Guidelines and Procedures for Use of US Government Letter of Credit Mechanism for Funding
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US Government Letter of Credit Guidelines and Procedures
for funding UNDP projects
The US Government has revised its reporting guidelines and requirements for reporting grants funded under the Letter of Credit (LOC) mechanism. As a result of the changes, UNDP Treasury is issuing revised guidelines and procedures for reporting UNDP project expenditures funded under the LOC mechanism. The revised guidelines are effective 1 January 2010 and should be used to report grant expenditures starting with expenditures for the quarter ended 31 December 2009.
Background
The US Government utilizes an LOC to fund most of its contributions to UNDP. The Agreements which are funded via the LOC mechanism are primarily on behalf of USAID and, in a few limited instances, the US Department of State. Following a review of reporting practices a need was identified to strengthen and standardize UNDP procedures in administering US grants made under this LOC mechanism to ensure that they fully comply with donor guidelines and UNDP financial processes. US Government Procedures All US Government agreements must be cleared by the Division for Resources Mobilization, Partnerships Bureau ([email protected]) before signing. Country Offices must ensure the agreements do not obligate UNDP to submit any reports to the US Federal Government Agency other than the reports listed below. Any request for additional reports should be cleared with the Partnership Bureau. After the UNDP Country Office signs the agreement with the local US Federal Government Agency counterpart, the US Government updates its public web-site with information on the new grant, making the funding available to UNDP. The website also provides standard reports on the status of all grants issued. These reports include information such as grant ID number, start date, amount of the grant or any increase/decrease in the grant value and expiry date. The website is also used by UNDP HQ to request draw-downs. US Government Reporting Requirements The new US Government grant procedures require the submission of a Federal Financial Report (FFR-425) which consolidates and replaces the previous SF-269 and PSC-272 reports. Responsibility for completing and submitting FFR-425 will be as follows:
1 (a) For ongoing projects, Country Offices are required to complete an interim FFR-425 {complete lines 10(d) to 10(o)} for each award and submit it to the local Contract/Agreement Officer’s Technical Representative (COTR/AOTR) within the time frame agreed with the COTR/AOTR (usually quarterly). This replaces the previously filed SF- 269.
(b) Upon project completion and grant expiry, Contributions Unit will prepare and submit a Final FFR-425 {complete lines 10(d) to 10(o)} for each award and submit it to the respective US Federal Government Agency HQ. The deadline to submit the Final FFR-425 is 90 days after grant expiry. This replaces the previously filed Final SF-269. Country Offices should NOT submit any donor checklist (including Recipient Closeout Statement) to the US Federal Government Agency upon project completion. Any requests from the US Federal Government Agency for additional documents should be cleared with HQ.
(c) Contributions Unit will file electronically a quarterly FFR-425 {complete Lines 10(a) – 10(c)} and FFR attachment through the DHHS Payment Management System (PMS) to report cumulative expenditures for all grants. The deadline for filing the quarterly FFR-425 is within 30 days from the end of the quarter. This replaces the previously filed PSC-272.
A copy of the Federal Finance Report (FFR-425) and FFR-425 line item instructions (for completing FFR-425) are attached for reference.
Country Offices are requested to enter 793511262 for DUNS Number and 1133417984A1 for EIN Number where requested in the FFR-425. Any changes to the DUNS or EIN Numbers will be advised by UNDP Treasury. Any questions on completing the form should be sent to Contributions Unit mailbox ([email protected]).
UNDP procedures To comply with the donor’s requirements UNDP must fulfil the following procedures. Failure to comply with these requirements could lead to request for return of grant funds and interest, and negatively affect the reputation of UNDP. Furthermore, the Country Offices will be responsible for absorbing any expenses already incurred. Setting Up the LOC in Atlas
2 Once Country offices have negotiated and signed grant agreements with the relevant US Federal Government Agency (Local USAID or US Department of State office), a copy of the signed agreement and the Chart of Accounts (COA) for the associated project should be sent to Contributions Unit ([email protected]) who will verify whether the new grant has been reflected on the US Government website. Contributions Unit will credit the project in Atlas based on the COA submitted by the Country Office. Country offices are responsible for creating the project in Atlas and completing all the relevant chart fields. Expenditure reporting: Contributions Unit will update the FFR-425 data online on a quarterly basis with cumulative expenditures for all grants using the HHS Payment Management System (PMS) based on the reporting deadlines advised by the US Federal Government Agency (USAID or US Department of State). This is generally within 30 days of each calendar quarter end (for example, 4Q 2009 has to be filed by January 31st 2010). Contributions Unit requires Country Offices to certify expenditure figures extracted from Atlas for operational grants, for each of their grants before the end of the month following the quarter in question. This requirement will be included in the quarterly closing instructions issued by OFA. In this regard Country Offices must ensure accuracy and completeness of expenditure data in Atlas. Expenditure certifications must be made using the attached certification template and forwarded to Contributions Unit ([email protected]) mailbox. LOC Draw Down: Based on an analysis of expenditure per grant, the Contributions Unit determines whether UNDP has unfunded expenditure (i.e. UNDP has incurred expenditure against the grant without drawing funds from the LOC). This analysis is performed for each grant separately, taking into account the current level of expenditure (increase/decrease) from prior quarter, the amount of cash already drawn and the grant expiry date. Contributions Unit will draw down the LOC by electronically requesting funds via the PMS system. Once requested, the transfer occurs within 2 business days. At present, the US government limits the value of draw downs to 3 days’ expenditure. Operating Guidelines for use of Letter of Credit
1. For each grant a unique Cost Sharing Project (in Fund 30000 or exceptionally in fund 16600 for Security projects as instructed by the Office of Planning & Budget) must be created in ATLAS (i.e. One Project = One Grant/Award). Any other arrangement requires prior clearance from
3 Treasury/Contributions Unit. The grant period should be recorded in the Project “End Date” field at the time the project is setup in Atlas.
2. No income will be allocated to a project by Contributions Unit without receipt of a copy of the signed grant agreement and project document (see below).
3. US grant income MUST NOT be transferred in Atlas from one project ID to another project ID without prior clearance from Contributions Unit.
4. Country Offices should notify the Contributions Unit of agreements to extend the grant expiry date. The notification (including signed modification agreement) must be sent to Contributions Unit within 10 working days of such extension being granted.
5. The Contributions Unit will inform Country Offices of grants expiring within 60 days prior to grant expiry. Country Offices are responsible for confirming to Contributions Unit the current status of the grant i.e. whether the project is complete, whether expenditure has been reported, and whether a no-cost extension has been requested and granted1.
6. In entering the project in Atlas, Country Offices must ensure that the GMS rate, as agreed with the US Federal Government Agency, in the agreement is entered accurately.
7. Contributions Unit is responsible for filing the Final FFR-425 reports (upon grant expiry and project completion), which must be submitted within 90 days of the grant expiry date. Contributions Unit is also responsible for filing quarterly FFR-425 reports for cumulative expenditure of all grants. Country offices are required to submit to Contributions Unit quarterly grant expenditure certification within 30 days of the quarter close.
1 If more time is necessary to complete the grant objectives, the project is not yet complete or the original funding has been expended but the project is not yet complete, then a No-Cost Amendment/Extension may be requested. To do so the Country Office must notify the relevant US Government Federal Agency Grants Officer in writing prior to the original expiration date (6 weeks is recommended), and provide the rationale for requesting the extension, the original date of expiration, the revised date, and the grant number.
4 8. Country offices are responsible for submitting interim FFR-425 {lines 10(d) to 10(o)} to the local Contract/Agreement Officer’s Technical Representative (COTR/AOTR) for on-going grants. This should be done within the time frame agreed with the COTR/AOTR (usually quarterly) using expenditure data from official financial records contained in the General Ledger and expenditure certification submitted to Contributions Unit. Contributions Unit will close out grants with the US Federal Government Agency HQ upon timely certification by the Country Office that the activities related to the grant have been completed.
Operating Guidelines for use of Letter of Credit-MATRIX
Step Timeframe/Report Responsibility Signed agreements at CO level CO from date of signing CO (agreement with the US Federal the Agreement Government Agency) Agree on frequency of interim FFR- Prior to signing CO 425 reporting requirements and agreement deadline with local COTR/AOTR Submit a copy of signed grant As soon as grant CO agreement to HQ agreement is signed Creation of Project in Atlas As soon as the project CO budget is finalized Credit project income in Atlas Upon receipt of executed HQ agreement or amendment File quarterly FFR-425 to local US As agreed with COTR / CO Federal Government Agency office AOTR Manage agreement against required As per agreement CO filing dates and expiry date requirements File final FFR-425 (individual grant) Within 90 days of grant HQ expiry following expenditure certification by CO File quarterly FFR-425 (consolidated Within 30 days of HQ for all grants) quarter’s end following expenditure certification by CO Step Timeframe/Report Responsibility Project Operational Close Before the grant expiry CO
5 date Project Financial Close After operational closure CO but not more than 90 days after grant expiry Cash Draw-Down Quarterly or other period HQ TBD by HQ. Grant Extension Notification to HQ CO within 10 working CO days of extension. Notification of Grant Expiry 60 days prior to grant HQ expiry date. Processing Refunds and De- After submission of Final HQ Obligations FFR-425.
Treasury Division 27 January 2010
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