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HomeMy WebLinkAboutAdministrative Order 2024-07 Adoption of the Grant Admin Policy and Procedures ADMINISTRATIVE ORDER NO. 2024-07 Adoption of the Grant Administration Policy and Procedures dated November 12, 2024. The Grant Administration Policy and Procedures were designed to support the City of Bozeman's internal grant activity. The Grant Administration Policy has four categories including: Pre-award activities, Award Acceptance, Post-Award Activities, and Compliance.The purpose of the policy and procedures is to outline responsibilities of the department receiving grant funds and to establish internal controls that ensure adequate compliance with administrative rules and regulations. BE IT HEREBY ORDERED that the Grant Administration Policy and Procedures are hereby adopted. This Administrative Order is effective immediately. jjDynted this 25th day of November 2024 Chuck Winn, City Manager Grant Administration Policy 11/12/2024 Scope and Applicability This policy is applicable to all Department directors and City staff for each grant related phase- pre-award, post-award, and closeout. All staff applying for grant funding on behalf of the City must be familiar with all grant application and post award requirements. Department directors are ultimately responsible for ensuring staff are aware of and follow the policies. Administration This policy is established by Administrative Order. Department directors may adopt additional procedures to monitor and control the types of grants applied for. Department directors are responsible for approving all grant applications and awards if received in addition to approvals from the Finance Director, the City Manager, and the City Clerk. Purpose The purpose of this policy is to establish internal controls that ensure adequate compliance with federal, state, and City administrative rules and regulations for applying, expending, tracking, and monitoring grants received by the City of Bozeman. This policy also outlines the responsibilities of the department receiving grant funding, in coordination with the Grants Coordinator in Finance. All projects funded fully or partially by grants are integrated with City operations. Compliance with this policy and applicable laws ensure that the City maintains its credit rating and avoid audit findings that could hinder future funding opportunities. Non-compliance—such as improper or inaccurate reporting, misuse of funds, or improper procurement, can be costly to the City and taxpayers and is unacceptable. Grant Policies A. Departmental Grant Manager Department Directors will appoint department personnel as a "Departmental Grant Manager" as a liaison to work with the Grants Coordinator for the application of and management of each grant application and award. B. Finance Grants Coordinator The Finance Grants Coordinator will support departments for each phase of a grant-pre- award, post-award, and closeout. General Policy P a g e 11 Grant Administration Policy 1. Pre-Award Activities Department grant manager in coordination with the Finance Grants Coordinator are responsible for the following pre-award activities: • Review notifications, solicitations and/or NOFOs to determine eligibility including the City's ability to meet all performance and contractual requirements, • Assess the grant funding opportunity for alignment with the City's mission, strategic priorities, capital improvement plan, and other applicable adopted plans. • Coordinate with Grants Coordinator to notify the Finance Director, the City Manager, and the City Clerk about the intent to apply for a grant. i. Per Administrative Order 2014-01, the City Manager and the City Commission are required to be notified within 30 days of all grant applications exceeding $20,000. • Make recommendations to the Finance Director as needed about whether the applicant can meet all special terms, conditions, and requirements, at both the application and award level before the application due date, i. If a department is seeking grant funding for a new program or activity that is not outlined in the strategic plan or adopted budget, prior approval from the Finance Director and the City Manager is required before submitting the grant application. • Coordinate with Grants Coordinator to develop application and submit application. 2. Award Acceptance Department Grant Managers, in coordination with the legal department must accept the grant award in accordance with the same procedures used to authorize contracts. Typically this means awards above $10,000 need to be added to the City Commission consent agenda, and signed by the City Manager. Awards under$10,000 should be signed off on by the Department Director. Contact the legal department directly for questions about grant acceptance. 3. Post Award Activities Department grant manager in coordination with the Finance Grants Coordinator are responsible for the following post award activities: a. Receive grant award notification and route award documents to Grants Coordinator for processing in DocuSign and Granicus for consent agenda item, b. Meet with Grants Coordinator to conduct a grant management plan meeting to facilitate proper delegation of, authority over, and responsibility for grant activities, c. Coordinate with Finance Director and HR Director for approval of new positions to be created as a result of grant funding. P a g e 12 Grant Administration Policy d. Assist with and monitor proper reporting. The Grants Coordinator will complete financial reporting, the Department Grants Manager will complete programmatic information reporting. 4. Compliance Department grant manager in coordination with the Finance Grants Coordinator are responsible for the following compliance requirements: a. Conduct all federal grant funded activities in compliance with the Single Audit Act and Title 2 U.S. Code of Federal Regulations (CFR) 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards (Uniform Guidance), and all applicable terms, conditions, assurances, certifications and requirements of all Federal and state laws, executive orders, regulations, and policies. i. Regulations, compliance requirements, and reporting requirements of individual funding agencies are in addition to, not replacement of, City policies and procedures. b. Typically, grants are managed on a cost-reimbursement basis which is the preferred method. In situations when grant agreements follow the advanced funding method', please reach out to the Finance Grants Coordinator. c. Consider a grant amendment or time extension if any of the grant may not be fully utilized per the initial terms. Contact the Finance Grants Coordinator for assistance with the formal request. d. Determine the allowability of costs under applicable cost principles and grant terms2 and the approved grant budget. i. Costs deemed allowable will proceed to AP claims or payroll process as appropriate for further review and approval in accordance with the City's accounts payable policies and procedures. e. Document time and effort charged to grants in accordance with grant requirements'. The approved grant budget defines how the funding will be spent. If time and effort is in the approved budget, it must be tracked separately and accordingly. f. Comply with the grant and City's Travel Policy for all travel4 identified in the grant award budget and activity related to the grant. g. Procure goods and services identified in the approved grant award budget' and the City of Bozeman Administrative Order 2023-03 policies and procedures and legal requirements. i. It is the responsibility of the department to monitor, expend, and amend (if needed) the goods and service vendor contracts procured with grant funds. 12 CFR 200.305 2 2 CFR 200.302(b)(7) 3 2 CFR 200.430 4 2 CFR 200.475 5 2 CFR 200.318 P a g e 13 Grant Administration Policy h. Verify that vendor is not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal or State assistance programs or activities6. i. Verify software purchases are not prohibited' before completing invitations for bids (IFB) or requests for qualifications (RFQ). j. Manage and dispose all equipment and/or real property acquired under a Federal award". k. Participate in sub-recipient monitoring if applicable to grant award or grant funded program. I. Submit required documentation to the Grants Coordinator in order to compile the annual Schedule of Expenditures of Federal Awards (SEFA). m. Disclose any non-compliance issues to the Grants Coordinator. 5. Under this Policy, the Finance Grants Coordinator is authorized to create necessary and applicable procedures for the application for, expenditure of, and tracking/monitoring of grants received. 6. Violations of this policy are subject to disciplinary action in accordance with the Employee Handbook and applicable union contracts. 7. All modifications to this policy will be made in writing. 6 2 CFR 200.214, MCA 18-4-241,ARM 2.5.402 2 CFR 200.216 $2 CFR 200.313 P a g e 14 Grant Administration Policy GRANT ADMINISTRATION PROCEDURES Introduction: Grant funding provides resources that enhance the City's ability to leverage funding and provide services which are in the best interest of our residents. Therefore, departments are encouraged to be proactive in their pursuit of supplemental funding sources while considering the administrative workload and temporary nature of grants. Projects funded with grant money are not independent of City operations so, due to the increasing cost of administration, grant applications less than $5,000 are discouraged. It is important to emphasize the need for strong internal controls over grants from application through closeout. Non-compliance with grant requirements can lead to audit findings,which reduce the City's ability to receive future funding and threaten the City's bond rating. Purpose: On November 25, 2024, the City Manager adopted a new Grant Administration Policy. The policy applies to all City Elected Officials, Directors, Deputy Directors, Boards, Districts, and their employees; hereinafter referred to as"applicant."The policy is intended to provide internal controls that ensure compliance with all Federal, State, and City administrative rules and regulations regarding the application for, expenditure of, and tracking/monitoring for grants received by the City of Bozeman. The purpose of the following Grant Administration Procedures is to ensure compliance with the City's Grant Policy. These procedures are intended to: 1. Implement internal controls as required by the Single Audit Act and 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) to avoid audit findings, 2. Provide time for adequate planning and review, 3. Ensure proper delegation of, authority over, and responsibility for grant activities, 4. Streamline and organize the grant administration process. Definition: Grant: A grant can be defined as an award, allocation or congressional appropriation of financial assistance, services, entitlement, and/or tangible property for which the City or a department thereof, is a recipient. Grants are received from federal, state, municipal and private sources. Generally, the award is a result of an application, although there are some instances where the City receives grant funding as entitlement community. Since grant funding may not be easily recognized, the following terms should be considered in addition to the obvious word, "grant": • Cooperative Agreement • Sub-agreement • Modification • Award • Contract for services (aka Fee for services) • Appropriation (federal or state - if it is state, it could be a federal pass-through appropriation to the state) • Donation of equipment, services, or surplus property from an agency that is paying for it with grant dollars on behalf of the City. Anytime a department receives funding,tangible property, or services from an outside source and it is not immediately identifiable as grant funding, please contact the Grants Coordinator and the Controller to verify those determinations to ensure proper accounting and reporting. General Overview of Grant Procedures: Grant Procedures are broken down into six different activities: 1. Intent to Apply for Grant Funding 2. Application for Grant Funding 3. Award of Grant Funding 4. Post Award Management 5. Monitoring of Grant Funding 6. Closeout/Audit of Grant Funding Intent to Apply for Grant Funding: After receiving a solicitation, notice of funding opportunity or a Request for Proposal (RFP), and before the development of an application, potential applicants must consider the following: • Matching requirements - Does this grant require that City resources, such as financial support or in-kind contributions, be designated as match? Can that match be readily identified in the applicant's current operating budget? • Requirements, terms, conditions, assurances, certifications - Are there any special requirements that may need to be addressed before accepting the award? • Administrative Workload - If the grant funds are received, will it require more administrative oversight than normally required? (Le., sub-recipients require additional and sometimes time-consuming administrative oversight.) • Supplemental Purchases- Will purchases of additional items like office equipment need to be made and budgeted for? • Sub-recipients- Will there be a pass through of grant funding to a third party to conduct grant related activities. Determination of a sub-recipient or vendor relationship should be investigated. Will monitoring be required? STEP#1: Grant Intent Notification Once a decision has been made to apply for grant funding, a Grant Intent Notification Form must be filed with the respective department Director, the Finance Director, the City Manager, and the City Clerk. Also, CC the Grants Coordinator in DocuSign when routing the grant intent notification form. STEP#2: City Manager and City Commission Notification of Grant Application Per Administrative Order 2014-01, the City Manager and City Commission are required to be notified within 30 days of all grant applications exceeding $20,000. The Grants Coordinator will assist with the notification process if desired. STEP#3: Grant Award Contract Approval With the original intent/application form from DocuSign, route the grant award agreement for signature via DocuSign. Once approved in DocuSign, add the agreement to the next available consent agenda for City Commission approval. All grant agreements require City Commission authorization regardless of dollar amount. No expenses may be incurred, and no grant related activities can be initiated, until the award is sianed by all parties and the grant award authorizes expenditures. STEP #4: Post Award Management Grant Management Plan: Once the award has been accepted and approved, the applicant is required to schedule a Grant Management meeting with the Grant Coordinator and Controller. During this meeting, a written management plan to determine the accounting, financial and programmatic reporting responsibilities will be discussed and agreed upon. In addition, the approved grant budget will be reviewed to discuss requirements for payroll, sub-recipients, contracts with vendors for goods or services, and guidance on procurement and contract development requirements. The Grant Coordinator must be involved in the development of all contractual agreements and procurement actions which obligate grant funding and any subsequent modifications to those agreements. STEP#5: Monitoring of Grant Funding Most grant funded projects have special conditions, reporting requirements, deadlines, and obligations, in addition to specific program objectives, that must be met. It is important that the responsible applicant is cognizant of those and ensures that they always comply. The Grant Coordinator will complete and submit all financial reports and requests for reimbursements. The department will complete and submit all programmatic reporting. In addition, the Grant Coordinator will maintain a list of all grant awards and funding, to have necessary information for the Schedule of Federal Awards (SEFA). The SEFA is submitted annually and all federal expenditures and/or contributions must be tracked at the end of each fiscal year. STEP#6: CloseoubAudit of Grant Funding External Audits: Each fiscal year the City of Bozeman must undergo a Single Audit by an external audit firm, including an examination of our Schedule of Expenditures of Federal Awards (SEFA). Any grant that is over the threshold to be considered a major program will automatically be audited. Several smaller grants may also be reviewed. Some grant programs may be chosen to be audited because they are considered 'high profile risk.' Additionally, if a previous annual external audit is not satisfactory, the external auditor may test more programs the following fiscal year. It is imperative to make certain that all applicants/grantees comply with all financial and programmatic requirements to guarantee that the City of Bozeman does not receive a written finding on our audit report. Closeout: Once the grant funds have been completely expended, or the period of performance end date of the grant has been reached, the grant is considered closed. All necessary payments must have already been processed and all programmatic and financial reporting must be promptly and properly completed. f Appendix B Grant Checklist Program Name Fiscal Year Completed Date DESCRIPTION By RFP PROCESS RFP received Submit Grant Intent Notification Form to Grants Coordinator APPLICATION PROCESS Read RFP and application instructions carefully Prepare application with assistance from the Grants Coordinator Per Administrative Order 2014-01, within 30 days, submit the grant application for the consent a enda to notify the City Manager and City Commission. The applying department must retain all application materials including the NOFO, the intent to apply form, and submitted application and send a copy to the Grants Coordinator. AWARD PROCESS Award received Prepare original grant routing form from the application process. Route original routing form and grant agreement via DocuSign to Finance, Respective Department Director, City Manager, and City Clerk Submit agenda item for City Commission to authorize award If properly noticed, the City Clerk will retain all grant award agreements in laser fiche. GRANT MANAGEMENT PLAN Meet with Grants Coordinator and Controller to prepare written plan to determine accounting, financial &programmatic reporting responsibilities. (Fill out the Grant Mana ement Plan form REPORTING Prepare and file quarterly progress (semi-annual, annual, etc, as prescribed in grant agreement) reports as the grant requires. Grants Coordinator will prepare and submit financial report and request for reimbursement(quarterly, semi-annual, annual, etc. as prescribed by grant award terms and conditions). Forward a copy of all grant amendments, closures, or other notices to the Grants Coordinator Ensure final reconciliation agrees with City's financial system.