Division Policy 6.22

SUBJECT

Policy and Procedure: Period of Performance

EFFECTIVE DATE

10-1-2025

AMENDED

N/A

RECISSIONS

N/A

EXPIRATION DATE 

This policy will be reviewed annually and updated as needed.

PURPOSE 

To communicate guidelines and procedures by which the Florida Division of Blind Services (FDBS) will demonstrate the process to ensure sound financial management of the federal grant awards so that all obligations and expenditures are correctly tracked and recorded within the period of performance and financial reporting is accurate.

AUTHORITY

CFR Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

2 CFR § 200.1 – Definitions

2 CFR §200.302 Financial management
2 CFR §200.306 Cost sharing or matching
2 CFR §200.307 Program Income
2 CFR §200.403 Factors affecting allowability of costs
2 CFR §200.404 Reasonable costs
2 CFR §200.405 Allocable costs

34 CFR Part 361 – State Vocational Rehabilitation Services Program

34 CFR §361.60 Matching Requirements
34 CFR §361.62 Maintenance of Effort (MOE)
34 CFR §361.63 Program Income  

Chapter 215 Florida Statutes

Section 215.422, F.S. – Payments, warrants, and invoices; processing time limits; dispute resolution; agency or judicial branch compliance

Accounting Codes Overview

Obligations must be tracked, recorded, and reported to a particular grant award under period of performance. FDBS manages this federal requirement using the Florida Accounting Information Resource (FLAIR) grant number. FLAIR is the state’s accounting system.  This grant number is part of the chart of accounts.

The information is entered into FLAIR by the Department of Education’s Revenue Management section. FDBS internal controls are built into the processes as described below.

When FDBS receives a new grant, the Bureau Chief of Operations and Compliance creates a spreadsheet and submits it to Risk Management with the codes.

Grant Number Format

The grant number is generated using the following format, for example:

FDBS Vocational Rehabilitation

Match – Basic Support 110

Program Income

Older Individuals who are Blind (OIB)

Blind Babies, Children, and Adults Programs

These programs are General Revenue funded, and the code does not change from year to year.

An expansion option is applied as a unique identifier to the grant code to further track expenditures. It is a two-digit code. You must also use an organization code and object code…. For FDBS each office, section, and district has its own organization code.  The object code is based on the service we’re paying for.

If the incorrect expansion option is used, the Operations Management Consultant Manager prepares a monthly grant award spreadsheet from FLAIR reporting that is reconciled with the Bureau Chief of Operations and Compliance (or designee). Any anomalies are corrected. Procedures are linked below and can be located at S:\Fiscal\RSA Procedures. 

RSA 17 Procedure_1.2025_.docx 

Tracking and Recording Obligations

All expenditures incurred against an obligation must be tracked and reported according to when the obligation was incurred, not when the liquidation occurs. According to The Education Department General Administrative Regulations (EDGAR) at 34 C.F.R. § 76.707 , obligations should be recorded in the tracking system according to the following table. FLAIR is the statewide accounting system, and AWARE is the case management system used by FDBS. FDBS utilizes automated processes for obligation assignment whenever possible.

In accordance with 34 CFR §76.707, FDBS will use the following outline as a basis to identify when obligations are made, depending on the nature of the purchased property or service. While the table references obligations made by a subgrantee, FDBS is not authorized to issue a subaward or use a subgrantee for Vocational Rehabilitation or Supported Employment.

If the obligation is for: (a) Acquisition of real or personal property.

The obligation is made: On the date on which a binding written commitment to acquire the property is made.

This category can include vehicles, furniture, and equipment.

FDBS incurs an obligation on the date a binding written commitment is made to acquire the property pursuant to State Purchasing requirements in Chapter 287, F.S. The obligation is the date in which FDBS places the order.

Vehicle purchases are coordinated through the state office in the Bureau of Operations and Compliance. All other real or personal property is purchased at the district or local office level through MyFlorida Marketplace which has the levels of authority for the purchasing process.

FDBS will ensure that state procurement laws have been followed and solicit vendors who are on State Term contract. This process includes:

*DBS ensures that prior approval is requested and received from RSA before a purchase is made applicable.

If the obligation is for: (b) Personal services by an employee of the State or subgrantee.

The obligation is made: When the services are performed.

FDBS incurs an obligation when services are performed. State employee wages and associated costs are obligated after the employee has worked the time for which wages are paid. FDBS employees are paid on the last workday of each month. Employees must record time worked in the State system, People First. Obligations are determined by the employee’s salary or hours worked for non-salaried employees. All time is verified and approved by the employee’s supervisor as documented in the automated system. FDOE payroll audits leave hours.

This process is automated based on time recorded in the system. Since employees are paid on the last day of each month, FDBS will rarely encounter a situation where this obligation will cross periods of performance. However, in instances where retroactive pay is warranted for an employee, FDBS will review to determine if such retroactive pay is within a carryover period (for a previous period of performance) or if such pay falls within the year of appropriation for the new grant award.

If the obligation is for: (c) Personal services by a contractor who is not an employee of the State

The obligation is made: On the date in which the state makes a binding written commitment to obtain the services.

FDBS incurs an obligation on the date in which the purchase order is effective, and the obligation is encumbered in FLAIR.

Personal services by a contractor who is not an employee of the State are procured through the state, district, or local office through MyFlorida Marketplace which has the levels of authority for the purchasing process. All purchase orders are reviewed by the Bureau Chief of Operations and Compliance (BCOC) to ensure that coding is correct. If coding is incorrect, the BCOC applies the correct code.

FDBS will ensure that state procurement laws are followed including:

If the obligation is for: (d) Performance of work other than personal services.

The obligation is made: On the date on which the State or sub grantee makes a binding written commitment to obtain the work.

All other services not included in category C, for example case services provided to consumers.

Administrative Costs:    

The VR regulations specify the administrative costs that are permissible within the VR program (34 C.F.R. § 361.5(c)(2)).

All other services not included in category C are procured through the state, district, or local office through MyFlorida Marketplace which has the levels of authority for the purchasing process. All purchase orders are reviewed by the BCOC to ensure that coding is correct. If coding is incorrect, the BCOC applies the correct code.

FDBS will ensure that state procurement laws are followed including:

In accordance with Section 110(d)(2) of the Rehabilitation Act, none of the funds reserved for Pre-Ets may be used to pay for administrative costs.

Case Service Costs:

The process is managed in AWARE using the auto budget option. The District Administrator and Assistant District Administrator have the authority to change the budget from Pre-ets to VR but otherwise, the system automatically applies the appropriate grant award.

Fund Source: This element tracks the type of funding available to FDBS down to an award level (i.e. federal awards, state general revenue match). AWARE allows funding priorities to be designated to allow the system to automatically apply obligations through the auto-budget selection process.

Special Case Characteristics and Special Programs: These elements allow for the identification of Pre-ETS, Supported Employment, and Older Individuals who are Blind Obligations. 

Budget: Budgets are established for each fund source for a particular time period in alignment with Period of Performance. While fund sources manage priorities in the auto-budget selection process, the corresponding budgets track available funds. Budgets are established and expired according to available funding. 

If the obligation is for: (e) Public utility services

The obligation is made: When the State or subgrantee receives the services.

FDBS incurs an obligation when the service is received. FDBS uses a blanket purchase order process for public utility services as these are reoccurring purchases through the State Fiscal Year.

Purchase orders are created in MyFlorida Marketplace at the beginning of each SFY using historical data as the basis for the purchase order amount. If a bill crosses a federal fiscal year (FFY), the FDBS may use carryover to pay the entire purchase order.

If the obligation is for: (f) Travel

The obligation is made: When the travel is taken.

FDBS incurs a travel obligation when the travel occurs. State employee travel is governed by 112.061, F.S., which describes travel authorization and approval requirements.

Employees must be granted approval before traveling. The process is as follows:

Once the travel is complete, the employee will:

Travel purchases, such as airline tickets and registration fees for conferences are usually required to be purchased in advance. Such purchases will be obligated accordingly.

If the obligation is for: (g) Rental of real or personal property

The obligation is made: **When the State or sub grantee uses the property.

FDBS incurs an obligation of rental expenses when FDBS uses the property or equipment. 

FDBS is required to encumber rental of real or personal property on an annual basis, which begins July 1 to pay the annual purchase orders from October 1 through June 30. FDBS uses the carry forward strategy to satisfy the remaining obligation.

Applicable Credits

Applicable credits refer to transactions that offset or reduce direct or indirect costs allocable to a Federal award. Examples of such transactions are purchase discounts, rebates or allowances, recoveries or indemnities on losses, insurance refunds or rebates, and adjustments of overpayments or erroneous charges. To the extent that such credits accruing to or received by the recipient or subrecipient relate to allowable costs, they must be credited to the Federal award either as a cost reduction or cash refund, as appropriate (2 CFR 200.406(a)).

Applicable credits are infrequent but may include refunds due to overpayments or duplicate payments. In such an event, internal controls are in place and described below to evaluate each occurrence and determine the cause.

If FDBS makes an overpayment and the grant award is still open, the Operations Management Consultant (OMC) Manager deposits the refund into that grant award. If the grant award is closed, the OMC Manager will reopen the grant and return the refund to Rehabilitation Services Administration (RSA).

The OMC Manager explores the nature of the error. Staff coaching, training, and personnel action may be taken depending on the results of the review.

Refunds are managed according to the original source of the funds. The OMC Manager deposits the refund into that grant award. If the grant award is closed, the OMC Manager will reopen the grant and return the refund to RSA.

Starting October 1, 2023, the U.S. Department of Treasury will no longer accept refund checks on behalf of the U.S. Department of Education (ED). After September 30, 2023, refunds to ED must be sent via Fedwire as an Automated Clearinghouse (ACH) transaction initiated through ED’s Grants Management System (G6) (g6.gov) or through a check sent directly to ED.

To Return Funds Electronically via the G-6 system:

For grantees that need to refund money to a closed award (or an award in Suspension), the person with the Payee role in G6 from the institution can do so via G6. They will follow the process as described in the return funds procedure linked below.

Returning funds electronically via G-6 Procedure_.docx

Deposits into State Treasury

When an expenditure is made from state funds, and a subsequent refund is received the funds are returned to the State Treasury. The OMC Manager investigates where the refund originated, deposits the refund into the bank, and posts it to the grant the initial expenditure was processed from.

LIQUIDATIONS AND GRANT CLOSEOUT

DBS must liquidate all obligations incurred under the Federal award by the terms and conditions of the award. This means DBS must make final payments after goods or services were received during the period of performance and/or cancel obligations when goods or services were not received during the period of performance.

Prior to the end of the FFY, the Bureau Chief of Operations and Compliance and Operations Management Consultant Manager reviews FDBS outstanding obligations and the outstanding grant award balance. If there is still a grant award balance, they also move some of the first quarter expenditures to the older grant to reduce the balance and also make a Journal Transfer entry.     

The BCOC and OMC Manager ensure that the obligation occurred during the carry forward period before moving expenditures to the older grant.

Managing unliquidated obligations effectively allows for the proper administration of the award and stewardship of award funds and timely and accurate reporting. DBS staff must adhere to established requirements for these purposes.

To ensure compliance, a monthly Grant Report is completed by the OMC Manager and then routed to the BCOC, Division Director, and the FLDOE Comptroller for review.

DBS closes out Federal awards when it determines that all applicable administrative actions and all required work of the Federal award have been completed, but not later than the liquidation date noted above. DBS will submit, by 120 calendar days (January 28th) after the end date of the period of performance, all financial, performance, and other reports as required by the terms and conditions of the Federal award (2 CFR 200.344).DBS draws down all grant funds prior to submitting the report on January 28th. 

PROGRAM FISCAL REQUIREMENTS

VR Carry Forward

Carry forward is the process where unexpended funds allocated for a grant award are “rolled over” or carried forward into the next budget period.

Section 19(a) and (b) of the Rehabilitation Act of 1973, as amended (Act), permits DBS to carry over Federal funds, which were not obligated or expended during the FFY of Appropriation (including funds received during reallotment), for obligation and expenditure during the subsequent FFY provided the DBS complied with applicable non-Federal share requirements.

This means that DBS may carry over the unobligated balance of Federal funds for one FFY beyond the FFY of Appropriation so long as the applicable match requirements have been satisfied.

DBS will spend and account for the federal Vocational Rehabilitation grant according to the terms and conditions of the grant, state laws, and applicable DBS procedures.  If DBS does not fully obligate its federal funds by the end of an applicable period of performance, and has satisfied its match requirement, DBS may obligate the remaining fundings during a carry forward period of one additional fiscal year.

DBS may carry forward the unobligated balance of federal funds for one FFY into the next FFY or budget period when the division:

DBS and Division of Vocational Rehabilitation (DVR) meet quarterly to discuss the status of meeting the state-level matching requirements to confirm carry forward eligibility. After reviewing State level non-Federal share, if neither of the divisions VR awards have met the requirements to carry forward Federal funds, financial obligations must be incurred by the end of the FFY of appropriation (4th quarter) and liquidated not later than 120 calendar days after the end of the FFY of appropriation, as specified in the Grant Award Notice (GAN) 2 CFR § 200.344. In this instance, the Period of Performance and the FFY of Appropriation are the same because they both end on September 30 of that FFY. Period of performance = one year.

After reviewing State level non-Federal share, if DBS’ VR award meets the carryover requirements by the end of the FFY of Appropriation, the Period of Performance will be extended to include the carryover year. DBS can then incur new financial obligations against Federal award funds during the carryover year in accordance with  Section 19(a)(1) of the Rehabilitation Act, the period of performance will be revised on the GAN to reflect the carryover year as part of the Period of Performance for that grant award. In this circumstance, the period of performance = two FFYs (the FFY of appropriation plus the carryover year).

DBS and VR submit the fourth quarter Federal Financial Report (RSA-17) to RSA. If the required criteria are met, DBS receives a revised GAN that includes the carryover year. 

Supported Employment Carry Forward

DBS does not receive a grant award for Supported Employment; however, supported employment services are provided through its Vocational Rehabilitation grant award.

Vocational Rehabilitation (VR) contracted training services allows DBS to partner with community-based programs to provide VR services, to include Supported Employment Services, which include the training and support needed to enable blind and severely visually impaired persons to be successful in competitive and integrated employment settings.

Pre-ETS 15% Reserve Funds

Section 110(d)(1) of the Rehabilitation Act of 1973, as amended (Rehabilitation Act), requires the state to reserve at least 15 percent of its state allotment, under the State Vocational Rehabilitation (VR) Services grant, for the provision of pre–employment transition services to students with disabilities under Section 113 of the Rehabilitation Act. The primary purpose of Pre-ETS provided or coordinated by DBS is to help students identify career interests and skills that can be further explored in subsequent individualized transition and other VR services under an individualized plan for employment (IPE).

The state allotment serves as the basis for the reservation of funds requirement and refers to the Federal VR funds awarded pursuant to Section 110(a) of the Rehabilitation Act.

However, section 110(b)(3) of the Rehabilitation Act makes clear that funds received during reallotment are considered an increase to the state’s allotment. Consequently, receiving additional funds during reallotment means that the state will need to calculate a proportionate increase to the amount of funds it must reserve for the provision of pre–employment transition services.

Similarly, funds relinquished during reallotment are considered a reduction to the state’s allotment. Relinquishing funds during reallotment means that the state may calculate a proportionate decrease to the amount of funds it must reserve for the provision of pre–employment transition services.

When determining compliance with the 15 percent Pre-ETS reserve funds, the State’s allotment is the lessor of:

  1. The maximum amount of the Federal VR award funds matched; or
  2. The amount of the net Federal VR award (at the end of the period of performance)

This means States must monitor expenditures throughout the lifecycle of the VR grant award since the 15 percent reserve is not a fixed number and may fluctuate based on a State’s ability to match its VR award funds, maintenance of effort penalties, and participation in reallotment.

Because both sections 110(d) and 113 of the Rehabilitation Act are clear that the state must reserve and use at least 15 percent of its total VR allotment for a specific purpose (pre–employment transition services) that benefits a specific population (students with disabilities), DBS must implement administrative methods and procedures that ensure proper data collection and financial accountability of these reserved funds, as required by 34 CFR 361.12. Moreover, the State of Florida’s accounting procedures must be such that the designated state unit is able to accurately complete all required forms, including financial reports, that show the reservation and use of these funds for this purpose, as required by 2 CFR 200.302.

Since the 15 percent reserve funds is a statewide requirement, DBS will meet quarterly with DVR to review spending levels and projections for the year.  The 15 percent reserve requirement can be carried forward and met in the second year, provided the carry forward provisions are met.

MAINTENANCE OF EFFORT

Maintenance of Effort (MOE) is a legislative, regulatory, or administrative requirement that a grant recipient must maintain a specified level of non-Federal expenditures (or the grant recipient’s effort) to receive Federal grant funds.

The Rehabilitation Act requires states to maintain a level of non-Federal expenditures that is at least equal to the non-Federal expenditures for the VR program from two years prior.

States must report all non-federal expenditures in the FFY in which those expenditures are incurred for purposes of satisfying the MOE requirement because MOE is determined on an FFY basis, not on the basis of a period of performance for an entire grant award.  Non-federal obligations and expenditures incurred during the carryover year do not count toward the prior FFY of appropriation’s match requirement but will count toward the current FFY’s MOE requirement.
MOE is a statewide requirement. DBS and DVR coordinate with one another to ensure compliance with MOE requirements.

DBS’ process of ensuring the MOE expenditures are properly tracked and reported and matching requirements are met by the OMC Manager and is located at:

S:\Fiscal\Procedures and is linked below;

MOE and Match Procedures 4.10.25.docx

DBS reports all of its non-Federal expenditures for new and replacement equipment, maintenance of equipment, and management services paid with the State’s Randolph-Sheppard Vending Facility Program set-aside funds and State appropriated funds as required under 34 C.F.R. § 361.12 and 2 C.F.R. § 200.302 and consistent with the instructions for completing the RSA-17 state appropriated funds spent on any allowable activity under 34 C.F.R. § 361.49(a)(5) must be reported as VR non-Federal share. 

MATCH

Requirements for match are promulgated under 34 CFR 361.60. Compliance with the matching requirement is assessed on a statewide basis. When determining compliance in states with blind and general agencies, the non-Federal share is calculated for both agencies individually and at the state level; however, compliance is determined only on the basis of the state-level calculation.  Non-Federal funds re-obligated after the fourth quarter, during the carryover period, are not counted as match for the period of performance for the award.

Match requirements for the State VR Services, State Supported Employment (SE) Services, and Independent Living Services for Older Individuals who are Blind (OIB) programs differ as follows:

**Note: At least a 50% match is required for the construction of a facility for community rehabilitation program purposes (34 CFR 361.60(a)(2)).

This is for Supported Employment funds reserved and expended for supported employment services to youth with the most significant disabilities. FDBS does not receive the Supported Employment grant at this time.

DBS utilizes the Match Calculator provided on the RSA website to calculate all required match contributions under the above programs.

Match can only be reported as such after an obligation has been incurred with non-Federal funds or the expenditure has been made. Expenditures reported as match are subject to the exact requirements as Federal funds under 2 CFR 200.306(b).

Match must meet the following criteria:

Unrecovered indirect costs, including indirect costs on cost sharing or matching, may be included as part of cost sharing or matching only with the prior approval of the Federal awarding agency. Unrecovered indirect cost means the difference between the amount charged to the Federal award and the amount that could have been charged to the Federal award under the recipient’s     approved      indirect cost rate.

Except for OIB (34 CFR 367.63), third-party in-kind contributions specified in 2 CFR 200.306(b) may not be used as match.

Program income cannot be used as match. 34 CFR 361.63(c)(4), 34 CFR 363.24, 34 CFR 367.65(b)(3).

Matching requirements must be met by the end of the year of appropriation (September 30/fourth quarter). DBS must track unliquidated obligations for the Older Independent Living for Older Individuals who are Blind awards on the SF-425 Federal financial reports, especially the fourth quarter. If the unliquidated obligations reported on the fourth quarter SF-425, counted as match, are not liquidated, DBS must adjust the amount reported as unliquidated obligations as of the fourth quarter to reduce the obligations that were not liquidated.

Since the RSA-17 requires reporting of previously reported unliquidated non-Federal share liquidated after the 4th quarter, the report features a built-in process for tracking non-Federal share obligated in the fourth quarter and later canceled. Funds for obligations reported as match on the fourth quarter RSA-17, canceled during the carryover period, may not be re-obligated or liquidated for expenditures during the carryover period and counted as match for the period of performance for the award.

The general provision for non-federal (state) match under 34 CFR 361.30(b) requires expenditures made under the vocational rehabilitation services portion of the Unified or Combined State Plan to meet non-Federal share under this section must be consistent with provisions of 2 CFR 200.306(b).

The FDBS primary source of match is State general revenue, and the Randolph-Shepherd (RS) set aside. 

The FDBS goal is to obligate match funds by June 30 of each year to ensure that match funds are liquidated by September 30. FDBS strategy is to use match funds for payroll and case services. In addition, the Bureau Chief of Operations and Compliance reviews all available general revenue funds to ensure that FDBS is utilizing any available source of funds. This serves as an audit of FDBS financial position.

Program Income

2 CFR §200.1 defines Program Income as gross income earned by the recipient that is directly generated by a supported activity or earned as a result of the Federal award during the period of performance except as provided in §200.307(c). Program income includes but is not limited to income from:

Program income does not include interest earned on advances of Federal funds; and, except as otherwise provided in Federal statutes, regulations, or the terms and conditions of the Federal award, program income does not include rebates, credits, discounts, and interest earned on any of them.

34 CFR§ 361.63(b) provides information about sources of program income including but not limited to:

FDBS derives its Program Income from Social Security reimbursements. FDBS may use program income to cover program costs and spends program income prior to drawing down VR grant funds. If DBS uses program income for VR services, expenditure of such funds will follow the same guidelines that apply to the grant to include:

FDBS primarily transfers program income to the older blind program. Procedures can be provided upon request.

The process for receipt and dispensation of program income is linked below and can be found at.

FEDERAL FINANCIAL REPORTING

Financial reports are prepared according to each federal grant’s requirements as follows.

The final financial reports MUST be submitted no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award (2 C.F.R. §§ 200.329 and 200.344(b)). While the final report may be submitted before this date, it may not be later than January 28th.

The policy will be reviewed annually and revised as necessary.

The original was signed by Robert L. Doyle, III, Director, on 12/16/2025. 

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DISCLAIMER: Links on the Florida Division of Blind Services (DBS) website that are directed toward websites outside the DBS, provide additional information that may be useful or interesting and are being provided consistent with the intended purpose of the DBS website. DBS cannot attest to the accuracy of information provided by non-DBS websites. Further, providing links to a non-DBS website does not constitute an endorsement by DBS, the Florida Department of Education or any of its employees, of the sponsors of the non-DBS website or of the information or products presented on the non-DBS website.