[lstac] Question about grant funded staff compliance
Sulin Jones
SulinJones at admin.nv.gov
Mon Jul 31 09:34:09 PDT 2023
LSTA jail!
I joke about it a lot (mostly keeping me out of it), and no, not really, but yeah, really. It is tricky.
Last year, I added elements from IMLS’s “I’ve signed my name, what’s it mean<https://www.imls.gov/sites/default/files/2022-05/ivesignedmynamewhatsitmean2022.pdf>” to training and the pre-app guidelines, to try and clarify all the legalese. I talk about compliance and how making sure Nevada represents the LSTA program well is my entire reason for being (oof). Plus, I never hesitate to throw IMLS and 2 CFR 200 under the bus when it comes to allowability and being in or out of compliance.
For salaries: We require a job description for all LSTA funded salaries and won’t reimburse without an LSTA Time and Effort form that has 1) job duty categories that match the job description and 2) been signed by the employee, their supervisor, and the person submitting the form (usually the project manager or fiscal person). With all of those signatures, I think/hope fuzzy interpretation of job duties is less of a thing.
From: lstac <lstac-bounces at omls.oregon.gov> On Behalf Of Rachel Cook via lstac
Sent: Thursday, July 27, 2023 10:47 AM
To: Enge, Kate A (EED) <kate.enge at alaska.gov>
Cc: lstac at omls.oregon.gov; eedlibrarygrants, eedlibrarygrants (EED sponsored) <eed.library.grants at alaska.gov>
Subject: Re: [lstac] Question about grant funded staff compliance
WARNING - This email originated from outside the State of Nevada. Exercise caution when opening attachments or clicking links, especially from unknown senders.
Hi Kate!
I require our libraries to track the hours specifically on a timesheet. There is almost always an element of giving benefit of the doubt for sure because there really is no way for me to watch and make sure they are only doing LSTA project activities. I try to really clearly communicate why LSTA dollars can only be spent on hours that actually went into the LSTA project - supplanting vs supplementing funding, protecting job funding, etc. Maybe training on that will help libraries maintain compliance if they know the why? Maybe you reduce the funding to 90% of the hours worked be funded to help give room for error?
Hope that helps, this is definitely a tricky question.
Thanks,
Rachel
On Thu, Jul 27, 2023 at 11:37 AM Enge, Kate A (EED) via lstac <lstac at omls.oregon.gov<mailto:lstac at omls.oregon.gov>> wrote:
Good morning,
What do you all do to make sure grant-funded library staff are 100% using those funds for the project? Do you just give the libraries the benefit of the doubt?
For example, Alaska has a long-running program hosted by a public library that has been funded by both State and LSTA funds over the years. Recently it has been funded 100% with LSTA funds. The staff at the library have a document they fill out and sign quarterly that says 100% of their salary was spent doing project duties. However, and I know this from working with the program, there are some activities that may or may not fit in 100% with the LSTA project depending on who is doing the interpreting. This has come up now because my boss is going over projects and programs with a fine tooth comb to make sure they are all in compliance.
Any help and guidance will be appreciated. If you want more specifics I can give those out as well.
Thank you everyone, I hope your fiscal year started off smoother than ours!
Kate
[APK: Alaska State Libraries]
Kate Enge (Ing-E)
Grants and Continuing Education Librarian
Acting OWL Librarian
Library Development Staff, Alaska State Library
Andrew P. Kashevaroff Building
Mail: PO Box 110571, Juneau, AK 99811
Visit: 395 Whittier St., Juneau, AK 99801
phone: 907.465.2271
email<mailto:kate.enge at alaska.gov> | web<http://library.alaska.gov/> | sign up for event notifications<https://public.govdelivery.com/accounts/AKDEED/signup/31850>
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