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HomeMy WebLinkAbout210-09POLICY & PROCEDURE Subject: ADMINISTRATION OF GRANTS Index: FINANCE Number: 210-09 Effective Date: 10/04/2021 Supersedes: 3/22/2018 Page: 1 of 9 Staff Contact: Kari Roller Approved By: 1.0 PURPOSE: The purpose of this policy is to establish guidelines for the identification, application, administration, and reporting of grants from various external sources. 2.0 ORGANIZATIONS AFFECTED: All departments/divisions 3.0 REFERENCES: N/A 4.0 POLICY: The City of Renton, through each department, shall actively pursue grant resource opportunities, maintain an active and diverse portfolio, and utilize grant funds to supplement and enhance the long-term goals and objectives of the City. Grant application and administration shall be coordinated with the Grant Analyst. This policy is applicable to all government grants regardless of dollar amount and for private grants over thirty-thousand dollars ($30,000). 5.0 DEFINITIONS: For the purpose of this administrative policy, the following definitions and descriptions apply: 5.1 Accounting System: The City’s financial and accounting software package used for entering, receiving, and monitoring departmental accounts; procurement of goods, services, and assets, and recording of fixed assets. ADMINISTRATION OF GRANTS p. 2 5.2 Accounts Receivable (AR): The component of the City’s accounting system that records transactions and also establishes a receivable for the grant amount billed. When the money is received, the AR System reduces the outstanding AR receivable/balance. All reimbursement requests sent to grantors must be processed through AR. 5.3 Administrative Policy: This policy may be revised from time to time and shall apply to all departments of the City. 5.4 Agenda Bill: A coversheet along with a resolution or ordinance (if necessary) and supporting documentation, completed by each department, submitted for City Council action at a Council Meeting. 5.5 Budget Analyst: The City employee responsible for assisting a department with the development of their budget; establishing project and account codes within the accounting system; determining costs and benefits of various programs; researching and analyzing data; reviewing financial records. 5.6 Catalog of Federal Domestic Application (CFDA): A database which helps the federal government track all domestically funded programs. Federal programs are assigned a number from the Catalog of Federal Domestic Assistance. 5.7 Federal Compliance Requirements: A series of directives established by the United States federal government that are contained in 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Compliance requirements on any given grant may include some or all of the following: Allowed/Unallowed Activities; Allowable Costs/Cost Principals; Cash Management; Eligibility; Equipment and Real Property Management; Matching, Level of Effort, and Earmarking; Period of Performance; Procurement and Suspension and Debarment; Program Income; Reporting; Subrecipient Monitoring; and Special Tests and Provisions. 5.8 Federal Grants: Federally funded grants awarded to the City, whether directly from federal agencies or indirectly through the State, county, or other quasi- judicial government agencies. Federal grant conditions must be met and are subject to the Single Audit Act. 5.9 Federal Procurement Requirements: The process by which the federal government of the United States requires all goods, services (notably construction), and interests in real property to be procured. Procurement requirements are one of several compliance requirements described in detail in 2 CFR 200, Subpart D. 5.10 Fiscal Year: The 12-month period beginning January 1 and ending December 31. ADMINISTRATION OF GRANTS p. 3 5.11 Grant: Funds, equipment or services obtained through a grant application process, which may be applied for by the City of Renton or jointly with another municipal or governmental agency and is documented by a written Grant Agreement. These grant funds or services shall include, but are not limited to: The acquisition of real property; equipment; materials; architectural; engineering; professional consultant services; construction; development or renovation of City facilities; construction or renovation of public infrastructure; funds to operate public programs or services; and funds to pay administrative costs for the provision of public programs, projects or services, which include direct awards or those that require matching funds. 5.12 Grant Agreement: A written contractual agreement, originated by the Grantor upon grant application approval, which contains all required conditions, specifications, and regulations applicable to the receipt of funds from a specified grant. 5.13 Grant Analyst: A Finance Analyst partially assigned to grant oversight for the purpose of providing financial information assistance to the Project Manager, as needed, during the grant application process; monitoring documentation for compliance and eligibility of reimbursement; identifying, requesting, and forwarding grant information to the appropriate departments regarding the grant application and administrative process; maintaining accurate documentation and accounting record for compliance with grant and audit requirements. 5.14 Grant Application: The document submitted to the Grantor to request funds. The document’s format is specified by the Grantor and contains a narrative and financial description of the program, project or service for which funds are being requested. 5.15 Grant Profile: Information related to the grant including but not limited to the award packet and the grant application submittal. 5.16 Grant Reimbursement Request: The internally generated documentation compiled by the Project Manager to submit to the Grantor that identified the grant information needed to process a grant billing. The following documents should be included in the grant reimbursement request: Accounts Receivable invoice request form, agency-specific coversheet, Eden Expenditure Detail Report, and supporting documents and/or invoices as required by the grantor. 5.17 Grantee: The City of Renton or consortium of agencies, if a joint grant. 5.18 Grantor: The entity or agency from whom the grant is received. ADMINISTRATION OF GRANTS p. 4 5.19 Project Manager: The employee responsible for the overall planning, monitoring and execution of a particular project or activity for which grant funds are being utilized. 5.20 Project Number: A number assigned to track revenues and expenditures pertinent to a specific grant, established by the Budget Analyst upon request from the Project Manager prior to the spending of funds. 5.21 Schedule of Expenditures of Federal Awards (SEFA): A schedule required by 2 CFR 200, Subpart F that includes a listing of all federal grant expenditures incurred during the fiscal year. The Grant Analyst prepares and submits the SEFA annually to the State Auditor’s Office (SAO) in conjunction with the City’s Comprehensive Annual Financial Report (CAFR). 5.22 Single Audit Report: The report prepared by the State Auditor documenting the results of its organizational-wide examination conducted under the Single Audit Act of 1984, subsequent amendments and the Rules of the Auditor General relating to agencies receiving federal grant funds. 6.0 PROCEDURES: 6.1 Grant Application: 6.1.1 The Project Manager shall actively research/review and request information regarding grant opportunities. Responsibilities include, but are not limited to, the initial notification to the Administrator of the respective department and coordination with other departments who may participate in some phase of the Grant Application. 6.1.2 If required by Grantor, departments shall obtain Council approval prior to applying for grants. If pre-application legislative action is not required, departments shall obtain authorization from the Administrator of the respective department to pursue any grant opportunities based upon the following considerations: Likelihood of award; consistency with City objectives and priorities; City cash match or in-kind requirements, if any; and the ability of the City to prepare an application, implement a program and meet compliance requirements should funding be received. Utilization of the grant decision-making matrix (appendix A) can assist in identifying a weighted score based on factors and criteria unique to the grant. The outcome of the matrix will help to determine if it is in the best interest of the City to pursue. ADMINISTRATION OF GRANTS p. 5 6.1.3 The Project Manager is responsible for ensuring that the cash match and in-kind services are clearly identified and applied during the application process to enable proper documentation throughout the grant implementation and close-out process, including identification in the City’s budget. 6.2 Grant Award Acceptance and Execution: 6.2.1 The Project Manager shall notify the Grant Analyst, in a timely manner, about grant awards. 6.2.2 Upon Grant award notification from the Grantor, the Project Manager shall prepare an Agenda Bill requesting City Council authorization for the execution and administration of the Grant Agreement and related documents and adjustment of the budget in the next budget adjustment. All intergovernmental grant awards, regardless of dollar amount, require Council approval. 6.2.3 Once approved by Council and the Grant Agreement has been signed, the Project Manager must forward the executed documents to the Grantor. 6.2.4 An original of the fully executed Grant Agreement (executed by the City and the Grantor) shall be received by the appropriate department and filed with the City Clerk’s office. The Project Manager will also forward a copy of the Grant Agreement to the Grant Analyst to assist in all procurement decisions to comply with the grant requirements. 6.3 Grant Administration/Implementation 6.3.1 Upon receipt of the fully executed Grant Agreement, the Project Manager shall coordinate revenue and expenditure account numbers with the Budget Analyst. A new project number will be assigned if one does not exist already. 6.3.2 A budget amendment request shall be submitted by the Project Manager to the Budget Analyst for inclusion in the next budget adjustment. All budget amendments shall be submitted in a timely manner following execution of the Grant Agreement in order to keep the budget current with respect to the financial status of the grant. ADMINISTRATION OF GRANTS p. 6 6.3.3 The Project Manager shall create a Grant Profile to maintain all departmental grant documents and provide read access of the folder(s)/file(s) to the Grant Analyst for integration with accounting information. 6.3.4 It is imperative that the Project Manager have a thorough understanding of the compliance requirements stated in the Grant Agreement and understand how to ensure those compliance requirements are met. If there are questions on any of the requirements, it will be the Project Manager’s responsibility to obtain an explanation or training on that requirement. Information regarding the grant requirements may be obtained from the Grantor itself, 2 CFR 200, or the Grant Analyst. Any unresolved questions should be directed to the Grant Analyst. 6.3.5 All invoices, billing requests, grant funded equipment, etc. shall require the correct project number and account number, including invoices being used to satisfy grant matching requirements. Payroll related costs must be tracked by coding grant-related time to the correct project number within the City’s payroll timekeeping system and must be approved by a supervisor with direct knowledge of the employee’s activities. The Project Manager is responsible for obtaining the required authorization for all costs related to the applicable grant. 6.3.6 The Project Manager is responsible for the expenditure of grant funds in accordance with the City’s established policies and grantor procurement requirements. When City policy differs from grantor procurement requirements, the most restrictive process must be followed. 6.3.7 Grant receipts and expenditures must be maintained in accordance with federal, state, and local guidelines/laws/statutes applicable to the agreement and generally accepted accounting principles for local governments. 6.3.8 A Grant Reimbursement Request shall be prepared by the Project Manager in accordance with City policies and the Grant Agreement. These should be submitted on a timely basis following the expenditure of funds and submitted to the Grant Analyst for verification of financial information prior to submission to the Grantor. The Project Manager shall forward a copy of all supporting documentation to the Grant Analyst for review prior to being processed through Accounts Receivable. 6.3.9 To assure that expenditures are proper and in accordance with the terms and conditions of the federal award and approved project budgets, the annual and final fiscal reports or vouchers requesting payment under the ADMINISTRATION OF GRANTS p. 7 agreements must include certification, signed by an official who is authorized to legally bind the City, which reads as follows: “By signing this report, I certify to the best of my knowledge and belief that the report is true, complete and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the federal award. I am aware that any false, fictitious, or fraudulent information or the omission of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise.” Department Administrators or their designee may sign this certification. 6.3.10 Advance payments are not allowed. Reimbursement requests must only include expenditures that have been previously paid, reflect as paid in the City’s accounting system, and the accounting period must be closed by Finance. An exception will be made in the event the grant agreement requires the reimbursement request to be submitted to the granting agency by a date prior to Finance’s closing of the accounting period. 6.3.11 Upon review, the Grant Analyst shall forward the reimbursement request to Accounts Receivable for final processing. If submitting directly online via a Grantor provided system, the department may submit the billing after it has been reviewed by the Grant Analyst. If not submitting through an online system, Accounts Receivable can submit the billing, on behalf of the Project Manager, directly to the Grantor via mail or email. A project number must be used for all grant activity including the issuance of requisitions, expenditures of funds, and receipt of grant reimbursements. 6.4 Grant Monitoring/Reporting: 6.4.1 The Project Manager shall prepare all reports of a statistical, programmatic or fiscal nature, with technical assistance available from the Grant Analyst; according to reporting frequency (e. g. monthly, quarterly, annually) as required by the Grant Agreement. A copy of the reports shall be forwarded to the Grant Analyst for Finance recordkeeping. 6.4.2 The Project Manager shall prepare departmental requests for changes in the scope of the budget, or schedule of the Grant Agreement. Copies of extension requests and approval must be provided to the Grant Analyst. The Project Manager must update the Grant Profile and forward the changes to the Grant Analyst within 30 days of approval of any of the following: A change in the grant award amount; a change in the granting period; a change to the other information required to maintain the schedules of federal and State assistance or the close-out of a grant ADMINISTRATION OF GRANTS p. 8 extension. All other changes of non-financial nature should be made in a timely basis. 6.4.3 When the Grant Agreement Grantor requires public review and/or City Council approval for revisions, the Project Manager will prepare the agenda item. 6.4.4 Grant program and financial records shall be maintained according to Washington State archive requirements (or longer, if mandated by the Grant Agreement) form the date of “close-out” as designated by the Grantor entity. 6.5 Audit 6.5.1 After the end of the fiscal year, the Grant Analyst shall prepare the Schedule of Expenditures of Federal Awards and State Financial Assistance (SEFA) and submit them to the State Auditor’s Office (SAO) in conjunction with the annual Comprehensive Annual Financial Report (CAFR). 6.5.2 Federal and State grants are subject to annual audits by the City’s external auditors and must comply with all procurement, cost, inventory, and performance standards required by the City’s own policies and the Grantor. If is the responsibility of the Project Manager to have these documents available for review by the auditor if questioned. 6.5.3 The Grant Analyst shall be responsible for the coordination and distribution of the Single Audit report to each granting agency. 6.5.4 The Grant Analyst shall furnish a copy of the Single Audit report to each Project Manager, upon request, when it becomes available. 6.5.5 Any recommendations, exit items, management letters or findings related to the grant reported by the external auditors in the Single Audit Report shall be shared with the Project Manager once the audit is complete. The Project Manager handling the response is required to assist the Grant Analyst in preparing a written response. In addition, the Project Manager shall be responsible for taking the appropriate steps to ensure that the situation is corrected and that it will not recur in future years. ADMINISTRATION OF GRANTS p. 9 APPENDIX A Grant Decision-Making Matrix Weight 1 2 3 4 5 6 Rating Weighted Score Value - amount of revenue generated per year by the grant; the contract amount 5 0 Organization resources and staff capacity - City staff available to designate their time to the procurement, management and oversight of the grant program 4 0 Reporting and compliance complexity - level and frequency of reporting; contract requirements designated by the grantor are in alignment with current City policies and procedures 3 0 Grant application deadline - amount of time designated by grantor to complete application process, taking in to consideration collaboration with other departments, if necessary (i.e. Finance, Purchasing, etc.)3 0 Matching funds required - grantor requirements to contribute City funds at a specified level in order to receive grant money 3 0 Project plan - analysis, design, scheduling and/or coordination to meet specified grant program requirements 2 0 Staff experience and credentials - specific skills, knowledge and know-how of City staff to successfully execute, manage and complete particular grant program 2 0 Administrative costs allowed - reimbursement of administrative City staff time and overhead costs related to the grant 1 0 Weighted Decision:0 Score < 75 = Do not apply Score > 75 = Apply The grant decision-making matrix is intended to be used as a guide only. Utilization of the grant decision-making matrix can assist in identifying a weighted score based on factors and criteria unique to the grant to determine if it is in the best interest of the City to pursue; however, may not be the final determination of whether to apply or not. CRITERIA Negative Neutral Positive Partially completed project plan, no compilation of supporting documenation Project plan complete with all supporting documentation attached More than $50K per year Requires significant investment of resources, including admin or support staff time; no staff time to commit, cannot reassign staff Requires some investment of resources; limited staff time available Requires minimal investment of resources; required time commitment can be met by appropriate staff Restrictive reporting and compliance requirements; does not align with City policies and procedures Mostly complies with City policy and procedures; some additional process/procedure implementation necessary Grant requirements align with City policies and procedures already in place Less than 30 days 30-60 days More than 60 days F A C T O R S Less than $15K per year $15-50K per year No federal grant experience; limited to no specific grant experience Federal and/or specific grant experience; unfamiliar with particular grant program Experience with federal grants and specific grant program No administrative costs allowed Partial administrative costs reimbursable; pending project setup in Eden Administrative costs fully reimbursed; project already setup in Eden to cost time to 100% Matching funds required; not currently budgeted Partial matching funds required No matching funds required No project plan completed/new project