

GRANTEE (SPONSOR) RESPONSIBILITIES

PROGRAM INSTRUCTION:

1. It is the grantee’s responsibility to ensure that federal or state funds are spent according to federal/ state requirements, including any sub-granted funds. Full responsibility for the overall program includes: fiscal administration, submission of required reports, program and personnel management, and meeting the goals and objectives in the approved grant application. The grantee cannot relinquish responsibility by having a board or representative act on its behalf.

The grantee shall maintain effective internal control and accountability for all grant funds and assets. Good internal control necessitates that fiscal responsibilities are clearly established. Accounting functions should be separated to the fullest extent possible, so that no one person authorizes, executes, and approves the same transaction.

Grants funded by the Division are for a specific grant award period and can only be used to pay obligations incurred during that time period. A grant may be extended upon receipt of a written request from the grantee and written authorization to extend the grant from the Deputy Administrator. The request should be submitted to the assigned Resource Specialist who will process the request. All requests for grant extension must be made prior to the end of the original grant period. Requests received after the original grant period has ended may or may not be honored.

2. The grantee upon termination/cancellation of a grant is responsible for any grant money owed to the Division. Payment in question is due on-demand to the Division.

3. A grantee must set up a system for managing sub-award activities. If the grantee has multiple funding sources they are responsible for establishing an allocation system to provide separate accountability for each grant or entitlement.

4. The grantee must maintain continuing responsibility for the overall program. This includes the establishment of policies and procedures for program operations.

5. The development and maintenance of personnel policies that include hiring, firing, supervising and evaluating the Program Director and staff.

6. Being accountable for all program revenue, expenditures and accurate preparation and submission of all required reports in a timely manner.

7. Monitoring the program to assure grant compliance.

8. Administration of the program in accordance with service specifications and fiscal requirements established by the Division.

9. The grantee shall ensure that each service provided will:

Provide an opportunity for participants to voluntarily contribute to the cost of the service;
Clearly inform each recipient that there is no obligation to contribute and that the contribution is purely voluntary;
Protect the privacy and confidentiality of each recipient with respect to the recipient’s contribution or lack of contribution;
Establish appropriate procedures to safeguard and account for all contributions;
Use all collected contributions to expand the service for which the contributions were given.

Sub-awards cannot be awarded to any organization that has been suspended, debarred or deemed ineligible to participate in federal/state assistance programs. If the organization falls within these terms while receiving grant funding, the organization must notify the Division immediately about their status.

Division for Aging Services PIN - 4
June 30, 1992
October 1, 2000
February 15, 2007

RETENTION AND DISPOSAL OF PROJECT DOCUMENTS

PROGRAM INSTRUCTION:

Financial records, supporting documents, statistical records, and all records pertinent to the grant agreement must be retained for a period of three years from the final submission of the expenditure report. Where there is an outside audit involving unresolved audit findings, or under appeals or litigation must be held until the action is completed or the dispute resolved.

During the three-year period, or any extended period resulting from litigation, claims, or audits, all financial records, supporting documents, statistical records and all other pertinent records will be available for examination. The Administrator of the Division, the Assistant Secretary of the Administration on Aging, the Comptroller General of the United States, or any of their duly authorized representatives shall have access to those records.

A grantee cannot be required to retain program records for more than six years. The statute of limitation, 28 U.S.C. 2415 (b), provides that an action to recover money paid under a grant program must be brought within six years after the right of action accrues.

Division for Aging Services PIN - 5
June 30, 1992
October 1, 2000
August 28, 2007

PROBATIONARY STATUS

PROGRAM INSTRUCTION:

A grantee may be placed on probationary status for the following reasons:

1. Non-compliance with Federal or State rules and regulations.

2. Non-compliance with the Division’s Service Specifications.

3. Non-compliance with the Older Americans Act, as currently amended, if receiving OAA funds.

4. Inability or improper management of the program.

5. Non-compliance with the approved grant application terms and conditions.

6. Non-submission of required reporting or not submitting reports in a timely manner.

7. When there are significant findings by an independent auditor that affects the programs funded by the Division. The independent auditor has also classified the grantee as high-risk.

8. Non-compliance with OMB Circulars when appropriate.

9. If the Division has classified the grantee as a “high risk” and there has been no significant improvement to correct deficiencies.

When a grantee is placed on probationary status the grantee may not be eligible for any supplemental funding. Eligibility will be determined by reviewing the progress of complying with the approved corrective action plan. Depending on the reason for the “Probationary Status”, the grantee may not be allowed to receive any grant payments in advance but will be reimbursed on an actual cost basis. If the grantee receives Federal funding and their financial management system fails to produce accurate, current and complete disclosure of the financial results of each Federally funded grant in accordance with the reporting requirements set forth in 2 CFR 215, as applicable, then the grantee is prohibited from receiving advanced funding.

The Administrator of the Division will determine the length and terms of the probationary period and will provide the grantee written notification of this determination.

If the grantee remains out of compliance with the approved corrective action plan after the initial probationary period has expired, the grantee will be required to contract with an outside licensed CPA. The CPA will conduct an audit of the grantee’s financial affairs and compliance with applicable provisions of laws, regulations, contracts, grant agreements. In addition, the CPA will focus on non-compliance issues in dispute. This audit will be paid by the grantee. If the grantee fails to schedule the financial audit within three months after the original length of the probationary period, grant fund payments for all Division funded grants will be placed on hold until the audit has been scheduled. The results of the audit will help determine continued funding or suspension by the Division. If the grantee is suspended from receiving Division grant funding then the grantee is limited for three years in re-applying for Division funding.

Division for Aging Services PIN - 6
June 30, 1992
October 1, 2000
February 15, 2007
August 28, 2007

MATCHING REQUIREMENTS FOR TITLE III
AND ALLOWABLE MATCH

PROGRAM INSTRUCTION:

All Title III funded grantees are required to provide a minimum of 15% in matching funds unless match is specified as being waived by the Division. Match may be non-federal cash contributions or non-federal in-kind contributions.

In-kind will be defined as any property or services provided without charge by a third party to a second party. The State of Nevada is considered as the first party, the grantee or sub-grantee is the second party and the third party is everyone else. The Division will accept the following as in-kind match:

1. Donated building space at fair market value by anyone other than the sponsor. Programs housed in buildings originally acquired, constructed or substantially renovated with federal funds are not eligible to use building space as a donation.

2. Volunteer services whose value is based on rates ordinarily paid for similar work in the grantee’s organization or at the fair market of the service provided, if there is no paid staff that does similar work. The volunteers must maintain time sheets for donated time, subject to the same requirements as paid employees. Volunteer time will be allowable only when determined to be reasonably necessary to the operation of the specific program.

3. Utilities, supplies and insurance may be allowed as in-kind grantee incurred match when they are determined to be reasonably necessary to the operation of the specific program. The items will be valued at fair market value at the time of donation (i.e., supplies) or at actual cost (i.e., utilities and insurance).

4. Depreciation or use charges for building and/or equipment may be used as in-kind grantee incurred match when the building and/or equipment is required for activities designated in the grant. A depreciation schedule or use allowance methodology must be provided. Depreciation or use charges must comply with OMB Circular A-122, attachment “B” sub-section 9 for non-profit grantees and OMB A-87 B.11.b for governmental grantees.

5. The value of all match must be documented, such as: appraisals, time studies, invoices, etc., which specifies the method used for arriving at the value. All match must directly benefit the program for which the federal funds are granted. Donated items become the property of the program for which it is provided.

6. In most cases, federal funds cannot be used to match other federally funded projects. Nevada Department of Transportation does allow federal funds to match their Section 10 and Section 11 programs. Independent living grant funds can also be used to match federal funds.

Division for Aging Services PIN - 8
June 30, 1992
October 1, 2000
August 28, 2007

INSURANCE COVERAGE

PROGRAM INSTRUCTION:

1. All program sponsors are required to provide fire and liability insurance to cover all capital assets in programs funded by the Division, including vehicles.

2. The grantee must have bonding insurance that can be purchased with the program’s regular insurance policy. The insurance should cover all employees who handle or have any access to cash, program checking accounts, making deposits or any other accounting function.

Division for Aging Services PIN - 9
June 30, 1992
October 1, 2000

CONFLICT OF INTEREST AND NEPOTISM

PROGRAM INSTRUCTION:

1. Paid program personnel and their immediate family shall not be a member of the grantee’s governing board. Immedia

TABLE OF CONTENTS

PROGRAM INSTRUCTIONS

GRANTOR AUTHORITY