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ATTENTION GRANT ADMINISTRATORS:  

The Illinois State Board of Education (ISBE) has recently updated its State and Federal Grant Administration Policy, Fiscal Requirements, and Procedures Manual.

This revision was needed to incorporate the Federal Uniform Guidance under Title 2 Code of Federal Regulations Part 200 that governs the administration of federal awards/grants as well as all state grants per the Grant Accountability and Transparency Act (GATA). 

Some major topics and changes include: GATA requirements, Internal Controls, Fraud Policy, General Procurement Standards and Policy, Time and Effort Reporting, Detailed Function and Object Descriptors, Recovery of Grant Funds.

While the State of Illinois ranks near the bottom in most key indicators of economic growth forecasting, the Illinois General Assembly is leading the way in a new philosophy directed toward prudent administration of grant funds. In fact, Illinois adopted the nation’s first state legislation requiring the standardization for accountability throughout the entire life cycle of a grant – the Grant Accountability and Transparency Act (GATA).

According to the Illinois State Board of Education (ISBE), the purpose of GATA is to increase accountability and transparency in the use of grant funds while reducing the administrative burden on both state agencies and grantees. The law, which has passed in both houses and was signed by the Governor, re-affirms Illinois commitment to apply federal rules for federally funded and pass-through grants as well as adopting these rules for state grants.  GATA specifically adopts 2 CFR 200 Uniform Requirements, which should streamline administrative functions.  The intent is to develop a coordinated process to limit redundancy and abuse. 

“GATA actually became effective on July 1, 2015, but state agencies are now in the process of implementing the requirements for the fiscal year 2017 grant cycle,” said Stephanie Blanco, CPA, Senior Audit Manager at John Kasperek Co., Inc. in Calumet City, Illinois.  “If you participate in giving or receiving state or federal grants then GATA applies to you and you should make sure that your organization understands the rules that apply to your grants.”

So what should grant administrators expect?  The key points as highlighted by the Illinois.gov website are as follows:

1. Establish a State Catalog of Financial Assistance;
2. Establish qualifications and testing of fiscal agents;
3. Establish Audit requirements for sub-recipients who do not meet the new $750,000 threshold, for-profit entities and state grants;
4. Establish a Grant Accountability Officer for each grant making agency;
5. Create a web portal for posting relevant information;
6. Set administrative requirements through supplemental rules, in accordance with 2 CFR 200;
7. Set Cost principle requirements including implementation of negotiation of indirect cost plans;
8. Establish a “State Debarred and Suspended” List (Excluded parties list);
9. Establish a Pre-qualification of grantees and contractors;
10. Establish Mandatory disclosures including conflict of interest;
11. Establish training requirements for staff of grant applicants;
12. Establish policies and procedures for an exemption process that allows exemption in whole or part to these rules in unique situations;
13. Establish a Grant Accountability and Transparency Unit (GATU) in the Governor’s Office of Management and Budget.