2020–21 School Improvement Grant Closeout Timeline
- Budget revision requests must be received by October 17, 2021.
- All funds must be expended by September 30, 2021, and obligations incurred must be liquidated by December 30, 2021.
- Final Expenditure and Fiscal Activity Reports must be received by October 31, 2021.
- The School Improvement and Support Office will review and approve the fiscal reports by November 15, 2021.
- Unspent School Improvement Grant funds will revert to the U.S. Department of Education.
Retention and Access to Records Requirements
Financial records, supporting documents, statistical records, and all other records pertinent to the 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, as reported to the federal awarding agency or pass-through entity in the case of a subrecipient (Code of Federal Regulations, Title 2, Section 200.334 [2 CFR. § 200.334]).
There is one exception for the length of time that a nonfederal entity must retain records relating to equipment. Records for real property or equipment acquired with §.
The Secretary and the Comptroller General of the United States, or any of their duly authorized representatives, shall have access, for the purpose of audit examination, to any records maintained by a recipient that may be related, or pertinent to, grants, subgrants, cooperative agreements, loans, or other arrangements or which may relate to the compliance of the recipient with any requirement of an applicable program. All records must be maintained in a way that provides timely and reasonable access in order to make audits, examinations, excerpts, and transcripts, including timely and reasonable access to personnel for the purpose of interview and discussion related to such documents (2 CFR. § 200.337).
Use, Management, and Disposition of Equipment and Supplies Purchased with Federal Funds
The use, management, and disposition of equipment and supplies purchased with federal funds is governed by federal regulations, particularly the Property Standards found at 2 CFR. §§ 200.310-200.316.
Regarding: “Equipment,” as defined:
“Equipment” is defined as tangible personal property having a useful life of more than one year, and a per-unit acquisition cost that equals or exceeds the lesser of $5,000 or the capitalization level established by the grantee for accounting/financial statement purposes (2 CFR. § 200.1).
Title to and Use of Equipment
Generally, a grantee acquiring equipment under the federal grant takes a “conditional title” to the Equipment – it owns and may continue to use the property subject to certain conditions. Those conditions include that the grantee must: (1) use the equipment for the authorized purposes of the project during the period of performance, or until the property is no longer needed for the purposes of the project; and (2) not encumber the property without state or federal approval (2 CFR. § 200.313[a]).
In addition, even after the grant ends, use and disposition conditions and requirements apply with respect to the equipment. For example, the grantee must continue to use the equipment in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the federal award (2 CFR. § 200.313[c]).
When no longer needed for the original program or project, the equipment may be used in other federally-supported activities, in the following order of priority: first, activities under another federal award from the U.S. Department of Education; and then second, activities under federal awards from other federal agencies. (Id.)
Management of Equipment until Disposition
Until disposition, grantees must continue to follow proper management procedures with respect to equipment. Such procedures will, at a minimum, include: (1) maintaining property records that include the information specified in 2 CFR. § 200.313(d)(1); (2) a physical inventory and reconciliation with the written records at least once every two years; (3) a control system to ensure adequate safeguards against loss, damage or theft; and (4) adequate maintenance procedures. (Id.)
Ultimate Disposition of Equipment
Generally, when equipment is no longer needed for the original project or program, or put to use in other currently or previously federally-supported activities, the following disposition rules apply: (1) items of equipment with a then-current per unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further responsibility to the U.S. Department of Education; (2) items of Equipment with a then-current per unit fair market value in excess of $5,000 may be retained or sold, but the U.S. Department of Education must be compensated for its share of the cost of the original purchase (i.e., the product of multiplying the current market value [or proceeds from the sale] by the federal agency’s percentage of participation in the cost of the original purchase). If the equipment is sold, then the grantee may deduct from the federal agency’s share the lesser of $500 or ten percent of the proceeds for its selling and handling expenses (2 CFR. § 200.313[e]).
Inventory
Regarding: “Inventory,” as defined:
“Inventory” is an itemized list for tracking and controlling property.
The governing board of each school district, shall establish and maintain a historical inventory, or an audit trace inventory system, or any other inventory system authorized by the State Board of Education, which shall contain the description, name, identification numbers, and original cost of all items of equipment acquired by it whose current market value exceeds five hundred dollars ($500) per item, the date of acquisition, the location of use, and the time and mode of disposal. A reasonable estimate of the original cost may be used if the actual original cost is unknown (California Education Code, Section 35168).
Materials and Supplies Costs Including Costs of Computing Devices
Regarding: “Supplies,” as defined:
“Supplies” is defined as all tangible personal property that does not qualify as “equipment” (because it does not have a useful life of more than one year, or a sufficiently high per-unit acquisition price) (2 CFR. § 200.1).
Title, Use, and Disposition of Supplies
Title to supplies acquired under the grant vests in the grantee. The grantee must use the supplies for the project or program for which they were acquired. Upon termination or completion of such project or program, the grantee may use any residual supplies in support of any other federal award (2 CFR. § 200.314).
If there is a residual inventory of unused supplies upon termination or completion of the project or program, and the supplies are not needed for any other federal award, then the grantee must compensate the U.S. Department of Education if the total aggregate value of such unused supplies at that time is greater than $5,000. If the total aggregate value is less than $5,000, then there is no compensation requirement. The amount of compensation is computed in the same manner as with respect to equipment, discussed above (2 CFR. § 200.314).
Resources
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
For additional information related to SIG, please visit the CDE SIG web page.