HomeMy WebLinkAbout(0009) Grant Policy Eff 10-1-20 redlined.PDFCity of Fort Worth
FORT WORTH.
Department of Finance
Grants Management Policy
I. Authority
The Fort Worth City Council is responsible for legislating, formulating policy, and
setting the overall direction of City government. This includes the approval of financial
policies which establish and direct the operations of the City of Fort Worth ("the City").
The City Manager is responsible for carrying out the policy directives of the City
Council and managing the day-to-day operations of the executive departments,
including the Department of Finance. This policy shall be administered on behalf of
the City Manager by the Chief Financial Officer/Director of Financial Management
Services ("CFO").
II. Purpose
The purpose of this policy is to:
A. Define practices and provide the guiding principles for grant management, including
the application, approval, set up, management, accounting, and reporting of grant
activity performed by the City.
B. Ensure that City personnel seek and apply for federal, state and other grants-in-aid that
address the City's current priorities and policy objectives, and administer them in
accordance with applicable federal and state laws and regulations, City policies, and
contractual obligations.
C. Establish controls to maintain, and enforce a sound system of operational procedures
in accordance with industry best practices and internal control objectives. These
controls address the operational nature of the processes associated with grant
management.
D. Require procedures related to the grant management process be in conformance with
this policy.
III. Applicability and Scope
All employees of the City, including uniformed employees, having grant management
or accounting responsibilities shall conduct all related activities in compliance with
rules and guidelines set forth by this policy and by their respective departmental grants
procedures.
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IV. Glossary
Definitions related to this policy will be incorporated into the Glossary for Financial
Management Policies.
Administering Department — theThe City of Fort Worth Department responsible for
applying for and overseeing the activities of a grant -funded program.
Indirect Costs — expenses/ ^--„a�., �---Expenditures the City will incur for managing
the grant program. TAny eligible indirect costs shall be calculated and included
in each grant application and shall be specified in the Mayor and Council
Communication M&C seeking approval to proceed with a grant application or award.
If a waiver of the -indirect costs is sought by the Administering Department, such waiver
shall be deta ea "' must quantify the estimated amount, explain the preeessreasoning
behind the request, and be approved by the Mayor and Council.
V. Policy
A. Grant Identification, Application, Acceptance
1. Each respective department of the City of Fort Worth may research and identify
grant opportunities that facilitate the City's overall goals, mission, and
initiatives and provide supplemental or alternative funding sources tefor either
capital expenses/expenditures or operating programs.
2. If grant opportunities are identified, departments are responsible for obtaining
Felevant approval from their- tvspeetiN�ehe corresponding Assistant City
Manager.
3. GfantPotential _grant opportunities shall be evaluated for administrative burden
and compliance costs when identifiedprior to application. Where the amount
likely to be received does not exceed the cost of applying for and administering
the grant, the City should not seek the grant. Where the amount awarded does
not exceed the cost of administering the grant, the City should not accept the
grant.
4. Prior to application, the Administering Department shall:
a. Complete an agenda item on a regularly scheduled City Council meeting
wherein approval to apply and accept, if awarded, the grant is requested.
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b. The Mayor- Council C—ewmmnneatienThe M&C requesting
application and acceptance approval shall include the following
components:
a. Name of grant,
b. Grantor,
c. Dollar award of grant along with the identification of required
matching funds, including the source of such matching funds,
d. Overview of the grant program, including how the City will use
the funds in support of City goals and priorities,
e. Required appropriation ordinances and language for the full
amount of the grant, includiniz match costs and program income,
if any, and
f. Dollar value of indirect costs being applied for in the grant,
calculated based on the indirect cost study in effect at the time.
Where reimbursing the general fund for the indirect cost burden
would impact program services, the department should weigh
the City's priorities in deciding whether to allocate additional
resources to the program from other sources.
g_��ayorStatements re ag rding responsibilities for collecting
revenue and Council Communie do ensuring that funds are
available prior to obligation.
5. The M&C shall be routed through the Grant Accounting Team of the Financial
Management Services Department (FMS) for review prior to being placed on a
City Council Agenda for consideration. This is accomplished by checking the
"Includes Any Federal, State, Interlocal or Grant Funding" box on the
"General" tab of a draft M&C.
6. After City Council approvals the Administering Department, in coordination
with the Finaneial Management Setwi es Depa *met#FMS Grant Accounting,
shall prepare all documents required in the application process and submit the
same to the granting agency.
7. Applications shall include a budget for all indirect costs allowable under the
grant.
8. It is acknowledged that grant application deadlines may not allow for approval
by the Mayor and Council prior to being due. In these instances, ratifying
Mayor and Council Communications shall be completed utilizing the same
process as non -ratifying May and Council Conan nicati^&Cs.
9. Once a grant is awarded, the Administering Department is responsible for
accepting the award and, in concert with the City Attorney's Office, seeing that
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the corresponding contract is correct and fully executed, including all
provisions required under 2 CFR 200 of the Code of Federal Regulations.
10. In instances where the City needs to further evaluate whether a grant meets the
City's objectives, mission, goals, and initiatives, it is acceptable to submit a
Mayor and Council Communication for approval to apply for the grant only. In
these instances, a supplemental Mayor and Council Communication is required
in order to accept the grant and appropriate funds.
B. Grant Set -Up
1. Upon award of a grant by a granting entity, FMS Grant Accounting shall
schedule a Grant Kick -Off meeting with the Administering Department. The
Grant Kick -Off meeting is to clarify grant management and accounting roles
and responsibilities specific to that particular grant, and should be attended by
management representatives of the Administering Department and FMS Grant
Accounting.. (and, where applicable, FMS Capital Assets).
2. The Administering Department is then responsible for completing and/or
collecting the following documents, with assistance and support from FMS
Grant Accounting, and submitting them to FMS Grant Accounting to be entered
into PeopleSoft (the City's system of record for all financial data):
a. The Grant Information Form (GIF),
b. A balanced Grant Project Budget,
c. The approved M&C,
d. The fully executed award agreement, -and
eThe funding location (FID) for any required matching expenditures, and
c—.£ Any Combo Codes necessM to process expenditures.
3. FMS Grant Accounting is responsible for setting up the award in PeopleSoft,
including entry of operating and financial reporting schedules. Grant
Accounting shall then provide the Administering Department with the
PeopleSoft project (grant) number.
4. The Administering Department and FMS Grant Accounting are responsible for
understanding grant conditions, including allowable costs for each grant. This
includes personnel expenditures and whether salaries, overtime and/or fringe
benefits are allowable. The Administering Department, with the support and
assistance of FMS Grant Accounting, is responsible for determining and using
the appropriate vehicle to ensure personnel charges are distributed to the grant
as accurately as possible. This may entail the use of ePARs, tasks groups/task
profiles and/or eembo eode Combo Codes. The Administering Department
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should ensure that grant -funded personnel understand how to code their time
for accurate accounting.
5. The Administering Department, with assistance and support from FMS Grant
Accounting, submits task gro"taskpr-ofile/cembeeedeany Combo Code
requests, which are reviewed by FMS Grant Accounting and set up by FMS
Financial Repo i gSystems Management. Any Task Groups/Task Profiles are
submitted through ITSM Self-service at http:// itsm.cfwnet.org.
C. Grant Management
1. The Administering Department shall manage awards in accordance with 2 CFR
200, Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards, applicable State laws and/or regulations, and
corresponding contractual agreements. FMS Grant Accounting shall provide
assistance and serve as a resource for clarification of any questions regarding 2
CFR 200.
2. If the grant has subrecipients:
a. The Administering Department, with assistance and support from FMS
Grant Accounting, shall perform a risk assessment for each subrecipient
before passing along awarded funds, in accordance with 2 Code of
Federal Regulations ("CFR") §200.331, "Requirements for pass -
through entities," and formulate a risk mitigation plan based on
identified risk factors.
b. The Administering Department, with assistance and support from FMS
Grant Accounting, shall perform subrecipient monitoring in accordance
with §200.330, "Subrecipient and Contractor Determinations," and
§200.331, "Requirements for Pass -Through Entities," and document
such monitoring.
3. The Administering Department shall monitoring contractors to ensure
compliance with all contract provisions.
4. All grant -related procurement activities must be conducted in accordance with
all applicable City policies and State and federal laws and regulations (e.g.,
Davis -Bacon Act).
a. If a capital asset is purchased or created with grant funds, FMS Grant
Accounting and FMS Capital Assets should be notified.
b. For federal grants, no local purchasing preference can be given.
c. For federal grants, cost plus a percentage of cost and percentage of
construction cost methods are prohibited.
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d. The City is responsible for full compliance with the procurement
regulations contained in 2 CFR 200 (200.317-200.326` for- the City
rf'rsea year— beginning Oeteber- 1, 2014 The Gity, neyeftheless, is
e. Vendors shall be checked against the list of debarred/suspended vendors
on SAM.gov prior to awarding any contract and annually thereafter, at
a minimum.
5. The Administering Department shall submit project status reports in accordance
with the award agreement, and provide copies of such reports to FMS Grant
Accounting to be attached in PeopleSoft.
6. Where financial reports —including financial status reports (FSRs), requests for
reimbursement (RFRs) or drawdowns, or close-out reports —are filed by the
Administering Department, the Administering Department should submit a
draft of the submission to FMS Grant Accountingfive ive (5) business days prior
to the due date for review and concurrence. Where such financial reports are
filed by FMS Grant Accounting they should be submitted to the Administering
Department five (5) business days prior to the due date for review and
concurrence.
6 7The Administering Department shall create and maintain adequate
documentation for all program operations and expenditures (activity reports,
invoices, purchase orders, receipt documentation, etc.).
7-.8The Administering Department and FMS Grant Accounting shall create and
maintain all pertinent award -related documentation in accordance with
§200.333 Retention Requirements for Records and applicable State law as
specified in City records management policies and supply it as requested to
authorized grant monitors.
8-.9FMS Grant Accounting willshall ensure awards are accounted for in accordance
with 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and
Audit Requirements for Federal Awards, applicable State regulations, and City
policies and procedures.
910. The Administering Department and FMS Grant Accounting shall, at a
minimum, review and analyze grant financials monthly. This review will
include a process to verify that all costs are allowable and appropriate and that
all revenues earned have been recognized.
44,11. As determined and spydocumented in the Grant Kick-off Meeting, either
the Administering Department or FMS Grant Accounting will submit financial
reports in accordance with the award agreement.
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12. Grant funds shall not be used to purchase gift cards or other cash -equivalent
items for distribution to recipients. All disbursements of funds and/or assets
shall follow standard Cily procedures to ensure accountability and compliance.
44-.13. Other roles and responsibilities for the Administering Department:
a. Ensure funding is managed according to the terms and conditions of the
award,
b. Request award extension and/or agreement amendments, if necessary,
c. Prepare M&Cs for grant amendments, if necessary,
d. Submit budget transfers requests and adjttstixgcorrectinn journal entries
to FMS Grant Accounting in a timely manner, and
e. Monitor grant terms and conditions for any changes throughout the
performance period (with support from FMS Grant Accounting).
�?14. Other roles and responsibilities for FMS Grant Accounting:
a. Ensure that all appropriate grant documentation is attached to
PeopleSoft Project Definitions and/or journal or budget entries,
b. Maintain all other appropriate grant -related documentation in the City's
physical or virtual storage,
c. Review grant amendment -related M&Cs for completeness and
correctness,
d. Serve as point of contact for financial matters and grant questions,
e. Attach and maintain copies of operating and financial reports in
PeopleSoft, and
f. Enter and approve budget transfers.
D. Grant Accounting
1. All grant -related financial activity must be accounted for in the City's primary
accounting system of record (PeopleSoft).
2. Direct and indirect costs should be clearly identified and separated.
3. City contributions (matching) and grantor funds should be clearly identified and
separated.
4. The Administering Departments and/or FMS Grant Accounting are responsible
to submitfor submitting all financial reports required by grantor agencies, as
determined and documented in the Grant Kick-off Meeting.
5. The Administering Departments and FMS Grant Accounting must ensure that
grant budgets set up in PeopleSoft are correct, appropriate, and allowable. FMS
Grant Accounting shall review submitted budgets for balance and correctness.
Multi -year grants pose special challenges, and, in conjunction with FMS Grant
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Accounting, Administering Departments should decide how various time
periods and activities are to be handled before the grant is initially set up. T4is
is nest *.,..ieal y handleThis should be decided and documented as part of
the Grant Kick-off Meeting.
6. The Administering Departments and FMS Grant Accounting must be aware of
the particular requirements of reimbursement, advance payment, or fee -for -
service grants as they apply to each award.
7. The Administering Departments, with support from FMS Grant Accounting,
must be familiar with, comply with, and document compliance with all
contractual requirements for applicable grants.
8. FMS Grant Accounting shall review PeopleSoft financials for each grant each
month and communicate any issues encountered to appropriate grant staff.
9. Expenditures/Expenses:
a. The Administering Departments-, in conjunction with the Purchasing
Division of the Financial Management Services Department-, shall
ensuringensure that all grant -related procurement is handled in
accordance with Financial Management Policy Statements, City
purchasing standard operating procedures (SOPS), and all applicable
state and/or federal grant regulations and contractual requirements.
b. The Administering Departments are responsible for ensuring that grant -
related funds are only obligated/expended when there is budgetary
authority to do so.
c. The Administering Departments are responsible for monitoring grant
budget status to ensure that necessary budget modifications are made
before expenditures are needed.
d. The Administering Department, with support and assistance from FMS
Grant Accounting, is responsible for ensuring that all expenditures are
necessary, reasonable, allowable, and appropriately allocated.
e. The Administering Departments and FMS are responsible for ensuring
that all disbursements are correct, and that any required retainage or
cash held by other entities is accounted for properly.
10. Revenues:
a. The Administering Departments must provide FMS Grant Accounting
with copies of aaU request for reimbursement (RFR) or drawdown
request each time they are submitted.
b. FMS Grant Accounting is responsible for making them journal
eentries to recognize the revenue and create a receivable.
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c. FMS Grant Accounting is responsible for monitoring bank account
activity, and, when ACH deposits hit the appropriate bank account,
making entries eRDDs to reflect the sums received.
d. FMS Grant Accounting is responsible for reconciling receivables and
payments received.
11. Journal Entries:
a. The Administering Departments are responsible for making all grant -
related journal entries corresponding to a particular accounting period
(month) no later than the deadline specified in each month's published
close schedule. Nothing herein shall prohibit FMS Grant Accounting
from identifying entries that need to be made and making them on behalf
of departments.. when necessary to ensure compliance with City policy,
grant requirements, or Generally Accepted Accounting Principles
G( AAP).
b. FMS Grant Accounting is responsible for reviewing and posting any
such journal entries.
c. For large journal entries better handled by uploading, the Administering
Department shall provide FMS Grant Accounting with the necessary
data and back-up, and FMS Grant Accounting will upload, review, and
post the journal entries.
d. FMS Grant Accounting is responsible for City fiscal year-end entries
such as accruals, adjusting entries, etc.
e. At the close of each grant, the Administering Department, with support
and assistance from FMS Grant Accounting, is responsible for ensuring
that all applicable revenues, expenditures, and transfers are reflected in
PeopleSoft.
12. FMS Grant Accounting will serve as the point of contact for the annual Single
Audit and coordinate and provide responses to the City's external auditors.
13. FMS Grant Accounting will prepare the annual Schedule of Expenditures of
Federal Awards (SEFA) and Schedule of Expenditures of State Awards
(SESA), and will coordinate with the City's external auditors to file the results
with the Federal Audit Clearinghouse (FAC).
E. Grant Closeout
1. After completion of all required performance period activities, the
Administering Department and FMS Grant Accounting shall perform grant
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closeout tasks in accordance with §200.343 Closeout or corresponding State
regulations, City policies, and contractual requirements.
2. The Administering Department and FMS Capital Assets shall ensure property
purchased, donated, or constructed in relation with grant funding is accounted
for in accordance with §200.310 - §200.316 and §200.329.
3. The Administering Department is responsible for final performance reports
required by the terms and conditions of the award and shall provide copies to
FMS Grant Accounting for attachment in PeopleSoft.
4. The Administering Department and FMS Grant Accounting are responsible for
preparing_ final financial reports required by the terms and conditions of the
award. The Administering Department and FMS Grant Accounting are
responsible for collecting and maintaining all appropriate back up
documentation for financial reports.
5. The Administering Department shall notify FMS Grant Accounting to close the
grant in City's financial system and provide all required closeout
documentation:
a. Project Closeout Checklist,
b. Request to inactivate _Combo Codes (}fwhere applicable), and
c. Request to inactivate or redirect Payroll Task Profiles (4where
applicable).
6. The Administering Department or FMS Grant Accounting (per the signed Grant
Kick-off agreeChecklist) shall ensure final reimbursement request is
submitted. FMS Grant Accounting shall verify that final reimbursement has
been received.
7. The Administering Department and FMS Grant Accounting shall ensure that all
financial activities are recorded, that revenues balance to expenditures, and that
revenues and expenditures balance to budget figures.
vim?e dra^,i.n' stering De 3iftmen4 sh"1 �ee"mbe e6�vrElesur—e-and task-
gr-eups4as i profiles for- elesufeor-occdir-eetion.. F R�4S Gr—£cir+i-Aeeouirtii _ 1 11
review d-approve, and F"�.ro Finaneial Repoi4ing will pr-eeesrs the eq s.
9-.8. FMS Grant Accounting shall complete the grant -closeout process in
PeopleSoft.
F. Post -Close
1. The Administering Departments and FMS Grant Accounting are responsible
for ensuring that their records are maintained in accordance with applicable City
policy, State law, and federal regulations.
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2. The Administering Departments are responsible for any programmatic
reporting required by the grant, regardless of performance period.
3. The Administering Department and FMS Grant Accounting are responsible for
responding to and cooperating with auditors, monitors, and other grantor
personnel, as well as the City's independent or internal auditors.
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