American Indian Tribally Controlled Colleges and Universities - Title III Part A Programs
- How is the TCCU program funded?
- What activities are allowable and unallowable in the TCCU program?
- What are the rules for drawing down funds?
- Are grantees allowed to make revisions in their budgets?
- What about carrying over funds from a previous fiscal year? Can this be done and, if so, do the funds have to be used solely for finishing activities from the previous budget period?
- What types of performance reports are required?
- What is the performance period of the grants and can it be extended?
- How can federal TCCU grant funds be spent on endowments?
- Is there a limit on the time for which an individual can work as project director or as another key staff member on grants?
- Can presidents of the tribal colleges/universities serve as project directors?
1. How is the TCCU program funded?
The Higher Education Opportunity Act (HEOA) of 2008, which reauthorized the Higher Education Act (HEA) of 1965, transformed the former competitive TCCU program into a largely formula-driven program. The revised law, however, stated that recipient institutions receive a minimum of $500,000. Also, at the behest of the Department of Education (ED or the Department), Congress has inserted language in all of the Department of Education’s annual appropriation bills (FY 2009, FY 2010, FY 2011) requiring that non-competing continuation (NCC) awards (in amounts not less than that originally authorized) be made to eligible grantees that had been selected by the previous competitive process. NCC funding for these older competitive grants is taken from their particular institutions' formula allotment. Their funding, however, may exceed what their institution is entitled to under the funding formula. The HEOA also gave the Department of Education the authority to reserve up to 30 percent of the annual appropriation for competitive one-year construction grants, an option the Department has not yet chosen.TOP
2. What activities are allowable and unallowable in the TCCU program?
Review the program regulations in 34 CFR 607.10 and 607.30 for guidance on which specific activities and costs are allowable. In general, grants focus on strengthening the institution in regard to academic activities. The operative word is institution as opposed to an individual student. One semi-exception is that TCCU grants can establish community outreach programs that encourage Indian elementary school and secondary school students to develop the academic skills and the interest to pursue postsecondary education. The major unallowable activities are:
- Recruiting students;
- Carrying out activities that are operational rather than developmental;
- Carrying out student activities such as entertainment, cultural or social enrichment programs, student publications, social clubs or associations;
- Paying for organized fundraising (However, you can strengthen the office dealing with fundraising and other forms of contributions.);
- Covering indirect costs;
- Paying salaries of the college President or other individuals with institution-wide authority.
3. What are the rules for drawing down funds?
One significant problem is that of insufficient drawdowns. Grantees must keep in mind that the Department regularly monitors cash drawdown activity for all grants. If funds are not being drawn down, ED officials will assume that the project does not need all of its funds and these can be reduced. Consequently, drawdowns should be made on at least a monthly basis. Furthermore, the project director should monitor the fiscal activity (drawdowns and payments) of the grant on a continuous basis to make sure that no erroneous actions take place (e.g., funds drawn down by another grant).
Moreover, one should draw down only as much cash as is necessary to meet the immediate needs of the grant project. It is essential to keep to a minimum the time between drawing down the funds and paying them out for grant activities. (See CFR 74.21-22 and 80.20-21.)TOP
4. Are grantees allowed to make revisions in their budgets?
Budgets can be revised and, in fact, the concept of formative evaluation assumes that budgets will be adjusted to deal with unexpected contingencies and produce the most effective projects possible. Budgets, in short, are not intended to be straight-jackets that prevent any changes in the grant. Proposed changes should be presented to the program officer to make sure that these do not involve unallowable activities and to keep the latter informed of grant activities. Also, new budgets are presented every fiscal year as new funding is provided. Grantees cannot develop these budgets until they learn the amount of funding that they will receive for the upcoming fiscal year.TOP
5. What about carrying over funds from a previous fiscal year? Can this be done and, if so, do the funds have to be used solely for finishing activities from the previous budget period?
Carrying over funds is permissible and does not require prior approval. Carryover funds can be used for any allowable cost. Any planned changes in the use of funds, however, should be brought to the attention of the program officer in order to determine the allowability of the new activities and to keep the latter informed of the activities of the project.TOP
6. What types of performance reports are required?
The TCCU program requires annual performance reports and an interim report that usually covers the first six months of the grant. The last annual report includes an executive summary that should cover the entirety of the grant, not simply the last year. Annual reports have been submitted electronically, while the interim report has been submitted by hard copy. Specific information on the performance report will be provided during the fiscal year in which it is due.TOP
7. What is the performance period of the grants and can it be extended?
The performance period for the current grants that are funded on a formula basis is five years, with one-year budget periods. No-cost extensions are allowed. A one-time extension of the project period for up to one year without prior approval is allowed as long as the following procedures are followed.
The grantee sends written notification of the planned extension to the program officer no later than 10 days before end of project period. The written request must provide the reason for the no-cost extension and the proposed new end date. No-cost extensions cannot be merely for the purpose of exhausting unexpended funds. An estimated budget should be provided. If a no-cost extension is granted, then a new Grant Award Notification (GAN) is generated and mailed to the project director and the certifying official.TOP
8. How can federal TCCU grant funds be spent on endowments?
Institutions may use up to 20 percent of the funds from an award period (e.g., FY 2011) for an endowment. The institution must match with one non-federal dollar for every dollar drawn down for the endowment. Federal funds can only be drawn down after a match takes place. For various reasons (especially the inability to meet the match), the institution can decide to use part of all of the funds intended for the endowment for other allowable grant purposes. It is essential to inform the program officer of the proposed change and the reasons for it.
During the grant period, the grantee may not withdraw or spend any of the corpus money put into the endowment. At the end the 20-year period, the institution may use the endowment corpus for any educational purpose.TOP
9. Is there a limit on the time for which an individual can work as project director or as another key staff member on grants?
If an individual is working on several grants, his or her total level of effort may not exceed 125 percent.TOP
10. Can presidents of the tribal colleges/universities serve as project directors?
This is permitted, but presidents or any other official with institution-wide authority cannot be paid by TCCU grant funds for this activity.TOP