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Business and Operating Policies and Procedures
Policy: 4.11 Procedural Guidelines and Policies for the Development and Implementation of Externally Funded Grants and Contracts
Adoption Date: October 26, 2020 Revised
EXTERNAL FUNDS POLICY
All externally funded grants and contracts must be related to the vision and mission of the district. Any proposals for externally funded grants or contracts not congruent with the district’s vision and mission are not permitted.
For the purpose of this policy, the terms “externally-funded grant(s)” and “externally-funded contract(s)” will be collectively interpreted as external projects. This policy excludes external project funding for student financial aid programs.
This district policy is enabled for full and proper review, approval, implementation, and reporting of these obligations that include sponsors’ contractual requirements, State/Federal laws, regulations, and guidelines.
A. Expectations
1. Project Costs
All external project costs are expected to be reimbursed by the funding source. Budgets should reflect the actual costs of the project including, but not limited to, salaries and benefits for staff time devoted to the project, supplies, equipment, and administrative cost allowances as allowed by the funding entity.
2. Matching & Cost-Sharing
The project director is responsible for assuring that matching, cost-sharing, or special situations are met by the appropriate department and properly documented, as well as, completing the required matching/cost-sharing reports.
- Matching occurs when the college allocates a specified, contractual percentage to the project.
- Cost-sharing occurs when the college pays for certain costs that are not reimbursed by the funding source.
Matching and cost-sharing situations are handled on an individual basis. All matching and cost-sharing proposals should include a budget that details the total cost of the project and identifies costs to be borne by the funding source and the district, respectively. The President may negotiate and accept these types of agreements when the project is an integral part of the district’s vision and mission, or when other more desirable financial arrangements are not possible. All matching, cost-sharing, and special situations must be approved by the President.
B. Proposal Development
1. Requests & Available Funding Opportunities
The college will actively pursue grants from appropriate private and public sources for the support and enhancement of the college’s mission, goals, and strategic plan. District proposal writers will coordinate the receipt of all unassigned, incoming requests for proposals and other unassigned, available funding opportunities, including Texas and Federal Registry notifications received by the district for their respective site. They will either:
- pursue these opportunities,
- broadcast unassigned notices for potential interest, or
- file the documentation in a central location within their offices for future reference.
2. Pre-Proposal Discussion
The receipt of external project funds usually benefits the district; however, it can create additional reporting requirements, record keeping, and responsibilities. Therefore, permission must be granted prior to pursuing external project funds. Discussion should first be directed to a cabinet member and encompass:
- scope of external funding opportunities,
- proposal specifics including contract period,
- financial and narrative reporting requirements,
- chair/director/coordinator,
- budgets,
- matching and/or cost sharing requirements.
- salaries and benefits in excess of district contract amounts, and
- administrative costs.
3. Pre-Proposal Form
If a favorable determination is made to pursue an external funding opportunity, the proposal writer shall:
a. Review the Procedural Guidelines and Policies for the Development and Implementation of Externally Funded Grants and Contracts, Policy Number 4.11.
b. Initiate the Request to Apply for External Funding and Proposed External Funding Budget forms and submit them to his/her division director or immediate supervisor, who will review, endorse, sign, and forward the forms to his/her respective cabinet member.
c. The cabinet member will review, endorse, and forward to the Chief Business Officer.
d. The Chief Business Officer will review the forms, endorse, and forward to the Chief Financial Officer.
e. The Chief Financial Officer will review for the fiscal impact upon the district, endorse, and make a recommendation to the President.
f. The President has the option of approving or disapproving the request. Upon the President’s decision, forms will be returned to the Chief Business Officer. In some instances, the President may inform the Board of Trustees of the funding opportunity.
g. Upon receipt of the approved Request to Apply for External Funding and Proposed External Funding Budget forms by the proposal writer, he/she may proceed with writing the proposal.
C. Proposals
1. Preparation
The proposal writer shall be responsible for the proposal-writing process with final oversight responsibility of document preparation, required college signatures, packaging, and delivery.
Upon request, the Chief Technology Systems/Data Security Officer will provide general college information, statistics, and demographics.
2. Review
Two weeks before the proposal due date:
a. The proposal will be reviewed and endorsed by the division director, immediate supervisor, or other appropriate personnel at the departmental level.
b. The proposal writer will review the budget with the Chief Business Officer.
c. The proposal writer will review the entire proposal with the appropriate Cabinet Member who will advise the President and other appropriate college officials of proposal completion and any unusual contractual requirements.
d. The proposal writer will obtain the President’s final approval and signature.
College personnel are cautioned not to sign any contractual documents since employees do not have authority to bind the district in legal agreements and since contractual documents received from funding sources occasionally contain conditions which are unacceptable in terms of college policy and/or operating procedures.
3. Negotiations
The district will negotiate any administrative details with the advice and assistance of the appropriate college administrator(s) or official(s), and the affected department(s). Open discussion between funding source personnel and the proposal writer are encouraged, but caution should be taken to ensure that no commitments are made in regard to funding, equipment, facilities, cost sharing/matching, administrative cost allowances, etc. Only the college President has the authority to approve such commitments. In no instance shall anyone sign a contract until this review and negotiation process has been completed.
4. Control Over Activities
The college shall maintain control of all project activities of any sort that are established under this policy. This control over the quality and type of activities is to ensure that project activities are always in concert with the college and its stated vision and mission. The college will not enter into any agreements in which ultimate control is not maintained over the college’s portion of the activities. The college will terminate any project that requires that the college relinquish control over its activities or actions.
5. Notice of Funding
When the district receives notice of funding, all documents received from the funding source including a Notice of Award or signed contract, effective dates, approved budget, budget detail, Catalog of Federal Domestic Assistance (C.F.D.A.) number (if applicable), project number, reimbursement procedures and completed and signed Project Budget Setup, shall be forwarded to the Chief Business Officer. Submission of documents on a timely basis will expedite establishment of a departmental account number.
Acceptance of external funds obligates the district to exercise full responsibility in pursuit of the project.
D. Administration of External Projects
1. Pre-Expenditure of Funds
Funds may not be pre-expended unless specifically allowed under the terms of the external project in which case a written agreement containing the items listed in Section C.5 - is delivered to the Chief Business Officer and a departmental account is activated.
2. Departmental Account Number Setup
When a written agreement containing the items listed in Section C.5 is delivered to the Chief Business Officer, a setup form will be completed and forwarded to the District Director Financial Accounting who will setup the external project in the fiscal system. The Project Director must allow a reasonable amount of time for college employees to setup departmental accounts and input initial budget amounts.
3. Administrative Costs
Administrative Costs are normally not authorized to be charged to external projects. Administrative Costs may be charged to external projects with special approval by the Chief Business Officer.
4. District Policies & Project Activities
District policies apply to all external projects. Projects will operate under the same policies and operating guidelines as normal activities of the district. The Project Director will approve expenditures and purchase requests. The responsibility to ensure all expenditures conform to project guidelines rests solely with the Project Director.
Effort should be made to adapt and assimilate the project to existing practices, policies, salary structures, and procedures.
5. Use of College Resources
a. Administration
The college President and Chief Financial Officer, as well as other college administrative officials, may provide expertise as they coordinate the project’s activities with the district’s educational focus and administrative direction. From time to time, the President may inform the Board of Trustees regarding project activities.
b. Business Office & Financial Accounting
The Business Office and Financial Accounting departments provide services such as accounts payable, bank reconcilement, cash receipts, travel reimbursement, petty cash reimbursements, journal entries, record keeping, and reporting.
c. Information Technology
The Information Technology department provides operating systems, licenses, maintenance, intranet services, and internet connectivity for district and project computer equipment.
d. Chief Business Officer & Financial Accounting
The Chief Business Officer, and the Financial Accounting Department, jointly or individually, provide services such as department setup, initial budget input and budget changes, periodic and final expenditure reimbursement requests, journal entries, audit preparation, revenue and expense reports, college financial statement preparation, etc.
The Chief Business Officer will approve all purchase requests and other financial requests.
e. Facilities and Fleet Department
The Facilities and Fleet department provides labor, supplies, and materials to clean and maintain project areas.
f. Human Resources Department
The Human Resources department provides services such as payroll calculation and payment, benefits coordination, and Federal and State wage and tax reporting, and record keeping requirements.
For new employees, the Project Director will complete a Payroll Recommendation form according to district policy. The Project Director will send the new employee to the Human Resources department to complete the required paperwork.
When the Project Director needs to modify an employee’s department number, object code, or salary amount, a Payroll Recommendation form must be prepared and forwarded to the Human Resources department.
It is the responsibility of the Project Director to approve and submit timesheets or electronic time sheets for their employees to the Human Resources department according to the cut off dates established by the Human Resources department.
g. Purchasing Department
The purchasing department provides services in the form of requisitions, purchase orders, P-Cards, and guidance with bids and college purchasing procedures.
Purchase requests must follow college policy at all times.
The college opts to delay implementation of the new OMB standards, as allowed, for two fiscal years and continue utilizing procurement standards as authorized in previous OMB guidelines.
h. Other Departments
Other departments, such as Student Services and Instruction, may recruit students for projects. Before hiring foreign students for a project, the Chief Human Resources Officer shall be consulted to ensure compliance with Internal Revenue Service regulations.
i. Other
The district often provides office and classroom space and services such as utilities, janitorial, and property/equipment insurance. Sometimes the district may opt to charge projects for these type costs.
6. Reporting
a. Periodic Financial Reimbursement Requests
Financial reimbursement requests will be prepared from data in the financial accounting system. All reimbursement requests will be submitted according to the project’s reporting requirements. The individual responsible for completing the requests is indicated on the Request to Apply for External Funding form.
- When the Project Director is responsible for completing the reimbursement request, the Project Director will deliver the request to the Chief Business Officer prior to submission, remembering that adequate time must be allowed for review. The Chief Business Officer will review the reimbursement request and upon their approval, the request may be submitted.
- When the Chief Business Officer prepares the reimbursement request, the program director will review and sign the report prior to submission.
The certified reports will be mailed (or electronically transmitted) to the funding source and signed site copies will be filed with other expenditure documentation in the appropriate files.
b. Program & Budget Amendments
Project and budget amendments will be prepared by the Project Director according to the terms and conditions of the project
- If an amendment alters the project’s scope and the amendment does not require the President’s signature, the Project Director must notify the Chief Business Officer in writing of the change.
- If an amendment modifies financial amounts, the Project Director will initiate an online budget adjustment in the college’s accounting system and provide an updated Notice of Award to the Chief Business Officer, when applicable.
- If a project end date changes, a copy of the notice must be provided to the Chief Business Officer who will notify the District Director Financial Accounting so that the accounting system can be updated.
c. Other Reports & Activities
- The Project Director is responsible for producing all statistical, narrative, and non-financial reports as required by the funding source. These reports must be completed and submitted according to the project’s contractual requirements.
- Monthly, the Project Director will review and reconcile project expenses (e.g., payroll distribution, equipment, supplies, telephone, copy charges, etc.) as recorded in the college accounting system. Discrepancies should be immediately reported to the Chief Business Officer.
- Monthly, the project director will ensure that a Time & Effort log is completed for each employee paid from their Federal and State funded project according to the OMB guidelines. The project director will then safeguard a copy of the log in their files.
d. Final Project Financial Reports
In order to close a project and prepare a final expenditure report by the specified project due date, purchase orders should not be issued during the last 21 days of a project. In the event that a purchase order is requested during the 21 days prior to the project end date, the Project Director must notify the Chief Business Officer in advance for approval.
P-Card purchases shall not be made 60 days or less from project end dates.
The Project Director is responsible for clearing all encumbered items. When possible, these items should be cleared prior to the last 21 days of a project.
7. Fiscal Year
When the district suspends annual purchasing to close the fiscal year books, project purchase orders, travel reports, P-Cards, and petty cash will not be an exception to the suspension.
8. Sub-Grants
Sub-grants are the responsibility of the Project Director. The Project Director will notify award recipients according to the original project guidelines, execute necessary contractual documents, initiate the required purchase requests for sub-payment, obtain the sub-payment expenditure support documentation, and produce or obtain from the sub-recipient all statistical, narrative, non-financial, and financial reports as required by the funding source according to the timelines.
For each fiscal year a sub-recipient receives funds, the Project Director will obtain an annual certified audit report and all other required reports from each sub-recipient. The Project Director must follow up on all audit appropriate findings with the sub-recipient.
In the event equipment is acquired with sub-grant funds, the college will inventory these items when they fall within the ownership scope of the college. If the project guidelines specify that the equipment becomes the property of the sub-recipient, the college will relinquish control of these items to the sub-recipient according to project guidelines.
9. Over Expenditures
Over expenditures shall be cleared no later than 14 days prior to the expiration of the project. The Project Director is responsible for covering over expenditures. If departmental funds are unavailable, the appropriate site and/or administrative area will be responsible for covering over expenditures. The Project Director is responsible for coordinating the funding of any over expenditures with the appropriate site and/or administrative area.
10. Permanent Records
A permanent file of each project will be maintained by the Chief Business Officer as required by the college Records Management Retention Schedule or as required by the terms of the project, whichever is greater.
E. Other Matters
1. Receiving Sub-Grants
In situations where Howard College is a sub-grantee, the college will follow policies of the fiscal agent when Howard College:
- receives written allowable activities,
- receives a written budget, and
- has written authority from the fiscal agent stating that they are following project policies and guidelines, State law, and/or Federal law.
2. Supplanting
When a grant disallows supplanting, such as the Carl D. Perkins Career and Technical Education grant which disallows supplanting for CTE students, the Project Director shall ensure that grant funds are not used in place of other private, local, state, or federal funds which would normally be expended.
For example, these types of non-supplanting funds cannot be used to pay for services, staff, programs, or materials that would be normally paid with other funds, such as:
- any program or activity required by State law,
- THECB rules and requirements, and/or
- college board policy.
The Project Director shall maintain documentation that clearly demonstrates that non-supplanting grant funds were expended for supplementary activities only and maintain the documentation in their records.
3. Research Projects
Research projects are typically more a function of the university environment than that of the community college environment. For this reason, Howard College usually will not solicit or engage in research projects.
While a researcher’s freedom to investigate and report results are preserved, research support from outside agencies should not undermine basic research principles.
If a research grant is written, all policies herein will apply to that project.
4. Duty to District
Administration will not allow a project activity to detract from the faculty or staff member’s obligation and duty to the district.
Any project activity that requires an undue amount of time from an employee’s normal duties must be covered by the project as a direct charge to the project’s salary and benefits categories. If significant project time is required, additional compensation through the district’s career pathing provisions may be utilized.
Fees paid to faculty or staff such as summer salaries, salary supplements, and consultant services must be approved in advance by the President, as well as the other opportunities mentioned in this section.
5. Dependency on External Funds
The district will not allow itself to become dependent upon external funding. Project funds will be used to enhance the normal activities of the institution and not to provide integral or generic services or functions.
6. Letters of Support
Letters of support can create obligations for the district, especially if district facilities are offered for project activities.
If an external entity requests a district employee to write a letter of support, the employee must complete a Request to Write External Letter of Support form and obtain administrative approval prior to writing the letter.
If an employee is requested to write a letter of support for a college proposal, the employee may proceed provided a Request to Apply for External Funding form has been approved by the college President.
F. EMPLOYEE CONFLICT OF INTEREST POLICY
No college employees, officers, or agents shall participate in the selection, award, or administration of a contract supported by external funds if a real or apparent conflict of interest would be involved. A conflict of interest would arise when the employee, officer, or agent, any member of his or her immediate family– or an organization which employs or is about to employ any of the parties indicated herein– has a financial or other interest in the firm selected for award. The officers, employees, and agents of the recipient shall neither solicit nor accept gratuities, favors, or anything of monetary value from contractors, or parties to sub-agreements. However, recipients may set standards for situations in which the financial interest is not substantial, or the gift is an unsolicited item of nominal value.
G. CONTRACTS
Contracts concerning agreements between the college district and other organizations may be made only with the consent of the President. Contracts for services to be performed by or for the district are to be signed by the President or designee.
H. INVENTORY
Department heads are designated as property custodian and have responsibility to manage, control, and account for personal property and controlled property items— as defined below— within their department.
1. Personal Property
All non-consumable property having an acquisition cost of $5,000 or more.
2. Controlled Property
Property listed below that costs between $500 and $4,999.99 such as:
- Data projectors
- Stereo systems
- Cameras
- Desktop CPUs
- Tablets & handheld devices
- Portable CPU laptops
- Video recorders/laserdisc players (TV, VCR, camcorders)
- Document cameras
College property management must follow the college’s policies and procedures as denoted in the Purchasing/Property Management Procedure Manual.
Personal property and controlled property items will be tagged with a college inventory tag containing a unique identifying number. In addition, items purchased with federal or state grants funds will also be tagged with a label that identifies the grant funding source.
Physical Inventory
The property manager is responsible for having the actual physical inventory of each department reviewed. The property manager will forward to the department heads a detailed listing of the property and equipment carried on the property manager’s records for the department. Each department head is responsible for seeing that an accurate inventory is conducted of all property assigned to their department in accordance with instructions given by the property manager. Any discrepancies should be noted on the detailed lists
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