Loading...
2021-057 Grants Management OfficeDate: August 13, 2021 Report No. 2021-057       INFORMAL STAFF REPORT TO MAYOR AND CITY COUNCIL SUBJECT: Grants Management Office EXECUTIVE SUMMARY: In September 2020, the Grants Management Office (GMO) began to operate with Laura Behrens as the new Grant Administrator and Daniel Jones as the Grant Analyst. GMO staff meet with City departments to better understand the types of grants departments were awarded, how grants were being administered, and their experience with grant management. A policy and standard operation procedures (SOP) document was drafted with input from several working groups within the City. They also incorporated general Federal, State, and local requirements as well as audit and accounting best practices. The policy outlines roles and responsibilities in managing grants and lays out a process for the review, approval(s), administration, and close-out of grants. The SOP provides additional detail specific to pre-award procedures and the post-ward procedures for the programmatic administration of a grant. DISCUSSION: The Grants Management Office (GMO) began to operate in September 2020 with Laura Behrens as the Grant Administrator and Daniel Jones as the Grant Analyst. The office was formed as a result of grant audits that recommended centralization and standardization in the management of grants to ensure compliance with requirements. GMO staff meet with City departments to better understand the types of grants departments were awarded, how grants were being administered, and their experience with grant management. The meetings identified needs in the following areas:  Evaluation of grant opportunities to determine eligibility, alignment with Council/City/Department initiatives, and feasibility in carrying out grant proposals  Coordination between departments and stakeholders in the planning and execution of proposed grant projects  Designated roles and responsibility for grant management and programmatic activities  Training on Finance procedures, the Procurement process, and general grant requirements  Documentation and record retention for reporting  Centralization of grant information and documentation  Standardization in grant evaluation and management A policy and standard operation procedures (SOP) document was drafted with input from the Internal Auditor, Legal, Finance, Purchasing and several working groups. They also incorporated general Federal, State, and local requirements as well as audit and accounting best practices. The policy outlines roles and responsibilities in managing grants and lays out a process for the review, approval(s), administration, and close-out of grants. The SOP provides additional detail specific to pre-award procedures and the post-ward procedures for the programmatic Date: August 13, 2021 Report No. 2021-057       administration of a grant. Both documents have been reviewed and approved the City’s internal Policy Review Committee. A major component of the new policy and process was the formation of the Grant Review Committee (GRC) to review and discuss proposed grants prior to submission. The purpose is to engage stakeholders prior to submission of the grant application and to better understand the commitments and requirements that go along with a grant award. The GRC is comprised of the Grant Administrator, Finance Director, Budget Manager, Procurement Director, Controller, and a Department Head. Other department representatives who may be involved or impacted by a proposed grant project are also included as needed. A recommendation is made by the GRC on whether to proceed with the application. Grant proposals meeting certain criteria also require City Council approval prior to submission of a grant application. Under the policy, the GMO is responsible for providing city‐wide coordination and monitoring of grants, ensuring the City’s grants management program is current and effectively meeting the City’s policies and granting agency’s requirements, and providing support in grant management and compliance activities. This includes helping identify grant opportunities, drafting grant briefs with essential information to determine eligibility and feasibility, helping in the preparation of applications, coordinating the review of grant proposals, facilitating the approval process for City Council, and supporting reporting and closeout requirements. Additionally, GMO has created tools to assist departments in grant management such as a grant workflow, budget workbook, and resource guides. The information is shared on the City’s internal HUB for easy accesses and availability by all staff. Record retention has been setup on the global drive to house all grant documents and training has also been developed and held with several departments on the new process. Departments are responsible for direct management of the grant, overseeing the administrative and fiscal activities of the grant, and ensuring the terms and conditions of the award are met. Departments lead the preparation of the application and make the submission. Departments also carry out the programmatic activities of the grant project, obtain and retain documentation, and perform reporting requirements. The division in responsibilities provides clarity in expectation, sets accountability, and incorporates best practices in review and approval processes. Responsibilities are also divided in this way because in most cases GMO staff do not have the technical knowledge to administer the grant projects and would not participate in programmatic activities. Departments are better positioned as subject matter experts and with direct knowledge and information on their grant activities for implementation, performance measuring, and reporting. In addition to the grant work at the department level, the GMO is taking an active role in the planning and preparation of programs related to the American Rescue Plan Act, the Hotel Occupancy Tax Revenue Fund Program, and assisting with Capital Project’s grant programs. Date: August 13, 2021 Report No. 2021-057       CONCLUSION: The GMO is evaluating a grant management solution to further centralize grant information and documentation for grants received as well as manage grants awarded out. The system would have the ability to filter and provide briefs on open grant opportunities, integrate with the City’s financial system to display grant account information, and set and send notifications on grant actions for those grant that have been awarded to the City. It would also provide functions to post grant opportunities, design and accept applications, provide reporting tools, and mange recipient monitoring for grants awarded out by the City. ATTACHMENT(S): Exhibit 1 – Grant Policy Exhibit 2 – Standard Operating Procedures Exhibit 3 – Grant Process STAFF CONTACT: Laura Behrens Grant Administrator Laura.Behrens@cityofdenton.com CITY OF DENTON POLICY/ADMINISTRATIVE PROCEDURE/ADMINISTRATIVE DIRECTIVE SECTION: FINANCE REFERENCE NUMBER: 402.10 SUBJECT: GRANTS INITIAL EFFECTIVE DATE: xx/xx/20 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. II. 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 the 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 the 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. III. DEFINITIONS 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 (CFDA) – Publication that includes information related to all Federal programs, including the program title, description, history, and assigned number (CFDA number). C. Data Universal Numbering System (DUNS) – 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 30th. 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 (EIN) – 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, loan 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 Entity – 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 (SEFA) – 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 ADMINISTRATIVE 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 6. 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. VI. 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 liability 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 1. 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 / 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 Opportunity.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. 1. 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.     Grants Standard Operating Procedure  1         SOP Owner Grant Management Office  Revision #   Implementation Date DATE APPROVED BY SUPERVISOR/MANAGER  Last Reviewed/Update Date   GRANTS STANDARD OPERATING PROCEDURE    PURPOSE  The purpose of this manual is to 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. The goal is to 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. ROLES AND RESPONSIBILITIES   GRANTOR  A governmental unit, foundation or other entity that awards grants. 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. 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. The Grant Administrator is responsible for:  Maintaining grant procedures  Maintaining an updated City-wide grants database  Oversee the activities of the Grant Review Committee  Researching grant opportunities and notifying departments of such opportunities  Acting as a liaison with funding agency when necessary  Assisting staff with proposal preparation as it concerns adhering to grant guidelines, policies, and deadlines   Grants Standard Operating Procedure  2    Assisting departments with completing items regarding applying for grants, accepting awards, and appropriating the grant budgets  Assisting Grant Managers with more complex non-routine aspects of grant implementation  Initiating the development of grant work plans and timelines  Reviewing agenda items related to grants prior to submission for City Council agenda  Maintaining a master file system that includes open grants and closed grants in accordance with the retention requirements  Developing and conducting grants administration training on grant management and compliance  Facilitating coordination between departments and / or other agencies in the application of grants GRANT ACCOUNTANT  Responsible for setting up grant accounts, monitoring grant expenditures, reconciling reimbursement requests, and reviewing required reports prior to submission. Other responsibilities include:  Providing the proper account codes to the recipient department  Ensuring that departments track and report programmatic and financial grant activity in a timely manner  Work with Purchasing Department to ensure all contracts, professional agreements, invoicing from vendors meet grant specifications for reporting and reimbursement  Reviewing and auditing required grant documentation necessary to meet grant funding requirements  Record Grant submittals as outstanding receivable and record receipt of reimbursement once received, and notify all interested parties GRANT ANALYST  The position responsible for providing support in grant management and compliance activities for the City such as:  Providing support in analyzing grant opportunities, conducting fiscal and operational analysis of potential grants  Working with the Grant Administrator, Grant Accountant, Grant Manager, Grant Coordinator, Purchasing and Finance personnel in order to gather all information required to meet grant funding requirements once awarded  Supporting operating departments managing grants internally  Preparing monthly analysis of expenditure forecasts  Conducts detailed examinations of statistics related to grant revenue and expenditures   Grants Standard Operating Procedure  3    Researching, preparing and maintaining statistical data and narratives required for grant applications and reporting  Performing a variety of delegated research tasks and projects, document findings, report preparation, graphs, charts, and other illustrative materials required 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. 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. 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. The Grant Review Committee is responsible for:  Reviewing the Intent to Apply form (Exhibit 1) and supporting information for reasonableness and determine that the administrative burdens of acceptance do not exceed the financial benefit to the City  Evaluating the Department’s ability to comply with all grant related requirements  Assessing short and long-term financial and service impacts associated with acceptance of an award  Making a recommendation to the City Manager or their designee as to the continuation of the grant process 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.   Grants Standard Operating Procedure  4   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 awards. The Department Head is responsible for ensuring grant programs meet the City’s current priorities and policy objectives and the following:  Performing an assessment of resources to ensure the Department can comply with and fulfill grant requirements  Ensuring the cost benefit factor is adequate relative to the project scope and its justification is appropriate  Ensuring the Department adheres to the grant directive and process  Assigning staff to adequately manage the grant awards  Reviewing and approving grant applications and proposals prior to submission  Approving any proposed programmatic and fiscal changes to the grant  Reviewing budget amendment requests if they affect commitments by the department GRANT MANAGER  The staff member responsible for the management activities on a grant or project. 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. The Grant Manager is responsible for:  Preparing the grant proposal with the assistance of the Grant Administrator, with an emphasis on the technical and budgetary components  Forwarding all grant agreements to the Grant Administrator for review prior to execution by the proper City officials  With assistance from the Grant Administrator, prepare the City Council agenda item and resolution (if required) requesting City Council authorization for the Mayor to execute the grant agreement and related documents, if approval of the grant agreement has not been previously authorized  Requesting that budget be established and approved prior to expenditures being made  Monitoring the project budget and ensuring the appropriate charging of expenditures to the project grant award  Monitoring expenditures to ensure grant funds are spent in accordance with the approved budget  Gathering supporting documentation on expenditures required for grant reporting and reimbursement requests  Notifying the Department Head about changes in project scope and budget  Working with the Grant Administrator and Grant Accountant to ensure the completeness, accuracy, and timeliness of programmatic and financial reports submitted to the granting agency   Grants Standard Operating Procedure  5    Ensuring the Grant Administrator and Grant Accountant receive copies of any financial reports for review prior to submission to the granting agency  Ensuring all reports, records or correspondence with the granting agency are documented in the designated grant file management system.  Adhering to the terms of the grant agreement and policies and notifying the Grant Coordinator and Grant Accountant if changes are needed GRANT COORDINATOR  The Grant Manager may delegate tasks related to grant management to a Grant Coordinator or Department 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. The Grant Coordinator is responsible for:  Identifying operational needs for potential grant opportunities  Developing specifications for the procurement of grant equipment or professional services  Obtaining the required supporting documentation for procurement of grant related purchases  Providing documentation of expenses to the Grant Manager for review and approval  Scheduling, tracking, reporting personnel activities related to eligible grant expenses  Ensuring subcontractor and subrecipients have complied with the appropriate work in a timely manner and in accordance with technical, financial, and other requirements of the award  Working with Grant Manager to prepare reimbursement requests and required reports PRE‐AWARD PROCEDURES  APPLICATION   1. Each department is responsible for assisting in the preparation of the grant application and provide all required documentation for submittal to the Grant Administrator. 2. The Grants Management Office will prepare and provide required demographic, statistical and narrative information for the City. 3. The Grants Management Office will also assist with communication formatting prior to submission. APPLICATION REVIEW PROCESS  1. The Department Head, or designee, shall respond to an Intent to Apply form (Exhibit 1) to provide pertinent information concerning the grant opportunity. Upon completion of the questionnaire, but prior to submission to any Federal, State or other granting entity, City Council or City Manager, the Department Head shall send the completed questionnaire, along with any required attachments to the Grant Review Committee.   Grants Standard Operating Procedure  6   2. After review by the Committee, the Intent to Apply form along with the Committee’s recommendation and comments shall be forwarded to the Assistant City Manager (ACM)/Chief Financial Officer (CFO). 3. After review by the ACM/CFO, the Intent to Apply form shall be forwarded to the City Manager. 4. The City Manager, or designee, shall notify the Department Head to move forward with grant application or decline further action in seeking the grant. If the City Manager approves moving forward, the Department Head can complete and submit the application to the granting agency. 5. Upon approval by the City Manager or designee, the Grant Management Office will create a file in the designated record management system. The completed Intent to Apply form and application will be added to the file to start the documentation process. 6. The Department Head, or designee, will prepare an agenda item for City Council’s approval prior to application submittal if the grant meets one of the following criteria: a. Proposed grant expenditures result in a total of $100,000 or more from the City. b. Will increase the number of personnel requiring additional on-going funding beyond the term of the grant period. c. Proposed grant will establish a new program and / or have a measurable impact on level of service. d. The Grant Review Committee makes a recommendation for City Council review 7. The Grants Management Office will facilitate City Council agenda items through the applicable reporting system. POST‐AWARD PROCEDURES  AWARD NOTIFICATION AND ACCEPTANCE  1. Once the award notification has been received, the Grants Management Office will be notified. 2. 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. 3. Each contract, agreement, or acceptance must be reviewed and approved by City Council. The Administering Department will prepare an agenda item for City Council approval of the award. a. Matching requirements should be stated in the agenda item as being accommodated in the current budget. If not, it must be made clear that a supplemental appropriation is needed and is being requested with the agenda item. If an award is a multi-year agreement, future matching requirements should also be disclosed.   Grants Standard Operating Procedure  7   b. If the grant application was approved prior to submission under Application Review Process (6) (a-d), a second review and approval by City Council is not required unless required by the grant. i. City Council will be notified by staff report of the grant application outcome. 4. Once approved by the City Council, 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. GRANT ADMINISTRATION  1. Upon approval of a grant, the Grant Management Officer shall schedule a Grant Kick-Off meeting with the Department. The Grant Kick-Off meeting is to clarify grant management and accounting roles and responsibilities specific to that grant (see Kickoff Meeting Form Exhibit 2). 2. The Grant Management Office and the Department will develop a grant work plan for each award or project that includes but is not limited to budget allocations, schedule of work and timelines. 3. The Department Head, designee or Grant Administrator must complete a Direct Deposit Authorization Form for the granting agency. This form should be submitted with the grant application or as soon as possible following approval by City Council. Contact the Senior Treasury Analyst to (1) notify them of the grant/agency and (2) ensure you have the most up to date information on the form. A copy of the form is included as APPENDIX B. 4. The Department Head or Grant Administrator shall ensure that the following items are placed in the designated record management system: a. The grant application b. Agreement with terms and conditions (T&C) c. Award notifications (email or letter) d. City ordinance or resolution approving the grant award e. Completed Direct Deposit Authorization Form. 5. The Department and Grant Management Office shall, at a minimum, review and analyze grant activities quarterly. DAILY ADMINISTRATION OF THE PROGRAM   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, City policies and corresponding contractual agreements.   Grants Standard Operating Procedure  8   2. 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. 3. If the grant has subrecipients: a. The Administering Department, with assistance and support from the Grants 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,” and formulate a risk mitigation plan based on identified risk factors. b. 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. 4. The Administering Department shall monitor contractors to ensure compliance with all contract provisions. 5. The Grant Manager is responsible for maintaining documentation evidencing compliance with all program requirements. 6. Prior to incurring program expenditures, the Grant Manager shall contact the Grant Accountant to determine the project coding of program expenditures. 7. The Grant Accountant shall ensure the general ledger accounts are set up and activated. 8. The Administering Department will initiate requests for award extensions and/or agreement amendments if necessary. Changes to the original terms of the award must be reviewed and approved by the Grant Administrator Prior to submission. PROCUREMENT AND SUSPENSION/ DEBARMENT  1. 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, the Grant Administrator and Grant Accountant should be notified. b. 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. 2. The Grant Manager is responsible for furnishing the Procurement Department with any special procurement requirements that shall be documented or followed during the procurement process. In addition, if available, the Grant Manager shall furnish a detailed list of the items the granting agency has approved for purchase.   Grants Standard Operating Procedure  9   3. The Grant Manager and / or Grant Coordinator is responsible for gathering supporting documents required for procurements. The supporting documentation must be filed in the designated record management system.  4. Grant purchases must be made by purchase order (PO) or through the appropriate bid process. Procurement cards (PCard) should not be used for grant related purchases. Exceptions for PCard use include training and travel expenses, emergency response and deployments, and vendors who do not accept PO’s.  REPORTING & REIMBURSEMENT REQUESTS  1. 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. 2. The Administering Department shall prepare reimbursement requests and submit to the Grants Management Office and Grant Accountant for review. The Grants Management Office will assist the Administering 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. 3. 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. 4. Reporting and reimbursement requests shall be submitted by the Grant Administrator to the Grantor on the form designated by the grantor and shall be accompanied by the supporting documentation specified in the grant/award agreement. 5. The Administering Departments shall maintain adequate documentation for all program activities and expenditures (activity reports, invoices, purchase orders, receipts, etc.) 6. For grants requiring Automated Standard Application for payments (ASAP) draws for reimbursement, the Grant Administrator shall request these draws after documentation is scanned into the grant folder of the designated record management system. RECEIPT OF GRANT FUNDS   1. 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 correct deposit coding. The funds shall be deposited in accordance with normal deposit procedures and the City’s Cash Handling directive. 2. If grant funds are to be received via ASAP, the Grant Administrator shall notify the Grant Accountant of the upcoming payment.   Grants Standard Operating Procedure  10   OTHER POST AWARD REQUIREMENTS  1. Real Property and 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. These regulations often entail the following: i. Property and equipment shall be used for the originally authorized purpose ii. The City shall not restrict or burden the title of such property or equipment iii. When real property or equipment is no longer needed for the authorized purpose, the City shall request disposition instructions from the awarding agency. b. The Administering Department will engage the Real Estate Department to facilitate the exploration and purchase of real property. c. 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. DOCUMENT MAINTENANCE  1. Grant records and documentation shall be stored in the designated record management system when available by the assigned staff. 2. The Grants Management Office is responsible for managing a centralized record management system for City grants. 3. Administering Departments are required to maintain a complete file of award records and supporting documentation for each grant award as outlined in Binder Management (Exhibit 3). 4. In addition to the items mentioned under previous sections, the Grant Administrator shall ensure that the following documentation is scanned into the appropriate grant folder as soon as it is available. a. Intent to Apply form b. Grant/award agreement or contract with Terms and Conditions, amendments, and any related correspondence. c. Documentation supporting all reports and reimbursement requests. d. Required performance, quarterly and other reports. e. Documentation evidencing the performance of any required physical inventories. f. Any other documentation evidencing that the City complied with all administrative and grant requirements (does not pertain to client specific files of programs such as CDBG and First Time Homebuyer).   Grants Standard Operating Procedure  11   5. The Grant Administrator shall coordinate with the City Secretary’s Office to ensure that a file copy of the agenda minutes and/or resolution approving the grant is made into the appropriate grant folder as soon as it is available. 6. The Grant Administrator shall coordinate with the Procurement Department to ensure that any contracts with vendors or related correspondence is scanned into the appropriate grant folder as soon as it is available. This also includes purchase orders. 7. The Grant Accountant shall ensure that the following tasks are completed to properly document the City’s entire grant program: a. Quarterly grant status reports that summarizes current active grant activity. b. Quarterly review of the grant folders in the shared drive for completeness of scanned documents. Any missing items shall be communicated to the respective Grant Administrator for completion. SUB‐RECIPIENT MONITORING  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 funds, in accordance with 2 Code of Federal Regulations (“CFR”) §200.331, “Requirements for pass-through entities,”. 2. Terms and conditions from an award will be imposed on a sub-recipient to the same degree that they are imposed on the City and / or the Administering Department as the prime recipient. 3. The Grant Administrator will ensure sub-recipient agreements include information in compliance with Uniform Guidance (UG) requirements. 4. 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. Monitoring includes ensuring the sub- recipient is: a. Performing the proposed and approved. b. Meeting programmatic, administrative, and fiscal requirements. c. Identifying and resolving problems / issues. d. Receiving the needed technical assistance. e. Meeting Federal regulations Sub-recipient monitoring shall be accomplished through the following methods: a. Technical assistance b. Desk review / audit c. On-site and assessment visits   Grants Standard Operating Procedure  12   AUDIT REQUIREMENTS  1. The Grant Accountant shall prepare a Schedule of Expenditures of Federal Awards and maintain this report throughout the year for audit planning and reporting purposes. 2. The Assistant Controller shall coordinate 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). 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). 3. Procurement of the audit services shall comply with State procurement procedures and the provisions of the UG. 4. If the Grant Administrator is notified of an upcoming review by Federal or State auditors, the Grant Administrator shall notify the Assistant Controller. A copy of any review reports received from the Federal or State auditors shall be forwarded to the Assistant Controller and the City Auditor. 5. Upon detection of irregularities or fraud, the Grant Administrator, Comptroller and City Auditor will be immediately notified. 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. CLOSEOUT  1. 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. 2. The Administering Department is responsible for final performance reports required by the terms and conditions of the award and shall record documents in the designated record management system. 3. The Administering Department and Grant Accountant are responsible for final financial reports required by the terms and conditions of the award. The Administering Department and Grant Account are responsible for collecting and maintaining all appropriate back up documentation for financial reports. 4. The Administering Department shall notify the Grant Accountant to close the grant in City’s financial system and provide all required closeout documentation. 5. The Administering Department shall prepare the final reimbursement request for review by the Grant Accountant. The Grant Accountant shall verify the final reimbursement prior to submission.   Grants Standard Operating Procedure  13   6. The Administering Department, Grants Management Office, and Grant Accountant shall ensure that all financial activities are recorded, that revenues balance to expenditures, and that revenues and expenditures balance to budget figures. 7. The Administering Departments and the Grants Management Office are responsible for ensuring that their records are maintained in accordance with applicable City policy, State law, and federal regulations. 8. The Administering Department and Grants Management Office are responsible for responding to and cooperating with auditors, monitors, and other grantor personnel, as well as the City’s independent or internal auditors. PROCESS FLOW CHART          RELATED DOCUMENTS   EXHIBIT 1  Intent to Apply form ‐ O:\GRANTS\Administration ‐ Grants\Forms  EXHIBIT 2  Kickoff Meeting form ‐ O:\GRANTS\Administration ‐ Grants\Forms  EXHIBIT 3  Binder Management ‐ O:\GRANTS\Administration ‐ Grants\Forms    Grant Process Overview GRANT PROCESS STEP 1: REVIEW GRANT OPPORTUNITY 1. Notice of funding opportunity (NOFO). What are the requirements? Can we meet them? What is the timeline for application / grant period? Do you have an eligible project? 2. Coordination Identify and contact the internal stakeholders impacted by grant proposal. Identify and contact external partners impacted / partnering on grant proposal. 3. Initiative / Goal Does the proposed grant meet a City initiative or Department goal / objective? 4. Grant proposal and application approved by Department Head. STEP 2: COMPLETE INTENT TO APPLY FORM 1. Submit to Grant Management Office (GMO) 20 days prior to application due date. 2. Included NOFO and completed grant application. STEP 3: GRANT REVIEW COMMITEE 1. GMO will schedule meeting with Grant Review Committee (GRC). 2. GRC will provide feedback and make a recommendation on proceeding. STEP 4: CIY MANAGER’S OFFICE APPROVAL 1. GMO will submit recommendation to the City Manager’s Office (CMO) for review and approval. 2. CMO will provide direction on proceeding with grant application. STEP 5: CITY COUNCIL APPROVAL 1. City Council approval is required for the following: >$100,000 expenditures Adding FTE’s New program / impacted level of service Recommended by GRC Required by grant 2. GMO will facilitate City Council agenda process. STEP 6: SUBMIT GRANT APPLICATION 1. Department submits application upon final approval. Final copy of application is submitted to GMO. STEP 7: NOTIFY GMO OF GRANT AWARD 1. Grant Accountant will be notified of grant award and budget will be created. STEP 8: KICK-OFF MEETING 1. GMO will schedule a Kick-off Meeting with department. Final grant award will be reviewed. 2. Establish grant budget. 3. Create grant timeline. 4. Notify Treasury of banking information STEP 9: GRANT MANAGEMENT 1. Create Grant Binder 2. Purchasing Follow all Purchasing policies and procedure for procurements. Follow PCard requirements / restrictions. Special / additional conditions required by grant. Maintain all purchasing documents. 3. Human Resources Follow all hiring policies and procedures. Notify Payroll of grant funded personnel costs. Maintain all Payroll documentation. 4. Performance / Progress Reports Completed by Department. Include copy in Record Management System (RMS) 5. Financial Reports Drafted by Department. Submit to Grant Accountant for review and approval prior to submission. Submitted to granting agency by Department. Include copy in Record Management System (RMS) 6. Financial Transactions Submit all reimbursement requests to Grant Accountant prior to submission. Notify Grant Accountant and Treasurer of all received checks and/or deposits. STEP 10: GRANT CLOSE OUT 1. Final reimbursement requests and financial reports. 2. Final performance / progress reports. 3. Record retention. 4. Procurement tracking How long do you have to keep equipment/purchases? Disposal instructions? 5. Grant extension requests. Notify GMO and Grant Accountant prior to request.