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HomeMy WebLinkAbout21-1559RESOLUTION NO. 21-1559 A RESOLUTION OF THE CITY OF DENTON APPROVING AND ADOPTING ADMINISTRATIVE POLICY NO. 402.10 "GRANT ADMINISTRATION"; AND PROVIDING AN EFFECTIVE DATE. WHEREAS, grants are an award of financial assistance, including cooperative agreements, in the form of money, property in lieu of money, professional services, staffing, or other financial assistance paid or furnished by the State, County, Federal government, or other entity to carry out a program in accordance with rules, regulations, and guidance provided by the grantor entity or agency; and WHEREAS, the City of Denton applies for, receives, and executes grants annually; and WHEREAS, the administrative policy will establish the framework for operating practices and procedures to execute grant programs and projects; and WHEREAS, the City Council deems it in the public's best interest to continue to be eligible for grants through program compliance and to formally approve and adopt the Grant Administration Policy; NOW THEREFORE, THE COUNCIL OF THE CITY OF DENTON HEREBY RESOLVES: SECTION 1. The following policy entitled Policy No 402.10 "Grant Administration" attached hereto and made a part hereof, is hereby adopted as an official policy of the City of Denton. SECTION 2. The attached policy shall be filed in the official records with the City Secretary. SECTION 3. This Resolution shall become effective immediately upon its passage and approval. The motion to approve this Resolution was made by ? -` _ and seconded by; GGA !� C This Resolution was passed and approved by the following vote [-7 Aye Nay Abstain Absent Mayor Gerard Hudspeth: Vicki Byrd, District 1: Brian Beck, District 2: J Jesse L. Davis, District 3: Alison Maguire, District 4: ,L Deb Armintor, At Large Place 5: Paul Meltzer, At Large Place 6: ,/ PASSED AND APPROVED this the 2kAtln, day of v �S , 2021. GERARD HUDSPETH, MAYOR ATTEST: ROSA RIOS, CITY SECRETARY APPROVED AS TO LEGAL FORM: CATHERINE CLIFTON, INTERIM CITY ATTORNEY :• CITY OF DENTON POLICYIADMINISTRATIVE PROCEDURE/ADMINISTRA.TIVE DIRECTIVE SECTION: FINANCE REFERENCE NUMBER: 402,10 INITIAL EFFECTIVE SUBJECT: GRANTS DATE: 08/24/21 TITLE: GRANT ADMINISTRATION LAST REVISION DATE: DIRECTIVE Grant funds received by the City of Denton support important programs and services the City provides to the community. These funds allow the City to extend pre-existing services, introduce new initiatives, gain technological advances, and subsidize programmatic staffing. While providing a financial benefit to the City, these programs also contain certain requirements for compliance by the City. The purpose of this directive is to develop, implement, and maintain meaningful grant oversight and coordination for the City, thereby increasing grant -related revenue, limiting the City's exposure to grant -related liability, and improving the efficiency and impact of programs and services funded through grants. This directive establishes the responsibility for ensuring contract compliance and provides pre -award, post -award, and close out processes as defined below. ADMINISTRATIVE PROCEDURES I. SCOPE AND APPLICABILITY All employees of the City 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 department grant procedures. Every grant opportunity and awarded grant shall follow the procedures outlined in this policy. Grant programs with approved policies and established procedures that require review by a City Council appointed board, commission, or committee will follow the approved policies for that program and all applicable federal and state laws, grant requirements, and City policies. 11. CONFLICT OF INTEREST City officials and employees should be diligent in the identification of potential conflicts of interest when working in any capacity with any proposed or funded grant involving the City. No officer or employee of City shall have any interest, financial or otherwise, direct or indirect, or have any arrangement concerning prospective employment that will, or may be reasonably expected to, bias the design, conduct, or reporting of a grant funded project on which he or she is working. POLICY/ADMINISTRATIVE PROCEDURE/ADMINISTRATIVE DIRECTIVE TITLE: GRANT ADMINISTRATIVE DIRECTIVE REFERENCE NUMBER: 402.10 It shall be the responsibility of Grant Manager for each particular grant funded project to ensure that in the use of project funds, officials or employees of the City and nongovernmental recipients or sub -recipients shall avoid any action that might result in or create the appearance of a conflict of interest and ensure adherence to City of Denton Policy 10.00 Ethics. A. Automated Standard Application for Payments (ASAP) — A Federal payment program that allows grantee organizations receiving Federal funds to draw from accounts pre -authorized by Federal agencies via an online website for automatic payment to the City's bank account. B. Catalog of Federal Domestic Assistance (CFDAJ — Publication that includes information related to all Federal programs, including the program title, description, history, and assigned number (CFDA number). C. Data Universal Numbering _S, System — The nine -digit number established and assigned by Dun and Bradstreet, Inc. (D&B) to uniquely identify entities. A non - Federal entity is required to have a DUNS number to apply for, receive, and report on a Federal award. The Federal Government uses the DUNS number to track how Federal money is allocated. The DUNS number for the City of Denton is 071380190. NOTE: This number is annually renewed by Finance every June 30'. D. Discretionary Grants — Funded by federal or state legislation to address current social issues. Allows legislation to use discretion in determining how the grant program will be designed and who will be eligible for funding. These grants are usually competitive in nature and are determined through a peer review process. E. Employer Identification Number (,EINE — The nine -digit number assigned by the Internal Revenue Service. The EIN number for the City of Denton is 75-6000514. F. Federal Awards — Grants of Federal financial assistance (grants, loans, Ioan guarantees, property, etc.) and Federal cost -reimbursement contracts that the City receives directly from the Federal awarding agency or indirectly through a pass-through entity. G. Formula Grants — Also known as entitlement grants, formula grant awards are determined by a mathematical formula defined in a statute (federal or state) that takes into account the demographics to be served by the grant. These grants are not competitive, although grantees are required to complete grant applications and comply with other grant requirements in order to ensure that grant funds are expended in accordance with the defined purpose and goals of the grant program. H. Funding Source — The originating Federal or State agency providing the grant. A pass-through grant from the State shall always have a Federal agency as the Funding Source. POLICY/ADMINISTRATIVE PROCEDURE/ADMINISTRATIVE DIRECTIVE TITLE: GRANT ADMINISTRATIVE DIRECTIVE REFERENCE NUMBER: 402.10 I. Grants — The overall encompassing term for an award of financial assistance, including cooperative agreements, in the form of money, property in lieu of money, professional services, staffing or other financial assistance paid or furnished by the State, County, Federal government, or other entity to carry out a program in accordance with rules, regulations, and guidance provided by the grantor entity/agency. J. Grant Administrator — Individual assigned daily responsibility for ensuring that the grant is administered in accordance with all grant requirements and that all applicable documentation is maintained. K. Grant Accountant — Accounting department employee assigned to ensure proper general ledger recording of grant funds. Employee will prepare the SEFA report and assist the Grants Management Office with compliance reviews. L. In -Kind — A contribution of equipment, supplies, or other tangible resource, as distinguished from a monetary grant. Some organizations may also donate the use of space or staff time as in-kind contribution. M. Pass-through,X — A non -Federal entity that provides a sub -award to a sub - recipient to carry out part of a Federal program. N. Program Income —Income from fees for services performed, from the use or rental of real or personal property acquired with grant funds, from the sale of commodities or items fabricated under a grant agreement and from payments of principal and interest on loans made with grant funds (where authorized). O. Sub -recipient — A non -Federal entity that receives a sub -award or sub -grant from a pass-through entity to carry out part of a Federal Program. P. Supplanting — To deliberately reduce budgeted funds because of the existence of grant funds. For example, when City funds are appropriated for a stated purpose and grant funds are awarded for that same purpose, the City replaces its budgeted funds with the grant funds and shifts the budgeted funds to a different purpose. Q. Schedule of Expenditures of Federal_ Awards (SEFAJ — A supplemental schedule to the financial statements that an organization is required to produce when it is subject to the single audit requirement. It is an essential document for planning and conducting the audit of the organization. It also provides assurance to those agencies that award financial assistance that their programs or grants were included in the audit. IV. ROLES AND RESPONSIBILITIES The following shall govern responsible parties for activities surrounding the submittal, implementation, maintenance, reporting and other related duties for grant funded projects by or on behalf of the City. The full development of a project or programs requires the assistance and support from all affected parties. POLICY/ADMINISTRATIVE PROCEDURE/ADMINISTRATIVE DIRECTIVE TITLE: GRANT ADMINISTRATIVE DIRECTIVE REFERENCE NUMBER: 402.10 A. Grantor — A governmental unit, foundation or other entity that awards grants. B. City Council — The City of Denton operates a Council -Manager form of government. There are six Council Members and a Mayor. Two Council Members and the Mayor are elected at -large with the remaining four Council Members elected from single -member districts. C. Grant Administrator — The primary person responsible for providing city-wide coordination and monitoring of grants. This individual is responsible for ensuring that the City's grants management and compliance program is current and effectively fulfills the compliance requirements of the City's administrative policies and external granting agencies. D. Grant Accountant — Responsible for setting up grant accounts, monitoring grant expenditures, reconciling reimbursement requests, and reviewing required reports prior to submission. E. Grant Analyst — The position responsible for providing support in grant management and compliance activities for the City. F. Procurement Department — The Procurement Department will process procurements according to the grant agreement, state and federal laws and regulations, and City policy. The Procurement Department will also provide guidance in the development of contracts and sub -recipient agreements in compliance with applicable regulations and requirements. Grant Managers are ultimately responsible to adhere to the stipulations from the approved award / contract to ensure that allowable expenditures are conducted. G. City Attorney — The City Attorney or their designee shall review the terms and conditions of a grant agreement. Grant agreements involve little or no negotiation. Despite the City's lack of bargaining power in this regard, it is nevertheless prudent to conduct a legal review of grant agreements to ensure that all of the terms of the agreement are legally enforceable. In consultation with the Legal Department, the City will decide on accepting or declining an award based on the terms of the agreement. H. Grant Review Committee — A Grant Review Committee will be formed with the purpose of reviewing grants prior to submission to evaluate the benefits to the City, alignment with City Council goals, consistency with strategic plans and core values of the City, ability to comply with grant requirements, and short and long-term obligations associated with a grant award. I. Administering Department — The Department within the City who was awarded the grant and / or is overseeing the activities of a grant -funded program or project. J. Department Heads — An executive manager with programmatic and fiscal responsibilities for a designated department. He or she is the individual who ensures adequate staff and infrastructure are provided for the appropriate performance of grant award management and supervises staff members identified as key members on grant POLICY/ADMINISTRATIVE PROCEDURE/ADMINISTRATIVE DIRECTIVE TITLE: GRANT ADMINIS'T'RATIVE DIRECTIVE REFERENCE NUMBER: 402,10 awards. The Department Head is responsible for ensuring grant programs meet the City's current priorities and policy objectives and oversight of the Grant Manager. K. Grant Manager — The Grant Manager is responsible for the management activities on a project/grant. Although some tasks may be delegated, the Grant Manager is the chief accountable person and bears responsibility for the overall administrative and fiscal conduct of the grant award for meeting the terms and conditions of the award and for representing the project to the granting agency. L. Grant Coordinator — The Grant Manager may delegate tasks related to grant management to a Grant Coordinator or Department Project Manager. This staff member is responsible for the programmatic activities of the grant. The Grant Coordinator is the subject matter / field expert or staff member directly involved with operations related to the grant. V. PRE -AWARD PROCEDURES A. Application All Applications/Requests for grant funding are to be tracked by the Grant Administrator and the Finance Department. This is to ensure that duplicate applications for the same grant are not performed as generally grantors will not consider any proposal from a municipality if more than one proposal is submitted during the same funding cycle. The City shall not submit multiple grant applications for any one funding announcement or program during the same funding cycle unless explicitly allowed by the Grantor and approved by the Grant Administrator. Grant applications involving multiple departments shall be coordinated by the Grant Administrator. Each Department that is involved with a grant shall be involved fiscally and programmatically and agree to the elements of the program that may affect their department after the funding has ended for the grant funding. Each Administering Department is responsible for assisting in the preparation of the grant application and provide all required documentation for submittal to the Grant Administrator. Under no circumstances should work outlined in the grant application Scope of Services begin prior to the award of the grant and executed agreement(s) being completed. The Grant Administrator will inform parties of this step being completed, and that work may begin under the grant agreement. B. Application Review Process Proposed grant applications will go through a process of review and approval prior to submission. The Department Head, or designee, will submit the grant application to the Grant Review Committee. The Committee will provide a recommendation on proceeding to the Assistant City Manager/CFO. After review by the Assistant City Manager/CFO, the recommendation shall be forwarded to the City Manager. The Department Head will be notified of approval to proceed. Additional direction or approval by City Council may be required. POLICY/ADMINISTRATIVE PROCEDURE/ADMINISTRATIVE DIRECTIVE TITLE; GRANT ADMINISTRATIVE DIRECTIVE REFERENCE NUMBER: 402.10 C. Grant Review Committee The Grants Management Office will oversee the committee. The committee will be comprised of: 1. Grant Administrator 2. Finance Director 3. Budget Manager 4. Procurement Director 5. Controller b. Department Head D. The Grant Administrator will schedule regular meetings for the Grant Review Committee. Grant requests shall be submitted to the Committee for review no later than 20 days prior to the grant agency submittal deadline. This allows for the adequate preparation of documents by the Department and review by Committee members. Exceptions to this requirement will be considered on a case-by-case basis and may be authorized by the City Manager or Chief Financial Officer. Exceptions made to this requirement do not constitute an exception to other requirements of this directive. E. The Committee and their related duties shall not, however, relieve the Department Head and Grant Administrator of primary responsibility for grant compliance. Vt. POST -AWARD PROCEDURES A. Award Notification and Acceptance Once the award notification has been received, the Grants Management Office will be notified, and a copy will be placed in the designated record management system. The Administering Department, Grant Administrator, Finance Director and assigned Grant Manager are responsible for reviewing the proposed agreement/document to assure that all conditions required by the Grantor can be fulfilled. In the event that the funds awarded by the granting entity are reduced from those requested in the original grant application, the recipient department must ensure that the goals, objectives and evaluation components can still be accomplished, and that adequate funding is available to accomplish the intent of the grant. If the review is affirmative, the recipient department will work with the Grant Administrator to initiate the administration of the grant. All award documents must be filed in the designated record management system. Once the grant has been approved and properly executed, it is the Administering Department's responsibility to carry out the project and/or activities associated with a grant to their full extent, while adhering to all of the terms and conditions prescribed by the Grantor. Failure to do so increases the City's exposure to legal Iiability and compromises current and future grant funding. POLICY/ADMINISTRATIVE PROCEDURE/ADMINISTRATIVE DIRECTIVE TITLE: GRANT ADMINISTRATIVE DIRECTIVE REFERENCE NUMBER: 402.10 B. Award Management Once the grant funding has been awarded, the work of project implementation begins. The Administering Department receiving the award must focus on the implementation, monitoring and evaluation of the grant funded program. Oversight of this process is critical to ensuring that the interests and responsibilities of the City are met. Grants management entails the establishment of standard operating procedures and clear, regular communication by the department and Grant Manager with the Grant Administrator regarding the status of the grant funded project and required communication with the granting entity. The Grants Management Office and 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. The Grants Management Office and Grant Accountant shall provide assistance and serve as a resource for clarification of any questions regarding 2 CFR 200. C. Grant Administration City Council Approval and Signing the Agreement a) Review and approval by City Council may be required for grant application or acceptance or to execute grant contracts/agreements. (1) A grant application reviewed and approved by City Council prior to submission will require no further action by City Council unless required by the grant or ordinance. b) Once approved by City Council, the grant can be accepted, and the agreement may be signed by the City Manager or Mayor as specified in the agreement or ordinance. 2, Daily Administration of the Program a) 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, city policies and corresponding contractual agreements. b) The Department Head may delegate their daily responsibilities for administering the grant/award to a Grant Manager. However, the Department Head still retains overall responsibility for the grant/award. C) If the grant has subrecipients: (1) The Administering Department, with assistance and support from the Grants Management Office, shall perform a risk assessment for each subrecipient before passing along awarded POLICY/ADMINISTRATIVE PROCEDURE/ADMINISTRATIVE DIRECTIVE TITLE: GRANT ADMINISTRATIVE DIRECTIVE REFERENCE NUMBER: 402.10 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. (2) The Administering Department, with assistance and support from the Grants Management Office, 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. Procurement and Suspension 1 Debarment a) 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). (1) Vendors shall be checked against the list of debarred/suspended vendors in the Excluded Parties List System (EPLS) on SAM.gov prior to awarding any contract and annually thereafter at a minimum. Documentation on a search confirmation must be included in the grant file. 4. Reporting and Reimbursement Requests a) The Administering Department shall initiate the reporting process to allow time for review by the Grants Management Office and Grant Accountant. Reporting shall be submitted to the Grantor in the timeframe specified by the grant/award agreement. b) The Administering Department shall prepare reimbursement requests and submit to the Grants Management Office and Grant Accountant for review. The Grant Management Office will assist the Department in ensuring reimbursement requests meet eligible expense and procurement requirements. Reimbursement requests shall be submitted to the Grantor in the timeframe specified by the grant/award agreement. C) The Grant Accountant shall review all reports and reimbursement requests prior to submission to ensure the reports agree to the general ledger and assist when needed. The Grant Accountant shall place the reconciliation in the grant folder in the designated record management system. 5. Receipt of Grant Funds When grant funds are received, the Grant Administrator or the Grant Accountant, whoever first identifies payment has been made, shall notify other necessary staff of the receipt. The Grant Accountant shall determine the POLICY/ADMINISTRATIVE PROCEDURE/ADMINISTRATIVE DIRECTIVE TITLE: GRANT ADMINISTRATIVE DIRECTIVE REFERENCE NUMBER: 402.10 correct deposit coding. The funds shall be deposited in accordance with normal deposit procedures and the City's Cash Handling directive. 6. Program Income Program income shall be accounted for as authorized by the Federal or State agency. Program income is usually deducted from total allowable costs to determine net allowable costs (i.e., Program income reduces the amount of money the City may be reimbursed with Federal funds). Costs financed by program income do not count toward satisfying a matching requirement unless they are expressly permitted in the terms of the assistance agreement. Program income does not include interest on grant funds, rebates, credits, discounts or refunds. D. Other Post Award Requirements 1. Real Property & Equipment a) Special rules apply to real property and equipment purchased with grant monies. These rules will be detailed in the regulations or in documents pertaining to the specific grant. b) The Grant Administrator or Department Head shall provide the Assistant Controller the necessary documentation authorizing disposal and record this documentation in the grant folder on the designated record managements system. 2. Equal Employment Opportunity Plan (EEOP) An Equal Employment Opportunity Plan (EEOP) may be required for some Federal grants awarded to the City. The purpose of an EEOP is to ensure that recipients of financial assistance are providing equal employment opportunities to men and women regardless of sex, race, or national origin. If a department has an EEOP for a grant, it should be filed in the grant folder in the designated record management system. A copy of the City of Denton's Equal Employment Opportunity policy is stored in the shared drive at O: Grants/Human Resources/100.01_- Equal Employment OEportunity_pdf. E. Documentation Maintenance Timely and accurate documentation is an important element of grant compliance. Documentation shall be stored in the designated record management system when available by the assigned staff. I. The Grants Management Office is responsible for managing a centralized record management system for City grants. 2. Administering Departments are required to maintain a complete file of award records and supporting documentation for each grant award. POLICY/ADMINISTRATIVE PROCEDURE/ADMINISTRATIVE DIRECTIVE TITLE: GRANT ADMINISTRATIVE DIRECTIVE REFERENCE NUMBER: 402.10 F. Sub -recipient Monitoring The Department, with assistance and support from the Grant Management Office, 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,". G. Audit Requirements 1. A Schedule of Expenditures of Federal Awards and the annual audit of grant programs (single audit) as promulgated by The Office of Management and Budget's (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly called "Uniform Guidance or UG) will be prepared and maintained as required. a) The Single Audit shall be completed and submitted to the Federal Clearinghouse within 30 days of the date of the auditors' report on the Comprehensive Annual Financial Report (CAFR). 2. The grant/award may also be subject to review by Federal, State and/or Internal auditors. The City will promptly respond and comply with audit requests. 3. If irregularities or fraud is detected, the City will be diligent in identifying and addressing issues that led to the action. Management will take steps necessary to mitigate the potential for further fraudulent actions. These steps may include, but are not limited to, directive review, reporting, staff training, and if applicable appropriate disciplinary action. VII. CLOSEOUT After completion of all required performance period activities, the Administering Department and Grants Management Office shall perform grant closeout tasks in accordance with §200.343 Closeout or corresponding State regulations, City policies, and contractual requirements. VIII. GENERAL PROVISIONS The City of Denton reserves the right to change, modify, amend, revoke or rescind all or part of this directive in the future.