In carrying out its responsibilities, OGA:
- Coordinates and supports consistent, quality management of formula and discretionary grants and cooperative agreements Department-wide. Develops and directs the Department's implementation of requirements for grants in OMB Circular A-123, Internal Control Systems; Provides Department-wide oversight of compliance with grants policies and procedures.
- Develops and conducts Department-wide grant management training.
- Develops and implements Departmental policies related to external audit follow-up, and oversees the Department's external audit resolution operations.
- Resolves and closes discretionary grant audits and various formula grant audits for the Department.
- Develops and implements indirect cost policy, and negotiates indirect cost rates on behalf of the Federal Government for all State Education Agencies and other entities in which the Department holds a predominate financial interest.
- Grants Administration, Controls, and Training Group
- Indirect Cost Group
- Audit Resolution and Risk Treatment Group; and
- Risk Engagement and Assistance Coordination Team (REACT)
- Internal Controls Division
Grants Administration, Controls, and Training Group (GACTG)The Grants Administration and Internal Control Group (GACTG) is responsible for promoting Department-wide consistency and effectiveness of grant oversight and accountability. GACTG manages, coordinates and improves grant policy for discretionary and formula grants. GACTG also leads grant administration and management internal control reviews to assess grant policy implementation, operational risks, and performance analyses. To carry-out its responsibilities, GACTG has three teams:
Grants Administration Team (GAT)
- Establishes Department-wide policy designed to support consistent and effective grant oversight and accountability.
- Develops and improves grant policy for discretionary and formula grants. Implements cross-cutting grants administration and management policy.
- Solicits and provides direction from the Program Office Senior Leadership Orchestrates the Department-wide Grants Policy Forum.
- Serves as Grant Policy Liaisons to the Department’s Principal Offices.
Grants Procedures and Controls Team (GPCT)
- Issues discretionary grant licenses and formula award obligation authority Administers GrantsMAT
- Issues non-procurement debarment and suspension notices
- Manages Late Liquidation requests
- Implements Gone Act Requirements
- Uses risk assessment tools identifies and presents elevated areas of risk to be tested during an A-123 internal controls review of the grants process
- Assesses internal control procedures and systems used by grant making POCs
- Provides technical assistance to the grant making POCs on developing and maintaining a strong internal control program
Grants Training and Capacity Building (GTCB)
- Assesses the needs for capacity building and topics of need through the analysis of available data e.g. audit and monitoring findings, solicitation from Program Offices, grantee surveys
- Develops curriculum plans and training materials on Department-wide grant management training; training includes but is not limited to the following areas: grant policy, general grants management, internal controls, audit resolution and closure, financial management and monitoring, and indirect costs.
- Maximizes on technology to deliver training, materials, and tools available to more customers
Indirect Cost GroupThe Indirect Cost Group (ICG) is responsible for developing, implementing and managing the Department’s indirect cost policy in accordance with OMB Circulars A-87, Costs Principles for State, Local, and Indian Tribal Governments, and A-122, Cost Principles for Non-Profit Organizations. In carrying out its responsibilities, ICG:
- Negotiates and establishes indirect cost rates on behalf of the Federal Government for all State Education Agencies, and negotiates and establishes indirect cost rates for other State agencies where the Department holds a predominant financial interest.
- Negotiates and establishes indirect cost rates on behalf of the Federal Government for Institutions of Higher Education, nonprofits, and commercial firms where the Department holds a predominant financial interest.
- Negotiates and settles liabilities resulting from excessive indirect cost reimbursement, resolves and closes audits on indirect cost issues, and administers any related appeals.
- Provides technical advice to external and internal customers on cost allocation issues under grants and contracts.
- Serves as the Department's liaison with OMB on fulfilling the cognizant agency responsibilities for cost policy and oversight.
- Oversees the program where States may receive delegations of authority to administer indirect cost oversight for their Local Education Agencies.
- Develops and implements indirect cost policy.
Audit Resolution GroupThe Audit Resolution Group (ARG) is responsible for policy development, implementation and oversight for the Department's response to the Inspector General Act of 1988 (P.L. 100-504) and OMB Circulars A-50, Audit Follow-up; Single Audits of States, Local Governments, and Non-Profit Organizations. As such, ARG has overall responsibility for the external audit follow-up function at the Department. ARG resolves and closes grantee Single Audit findings of the Department's discretionary grant programs, as well as various formula grant audit findings, in accordance with OMB Uniform Guidance requirements. In addition, ARG provides oversight, technical assistance, and high-risk grantee assessment and support to the Department’s program offices. In carrying out its responsibilities, the Audit Resolution Team (ART) supports the ARG as follows:
Audit Resolution Team (ART)
- Oversees external audit follow-up for the Department.
- Resolves and closes discretionary grant findings in single audits and OIG external audit reports, as well as formula grant findings that deal with cash management and sub-recipient monitoring.
- Identifies the Department's grantees that failed to submit a single audit to the Federal Audit Clearinghouse (FAC) and notifies program offices.
- Works with the FAC to process and assign audit findings received on a weekly basis; Overall management of the Department's interagency agreement with the FAC.
- Conducts internal reviews and reports on program office closure of single audits and ED-OIG external audits.
- Oversees revisions to the Handbook for the Post Audit Process.
- Annually coordinates and updates the Department's compliance supplement submission to OMB, which serves as a guide for auditors reviewing Department grants.
- Serves as the central point in the Department for information regarding external audit follow-up.
- Analyzes audit data and provides results to ED program offices to inform work around program risk, audit finding trends, priorities and strategies for effective grant management responsibilities.
Internal Controls DivisionThe Internal Controls Division is responsible for providing assurance that the Department is in compliance with numerous legislative and regulatory requirements that promote and support the effective grants management and control. The staff focuses on providing leadership in conducting grants internal control reviews, risk assessments, monitoring, performance analysis, and internal controls training.
In performing its responsibilities, the Staff:
- Resolves discretionary grant audits and various formula grant audits for the Department.
- Designs and implements internal grants audit initiatives to reduce risks in the Department's lines of business.
- Develops and directs the Department's implementation of the requirements for the Improper Payments Act of 2002; provides assistance to Principal Offices by reviewing and identifying grant programs and activities that may be susceptible to significant improper payments, developing estimates of improper payments, conducting data analyses to support efforts to reduce improper payments, and developing and monitoring the timely completion of corrective actions.
Risk Engagement and Assistance Coordination Team (REACT)
Works with program offices to identify risk strategies and treatments to inform grant awards and monitoring plans
- Applies criteria and rubrics to drive the investment of resources around high risk grantees to support targeted efforts that lead to demonstrable outcomes.
- Provides technical support to the Department’s program offices with customized pre-monitoring risk analysis.
- Participates, at the request of program offices, on grantee site visits to provide risk assessment support (i.e. “root causes”).
- Conducts risk briefings on selected states and districts to provide program offices with risk assessment (i.e. overall fiscal status and climate, potential and emerging audit issues, and other related information.)
- Leads coordination of Departmental systemic, long-term audit finding resolution and closure efforts.
- Supports program offices in the development of risk profiles