USDOE SETS STRICT RULES FOR FEDERAL FUND RELEASE TO GDOE
The Guam Department of Education has received the USDOE’s amended special conditions letter, which identifies Superintendent Dr. Nerissa Underwood and GDOE internal auditor Lester Kuykendall as the point of contacts who will provide assurances to federal agency that the conditions for drawing down funds are complied with.
Under this condition, Underwood and Kuykendall will have to demonstrate to USDOE that the monies drawn down meet each grant management plan’s objectives and activities.
Except for stimulus funds, all other grants awarded on or after Nov. 25 must be cleared for release by the third party agent before GDOE can draw down funds.
For grants awarded before the Nov. 25 letter, GDOE may draw down funds before the third party agent is in place provided that Underwood and Kuykendall submit a written assurance that the internal auditor will have additional oversight on over the grants and provide USDOE with monthly reports regarding the obligation and liquidation of those funds.
A component of the 2008 consolidated grant can be used to cover shortfalls provided that it is approved by USDOE and that GDOE include it in its FY2009 consolidated grant application and a detailed description of how it will be used.
The amended special conditions letter that the Guam Department of Education received yesterday from USDOE covers all grants that will be awarded to GDOE as well as formula grants awarded under the American Recovery and Reinvestment Act and funds received by Gov. Felix Camacho from the State Fiscal Stabilization Fund which totals to approximately $117 million.
Guam stands to receive $12 in stimulus funds and $60 million from the state fiscal stabilization fund. Additionally, $25 million in consolidated Title V grants, $15 million in special education grants and $4 to $5 million in discretionary grants are expected to come to GDOE.
The amended special conditions also applies to all grant funds previously awarded to GDOE that are still available for obligation or liquidation.
The letter also stated that if GDOE used local funds for the costs of any USDOE grant programs before the time it was authorized to draw down 2009 grant funds, the third party agent can seek allowable pre-award costs on GDOE’s behalf.
The amended conditions also require GDOE to revise its comprehensive action plan and must provide to USDOE a quarterly report on its progress in implementing the measures under the plan.
By Dec. 15, GDOE must also provide USDOE a detailed description of the standard operating procedures and other information concerning GDOE’s procurement procedures since it turned over its procurement operations to the Guam General Services Agency.
“This description should also include the process for ensuring that supporting documentation is being maintained for all contracts and purchase orders paid with federal funds,” stated the letter.
USDOE also wants new written assurance from GDOE that improvements in internal controls are reinforced by leadership and management within the organization, including Underwood’s management team and in accordance with the Guam Attorney General’s Sept. 24, 2008 legal opinion which states that the superintendent is ultimately responsible for all federal grants.
MVar 11/27/09
Posted: November 27th, 2009 under American Recovery and Reinvestment Act, Federal Agency Announcments, Grant Financial and Performance Reporting, Grant/Program Audit.
Comments: none
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