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Low Income Home Energy Assistance Program assistance with heating and cooling costs

Revision to Previously Issued Guidance Regarding Financial Reporting Requirement for All LIHEAP Grantees - SF 269A

THIS CONTAINS INFORMATION ISSUED BY THE U.S. ADMINISTRATION FOR
CHILDREN AND FAMILIES IN LIHEAP ACTION TRANSMITTAL NO. LIHEAP-
AT-2008-1, DATED 11/30/07                       
         
TO: LOW INCOME HOME ENERGY ASSISTANCE PROGRAM (LIHEAP) GRANTEES AND OTHER INTERESTED PARTIES
SUBJECT: Revision to Previously Issued Guidance Regarding Financial Reporting Requirement for All LIHEAP Grantees - SF 269A
RELATED REFERENCES: Low Income Home Energy Assistance Act, Title XXVI of the Omnibus Budget Reconciliation Act of 1981, Public Law 97-35, as amended; Final Rule amending the HHS block grant regulations (45 CFR 96.30(b)), as published in the Federal Register on October 15, 1999 (64 FR 55843-55858); LIHEAP AT-2000-2, dated November 18, 1999, transmitting a copy of the Final Rule; LIHEAP AT-2001-1, dated October 18, 2000.
PURPOSE: To give grantees revised guidance in meeting the requirement that they file a Standard Form 269A report on the obligation of LIHEAP grant funds. This report is due on December 31, 2007. In addition, grantees have the option to file the 269A electronically through the ACF Online Data Collection (OLDC) system.
BACKGROUND: On October 15, 1999, a Final Rule amending the regulations governing U.S. Department of Health and Human Services block grants (including LIHEAP) was published in the Federal Register (64 FR 55843- 55858). The Rule took effect on November 15, 1999, and among other things, included a new requirement that recipients of HHS block grants must report on the obligation and/or expenditure of block grant funds. The provision required that LIHEAP grantees must submit, within 90 days of the end of the fiscal year, a report on the dollar amount of the funds obligated by the grantee during the fiscal year and the date of the last obligation of funds for the fiscal year. The form to be used is the OMB Standard Form 269A, Financial Status Report (short form). This requirement is found in the regulations at 45 CFR 96.30(b). We issued an Action Transmittal on October 18, 2000 (LIHEAP-AT-2001-1) to provide LIHEAP grantees with guidance on the 269A reporting requirements for LIHEAP block grant funds and emergency contingency funds. CONTENT: Section 96.30(b) of the regulations applying to the HHS block grant programs requires that all LIHEAP grantees, including tribal and territorial grantees, must submit a report on Standard Form (SF) 269A on the amount of LIHEAP funds obligated during each fiscal year. The next report is due on December 31, 2007 for LIHEAP obligations taking place in FY 2007 (October 1, 2006 - September 30, 2007). Our previous guidance asked grantees to disregard the general SF 269A instructions, and limited the amount of LIHEAP financial information that was required on the SF 269A form; however, the minimal information did not meet the needs for monitoring and oversight by the ACF Office of Grants Management. Therefore, we are requesting that LIHEAP grantees provide additional financial information on the SF 269A. We do not believe that this additional information will cause an undue burden on LIHEAP grantees, since what we are now requesting will show the calculations used by grantees to determine the amount of funds previously reported on the form. In addition, separate SF 269A reports must also be filed for leveraging incentive funds and Residential Energy Assistance Challenge Program (REACH) funds that LIHEAP grantees were awarded in FY 2007. More information on the timing of the 269A reports for leveraging and REACH is provided in this Action Transmittal. Changes to 269A Reporting Requirements Attachment 1 provides guidance on how the SF 269A should be completed when reporting on LIHEAP funds, with specific instructions in supplying information for each identified item number. Attachment 2 provides an example of a completed SF 269A. Because not everything asked for on the 269A form is required for LIHEAP, we recommend that grantees follow our guidance, in lieu of the "general instructions" provided on the back of the SF 269A form. The example shows what item numbers are required for LIHEAP. However; grantees may wish to use the general instructions provided on the back of the SF 269A to remain consistent with reporting requirements for other Federal programs. Either the general SF 269A instructions or the LIHEAP guidance in Attachment 1 may be used when completing the form. If you plan to use the general instructions, you must also provide, under Item #12, the date of the last LIHEAP obligation for the reporting period. The additional information we are requesting to be completed on the SF 269A form is minimal. We are asking that the amounts used to calculate the amount previously reported also be added to the form, which essentially requires grantees to include amounts for items 10c, 10f and 10g. Please see revised guidance in Attachment 1 for further details. Attachment 3 provides the SF 269A form, which is also available electronically from the GSA Forms Library at: http://www.gsa.gov/Portal/gsa/ep/formslibrary.do?fo rmType=SF Specific Instructions for LIHEAP Block Grants and Contingency Funds In FY 2007, LIHEAP grantees received grant awards for regular block grant funds, contingency funds, and reallotment funds. For the report due December 31, 2007, grantees must report obligations of LIHEAP funds for Federal fiscal year 2007, October 1, 2006 to September 30, 2007. Grantees may have also carried over FY 2006 funds to obligate in FY 2007. Grantees must report on the obligations of all these different types of LIHEAP funds (regular block, reallotment, contingency and carryover) and must use separate SF 269A forms for each type. These different funding types will be distinguished by the accounting information on the Notice of Grant Awards, under the Common Accounting Number or "CAN" and the "Grant Document Number." CAN Numbers FY 2007 Regular Block Grant Funds: 2007 G992201 FY 2007 Contingency Funds: 2007 G992212 FY 2006 Regular Block Grant Funds carried over into FY 2007, and FY 2006 Reallotment Funds issued in FY 2007: 2006 G992201 FY 2006 Contingency Funds carried over into FY 2007: 2006 G992212 Grant Document Numbers For States and Territories: Grant Document numbers will look something like this: G-07B1MMLIEA For Tribes/Tribal Organizations: Grant Document numbers will look something like this: G-07LLMMLIEA Note that REACH grant document numbers for both States and Tribes end in LIE5. Therefore, each grantee will submit an SF 269A for regular block grant funding, an SF 269A for contingency funding and one or more SF 269A forms for FY 2006 funds carried over and obligated in FY 2007. If no FY 2006 funds were carried over into FY 2007 for obligation, then an SF 269A form for carried over funds will not be required. Note that there were two distributions of FY 2007 emergency contingency funds in August and September. The normal obligation rules for these funds were waived. The FY 2007 contingency funds are not subject to the 10 percent carryover rule (and should not be included in the annual carryover reports due August 1). Therefore, grantees can obligate some or all of these funds in FY 2007, and some or all of these funds in FY 2008. Only those contingency funds obligated in FY 2007 should be reported by December 31, 2007; obligations in FY 2008 will be reported at the end of FY 2008, for the report due December 31, 2008. Note on Reallotment Funds: The FY 2006 reallotment funds issued at the end of September 2007 should be reported this year as indicated above; the reallotment funds are not subject to the 10 percent carryover rule since they were released too late in the fiscal year for most states to obligate them. (Next year, grantees will report on any FY 2006 reallotment funds carried over into FY 2008 when filing next year's 269A form due December 31, 2008.) Specific Instructions for LIHEAP Leveraging and REACH Funds In FY 2007, some LIHEAP grantees received grant awards under the leveraging and REACH programs. Beginning with FY 2007 funds, a separate SF 269A report must be filed for each. Unlike block grant funds, leveraging and REACH funds can be obligated in the year they were awarded or the year following, but must be fully obligated before the end of the second year. For the report due December 31, 2007, grantees must report obligations of leveraging and REACH funds for Federal fiscal year 2007, October 1, 2006 to September 30, 2007. If no leveraging or REACH funds were obligated in FY 2007, then a 269A form will not be required until filing the SF 269A report due by December 31, 2008. Note on REACH Funds: In the past, REACH awardees were required to use the SF 269 long form to report on these funds, and to file a 269 every 6 months. The long form and semi-annual reporting are no longer required for REACH. Like leveraging funds, the status of REACH funds should now be reported on the 269A short form and filed once a year by December 31. CAN Numbers FY 2007 Leveraging Grant Funds: 2007 G992204 FY 2007 REACH Funds: 2007 G992206 Filing the 269A Report The SF 269A Reports for FY 2007 are due December 31, 2007. The report may be submitted in hard copy or electronically. Paper Filing: LIHEAP Grantees should continue to submit the SF 269A reports to the Office of Grants Management (not to the Division of Energy Assistance). The address and other contact information for the Grants office is listed below. Electronic Filing: LIHEAP Grantees can now choose to submit the 269A reports electronically through the ACF Online Date Collection (OLDC) system. Many grantees may already be familiar with OLDC through their 269A reporting for other ACF programs. We encourage you to use the OLDC to file your LIHEAP 269A reports electronically. Attachment 4 provides the OLDC request form, and instructions to request a new OLDC account or to add additional permissions to an existing account. The completed request form and all questions about OLDC access should be sent to Lydia Peele in the Office of Grants Management via telephone or her e-mail address provided below. SUBMISSIONS TO: Administration for Children and Families Office of Administration Office of Grants Management Division of Mandatory Grants Attention: Lydia Peele, Mail Stop: OA/OGM/DMG 370 L'Enfant Promenade, S.W. Washington, D.C. 20447 Telephone: (202) 401-6493 Fax: (202) 401-5519 E-mail: Lydia.Peele@acf.hhs.gov ATTACHMENTS: (1) LIHEAP Guidance on Completing the SF 269A Report (2) Example of a Completed SF 269A Report (3) Blank SF 269A Form and General Instructions (4) OLDC Form and Instructions to Request OLDC Access INQUIRIES TO: Joseph Lonergan, Director Division of Mandatory Grants Office of Grants Management, OA/ACF Telephone: (202) 401-6603 E-mail: Joseph.Lonergan@acf.hhs.gov ______________/s______________ Nick St. Angelo Director Division of Energy Assistance Office of Community Services