Temporary Assistance for Needy Families Program Instruction |
Administration
for Children and Families Office of Family
Assistance |
No. TANF-ACF-PI-2007-03 |
Date: July 18, 2007 |
TO: |
Indian
Tribes who submitted Temporary Assistance for Needy Families (TANF) plans or
amendments, States, and other interested parties. |
SUBJECT: |
Pre-award
Costs for Potential Tribal TANF Grantees. |
REFERENCES: |
Old OMB
Circular A-87, codified now at 2 CFR Part 225, and the Cost
Principles for State, Local and Indian Tribal Governments. |
PURPOSE: |
This
Program Instruction addresses whether TANF funds can be used for pre-award
costs for potential Tribal TANF grantees. |
BACKGROUND: |
2 CFR Part
225, defines pre-award costs as those incurred prior to the
effective date of the award directly pursuant to the negotiation and in
anticipation of the award where such costs are necessary to comply with the
proposed delivery schedule or period of performance. Such costs are allowable only to the extent
that they would have been allowable if incurred after the date of the award
and only with the written approval of the awarding agency. We have been asked whether or not expenses associated with planning to operate a TANF program prior to the approval of the plan qualify as pre-award costs and thus can be paid retroactively with TANF funds once the plan is approved. This Program Instruction responds to this question. |
POLICY: |
Planning
expenses associated with the development of an acceptable TANF plan prior to
the approval of such a plan cannot be retroactively charged against the TANF
grant. Such costs need to be covered
by other non-federal Tribal funds.
This is because:
Use of
TANF funds for pre-award planning will result in a determination that a TANF
misuse of funds penalty has occurred. |
EFFECTIVE DATE: |
Immediately
|
INQUIRIES: |
Inquiries and comments should be
directed to the appropriate Administration for Children and Families (ACF)
Regional TANF Program Manager. |
|
|
|
Sidonie Squier Director Office of Family Assistance |