• Overview

• Source Documents

• Financial Reporting Requirements

Overview

Over the course of the grant term, the Pro Bono Legal Corps (PBLC) operating sites are required to prepare several financial reports on their AmeriCorps project. The Corporation for National and Community Service (CNCS), the federal agency that oversees AmeriCorps, requires AmeriCorps programs to complete these reports as part of a broader set of fiscal management systems and procedures. Equal Justice Works, the PBLC grantee and fiscal administrator, considers these reports and systems extremely important in ensuring compliance and accountability at both the national program and local operating site levels.

The following guidance is designed to help PBLC project directors and financial managers understand and prepare the required fiscal reports. As the grant term progresses, CNCS may require additional fiscal reports or may make modifications to existing reports.

Equal Justice Works has designated each of the required reports as either internal or external. Internal reports are retained at Equal Justice Works, except in the case of timekeeping reports. Timekeeping reports will be retained by the sites themselves, although, under certain circumstances, Equal Justice Works may request submission of completed timekeeping reports or review sample timekeeping records during a site visit. Equal Justice Works compiles all external reports and submits a final summary report to CNCS that reflects the entire PBLC's figures.

Throughout the grant term, four different fiscal reports are required:

1. Site Operating Budgets (external report)
2. Periodic Expense Reports (internal report)
3. Quarterly Financial Status Reports (external report)
4. Member and Project Staff Timekeeping Reports (internal report)

The four types of fiscal reports are connected to each other. Together, these reports comprise a system of checks and balances for PBLC fiscal activity. To illustrate:

• Monthly timekeeping data correlate with the amount of salaries recorded on the periodic expense report.
• The periodic expense reports are aggregated at the end of each quarter to prepare the quarterly Financial Status Report (FSR).
• The FSRs compare cumulative expenses with the authorized funding amount from the site's operating budget.

It is essential that operating sites maintain the correlation between these fiscal reports. An adjustment to any of the reports triggers a corollary adjustment to other reports. Site financial and accounting staff should be familiar with the required PBLC fiscal reports, as they are comparable to financial reports required by other funding sources.

The sections that follow address the reading, financial reporting and timekeeping requirements necessary to effectively fulfill the PBLC fiscal and programmatic responsibilities. Project directors and fiscal managers should be thoroughly familiar with the fiscal management and reporting requirements of the AmeriCorps grant. Each site is responsible for compliance with all of these requirements and will be responsible for any noncompliance findings or recommendations determined by CNCS.

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Source Documents

The following documents from CNCS and Equal Justice Works address PBLC fiscal and programmatic responsibilities. PBLC sites are responsible for familiarizing themselves and for complying with the documents identified below. AmeriCorps grant regulations are available online at www.americorps.gov/for_organizations/manage/index.asp .

1. OMB Circular A-110
2. OMB Circular A-122
3. OMB Circular A-133
4. PBLC Subgrant Agreement
5. Notice of AmeriCorps Grant Provisions Compliance Requirement
6. Special Conditions and Reporting Requirements
7. Acceptance of Subgrant Award Form
8. The National and Community Service Act of 1990, as amended
9. The Grant Award Letter
10. CNCS Regulations
11. AmeriCorps 2003-04 Grant Provisions
12. 45 CFR 2543, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals and other Nonprofit Organizations

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Financial Reporting Requirements

This section contains fiscal reporting instructions. The instructions identify how each form is connected to other fiscal reports. Fiscal reporting forms and instructions are subject to change by CNCS.

1. Site Operating Budgets

Site Operating Budgets are prepared annually when sites submit their grant application to Equal Justice Works. Operating site budgets are based on the forms and instructions contained in the CNCS Application Guidelines. Sites should be aware that CNCS modifies these guidelines from year to year.

2. Periodic Expense Reports

Periodic Expense Reports (PER) are prepared by PBLC operating sites at the end of each month and show cumulative expenditures of CNCS and non-CNCS funds, or grantee share of funds commonly referred to as match. The expense categories for the PER are the same as those from the operating site budget.

Most importantly, the PER serves as the basis for issuing monthly grant checks to PBLC projects and for preparing the quarterly Financial Status Reports. Checks are issued on a reimbursement basis.

3. AmeriCorps Financial Status Report (FSR)—Form 269A

PBLC sites are required to prepare an FSR at the end of each quarter. The FSR is the primary expense report submitted to CNCS. It shows cumulative actual expenditures incurred against the CNCS grant and expenses incurred against all other project resources, including matching grants and in-kind contributions. In addition, the FSR is used to report total federal funds authorized for the site and the site's unobligated balance. The FSR is prepared using the periodic expense reports for the respective quarter.

The budget, financial status report and periodic expense report forms are available online at http://wbrs.net .

4. Timekeeping Requirements

Timekeeping reports are prepared contemporaneously by each individual staff employee whose time toward the PBLC project is billed to either the site's AmeriCorps grant or its match. The timekeeping reports must show the actual number of hours the staff employee spent on the PBLC project each day, distinguish those hours from time spent on non-PBLC work, and account for 100 percent of the employee's time. AmeriCorps Attorneys are also required to keep time records. Sites are not required to use a particular timekeeping system, but must ensure that their system meets certain minimum standards and complies with the requirements of OMB Circular A-122. Projects are encouraged to implement these requirements using their current timekeeping systems to the extent possible. Where the current system does not meet the requirements outlined below, sites must adjust it or create supplemental systems to do so.

Specifically, each individual time record must include:

• Staff/member name and title (if applicable);
• Number of actual hours spent toward the site’s AmeriCorps project (by staff);
• Number of actual hours spent toward other, non-AmeriCorps work (by staff);
• Location of work/service activities;
• Contemporaneous record of total number of hours worked each day;
• Differentiation between hours spent providing services versus in training (by members); and
• Staff’s/member’s and supervisor’s signatures.

In addition, each site’s timekeeping system must have the capacity to collect, on a monthly basis, the following information:

• Total number of actual hours spent by all employees toward the site’s AmeriCorps project and charged to either CNCS funds or the site’s matching funds for salaries and benefits. This information should be retained at the site, but Equal Justice Works may request copies as circumstances require.
• Total amount, based on actual staff hours, billed toward CNCS funds for salaries and benefits, versus total amount billed toward the site’s match for salaries and benefits. Sites are required to report this information each month in their periodic expense reports that are submitted to Equal Justice Works.
• Sites must keep activity-based time logs for staff designated as the PBLC project director and fiscal manager. This can be a brief narrative of what the staff member worked on during the time allocated to the grant on a specific day.

Any additional information sites choose to incorporate in a timekeeping system would be solely for the benefit of the site.

5. Important Points to Remember

• Sites cannot reprogram or transfer funds from Member Support Costs (such as member allowances and benefits) to cover Other Member Costs.
• Reallocation of project funds must be coordinated through Equal Justice Works.
• Reallocation of funds within the Other Member Support Costs group that exceed 10 percent of the grant award must be approved by Equal Justice Works.
• Sites must notify Equal Justice Works of changes affecting the PBLC project budget, including changes in the number of project members or staff, modifications to the site's operating plan, or changes involving the site's fiscal contact person.
• You will be provided with the due dates for all of the fiscal reporting documents for the duration of the service year. If you have a question about these deadlines or do not have access to them, please contact Equal Justice Works staff.
• Note about supporting documents and retention of records: Sites are required to maintain all supporting documentation of expenses charged to the grant including CNCS and non-CNCS match share. Documentation must be retained for a period of three years after the official closeout of grant award by CNCS.

QUESTIONS?

Please refer questions about PBLC or AmeriCorps fiscal requirements to Amin Kakeh, Equal Justice Works Comptroller.