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LOGIC

LOGIC: Logistics of Grants Internal Controls

LEAs (local educational agencies, which includes Independent School Districts and Open-Enrollment Charter Schools) must establish and maintain effective internal control over their federal grant awards. The internal controls should provide reasonable assurance that the LEA is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR §200.303
 

The purpose of the Education Service Center, Region 20 (ESC-20) LOGIC webpage is to provide resources to assist LEAs with certain internal control processes.

EDGAR: Education Department General Administrative Regulations

EDGAR contains cross-cutting grant management requirements that are applicable to the administration of all federal education grants. Uniform Guidance 2 CFR Part 200 (UGG) is part of EDGAR.
 
Uniform Guidance/EDGAR was revised, effective November 12, 2020 (with two specific regulations effective 8/13/20). The revisions are applicable to federal grants issued on or after the effective date of the revisions.
LEA's Administrative Procedures Manual (APM)/EDGAR Manual must be reviewed annually and updated as appropriate to incorporate revisions to federal, state, or local regulations, rules, or policy. 
 
Link to the most current version of the Uniform Guidance 2 CFR Part 200
 
Link to the Redlined Version that illustrates the revisions to the Uniform Guidance (scroll to the section regarding 2 CFR Part 200, beginning with page 87)
 
Link to the OMB* Frequently Asked Questions (May 3, 2021) regarding the Uniform Guidance revisions
 
Link to the OMB* Frequently Asked Questions regarding the Prohibition on Covered Telecommunications and Video Surveillance Services or Equipment (2 CFR 200.216)
 
Link to TEA's To the Administrator Addressed Letter dated April 22, 2021 regarding Changes to Federal Grant Regulations
 
Link to TEA's prerecorded statewide training presentation on UGG/EDGAR Revisions (April 2, 2021)
 
Link to TEA's presentation slides (pdf) of statewide training presentation on UGG/EDGAR Revisions
 
*OMB = Office of Management and Budget
EDGAR Express contains brief summaries of various EDGAR topics. These summaries have been updated as appropriate to reflect the November 2020 revisions to the Uniform Guidance that might be applicable to the specific topic.
 
If your specific grant program is more restrictive than EDGAR, you must follow the most restrictive.
 

If state rules or local policies are more restrictive than EDGAR or the specific grant's regulations, you must follow the most restrictive.

Please note: These TEA Documentation Checklists were created prior to the 2020 Uniform Guidance revisions, so some of the citations may differ from current citations.

CALENDARS

You are encouraged to subscribe to TEA's Updates listserv for topic-specific subscriptions in order to be informed of various due dates and deadlines.
 
Additional TEA resources:
 
Please view TEA's Coronavirus (COVID-19) Support and Guidance webpage for the most up-to-date information and resources applicable to the coronavirus pandemic.
 
TEA posts Agency Calendars on it's "About TEA" webpage.
 
A State Funding Calendar is posted under "District & Charter Planning Tools" on TEA's State Funding webpage. 
 

INTERNAL CONTROL RESOURCES

The Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides frameworks and guidance on enterprise risk management, internal control and fraud deterrence.

2 CFR §200.303(a) includes COSO's "Internal Control Integrated Framework" as a suggested resource for internal control guidance.

Access the COSO "Guidance on Internal Control" webpage.

The U.S. Government Accountability Office (GAO) sets the standards for an effective internal control system for federal agencies in the Standards for Internal Control in the Federal Government, known as the "Green Book." 

The Green Book may also be adopted by state, local, and quasi-governmental entities as a framework for an internal control system.

2 CFR §200.303(a) includes GAO's "Standards for Internal Control in the Federal Government" as a suggested resource for internal control guidance.

Access the GAO "The Green Book" webpage.

The United States Department of Education (USDE) developed an Internal Controls Tool Kit that includes:

  • Use of Funds Guidance
  • Self-Assessment Checklists
  • Procurement Examples
  • Internal Control Glossary

 

Access the USDE "Internal Controls" webpage. 

SCHOOL FINANCE CODES

ESC-20 produced a booklet titled "An Administrators Guide to School Finance Codes".
 
The booklet provides an overview of TEA's requirements for the school finance accounting code structure and lists frequently used accounting codes for fund, function, class object, organization, and program intent codes.
 
Access the ESC-20 eStore for purchase information.

TIME AND EFFORT (TIME DISTRIBUTION) RECORDS - FEDERAL REQUIREMENT

Time Distribution Records are applicable to any employee paid in full or in part with federal funds.

Compensation charges to federal awards must be reasonable, accurate, allowable, and properly allocated.

Federal regulations require time distribution documentation to ensure that charges to each federal program reflect an accurate account of the employee's time and effort devoted to that program.

2 CFR 200.430(i) 

LEAs must have adequate internal controls to ensure charges to the Federal awards are reasonable, accurate, allowable, and allocable. The Uniform Guidance 2 CFR Part 200 is less prescriptive regarding time distribution documentation than previous EDGAR (Education Department Regulations) requirements. 

As long as the LEA's internal controls and documentation meet the Standards for Documentation of Personnel Expenses illustrated in 2 CFR §200.430(i), the LEA has flexibility on how they comply with time distribution records.

Please review the Time and Effort information documents located under the "EDGAR Express Topics" heading in the "EDGAR" section of this webpage.

Best practice recommendations and sample forms created by ESC-20 are provided below.

The Documentation Decision Tree is a resource developed by ESC-20 to help you navigate the types of time distribution records recommended for employees working on a Single Cost Objective or Multiple Cost Objectives for their regular job duties, and recommended documentation for employees who receive additional pay outside their regular work hours and job duties. LEAs have flexibility in developing their own processes, provided their procedures comply with the Federal requirements. The Documentation Decision Tree provides best practice recommendations that an LEA may choose to adopt for their local policies and procedures.

The Employee Schedule and Certification form, applicable to certain employees working on Multiple Cost Objectives, is accessed on TEA's Substitute System of Time and Effort Reporting webpage. 

DISCLAIMER

Within the LOGIC webpage are resources developed, adapted, or acquired by ESC-20 from public websites and other public sources readily available in the public domain. No copyright is claimed for those materials.

ESC-20 and its affiliates and suppliers disclaim any representations or warranties that use of the LOGIC resources will satisfy or ensure compliance with any legal obligations or laws or regulations. The disclaimer applies to, but is not limited to, the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"), the Gramm-Leach-Bliley Act of 1999, the Sarbanes-Oxley Act of 2002, or other Federal or State statutes or regulations.

Use of the LOGIC resources are entirely at the LEA's risk and does not guarantee that the LEA will not have an audit finding or questioned costs.

To the maximum extent permitted by applicable law, ESC-20, its affiliates, and suppliers disclaim all warranties, expressed or implied, including any warranty that the LOGIC resources are fit for a particular purpose, title, merchantability, data loss, non-interference with or non-infringement of any intellectual property rights, or the accuracy, reliability, quality, or content in or linked to the LOGIC webpage.

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