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Grant Accountability and Transparency Act
Fiscal and Administrative Internal Control Questionnaire
All grantees must annually complete and submit a Fiscal and Administrative Risk Assessment
(Internal Control Questionnaire (ICQ). The ICQ is found in the Governor’s Office of Management and
Budget GATA Unit (GATU) Grantee Portal. ISBE will not approve fiscal year grant applications, nor
will awards be made, without completion of the ICQ.
Three crucial systems must be completed and linked in preparation for grant applications.
• Active Unique Entity ID (UEI) registration in the federal System for Award Management
(SAM.gov).
• Approved ICQ in the GATA Grantee Portal.
• Approved Organizational Risk Assessment, which also includes the Performance Reporting
Assessment, located in IWAS under active grants.
As your cognizant agent, ISBE is required to impose conditions for grantees with elevated risk, as
assessed by the ICQ. For reference, the portal provides access to prior year ICQ responses. FY23
risk conditions
Detailed instructions created by GATU are included below and may not be specific to ISBE grantees.
A GATA profile will need to be created if your organization has yet to receive a grant from the state of
Illinois or has not previously registered in the GATA Grantee Portal.
Go to the GATA Grantee Portal and click “Create Account” to create a GATA account. Follow the
prompts to create and activate it. (See below “Creating and Recovering an Illinois Public Account.”)
Once the account is activated, go back to the GATA Grantee Portal and click “Sign In.” The system
will redirect you to Illinois.gov to enter your username and password. Please note the system will
automatically add an extension to the username; you do not need to remember or note the
extension. Also, it is important to always start at the link above because starting directly at Illinois.gov
will generate error messages.
Grantees with active profiles should annually verify contact and portal access.
Pending access must be approved by your portal administrator or GATU.
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The transition from UEI (DUNS) to UEI (SAM) is a federal, governmentwide initiative. ISBE
encourages all grantees to review their SAM ID and account status at SAM.gov. Registrations must
be renewed annually, and entities should begin the renewal process at least 16 weeks prior to
expiration. Links below will assist with both new and renewal profiles. SAM.gov, CAGE, NCES,
ePS/IWAS profile must match to validate.
SAM Registration – NEW
SAM Registration – Updating or Renewing
The GATA Grantee Portal screen should show all status as “Good” after you log in. Please log into
the SAM.gov to complete the registration process. All grantees must maintain an active SAM/UEI
number and registration in SAM.gov. Such registration must be renewed annually. Expired or invalid
SAM accounts will delay the ISBE grant application process as ISBE will not approve grant
applications nor will awards be made to grantees with expired SAM accounts.
SAM.gov accounts marked private or not registered in SAM.gov display as UEI not found.
Section 2: Quality of Management System 2 CFR 200.302
This system encompasses the organization’s accounting system as a whole and helps maintain
effective control and accountability for all funds, property, and other assets. Grantee must identify the
type of accounting system utilized, its functionality, and system safeguards.
Safeguards include, but are not limited to:
• Separation of accounts to track receipts and non-duplicated payment/expenditures.
• Proper separation of duties for purchase approval, record keeping, and cash management.
• Monthly general ledger/bank statement reconciliation.
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Section 3: Financial and Programmatic Reporting 2 CFR 200.328
The specifications of each grant determine both reporting requirements and if performance metrics
are tied to a grant budget.
Reporting information must be collected with the frequency required by the terms and conditions of
the federal award. Performance metrics measure the recipient's performance to show achievement of
program goals and objectives, share lessons learned, improve program outcomes, and foster
adoption of promising practices.
Organizations should ensure they have the knowledge, fiscal/programmatic ability, and skills to
complete performance reports and budgets.
Further information can be found in the ISBE State and Federal Grant Administration Policy, Fiscal
Requirements and Procedures Handbook.
Section 4: Ability to Effectively Implement Requirements
Q4.01-4.04 Cost Principles 2 CFR 200.400
This provides an overview of allocable use and training consistent with underlying agreements,
program objectives, and the terms and conditions of the federal award. A grantee, in recognition of its
own unique combination of staff, facilities, and experience, has the primary responsibility for
employing whatever form of sound organization and management techniques to assure proper and
efficient administration of the award. Grant staff of smaller entities may be limited to the same
administrative personnel.
Within each grant are specific terms that can be utilized as a checklist per se to guide staff to use of
funds alignment with terms of the approved budget. This ensure that all costs are allocable and meet
all criteria of the grant award.
The application of these cost principles should require no significant changes in internal accounting
policies and practices. However, the accounting practices must have adequate documentation to
support the accumulation of costs charged to the grant. Reported costs benefiting the organization
are allocated appropriately and proportionally, and not supplanted. This ensures that they are
necessary, reasonable, and allowable for purposes outlined in the award.
Applicable credits refer to those receipts or reduction-of-expenditure-type transactions that offset or
reduce expense items allocable to the federal award as direct or indirect costs. 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.
In some instances, the amounts received from the federal government to finance activities or service
operations of a non-federal entity should be treated as applicable credits. Specifically, the concept of
netting such credit items (including any amounts used to meet cost sharing or matching
requirements) must be recognized in determining the rates or amounts to be charged to the federal
award. Examples of cost sharing are E-Rate, District Broadband, and School Maintenance grants.
Q4.04 Indirect Cost Rate Delegation
• Yes – Selecting “Yes” to question 4.04 indicates that you plan to apply an indirect cost rate to a
grant in the upcoming fiscal year.
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• No – Selecting “No” to question 4.05 indicates that you do not plan to apply an indirect cost
rate to a grant in the upcoming fiscal year.
Q4.05 Federally Negotiated Rate
• Selecting “Federally Negotiated Rate” indicates that the entity has negotiated an indirect cost
rate with a federal agency. Note: All Local Education Agency (LEA) and LEA-type entities
(school districts, Regional Offices of Education, Intermediate Service Centers, area vocational
centers, charter schools, university laboratory schools, and governmental entities formed by a
joint agreement that operate K-12 educational centers) that apply an indirect cost rate to a
grant should select this option because ISBE negotiates indirect cost rates at the federal level
on behalf of all school districts. ICR
• State Negotiated Indirect Cost Rate – Selecting “State Negotiated Indirect Cost Rate” indicates
that the entity has negotiated an indirect cost rate with the Governor’s Office of Management
and Budget.
• De Minimis Election – Selecting “De Minimis Election” indicates that the entity has completed
the Crowe Activity Review System (CARS) process and has selected to be assigned the de
minimis indirect cost rate of 10%.
• Single Function Entity –A Single Function Entity is a grantee that receives only one grant for
one purpose. This will be eliminated because if a grantee only receives one grant for one
purpose, by definition it cannot have any shared (indirect) costs.
• The Organization Will Make an Election Within the Required Time Frame. Selecting “The
Organization Will Make an Election Within the Required Time Frame” indicates that the
organization plans to apply an indirect cost rate to one or more of its grants in the coming year
but has not yet completed the CARS process.
• “None of the Above” – Selecting “None of the Above” indicates that the grantee plans to apply
an indirect cost rate to one or more grants in the coming year but that the rate being applied
was not one of the following:
o Federally negotiated
o State negotiated
o De minimis
o Single function entity
Q4.06-4.09 Organizational Governance
Governance brings authority and accountability while enabling effective decision-making in an
organization. This holistic approach encompasses the processes, standards, rules, and practices
an organization follows. It guides operations and administration, ethics, risk management,
compliance, and more.
Q4.10-4.14 Property Standards 2 CFR 310-316
Physical inventory and records must be reconciled at least every two years. There must be purchase
and disposal records for all physical property and an adequate control system to safeguard against
loss, theft damage, disposal, and unauthorized use.
Q4.15-4.17 Procurement Standard 2 CFR 317-326
Uniform Guidance requires written policies and procedures that reflect applicable federal, state, and
local laws and regulations. Requests for Proposals (RFPs) must be publicized and identify all
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evaluation factors and their relative importance. RFPs must be solicited from an adequate number of
qualified offerors. Any response to publicized RFPs must be considered to the maximum extent
practical.
There must be written standards of conduct pertaining to conflicts of interest and governing the
actions of employees engaged in the selection, award, and administration of contracts. No employee,
officer, or agent may participate in the selection, award, or administration of a contract supported by a
federal award if he or she has a real or apparent conflict of interest.
Q4.18-4.20 Subrecipient Monitoring and Management 2 CFR 330-332
A Pass-Through Entity must make a case-by-case determination whether each agreement it makes
for disbursement of federal funds casts the receiving party into the role of a subrecipient or contractor.
See recipient checklist.
Q4.21-4.29 Budgetary Control- 2 CFR 200.308
There must be additional safeguards to ensure a grantee’s financial systems have the ability to
monitor expenditure and receipt of grantors’ prior approval of budget revisions.
There must be written policies and procedures to ensure proper allocation of personnel time and
effort by funding source. Allowable performance and programmatic activities must be monitored, per
grant agreement.
Section 5: Audit 2 CFR 200.500
This sets forth standards for obtaining consistency and uniformity among federal agencies for the
audit of non-federal entities expending federal awards. Current instructions on the audit review
process can be found at in Guidance for GATA Audit Requirements and a CFSA crosswalk.
Changes in key personnel, prior year financial statement audit findings, and implementation of
corrective action are also disclosed in this section.
There are three audit types: Single, generally accepted auditing standards (GAAS), and generally
accepted government auditing standards (GAGAS).
GAAS –Non-federal entities that do not meet the requirements of a GAGAS audit but expend
$300,000 or more during the non-federal entity's fiscal year in state, direct federal, and federal pass-
through funds either singularly or in any combination must have a financial statement audit conducted
in accordance with GAAS.
GAGAS – Non-federal entities that expend less than $750,000 during the fiscal year in federal
awards (federal pass-through and/or direct federal funds) from all sources are exempt from federal
audit requirements for that year.
Single/Program-Specific –A non-federal entity (awardee) that expends $750,000 or more during the
fiscal year in federal awards (federal pass-through and direct federal funds) from all sources must
have a single audit conducted in accordance with 2 CFR 200.514. Awardees meeting certain
requirements may elect to have a program-specific audit conducted in accordance with 2 CFR
200.507 with the approval of their cognizant agency.
Approval: Upon completion, the ICQ must be certified and submitted for review and approval by
ISBE or cognizant agent. Any questions will be emailed to the main grantee portal access and, if
necessary, the ICQ will be returned for correction. Once approved, the ICQ will interface overnight
