OMB-200 Circular and Cost Principles for Financial Management

FINANCE DISCUSSION Presented by Karen Sell, Chief & Tabitha Johnson, Finance Manager Bureau of Nutrition and Physical Activity Health and Wellness for all Arizonans

What do you need to know about the OMB-200 Circular? Supersedes OMB Circulars A-21, A-50, A-87, A-89, A-102, A-110, A-112 A-122, A-133, and, CFR Sections 3015 through 3019. 200.110 Effective Date Agency implementation effective December 26, 2014. Apply to WIC and BFPC awards and award increments issued after October 1, 2015. Apply to audits for FFY 2016 beginning after September 30, 2016. Health and Wellness for all Arizonans

Cost Principles 200.412 Classification of Costs It is essential that each item of cost incurred for the same purpose be treated consistently in like circumstances either as a direct or an indirect (F&A). Transferring item of cost incurred originally as direct to indirect is not allowed. Health and Wellness for all Arizonans

Cost Principles 200.414 Indirect (F&A) Costs Must accept approved negotiated rates, except: Allowed by Federal statute or regulation, and Approved by agency head or delegate, OMB notified of deviations. 10% of MTDC de minimis IDC for non-profits only. First timers and new grantees who have never had an approved IDC or receive < $35 million in federal funds. One time four-year extension of current approved rate (final and pre-determined rates only) with approval. Health and Wellness for all Arizonans

Cost Principles 200.430 Compensation Personal Services Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Internal controls are KEY. Substitute systems are allowed (430 (i) (5)). Blended and braided funds allowed with Federal approval (430 (i) (7)). Use of institutional base salary for IHE. Health and Wellness for all Arizonans

Reasonable Costs In determining reasonableness of a given cost, consideration must be given to: Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. The restraints or requirements imposed by such factors as: sound business practices; arm's-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award. Market prices for comparable goods or services for the geographic area. We are all required to relate financial data to performance accomplishments and established goals. Approved WIC budget. Health and Wellness for all Arizonans

Reasonable Costs Examples Nutrition Education High risk nutrition counseling. Participant Certification/Case Management Anthropometric screenings (heights, weights) and blood work. Screening for other medical conditions which affect the participant s nutritional status and needs (no laboratory analysis). Health and Wellness for all Arizonans

Special WIC Financial Reporting WIC requires the reporting of expenditures by four functional areas that must be supported by financial documentation Four function areas are: Program Operations, Nutrition Services, Breastfeeding Education, and Client Services. Financial documents include: Timecards, Certification of Duty / Time Study, PARs, Annual Summary Reports, and CERs. Health and Wellness for all Arizonans

Are you paid by multiple programs or 100%? PERSONNEL ACTIVITY REPORT (PAR) OR 100% WIC FUNDED CERTIFICATE OF DUTY TIME REPORTING OR PERSONNEL ACTIVITY REPORT (PAR) MULTI-FUNDED Health and Wellness for all Arizonans

Time Reporting Requirements Must be prepared at least monthly AND coincide with one or more pay periods MULTI- FUNDED PAR Must be signed by both the employee and the supervisor Must include which functional area(s) their time was spent Health and Wellness for all Arizonans

Time Reporting Requirements 100% WIC CERTIFICATE OF DUTY PAR Employee must include the average percentage of time spent in each functional area Same requirements as what is listed on prior slide Must be completed semi-annually TIME STUDY Must be prepared a minimum of one week per month OR 1 month per quarter Must include how much time was spent in each functional area Health and Wellness for all Arizonans

Personnel Activity Report (PAR) Labor and Personnel Activity Report Department of Health Services 12/20/14 01/02/15 Pay Period: To: Timekeeper's Name: America Coles Position No: 12345 Name: Johnson, Tabitha EIN: 678910 Telephone Number: 602-555-1212 12/20 12/21 12/22 12/23 12/24 12/25 12/26 12/27 12/28 12/29 12/30 12/31 1/1 1/2 Default Funding % Change Description Index PCA AY - % - Total S S M T 8 W T 8 F 4 4 S S M T 8 W T 8 F 4 4 40 40 50% 50% 0% 0% WIC Breastfeeding Peer Counselor 50% 50% 8 8 8 8 100% PAR Breastfeed Peer Counselor # Hours **Direct Total Hours Worked 100% 0 0 8 8 8 8 8 0 0 8 8 8 8 8 80 0% 40 8 8 4 8 8 4 WIC # Hours Program Operations # Hours Nutrition Services # Hours Breastfeeding Education # Hours Client Services 0 0 24 16 4 4 4 4 4 4 4 4 4 4 0 0 0 8 0 8 4 0 0 0 8 0 8 4 40 Total WIC Hours Health and Wellness for all Arizonans

Certificate of Duty Employee USE MONTHLY OR QUARTERLY AVERAGE PERCENTAGE CALCULATED FROM YOUR TIME STUDY Supervisor Health and Wellness for all Arizonans

Time Study Health and Wellness for all Arizonans

FFY- -2014 Contractor Expenditure Payments by Month Health and Wellness for all Arizonans

New Audit Requirements Non-Federal entity that expends >$750,000 or more in Federal Awards in one year must have a single or program specific audit annually in accordance with 200.514. However, new rules require risk based auditing to ensure compliance and reduce risk. Health and Wellness for all Arizonans

QUESTIONS Health and Wellness for all Arizonans