Fiscal Accountability Guidelines
In order to successfully achieve learning acceleration during the COVID-19 pandemic, LEAs and community-based agencies have adjusted policies and procedures and ways of working together. While some flexibility may have been provided for federal and state programs, certain fundamental accountability requirements remain in effect including maintenance of internal controls, documentation of policy and procedure changes, fiscal accountability, expenditure compliance, and accurate accounting and reporting.
Additional Fiscal and Program Accountability and Compliance Requirements
In addition to the key federal Uniform Guidance requirements below, LEAs and community-based organizations must also ensure compliance with other fiscal and program accountability and compliance requirements as provided in the General Education Provisions Act, Education Department General Administrative Regulations, California Code of Regulations, federal and state program specific requirements, and other state, program, contract, or grant specific requirements. Further, the Governor’s Executive Orders, federal waivers, and other program-specific guidance may apply to various programs. The CDE’s COVID-19 website has a substantial amount of additional guidance.
Uniform Guidance—Title 2, Code of Federal Regulations
The Uniform Guidance requirements are incorporated into many federal and state programs. Some key accountability and compliance requirements are as follows:
The Uniform Guidance sections 200.61, 200.62, 200.302, and 200.303 require agencies to effectively implement financial management and internal controls. Additional guidance regarding internal controls are located in the Standards for Internal Control in the Federal Government (PDF), published by the federal Government Accountability Office. These standards also apply to changes in policies and procedures in response to the COVID-19 pandemic.
Policies and Procedures
The Uniform Guidance requires the development and implementation of policies and procedures including, but not limited to, the following:
- Allowability Procedures, section 200.302(b)(7)
- Conflicts of Interest Policy, section 200.318(c)
- Procurement Procedures, section 200.319(c)
- Travel Policy, section 200.474(b)
- Equipment Procedures, section 200.313(d)
- Cash Management Procedures, sections 200.302(b)(6) & 200.305
The Uniform Guidance sections 200.317 through 200.326 require agencies to effectively implement standards when procuring property and services using federal funds. Section 200.320 identifies five methods of procurement: (1) micro-purchase; (2) small purchases; (3) sealed bid purchases; (4) competitive proposal; and (5) noncompetitive purchases. All five procurement methods must comply with the following requirements:
- Documented procedures
- Be reasonable and necessary
- Open competition
- Conflict of interest policies
- Proper documentation
In addition, LEAs must comply with Public Contract Code sections 20111(a) and 22002(c), which require competitive bids to be obtained for applicable contracts.
The Uniform Guidance, section 200.403 states the following general criteria must be met in order for costs to be allowable:
- Be necessary, reasonable, and allocable
- Conform to any limitations or exclusions for types or amount of cost items.
- Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities.
- Be accorded consistent treatment between federal and non-federal programs.
- Be determined in accordance with generally accepted accounting principles.
- Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. See also Section 200.306 Cost sharing or matching paragraph (b).
- Be adequately documented. See also sections 200.300 statutory and national policy requirements through 200.309 Period of performance of this part.
Uniform Guidance, Subpart E, sections 200.400 through 200.475 provide guidance related to specific types of costs. Additional time and effort and other guidance issued during COVID-19 is located at:
- COVID-19 Time and Effort Requirements
- Fact Sheet: Select Questions Related to Use of Department of Education Grant Funds During the Novel Coronavirus Disease 2019
Uniform Guidance, section 200.333 requires that financial records, supporting documents, statistical records, and all other non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report, or, for federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively.