Grants Policy

Financial Management Policy 31200

1. Purpose

The purpose of this policy is to provide general information and guidance to individuals regarding the financial administration of grant awards.

2. Policy

2.1 Overview: External funding to Germanna is important to supplement operating resources for matters such as the development of new programs and services; supplementing existing programs and services with equipment or other resources; and, providing resources for professional development.

2.2 Sponsored program/grant agreements and funding are binding legal agreements awarded to the College (never to an individual or department) and must be approved by the College.

2.3 Except in rare instances where federal regulations depart from Commonwealth of Virginia policies, personnel matters and financial transactions shall comply with Germanna, VCCS, and Commonwealth of Virginia policies, procedures, and regulations.

2.4 To provide proper segregation of financial transactions and balances, grants shall be assigned unique department codes within the College’s accounting system separate from other grants and from other College programs and activities.

2.5 The official system of record for grant finances shall be the College’s financial enterprise management system. Presently, that system is the Oracle/PeopleSoft Administrative Information System (AIS).  Supplemental systems are acceptable to guide or assist managers; however, official reports of revenues, expenses, cash or other financial categories shall be based on balances contained in AIS.

2.6 Responsibilities

2.6.1 Business Office, including Accounting and Procurement.

2.6.1.1 The College must ensure its accounting system and practices operate in compliance with 2 CFR, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, audit requirements as well as with Commonwealth of Virginia and VCCS policies, procedures, and regulations.

2.6.1.2 The Business Office will work with the VCCS Office of Fiscal Services to establish departments for each grant, maintain accounting journals and ledgers, produce financial reports from the accounting software system, and provide financial information to the Grant Manager, auditors, and other parties as needed.

2.6.1.3 Generally, grant departments shall be established in Ledger 2 of the accounting software system. Exceptions may be granted by the VP for Administrative Services for local or private grants to be recorded in Ledger 5 of AIS.

2.6.1.4 The Business Office shall work with the Grant Manager to ensure that reimbursable grants have adequate, but not excessive, cash advances from the College’s Local Funds to ensure grant programs and activities occur as scheduled and that excess cash advances are returned timely to the College’s Local Funds.

2.6.1.5 The Budget Manager shall ensure the approved grant budget is reflected in the accounting system and that adequate appropriations and allotments from the State, via the VCCS, are received timely.

2.6.2 Project Manager

2.6.2.1 The Grant Manager will notify the Business Office of any changes in the award period and approved budget of the grant.

2.6.2.2 The Grant Manager will monitor expenses on a regular basis via reports and online access to the College’s accounting system.

2.6.2.3 The Grant Manager will comply with all grantor, State, VCCS, and College policies on all financial and human resource matters.

2.6.2.4 Technical or narrative reports by the grantor/funding agency are to be prepared by the Project Manager.

2.6.2.5 The Grant Manager will work with the Business Office for the submission of all financial reports and will ensure all reports are submitted timely.

2.6.2.6 The Grant Manager will collect data and compile reports detailing matching and in-kind contributions of the College, including the value of matching or in-kind salaries and benefits.

2.7 Grants shall be closed out timely following the grant’s ending date. Cash advances shall be returned to the College Local Funds and recurring expenses, including payroll and personnel costs, will be discontinued to the grant accounting codes.  Final reports shall be submitted by the Grant Manager to the grantor timely.

3. Procedures

3.1 Grant Establishment: Following notification of an award, the Grant Manager or grant writer shall notify the Business Office the grant award, providing a copy of the award notice, grant application and narrative, approved budget, and CFDA number, if applicable.

3.1.1 The Business Office shall work with the VCCS Office of Fiscal Services to establish a grant department code in a timely manner after receiving all necessary information from the Grant Manager or grant writer.

3.2 Management of Funds: The Grant Manager is responsible for managing grant funds in addition to the Business Office. The Grant Manager will approve invoices, contracts, payroll time and attendance, compare actual expenses to budgets, and manage the grant budget under the direction of his/her supervisor.  The Business Office shall ensure grant revenues and expenses are recorded timely and accurately to the assigned grant departmental code.

3.2.1 The Grant Manager shall notify the Business Office of any changes in grant terms and conditions, including dates and budgets.

4. Definitions

4.1 CFDA: Catalog of Federal Domestic Assistance; provides a full listing of all Federal programs available to State and local governments. The CFDA number assigned to the grant is required by the Business Office, the VCCS Office of Fiscal Services, and the Commonwealth of Virginia Department of Accounts in order to establish a new department code within the College’s Accounting System (AIS – Oracle/PeopleSoft).

4.2 DUNS: Data Universal Numbering System administered by Dun and Bradstreet.  The College has a DUNS number assigned. Project Managers should not request a new DUNS number.  Some grantors request the College’s DUNS number. That number is available from the Director of Finance (aka Business Manager).

4.3 FEIN: The Federal Employer Identification Number, which is assigned by the Internal Revenue Service (IRS). This number is available from the Business Office, Human Resources and Payroll, or the Vice President for Administrative Services.

4.4 Grant Manager: also referred to as Project Manager, Program Manager, and Principal Investigator.  The Grant Manager is the person responsible for overseeing the program activities, operations and finances of the grant in accordance with the terms and conditions required by the grantor while also ensuring compliance with College, VCCS, and Commonwealth of Virginia policies, procedures, rules, and regulations.

4.5 Indirect Costs/Administrative Costs: Costs that are incurred for multiple objectives and are not easily identified for any one particular objective.  Examples include, but are not limited to, utilities, copier usage, telephone usage, computer network usage, insurance coverage, building maintenance, Admissions & Records services, Financial Aid Services, Accounting, Procurement, and Fleet Management. The value of these services and the amount able to be charged to grants is often negotiated with the grantor. Many grants have limits on how much indirect cost can be charged to the grant.  In the event indirect costs are not permitted to be charged to the grant they are often permitted to be included as a matching cost.

In accordance with VCCS Policy, the College performs or has performed on its behalf, an indirect cost study that results in an indirect cost rate.  That rate can be obtained from the Associate Vice President for Administrative Services, the Vice President for Administrative Services or the Grants Coordinator.

4.6 Non-personnel Costs: also referred to as Other Than Personal Services (OTPS). Items such as supplies, contracted services, travel, meals, equipment, software, and professional development.

4.7 Pass-Through Entity: a non-Federal organization that provides a sub-award to a sub-recipient to carry out part of a Federal grant program.  An example may be a Federal Department of Education program awarded to a state department of education and then a subsequent award made to a college from those federal funds.  The state department of education serves as the pass-through entity in that example.

4.8 Personnel Costs: salaries, wages, and benefits paid to or on behalf of a position including retirement, social security, group life insurance, and health care.  All persons to be paid via payroll check should be included in this cost category.

4.9 Project Manager: also referred to as Grant Manager, Program Manager, and Principal Investigator.  The PM is the person responsible for overseeing the program activities, operations and finances of the grant in accordance with the terms and conditions required by the grantor while also ensuring compliance with College, VCCS, and Commonwealth of Virginia policies, procedures, rules, and regulations.

4.10 Sub-award: an award provided by a pass-through entity to a sub-recipient for the sub-recipient to carry out part of a Federal award received by the pass-through entity.  It does not include payments to a contractor or payments to an individual that is a beneficiary of a Federal program.  A sub-award may be provided through any form of a legal agreement, including an agreement that the pass-through entity considers a contract.

4.11 Sub-recipient: a non-Federal organization that receives a sub-award from a pass-through entity to carry out part of a Federal program.  This does not include an individual that is a beneficiary of such a program.  A sub-recipient may also be a recipient of other Federal awards directly from a Federal awarding agency.  That is, the status of recipient, sub-recipient, or beneficiary is determined for each award and is not attached to an organization in general.  It is important to determine whether or not the College is a sub-recipient so that proper reporting occurs to both the State and Federal programs providing the funds.  In some cases, the Project Manager may think they are the recipient of a state or local award but they are actually the sub-recipient of a Federal award.  If the College is a sub-recipient of a Federal award, a CFDA number will be assigned to the grant and must be provided to the College Business Office when establishing the department code for the grant.

5. References

Bloomfield College, Grants Financial Management Policy, April 2014

6. Point of contact

Vice President for Administrative Services

7. Approval

College Council: May 29, 2015
President’s Council: June 15, 2015