In the fiscal guidance, it states to indicate in NOVA under fiscal declaration if there are changes. When in NOVA, in the CFAD changes to fiscal agent, structure, and allocations can be made and they would need to indicate a change and then add a description of what change is happening and why.

When you indicate a change this will trigger CAEP to fund appropriately.

Please see the CCC Budget & Accounting Manual and the CAEP Fiscal Management Guide Section 12, page 22 ( the college info is on page 24) . Community College Districts must adhere to the following reporting requirements:

The following requirements address the appropriate accounting for community college districts receiving CAEP funds either as a fiscal agent, as a participant/provider, or both. The treatment of funds received as the fiscal agent for disbursement to other participants is different than for funds received by the district for the direct costs of providing adult education services.

Fiscal Agent
Fiscal Agent Funds received from the State under a fiscal agent agreement that are then disbursed within 45 days to other adult education providers should be recorded in the restricted General Fund as 8900 “Other Financing Sources” using revenue object code 8970 “Fiscal Agent Pass Though”. Disbursements should be coded to “Other Outgo-Other Transfers” using expenditure object code 7400 “Other Transfers”, excluding indirect cost recovery. Under CAEP, districts have no fiduciary requirement regarding the use of the funds by the other participants. The only obligation of the fiscal agent is to disburse within 45 days.

Participant/Provider
If a portion of the funds received as a fiscal agent are for the district’s own adult education program, then those funds should be recorded initially as described above. A transfer (other outgo) will be recorded to the fiscal agent funds for the district’s share. The district will recognize its share of the funds in the restricted General Fund using revenue object code 8620 “General Categorical Programs”.
Expenditures should be recorded in expenditure object codes 1000-6000 as appropriate. Likewise, if the district is not the fiscal agent and is receiving CAEP funds, those funds should be recorded to the restricted General Fund using revenue object code 8620 “General Categorical Programs” and expenditure object codes 1000- 6000 as appropriate.

Yes - you are able to complete an allocation amendment for last year today. You are able to make allocation amendments on fund years at anytime until the funding expires.

The rules are everyone gets COLA unless you have cause under EC 84914 for them not to get the COLA. Having a fiscal agent doesn’t affect the COLA requirement. It just makes it easier to move money around. So as long as you have the discussion about who gets COLA, and who doesn’t – and if everyone gets it – the CFAD will show that documentation.

The one issue with having the fiscal agent “hang on” to the money is that trailer bill language (which is now code) mandates that fiscal agents must release the funds within 45 days of receipt. So the fiscal agent can’t hold the funds. But the consortium could make a decision to fund future projects (with everyone pitches in X amount), and then when those expenses come due, the fiscal agent deducts or pays that amount from what should be going out that month. It’s a little complex because there could be delays in payment from the state. So it could work – but it’s a lot of work for the fiscal agent. And you would have to figure out who is paying for the future projects (who gets the invoice), how that is deducted from the member allocations, and make sure the fiscal agent actually has the funding in their account (and hasn’t violated the 45 day hold requirement).

A better solution – go through the CFAD process. Then after its submitted agree to hold X amount for consortium projects. Also agree upon who will pay for these projects (fiscal agent or another member). Then do an one-time allocation amendment to move funds to the agreed upon member and they pay the bills. This method will keep you from violating the 45 day rule.

Per the CAEP Office, the pass through for a fiscal agent is limited to 45 days upon receipt of funds. They can charge up to 5% indirect, but that is negotiable. Some fiscal agents charge nothing, some charge a small amount, and some charge more. So – it varies.

The fiscal agent must follow the fiscal education code for CAEP.

Plus a community college fiscal agent must follow the Budget and Management Manual.