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Frequently Asked Questions

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  1. What are the Federal Laws and Regulations on cash management?
  2. What are CMIA requirements?
  3. What are the Education Department General Administration Regulations (EDGAR) requirements?
  4. Who is responsible for Cash Management?
  5. Who is responsible for monitoring cash drawdowns to ensure compliance with cash management policies?
  6. How soon may I draw down funds from the G5 grants management system (G5 replaced E-Payments in December 2007)?
  7. How may I use Federal funds?
  8. What types of changes require prior approval?
  9. What if I used Federal funds for other than the specific purpose for which it was given?
  10. What are the consequences to recipients/sub-recipients for not complying with terms of the grant award?
  11. Am I able to extend my budget period for my project?
  12. What do I need to let DOED know about Personnel Change?
  13. What happens if I have a scope change?
  14. What are the reporting requirements?
  15. Where can I get more information regarding FERPA?
  16. Where can I get information regarding PPRA?

1. What are the Federal Laws and Regulations on cash management?

The Cash Management Improvement Act of 1990 (CMIA) is the overriding public law for cash management. It was enacted by Public Law 101-453, 31 U.S.C. 3335 and 6503. The implementing regulations are in Title 31 of the Code of Federal Regulations (CFR), Part 205, http://www.fms.treas.gov/fedreg/31cfr205final.pdf. In addition, the Education Department General Administrative Regulations (EDGAR) defines the CFR specific to administering the U.S. Department of Education’s (the Department’s) grants in 34 CFR, Part 74 and Part 80, http://www.access.gpo.gov/nara/cfr/waisidx_08/34cfrv1_08.html

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2. What are CMIA requirements?

States that draw funds under programs subject to the CMIA must draw funds as required under the Treasury-State Agreement (TSA) for the State. If a State draws funds under one of these programs to make payments to a sub-recipient, the payment request to the Department should only be made at the request of the sub-recipient, which must make draw requests to the State as required under the requirements in EDGAR.

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3. What are the Education Department General Administration Regulations (EDGAR) requirements?

Payments to States and other governments under programs not covered by the State's TSA and payments to other governments are subject to the requirements in Part 80 of EDGAR. These payment requirements also apply to all other types of recipients under Part 74 of EDGAR, which applies to nonprofit organizations, institutions of higher education, hospitals, and commercial organizations. States that draw funds on behalf of sub-recipients under programs not covered by a TSA should remind sub-recipients that they may only request funds from the State under the payment standards in Part 74 or Part 80, as applicable. The EDGAR is available on the Web at http://www.access.gpo.gov/nara/cfr/waisidx_08/34cfrv1_08.html.

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4. Who is responsible for Cash Management?

The Department's grant and cooperative agreement recipient(s) are charged with the administration of Federal funds. In addition, recipients are responsible for ensuring that sub-recipients are aware of cash management policies. For more information, see the recently issues Memorandum from the Chief Financial Officer on Cash Management which is posted on the ed.gov "ED Memoranda to Grantees" page at http://www2.ed.gov/policy/fund/guid/gposbul/gposbul.html

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5. Who is responsible for monitoring cash drawdowns to ensure compliance with cash management policies?

Recipients must monitor their cash drawdowns and their sub-recipients to assure substantial compliance to the standards of timing and amount of advances. Additionally, when considered necessary and feasible by the Federal agency, recipients may be required to report the amount of cash advances in excess of three days' needs in their hands and of their sub-recipients and to provide short narrative explanations of actions taken by the recipient to reduce the excess balances.

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6. How soon may I draw down funds from the G5 grants management system (G5 replaced E-Payments in December 2007)?

Grantees are required to minimize the amount of time between the drawdown and the use of funds from their bank accounts. (See EDGAR §74.21-22 and §80.20-21.) Funds must be drawn only to meet a grantee's immediate cash needs for each individual grant. Each time you use the G5 system to draw down a payment you check a box certifying that you are adhering to cash management requirements and that the funds will be spent within 3 days. The G5 screen displays the following message: I certify, by processing this payment request and/or re-allocation, that the funds are being expended within three business days of receipt for the purpose and condition of the agreement.

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7. How may I use Federal funds?

Federal funds must be used as specified in the application that the Department of Education has approved.

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8. What types of changes require prior approval?

A scope change, any revisions above 10 % of the total approved budget, hiring of new key personnel, and location changes.

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9. What if I used Federal funds for other than the specific purpose for which it was given?

This will be deemed a disallowed expenditure, and funds (including any earned interest) must be returned to the Department.

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10. What are the consequences to recipients/sub-recipients for not complying with terms of the grant award?

If a recipient or sub-recipient materially fails to comply with any term of an award, whether stated in a Federal statute or regulation, EDGAR, an assurance, a cooperative agreement, a TSA, an application, a notice of award, or elsewhere, the awarding agency may take one or more of the following actions:

(1) Temporarily withhold cash payments pending correction of the deficiency by the recipient or sub-recipient or more severe enforcement action by the awarding agency,
(2) Disallow (that is, deny both use of funds and matching credit for) all or part of the cost of the activity or action not in compliance,
(3) Wholly or partly suspend or terminate the current award for the recipient’s or sub-recipient's program,
(4) Withhold further awards for the program, or
(5) Take other remedies that may be legally available.

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11. Am I able to extend my budget period for my project?

Please contact your Program Officer. Budget periods are extended based on the need and nature of the project.

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12. What do I need to let DOED know about Personnel Change?

A resume must be given prior to the official hiring of the new recipient.

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13. What happens if I have a scope change?

You must let the Department of Education know prior to the change.

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14. What are the reporting requirements?

Fund for the Improvement of Education grantees are required to submit an annual report and final report in order to comply with EDGAR rules.

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15. Where can I get more information regarding FERPA?

http://www2.ed.gov/policy/gen/guid/fpco/index.html. School officials and grantees may also email FERPA@ed.gov for more questions.

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16. Where can I get information regarding PPRA?

You may email PPRA@ed.gov or view the PPRA website at http://www2.ed.gov/policy/gen/guid/fpco/index.html.

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Last Modified: 07/18/2011