Loading...
HomeMy WebLinkAboutGrants Management Policy Final 12-18-17 Page 1 Administrative Policies and Procedures Title: Financial Policies Resolution No.: Section: Grant Management Policy Date of Version: December 2017 SECTION I - POLICIES A. Grants of $60,000 or more or that are federally funded must be submitted by the Department or Division Head to the City Controller to be given to the Grant Oversight Committee for approval before applying for a grant. Approval is not needed before applying for grants funded by the Iowa Department of Transportation, Federal Aviation Administration, Federal Transit Administration or Housing and Urban Development. (See Appendix F)   B. For grants less than $60,000 and that are not federally funded, a cost-benefit analysis shall be completed by the department applying for the grant to determine if the cost of managing the grant will be greater than the expected benefit. This form along with the Grant Review Form should be submitted to the City Controller to be given to the Grant Oversight Committee for approval. (See Appendix G) C. A minority impact statement shall be provided to the Grant Oversight Committee for every grant of $60,000 or more. (Included in Appendixes E & F) D. The Grant Oversight Committee will meet as needed. E. A Grant Project Manager from the department applying for the grant must be assigned to every grant. F. The City Manager or designee must sign all grant applications. Grant applications which the City is responsible for a match of $150,000 or greater must be approved by the City Council. G. Upon notification that the grant has been awarded, the Grant Project Manager must notify the City Controller. Page 2 H. The Grant Oversight Committee must review all grant awards before the grant can be accepted. Some grants may also require City Council acceptance. I. The Grant Project Manager is responsible for ensuring compliance with all state and federal laws and that the work is performed in accordance with the grant document. J. The Accounting division will prepare all grant draw requests except for certain grants that the Engineering division will prepare the draw request for. For those grants, the Grant Project Manager will prepare the draw request. If the Grant Project Manager prepares the draw request, a copy, along with supporting documentation, must be given to the Accounting division upon completion. Draw requests should be prepared at least quarterly, if the grant allows for periodic draws. K. If the grant allows for periodic draws, a draw must be completed for expenses incurred during the period ended June 30th for the current fiscal year. This draw request must be completed and forwarded to the Accounting division by August 31st. L. The Accounting division is responsible for the financial grant reporting unless the exception in part J exists. If someone other than the Accounting division prepares the financial grant reporting, a copy must be given to the Accounting division upon completion. The Grant Project Manager is responsible for all other grant reporting, e.g. metrics, narratives, performance data. M. The Grant Project Manager is responsible for requesting any amendments to the grant agreements or any time extensions. Any amendments to the grant agreements or any time extensions should be approved by the City Manager or designee. A copy should be forwarded to the Accounting division. N. The grant should be closed out as soon as possible after it has been completed or the grant term has expired. The Grant Project Manager and Accounting division are responsible for preparing the required information. O. Both the Grant Project Manager and the Accounting division must maintain a grant file. (For minimum file requirements, see Appendix B) P. The Accounting division is responsible for the preparation of the Schedule of Expenditures of Federal Awards, which is included in the City’s Comprehensive Annual Financial Report. Page 3 Q. The City is required to have a Single Audit conducted by an independent auditing firm. The Accounting division will be the main point of contact for the auditors. However, depending on the grants to be audited, other City departments may have to assist with gathering the information needed. R. The purchasing policies stated in the purchasing manual are not preempted by the requirements for state and federal grants unless the city requirement is inconsistent with the state or federal grant requirements, in which case departments shall follow the strictest of any applicable policy. Departments shall adhere to the City’s purchasing policies and all state and federal requirements, including completion of all required documents. In addition, all applicable conditions of state or federal funding must be included in bid and proposal solicitations. S. If any personally identifiable information is obtained as part of a grant, that information must be kept in a secure location. It should only be shared with granting agency with the individual’s permission. SECTION II – PROCEDURES A. When a Department/Division Head determines that they want to apply for a grant, a Grant Project Manager must be assigned by the department/division, and the following parameters must be followed: i. For grants of $60,000 or more or that are federally funded, a Grant Review Form (See Appendix F) must be completed and submitted to the City Controller. Except for those grants funded by the Iowa Department of Transportation, Federal Aviation Administration, Federal Transit Administration or Housing and Urban Development. ii. For grants of less than $60,000, a Grant Review Form and a cost-benefit analysis (See Appendix G) shall be completed by the department/division applying for the grant with assistance from the Accounting division to determine if the cost of managing the grant is greater than the expected benefit and submitted to the City Controller B. The City Controller will convene the Grant Oversight Committee as needed. The Grant Oversight Committee will review the Grant Review Form to assess the following impact of the grant and to approve or deny the request: i. Relevance and linkage to the City’s strategic plan goals and priorities ii. Budgetary impact iii. Use of City’s resources iv. Legal obligations v. Risks and controls vi. Minority impact Page 4 C. In addition, the Grant Oversight Committee will determine if the grant competes with other grants or grant applications within the City. If so, the Department/ Division Head responsible for each grant will attempt to resolve the internal competition and their solution will be presented to the Grant Oversight Committee for approval. If the Department/Division Heads cannot reach a suitable solution, the City Manager will make the final decision. D. All grant applications must be signed by the City Manager prior to being submitted. For grants which the City is responsible for a match of $150,000 or greater, the completed grant application should then be submitted to the City Council for approval. E. If the grantor awards the grant to the City, the City must decide whether to accept the award as written, request modifications in the terms of the award or decline the award. The grant award language should be examined by the Grant Oversight Committee to ensure the City can both comply with the terms and is willing to comply. The grant documents and the Grant Information Form (See Appendix E) should be sent to the City Controller to be given to the Grant Oversight Committee. i. If the City accepts the award as written, the City Manager will sign the award and return it to the Grant Project Manager. Some grants may also require City Council acceptance. The Grant Project Manager will keep a copy for their grant file and will send a copy to the Accounting division for the grant financial file. ii. If the City determines the terms of the grant need to be renegotiated, the Grant Project Manager and the subject matter expert will engage the grantor in discussions to amend the language. If suitable language is reached, the changes need to be documented in writing by the grantor. Once received, the revised grant award will follow the same approval and distribution process noted above. iii. If the grant is declined by the City for any reason, the Grant Project Manager will document the reason for the rejection and will send a formal letter to the grantor declining the award. The Grant Project Manager will file a copy in their grant file and will send a copy to the Accounting division for inclusion in their file. F. The completed Grant Information Form will be entered into the Grants Database by the Accounting Division. (For information maintained in Grants Database, see Appendix D) Page 5 G. The Accounting division or the Grant Project Manager (if being managed by the Engineering division) will prepare the draw request and collect the needed supporting documentation. The request may be a manual form or it may be submitted electronically. If the Accounting division prepares the draw request, it needs to be approved by the Grant Project Manager before it is submitted. If the Grant Project Manager prepares the draw request, a copy must be sent the Accounting division along with the supporting documentation. H. The Grant Project Manager prepares all reporting information relating to progress, issues, delays, etc. and financial information if they prepare the draw requests. If the Accounting division prepares the draw requests, they will provide the financial information for any required reporting. Each preparer should maintain a copy of the documentation they create in their grant file. If the report is jointly prepared, both the Grant Project Manager and the Accounting division should maintain a complete copy of the report sent to the grantor. I. The Grant Project Manager will initiate the closeout process as soon as possible. The Grant Project Manager and the Accounting division, if the Accounting division has been involved with the grant, will work together to gather the necessary information needed for the closeout. Both the grantee department and the Accounting division will maintain a copy in their respective files. J. The Grant Project Manager will request any amendment or time extension if it is needed. The City Manager should approve these requests. A copy of the time extension request and the subsequent approval or rejection should be maintained in both the Grant Project Manager file and the Accounting division file. Page 6 APPENDIX A Parties engaged in grant management 1. Department/Division Head - This is the individual at the grantee who is ultimately responsible for the grant solicitation and, if the grant is awarded, performance under the grant. 2. Grant Project Manager – This person may or may not be the Department/Division Head. The Grant Project Manager is responsible for grant performance and reporting. 3. City Manager’s Office Representative – This individual is a high-ranking member of management with a clear view of the strategies and operations of the City. This individual is responsible for overall acceptance or refusal of grants; retains signature authority for grant reporting (absent specific grant requirements to the contrary); chairs the Grant Oversight Committee. 4. Legal Representative – A member of the City Attorney’s Office who regularly participates in the Grant Oversight Committee and is charged with reviewing grants from a compliance and risk management perspective. 5. Budget Representative – A member of the Finance Department who regularly participates in the Grant Oversight Committee and is charged with reviewing grants from a budgetary perspective. 6. City Controller – A formal position within the City of Iowa City. This position has overall responsibility for ensuring grants funds are properly recorded in the accounting system. This position supervises the Accounting division who has the responsibility for filing reimbursement requests, invoices, required financial reports, etc. with the grantor. 7. Grant Oversight Committee – This committee is comprised of a core group: the City Manager’s Office Representative (as Chair), the Legal Representative, the Budget Representative, and the City Controller. This committee is augmented by the Department/Division Heads who are seeking or implementing grants. Page 7 APPENDIX B Grant File Contents There will be two grant files maintained by the City. While some data between the two will overlap, there will be data that is unique to each file. Each grant will have a unique file. The purpose and minimum contents of each file are described below. Department/Division Head (or Grant Project Manager) File Purpose: To ensure the grant’s requirements and grantor’s expectations were met; to support the accomplishment of the grant’s objectives; and to manage the project to a successful completion according to grant terms. File Contents: 1. Notice of grant availability 2. Grant Application 3. Revisions from the Grant Oversight Committee 4. Assigned Project Number in the Project Ledger or General Ledger and/or the Fund and Org Account Numbers 5. Correspondence from/to the Grantor 6. Requested extensions, modifications, etc. 7. Approval of extensions, modifications, etc. in writing from the grantor 8. Written approvals required by this policy 9. Grant close-out report 10. Support for reports made or created for the grantor Accounting File Purpose: To support the accuracy and timeliness of draw requests made under the contract; to ensure grant proceeds are properly recorded; to assist in grant reporting for the annual financial statement audit. File Contents: 1. Grant Application 2. Assigned Project Number in the Project Ledger or General Ledger and/or the Fund and Org Account Numbers 3. Correspondence to/from the Grantor 4. Written approvals required by this policy for Accounting transactions and activities 5. Grant close-out report 6. Support for reports Accounting makes or creates for the grantor 7. Draw requests, invoices, etc. 8. Approved extensions, modifications, etc. 9. Coding for grant funds received under the grant Page 8 APPENDIX C Types of Grants or Grant Funding 1. Block Grants – a broad intergovernmental transfer of funds or other assets by the US Congress to state or local governments for specific activities, such as community development and housing rehabilitation. There are few restrictions attached to such grants. Block grants are distributed according to legal formulas defining broad functional areas such as health, income security, education or transportation. They are used for a wide variety of activities, largely at the recipient’s discretion. 2. Competitive (Discretionary) Grants – an award of financial assistance in the form of funds, or property in lieu of money, by the Federal or State government to an eligible grantee, usually made on the basis of a competitive review process. 3. Continuation of any grant type – a continuation grant that provides additional funding or time to complete grant requirements, for budget periods subsequent to the initial budget period. 4. Conditional Grants – a grant that involves one grant maker seeking the involvement of others by making their grant (only a part of the total costs of the project) conditional upon the remainder of the cost being funded from another source. 5. Earmark – refers to a provision in legislation requiring that a portion of a certain source of revenue be designated for specific projects usually at the request of a legislator. Typically, the City submits requests for projects to state and federal legislators who seek to obtain funds for those requests which are usually to be spent in the district the legislator represents. Earmarking bypasses the normal procedure by which revenues are pooled in a general fund and then allocated among various government spending programs as opposed to a specific project. 6. Formula Grants – a grant of federal funding to states, territories or local units of government that is determined by a formula in the authorizing legislation or regulations. These grants are sometimes referred to as state administered programs. To receive the grant, the grantee must meet all the eligibility requirements which are pre-determined. 7. Pass-thru of any grant type – grant funds received from one grantor but passed through another grantor or funding source. 8. Reimbursement Programs – a type of funding program under which the grantee is reimbursed for qualifying expenditures already incurred, as specified in the terms of the grant agreement for such a program. 9. County Grants – a grant made by Johnson County government. 10. State Grants – a grant made by the State of Iowa government. Federal dollars that pass-thru a State agency to the City are considered Federal grants. 11. Federal Grants – a grant made by the US Federal government. These grants may pass-thru a State agency, but they are still considered Federal grants and will be subject to the Single Audit requirements. Page 9 12. Foundation Grants – a grant made by a philanthropic foundation. 13. Corporate Grants – a grant made by a corporate foundation. APPENDIX D Grant Database The City will maintain a grant database that includes the following information: 1. Grantor 2. Grant Number and CFDA Number if applicable 3. Internal Project Ledger Number, General Ledger Project Number and/or Fund and Org Account Number 4. Grant Coverage Dates 5. Grant Amount 6. Summary of purpose of the grant 7. Grantor Contact Name, Address, Phone Number and Email Address 8. Grantee Contact Name, Office Address, Phone Number and Email Address 9. Phase of the Grant: Pre Award, Application Submitted, Awarded and Active, Awarded and Declined, Closed, Report requirements and due dates, e.g. SF425. 10. Date of: Application, Award Due Date, Award Received Date, Award Accepted, Award Declined, Grant Closed. 11. Draws with date requested and dates received. 12. Date Grant extension, modification, etc. requested 13. Brief Description of grant extension, modification, etc. 14. Date grant extension, modification, etc. approved. 15. Date of grant modification made by the grantor (not requested by the City) 16. Brief Description of the grant modification made by the grantor. The Department/Division Head or Grant Project Manager will complete the Grant Information form for items 1-16 with the exception of Items 3 &11. Items 3 & 11 will be completed by the Accounting division. For ease of reporting, all grants will be assigned an identifying number in MUNIS, e.g. project ledger or general ledger project number, fund and org account number. Page 10 APPENDIX E Grant Information Form 1. Grantor: 2. Grant ID: 3. CFDA #, if applicable: 4. Grant Start Date: 5. Grant End Date: 6. Grant Amount: 7. Brief Description of Grant: 8. Grantor Contact Name: 9. Grantor Contact Phone: 10. Grantor Contact Email: 11. Grantor Contact Address: 12. Date Grant Application Submitted: 13. Date Grant Award Received: 14. Date Grant Award Accepted: 15. Date Grant Award Declined: 16. Report Requirements and Due Dates: 17. Is there a match requirement? Yes ☐ No ☐ If so, how much? : 18. Have the grant related expenses been budgeted for? Yes ☐ No ☐ 19. Minority Impact Statement: Census Tract Minority Population: Choose an item. Summarize Positive/Negative Impacts: If there is a negative impact, please explain the reason for proceeding with this grant: 20. Grant Project Manager: Page 11 21. Updates to Grant 22. Date Grant Extension, Modification, etc. Requested: 23. Date Grant Extension, Modification, etc. Approved: 24. Brief Description of Grant Extension, Modification, etc.: 25. Date of Grant Modification made by the Grantor (not requested by the City): 26. Brief Description of the Grant Modification made by the Grantor: Page 12 APPENDIX F Grant Review Form 1. Grantor: 2. Grant ID/Name: 3. CFDA #, if applicable: 4. Anticipated Grant Start Date: 5. Anticipated Grant End Date: 6. Grant Amount Applying For: 7. Brief Description of Grant: 8. Brief description of the need for the project that the grant will be funding: 9. Is there a match requirement? Yes ☐ No ☐ If so, how much? : 10. Have the grant related expenses been budgeted for? Yes ☐ No ☐ 11. Minority Impact Statement: Census Tract Minority Population: Choose an item. Summarize Positive/Negative Impacts: If there is a negative impact, please explain the reason for proceeding with this grant: 12. Grant Project Manager: