Updated: 07/23
1601 Prior Written Approval of Indirect, Special or Unusual Costs
Under any given Federal award, the reasonableness and allocability of certain items of costs may be difficult to determine. Consistent with 2 C.F.R. §200.407, in order to avoid subsequent disallowance or dispute based on unreasonableness or non-allocability, the non-Federal entity may seek the prior written approval of the cognizant agency for indirect costs or the Federal awarding agency in advance of the incurrence of special or unusual costs. Prior written approval should include the timeframe or scope of the agreement.
1601.01 Methodology for Indirect Costs
DORS will determine the reasonableness and allocability of items of indirect costs from grants and funds received from the U.S. Department of Education, Rehabilitation Services Administration (RSA) to Implement Title IV of the Workforce Innovation & Opportunities Act (WIOA).
DORS will confirm with the Maryland State Department of Education (MSDE) Deputy Superintendent of Schools for Finance and Administration the reasonableness and allocability of indirect costs from grants and funds received from the U.S. Department of Education to Implement Title IV of WIOA.
If either DORS or the MSDE Deputy Superintendent of Schools for Finance and Administration is uncertain about the reasonableness and allocability of the indirect costs, DORS will seek Prior Written Approval of the indirect cost from RSA.
1601.02 Methodology for Special or Unusual Costs
DORS will determine the reasonableness and allocability of special or unusual costs from grants and funds received from RSA to Implement Title IV of WIOA.
DORS will confirm with the MSDE Deputy Superintendent of Schools for Finance and Administration the reasonableness and allocability of special or unusual costs from grants and funds received from RSA to Implement Title IV of the WIOA.
If either DORS or the Deputy Superintendent of Schools for Finance and Administration is uncertain about the reasonableness and allocability of the special or unusual costs, DORS will seek Prior Written Approval of the special or unusual cost from RSA.
1602 Prior Written Approval for Equipment and Software Purchases
DORS will review the prior year’s cost to purchase either equipment or funds used to support Participant Costs to provide an estimate for the utilization of grant funds in accordance with 2 CFR § 200.407 for Prior Written Approval.
1602.01 Methodology for Case Services Equipment and Software Purchases
In accordance with TAC 18-02, DORS will submit, at minimum, a request once a year to RSA for each fund grant that it expects to utilize in the coming fiscal year. The request will be sent in
no later than September 1st for the upcoming federal fiscal year.
Equipment/Software Purchases for Client – Purchase of equipment/software for a client is only allowed if that equipment/software is necessary to participate in a training program or for purposes of meeting the requirements for obtaining or maintaining employment. Equipment/software must be on an approved Individualized Plan for Employment prior to the purchase of the equipment.
Currently the DORS-approved inventory threshold is $50 for sensitive equipment and $100 non-sensitive equipment/software. Sensitive equipment is considered to be highly theftable items (i.e., computers,Braille Notes, cell phones, etc.). Non-sensitive is all other equipment and software.
Monitoring Equipment/Software Purchases – A monthly report from AWARE™ will be generated to track these expenses. In the event that actual purchases appear to be tracking higher than DORS' Prior Approval Authority, a revised request for Prior Approval will be sent to RSA.
The following
sub-categories will be utilized to track encumbrances and expenditures:
- Assistive Listening Devices
- Augmentative Communication Equipment
- Computer Hardware/Software
- Hearing Aids
- Home Modification Equipment
- Low Vision Aids
- Occupational Tools/Equipment
- Rehabilitation Technology Devices
- RISE Program Equipment
- Vehicle Modification Equipment
1602.02 Methodology for Administrative Equipment and Software Purchases
In accordance with TAC 18-02, DORS will submit, at minimum, a request once a year to RSA for each fund grant that it expects to utilize in the coming fiscal year. The request will be sent in no later than September 1st for the upcoming federal fiscal year.
Administrative Equipment/Software Purchases – Purchase of equipment/software for DORS use must be approved by the Administration & Financial Services (AFS) Director prior to the purchase being made by DORS staff, to assure that DORS has not exceeded its Prior Approval Authority from RSA.
Currently the DORS-approved inventory threshold is $50 for sensitive equipment and $100 non-sensitive equipment/software. Sensitive equipment is considered to be highly theftable items (i.e., computers, iPads, cell phones, etc.). Non-sensitive is all other equipment and software. Capital Equipment is equipment that is attached to the Workforce & Technology Center and most go through the Department of General Services.
Monitoring Administrative Equipment/Software Purchases – The AFS Office will generate a monthly report from the State’s Financial Management Information System (FMIS) to track these expenses. In the event that actual purchases appear to be tracking higher than DORS' Prior Approval Authority, a revised request for Prior Approval will be sent to RSA.
The following
Comptroller Object Codes will be used to track encumbrances and expenditures:
- Object 0858 – Software Licenses
- Object 0861 – Application Software
- Object 0863 – System Software
- Object 10 – Equipment: Replacement
- Object 11 – Equipment: Additional
- Object 13 – Equipment: Capital
