DINAP BULLETIN 96-05
Establishment of a Regular Drawdown Schedule for Improved Financial Management.
To inform grantees of financial management oversight procedures instituted by the Division of Indian and Native American Programs (DINAP), and to encourage grantees to establish and implement regular drawdown schedules when obtaining section 401 funds.
References: Departmental regulations at 29 CFR 97.20(b)(7) and 29 CFR 95.21(b)(5); Treasury regulations at 31 CFR 205.7(b) and (c); DINAP Bulletin No. 95-27. Background: Most section 401 grantees have received their signed grant documents and Notices of Obligation (NOO's), which authorizes the operation of a title IV-A program for PY 1996. Grantees who use the Payment Management System (PMS) to draw down their JTPA funds should have established a regular drawdown schedule to comply with the above-referenced regulations, and to avoid having excess cash on hand. Grantees receiving grant funds through the SF-270, Request for Advance or Reimbursement are not affected by this bulletin. Information: During PY 1995, DINAP began using the attached sample printout from the Department's Grants and Contracts Management Information System (GCMIS) to analyze grantee PMS cash drawdowns against the percentage of elapsed program year, e.g., on March 15, 1996, the XYZ Tribe had drawn down $35,000 or 70.19% of their IV-A allocation and the number of days completed in the program year were 258 or 70.68% The GCMIS cash drawdown data are updated daily and available to DINAP staff for the purpose of monitoring grantee cash drawdowns. As grantees withdraw grant funds, the GCMIS system updates the new level of available funds within 24 hours. Any grantee evidencing an unusal variance (high/low) between the percentage of elapsed program year and the percentage of cash drawn down will be contacted by their Fed Rep Team to explain and possibly correct the discrepancy. Corrective action generally requires a forty-eight (48) hour reverse cash transfer procedure that is conducted through the bank that processes the grantee's PMS cash drawdowns. Approximately fifteen (15) grantees were contacted in PY 95 regarding their cash drawdowns and a few were required to take corrective action due to excess cash on hand. Action: To avoid excess cash on hand, grantees should establish a tentative drawdown schedule for PY 1996 if they have not already done so. Grantees should adhere to this schedule until a pattern of financial need is established. At that time, the drawdown schedule should be adjusted to reflect actual cash needs. This drawdown schedule should be re-evaluated periodically, perhaps monthly, to ensure that drawdowns are executed as needed thereby avoiding excess cash on hand. Additionally, drawing down too little money as opposed too much can indicate a weak financial management system. This practice can become a problem during the closeout and funds carryover process. Beginning in PY 1996, DINAP will provide each grantee on a semi- annual basis (December 31 and June 30), a copy of the the most current GCMIS status report. Grantees may also request a status report at anytime should the need arise, e.g., change in finance officer or program director, unresolved closeout issue, etc. Inquiries: Questions should be addressed to your Federal Representative team or to Greg Gross on (202) 219-7509.
All Indian And Native American Grantees
Thomas M. Dowd Paul A. Mayrand