(1) OEO Form 315a, Grantee Quarterly Financial Report. See CSA Instruction 6807-2.

(2) CSA Form 325b, Request for Amendment to Grant. This form is used for all amendment requests. Where the request involves no budgetary changes, the CSA Form 325b is the only form required. The form is self-explanatory; it provides essentially for a narrative description of the programmatic and/or budget changes requested. Blank sheets should be used to complete any continuation pages. If the amendment involves changes in the grantee target area, by-laws, etc., appropriate documents such as maps, new proposed bylaws, etc., should be attached to the CSA Form 325b.

(3) CSA Form 325, Budget Summary. This form is used when the requested amendment involves an increase in the total program cost (whether or not supplementary funds are required), an increase or decrease in the Investment Capital cost category, an increase in the Indirect Cost category (if applicable), or an extension of the funding period without additional funds (a "nocost extension") for four to twelve months beyond current termination date

NOTE: No-cost extensions of four months or less require only the CSA Form 325b; no-cost extension of more than 12 months are refundings, subject to CSA Instructions 67106).

Detailed instructions on how to complete CSA Form 325 for amendment requests may be found in CSA Instruction 6710-8.

(4) CSA Form 325a, Budget Support Sheets (Parts I and II). (i) This form will normally be used in any amendment request involving an increase in program costs (whether or not supplementary funds are requested), or a nocost extension for more than four months. It may even be necessary for certain requests to shift funds among budget cost categories. However, there may be fairly simple amendment requests where the necessary budgetary back-up justification can be provided directly in the narrative on the CSA Form 325b, in which case the CSA Form 325a will be unnecessary.

(ii) Where the CSA Form 325a is used, it will provide the detailed cost basis

(a) Upon receipt of an amendment request it will be reviewed by the appropriate OED staff and either approved or disapproved. If the request is disapproved, the "Disapproved" box will be checked on the bottom of the CSA Form 325b, and the form will be signed and dated by the OED director or deputy director and returned (together with any supporting forms and documents) to the grantee.

(b) If the request is approved, the procedure followed by OED will depend on the nature of the amendment request, as follows:

(1) Amendments Which Neither Obligate New Funds Nor Extend the Grant Period. OED approval will be indicated by checking the "Approved" box on the bottom of the CSA Form 325b, and by signing, dating, and returning the form (together with any supporting forms and documents) to the grantee. If any modifications are made in the amendment as approved, such modifications will be indicated on the CSA Form 325b or on attached conditions or explanatory materials. If the amendment involves a budgetary change, OED will complete Column F of the CSA Form 325 submitted by the grantee with the amendment request and will return the 325 along with the 325b to the grantee. The CSA Form 325, with Column F completed, will now constitute the official, approved grant budget as amended.

(2) Supplemental Grants and No-Cost Extensions. OED approval of grant amendments involving the obligation of additional funds or extending the funding period beyond the current termination date is indicated in the same way as the initial grant or refunding, by executing a CSA Form 314, Statement of CSA Grant. For this group of amendments OED approval is not

shown on the CSA Form 325b, and that form is therefore not returned to the grantee. If the approved amendment involves a supplemental grant, the amount of the new funds awarded will be shown on the CSA Form 314 (not the total grant as amended). If the amendment is a no-cost extension, the CSA Form 314 will show zero (0) funds awarded but will indicate the new, extended termination date for the grant. If the amendment both supplements and extends the grant, the CSA Form 314 will indicate both the amount of new funds awarded and the new, extended termination date. For supplemental grants and no-cost extensions of four to 12 months, the CSA Form 325, with Column F completed by OED, will be attached to the CSA Form 314 to indicate the new revised budget (for either the current grant period amended or for the new extended period) as approved by OED. For no-cost extensions of four months or less, the grantee was not required to submit a CSA Form 325 and therefore no such form will be attached to the CSA Form 314. If OED approval of the amendment is contingent on certain conditions or modifications, special conditions or an explanation of program or budget changes will be attached to the CSA Form 314.

as

(c) Following receipt by the grantee of a signed CSA Form 325b approving an amendment which neither obligates new funds nor extends the grant, the grantee need take no further action, unless the amendment was approved subject to certain conditions requiring action by the grantee. Following receipt by the grantee of a signed CSA Form 314 approving a supplemental grant or no-cost extension, the grantee must sign the CSA Form 314, as in the case of the initial or refunding grant, and return it to OED to signify official acceptance of the grant or extension. If any special conditions are attached, the grantee must also take such action as is indicated.

Subpart 1067.17-Preparing a Budget for a Title VII Grant Under the Community Services Act (CSA Instruction 6710-8)

SOURCE: 41 FR 26689, June 29, 1976, unless otherwise noted.

§ 1067.17-1 Applicability.

This subpart applies to all applications for community economic development grants under title VII of the Community Services Act of 1974.

§ 1067.17-2 Purpose.

This subpart prescribes the requirements and procedures for preparing a budget for Title VII applicants.

1067.17-3 Preparation of budget forms for grant action.

(a) Budgets must be submitted for the following types of grant actions: (1) Initial and Refunding Grants, See CSA Instruction 6710-6.

(2) Budget Amendments. See CSA Instruction 6710-7.

(b) CSA Form 325, Budget Summary, is required to describe the proposed budget. The budget detail should, in most cases, be presented on CSA Form 325a, Budget Support Sheet. Salaries and wages are listed in Part I of the CSA Form 325a, and other expenses are listed in Part II. They should be grouped by the following budget categories:

BUDGET CATEGORY

(1) 1.1 Salaries and wages.

(2) 1.2 Fringe Benefits.

(3) 1.3 Consultants and Professional Services.

(4) 2.1 Travel.

(5) 2.2 Space Costs and Rentals.

(6) 2.3 Consumable Supplies.

(7) 2.4 Lease and Purchase of Equipment and Property.

(8) 2.5 Investment Capital.

(9) 2.6 Other Direct Costs. (10) 3.0 Indirect Costs.

81067.17-4 CSA Form 325a, Budget

Support Sheet (Parts I and II).

(a) This form will be used in all initial and refunding grants and normally in any amendment request involving an increase in program costs (whether or not supplementary funds are requested) or a no-cost extension for more than four months.

(b) It may even be necessary for certain amendment requests to shift funds among budget cost categories. However, there may be fairly simple amendment requests where the necessary budgetary back-up justification can be provided directly in the narrative on the CSA Form 325b, Request for Amendment to Grant, in which case the CSA Form 325a will be unnecessary.

(c) The CSA Form 325a should be completed before CSA Form 325, detailing the cost basis for each budget cost category. Under Part II more than one category may be shown on the same page if space allows. Additional copies of the 325a should be used as continuation sheets to complete Part II (or in unusual cases where the number of personnel exceeds the number of lines on the form, to complete Part I). Once the 325a is completed, the totals should be carried over to column D or E, depending on the type of grant action, of section I on the 325.

(1) Part I (Salaries and wages: Budget category 1.1). Items 1, 2, and 3 are selfexplanatory. Under items 4 and 5 enter the salary, wage or the valuation of services of all paid employees and volunteers participating in the program.

(1) Paid personnel. (A) All salaries of grantee employees paid with CSA project funds must be established as a part of a structured salary plan which sets salaries or salary ranges for each position or group of positions based on the responsibilities of the position, its relationship to other positions, and the salaries of comparable positions in other public or private non-profit agencies.

(B) Any person hired to fill a CSA funded position must be paid at a rate no higher than the rate established for that position in accord with most appropriate local comparability or at a rate comparable to that paid for simi

lar positions in the community from which the applicant was hired. (The grantee should have a record of the comparability data and be able to produce such upon request by CSA). For salaries in excess of $15,000 per year, comparability data should accompany the application. See OEO Instruction 6900-02.

(C) Salaries entered on the 325a are maximums. Applicants are cautioned that particular incumbents of any given position may be prescribed from receiving such maximums by the provision of OEO Instruction 6900-01, which limit entry salaries or salary increases to 20% or $2,500, whichever is smaller, of an individual's prior annual salary.

(D) A separate entry should be made on the 325a, item 4.A for each different position title. If two or more employees are employed in identical positions, only one entry should be made in 4.A with the number of employees in the position shown in parentheses after the position title. The entries in 4.B and 4.C should be the man-months and salaries for an employee in the respective position in 4.A multiplied by the number of employees in that position.

(E) On the Budget Support Sheet, part-time employees should be shown separately. Do not list two employees each working half a year as one employee working full-time. Where a position is part-time the fraction of fulltime employed (e.g. half-time or onethird time) should be shown in parentheses after the position title. The number of man-months shown for a part-time position should in all cases be based on full-time employment. For example, a half-time employee working for an entire year is considered to work six man-months.

(ii) Volunteers. If volunteer workers are going to participate in the program, their time may be valued for the purpose of calculating non-Federal share. Valuation methods are prescribed in §§ 1068.9-1 through 1068.9-5 (OEO Instruction 6802-1a). A person should be treated as a volunteer only if he receives no compensation from anyone for work in the program. All volunteer positions should be entered in item 5 of the 325a. When an employee is paid but an employer other than the grantee furnishes the services, he

should be listed under item 4 of the 325a and his services valued in 4.E at his regular rate of pay, provided these services are in the same skill for which he is normally paid. This would be the case, for example, if a private law firm assigned an employee to work one day a week in a CSA funded CDC office.

(2) Part II (Budget support data: Cost categories 1.2–3.0). (i) Estimated costs or valuations for all projected program needs, other than salaries, wages and volunteer services are to be entered in this part.

(ii) Items 1, 2, and 3 are self-explanatory.

(iii) For each budget item enter:

(A) Its cost category number (see section below on cost categories for further guidance) under column A.

(B) A description of the item and its basis for valuation under column B (NOTE: For items under Cost Category 2.5-Investment Capital the basis for valuation is not required. Only identify, to the extent possible, the ventures or types of ventures to be invested in, including revolving loan or loan guarantee funds, where applicable. For all entries in other cost categories show how the Federal and non-Federal estimates were numerically derived. See sections below on cost categories for further guidance.)

(C) The Federal share of its estimated cost under column C.

(D) The non-Federal share of its estimated cost or valuation, under column D.

(iv) All budget items under Part II are to be grouped under the following cost categories:

(A) Cost category 1.2: Fringe benefits. (1) This category includes not only such items as health insurance, life insurance, and retirement contributions, but also workmen's compensation, unemployment taxes, and social security taxes.

(2) If fringe benefits shown are a percentage of total compensation, the applicant should identify each benefit and its share of the overall percentage figure, e.g., employer's contribution for social security.

(3) Fringe benefits must cover at least social security and workmen's compensation. Other options which may be included in fringe benefits are

health insurance, life insurance, and retirement. However, when these fringe benefits do include the added options, the options should be equitable to both high and low salaried employees. Plans which are only affordable by high salaried people should not be acceptable in CSA funded antipoverty programs. A 15% fringe total is average for title VII grantees.

(B) Cost category 1.3. Consultants and Professional Services. (1) This category includes legal fees, accountants' fees, consultants' fees, and the like.

(2) A reasonable percentage of the budget (depending on specific programs and need for training) may be set aside for consultant and professional services. The two most important areas which must be covered (whether with Federal or non-Federal funds) are audits and legal fees.

(i) Audits. CSA grant funds may not be used to pay for more than one audit annually, except where CSA requests in writing additional audits. For detailed CSA audit requirements see OEO Instruction 6801-1. Generally, the cost of an audit will depend on the size of the grant, whether or not there are any delegate agencies, where the records are located (in one place or scattered) and how well the grantee's accounting procedures were set up. Audit costs will also vary in different localities. A cost of $3,000-$5,000 for an audit on a $1 million grant is considered reasonable. The grantee may wish to talk with several CPA's in the area before selecting the contractor to insure the CPA's estimate is fair. For title VII grantees which have ventures in addition to administrative funds to audit, the cost of the audit will be higher.

(ii) Legal fees. Legal fees are paid on a case-by-case basis. title VII grantees' legal fees average $2,000-$4,000 per year.

(iii) Other consultant service. May include board training, staff training, management training, feasibility studies and surveys. In estimating the other consultant costs the following should be considered: Number of days, daily fee rate, cost of transportation, and per diem. Normally $100 per day is the maximum daily fee permitted. However, in view of the highly technical specialists frequently required in certain ventures and business planning,

fees in excess of $100 per day are allowable for certain title VII grantees under conditions described in the general or special conditions to such grants. Where such higher fees are allowable an average of $150 per day is usually quite adequate.

(C) Cost category 2.1: Travel. (1) Cost of travel should be broken down in Part II of the 325a in terms of travel within grantee's target area, and travel outside of the area. Items covered should include number of employees or board members expected to travel, number of miles at x cents a mile, or number of trips outside target area and average cost of trip and per diem. See example below:

(i) Number of travellers × number of miles x number cents per mile = cost of travel in target area.

(ii) Number persons travelling × number trips per person x average cost per trip (air fare + per diem + other coststaxi, phone, etc., usually $10 per day per person is adequate) = cost of travel outside target area.

(D) Cost category 2.2: Space costs. (1) Projects located in urban areas will normally have to spend more money per square foot of space than projects located in rural areas. The Office of Economic Development can provide to grantees upon request estimates for the cost per square foot of space in all cities in the country which GSA uses as a guideline in determining reasonable costs.

(2) GSA estimates that approximately 150 square feet of space as an average is needed for professional employees. For clerical positions approximately 60-75 square feet of space is needed per person plus file space. In general, an average of 105 square feet per person is a reasonable allotment of space. This does not include meeting rooms, etc. Space costs are determined by multiplying the number of employees x square feet per person x the cost per square foot of the space. The cost of space per square foot normally includes maintenance and utility charges. Grantees should generally not enter into a lease where these charges are not included. An exception might be made for grantees who own maintenance companies and may want to channel this money into their own

businesses. In these cases, the cost per square foot of space should be reduced to accommodate these charges. Separate charges for maintenance should be accounted for under cost category 2.6— Other Direct Costs.

(3) It is also recommended that a grantee take a lease for the period of the grant with an option to renew. A short lease which would expire during the course of the grant period may cause the grantee to have to move. A lease longer than the period of the grant may cause legal problems in the event the grantee does not have funds to continue.

(E) Cost category 2.3: Consumable supplies. Consumable supplies include desk top items-pens, pencils, paper, cellophane tape, staples, etc. If a grantee publishes a newsletter or if a support grantee provides a service requiring frequent contact with other grantees through the mails, the costs will be higher than average.

(F) Cost category 2.4: Lease and purchase of equipment and property. The rule of thumb to use in determining whether or not to lease or purchase equipment and property is: If 3 years' leasing cost is more than the purchase price plus servicing costs, it is more economical to purchase the equipment. If a grantee is leasing equipment, it frequently is an advantage to do so with the option to buy.

(1) Proposed purchases of property with a unit cost of more than $500 must be specifically approved by OED. Such purchases should be itemized in Part II of the 325a.

(G) Cost category 2.5: Investment capital. (1) This category includes such items as transportation of things, repairs, utilities, telephone, postage, insurance, bonding, etc.

(2) This category also includes stipends which may be paid to program beneficiaries to support them during their participation in a program.

(3) Dues for membership of the grantee in professional organizations may be included in this category, but only if the grantee's membership can be shown to be related to the purposes of the CSA grant. Dues paid for individual memberships, as contrasted with agency memberships, in professional organizations will not be allowed.