CSCC Grants Administration Handbook; Last Revised 12/21/2012

Transcription

1 1 GRANTS ADMINISTRATION HANDBOOK Adopted September 2010

2 Introduction The Grants Office and Fiscal and Compliance Services manage external funding to advance the teaching, workforce development, research, and public service mission of the College. External funding is an important supplement to public support, tuition and fees, gifts, and other sources of revenue available to the College. The Grants Office has the responsibility to: facilitate the process of submitting proposals and managing funded awards for the College; protect the interests of the College in addition to supporting the faculty or staff members with submitting proposals or managing funded awards; and ensure that proposals from and awards to Columbus State Community College comply with applicable federal, state, and other government regulations and, as appropriate, with human and animal research guidelines. Fiscal and Compliance Services has the responsibility to: conduct proposal budget review; perform project accounting and financial reporting functions; and ensure that accounting processes comply with applicable federal, state, and other government regulations and, as appropriate. This Operations Manual details the process for each phase of grants administration that will assist Project Coordinators with the day-to-day operation of the project. Throughout this manual, the term grant refers to any grant, contract, and cooperative agreement that supports College projects. These procedures are appropriate for a predominantly undergraduate institution and are in compliance with: Title 2 CFR PART 215, (United States Office of Management and Budget Circular A-110), Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospital, and Other Non-Profit Organizations; and Title 2 CFR Part 220, (United States Office of Management and Budget Circular A-21), Cost Principles for Educational Institutions. The procedures reflect best practice as outlined in: Fundamentals of Sponsored Project Administration 2001, compiled by the National Council of College Research Administrators; and Managing Federal Grants 2004, compiled by the National Council of College Research Administrators and National Association of Colleges and College Business Officers. Abbreviations used throughout the Operations Manual include the following. A-21 Title 2 CFR Part 220, Cost Principles for Educational Institutions (US Office of Management and Budget Circular) A-110 Title 2 CFR PART 215, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospital, and Other Non-Profit Organizations (US Office of Management and Budget Circular) 2 College Columbus State Community College

3 3 Foundation Columbus State Community College Foundation Information in the manual was compiled by representatives of the areas that contribute to the overall grants administration process, including: Fiscal and Compliance Services Grants Office Human Resources Purchasing When Columbus State Community College seeks grants that must be awarded to an entity with non-profit status (501-C3), the application is routed through the Columbus State Community College Foundation (Foundation) for signature. Organizational Chart

4 TABLE OF CONTENTS 4 Pre-Award Process Proposal Development: Accountability and Approvals Finding Funding Sources Developing the Proposal Drafting the Proposal Budget Cost Sharing Administrative Fee Facilities and Administrative (F&A) Cost Rate Financial Conflict of Interest Disclosure Hard Match Account Proposal Signatures Proposal Tracking Post-Award Process Proposal Award Proposal Denial Award Agreements and Sub-Award Agreements Budget: Use, Tracking and Adjustments Closeout Computers and Other Technology Purchases Consultant or Vendor Agreements Food Purchases Personal Reimbursement Program Income Purchasing Purchasing Signature Approval Protocol Purchasing Approval and Agreement Signature Matrix Purchasing Credit Card and Gift Card Procedures Pre-Paid VISA Card Reporting Time and Effort Residual Funds Responsible Conduct in Research Vendor Registration

5 5 Database Grants Office Files Initial Award Checklist Process Tools Compliance Accounts Payable, Approvals, and Documentation Accounting Systems, Posting and Adjustments Cash Management Procedures Chart of Accounts Cost Allowability and Cost Limitations Facilities and Administrative (F&A) Cost Rate Federal Fund Bank Account Reconciliation General Fund Bank Account and Reconciliation Subrecipient Monitoring Agency Speciifiic US Department of Labor Allowability of Costs Participant Supportive Services Participant Training by Category CSCC Personnel Policies and Procedures Procurement, Contracting and Purchasing Program Income (29 CFR 97.25) US Department of Education Allowability of Costs US Department of Health and Human Services Allowability of Costs National Science Foundation Allowability of Costs

6 6 Pre-Award Process

7 7 Proposal Development: Accountability and Approvals The Grants Office assists the faculty, staff and administrators of Columbus State Community College in developing proposals for grants. Chairs and Deans approve faculty to serve as Project Coordinators for proposal development and grant administration. Staff serving as Project Coordinators for proposal development and grant administration is approved by a director and Dean or Vice President. Cabinet members serving as Project Coordinators for proposal development and grant administration are approved by the President. Adjunct faculty and part-time employees may not serve as Project Coordinators. When Columbus State Community College is the applicant, all proposals, including budgets, will be written and/or reviewed by the Grants Office prior to submission. The Grants Office also has oversight of any and all proposals, including budgets, submitted through online grant portals. When Columbus State Community College is a sub-grantee or is identified as a partner in another institution s proposal, the narrative and budget will be reviewed by the Grants Office prior to submission. Grant Writers The Grants Office will write proposals or edit another s writing. If an external grant writer is needed, the Grants Office chooses the writer from a pool of vetted writers who have presented evidence of writing higher education proposals that were awarded. External Evaluators Sometimes proposals require or suggest the use of an external evaluator that will be paid with grant funds. This position may be interpreted as someone external to the grant-funded project (yet working within the College) or someone external to the College. The Grants Office will work with the writing team to identify an appropriate evaluator for the project. Evaluation experience and expertise will include at least some of the following: Quantitative and/or qualitative research skills Professional expertise on the issue (e.g., technical, theoretical, experience) Familiarity with a variety of evaluation and assessment tools Knowledge of the context (e.g., global, country, region, local) Ability to effectively communicate to the targeted users and audience Gender, cultural balance, sensitivity, and language skills Capability to prepare an evaluation report Potential evaluators must submit a résumé, work samples, and references.

8 8 Finding Funding Sources The Grants Office assists the faculty, staff and administrators of Columbus State Community College in seeking external funds and initiating proposals for grants. Columbus State pursues grants that address the strategic plan and priorities of the College and carry out its mission. College leaders determine and prioritize the proposals that are developed based on need and benefit. When faculty and staff have ideas that require grants funds, they discuss them with chairs, deans, or directors to gain initial support. Proposals are developed and submitted with assistance from the Grants Office. Once ideas are presented to the Grants Office, they are passed on to the Senior Vice President for Academic Affairs. Ideas will be discussed will division leaders and/or Cabinet as appropriate. Ideas and Funding Searches Options for locating a funding source: 1. College employees can meet with, call, or the Grants Office and request a search of funding databases. A general idea for a project and appropriate keywords are necessary to search the databases. 2. Utilize links in the Funding Opportunities page on the Blackboard site, CSCC Grants Office Information and Education to search for funding sources. If not already a user on this site, notify the Grants Office to be added. 3. Review and respond to funding opportunity information ed by the Grants Office. When a funding source is identified, the Grants Office will meet with the Project Coordinator to: discuss the funding sponsor s guidelines; determine eligibility to apply; consider cost sharing requirements; identify proposal development timeline; and confirm that the appropriate persons are informed (chair, dean, VP) The Grants Office will complete a Proposal Development Form and forward it to the appropriate chair/director, dean/vp, as well as the Associate Vice President of Academic Affairs. The Proposal Development Form will also be forwarded to Fiscal and Compliance Services with the accompanying Request for Proposal (RFP). Some funders issue a Notice of Intent to fund or request a Letter of Intent prior to inviting an application. The Grants Office will assist in reviewing, developing, and submitting these documents.

9 9 Developing the Proposal Guidelines Review The Grants Office will thoroughly review proposal guidelines noting details required for the proposal. The Grants Office will inform the Project Coordinator of the particulars and the importance of writing to the guidelines. Narrative Development The Project Coordinator and the Grants Office will determine how to develop the proposal. The Project Coordinator will understand that the Grants Office will not have the expertise to write program-specific content; for example, chemistry curriculum or student learning assessment. However, the Grants Office has the expertise to: research needs statement data; formulate measurable goals/objectives and evaluation plans; edit and rewrite for clarity; create tables and graphs to condense and represent information; and comply with the funder s required narrative format. Suggestions and tips for writing successful proposals are available in print resources in the Grants Office. Letters of Commitment, Partnership, and Support Grant proposals often require letters defining the College s role in a project or conveying its endorsement of an anticipated project. Letters of Commitment or Partnership obligate the College to provide funds, faculty or staff time, facilities, or other resources to ensure a grant-funded project is successful. These letters are composed by the Grants Office to reflect the intent of the proposal and to make certain stated costs are correct. They are printed on the appropriate letterhead and signed by the President or the appropriate Senior Vice President. Letters of Support are printed on appropriate letterhead and may be signed by Deans, Associate Vice Presidents and Senior Vice Presidents. Upon request, the Grants Office will assist in drafting these letters. They include the following information: title of the grant and sponsor; relationship between the College and applicant; impact of proposed project on the general community; or how the College division or department can support or benefit from the project. Support letters are generally written for an applicant other than the College. Supporting Documents The Grants Office maintains an updated file of supporting documents that provide additional information about the College. The Grants Office obtains signatures and provides them in paper or electronic format as requested. These include, but are not limited to, the following: Accreditation Status Affiliation Agreements Federal Certifications and Assurances Financial Statements/Audits Liability Insurance Certificate Organizational Charts Proof of Self-Insurance Roster of the Board of Trustees Tax Exempt Status

10 10 Drafting the Proposal Budget The Grants Office uses a standard MS Office Excel budget format, known as the internal budget, for all proposals. As part of the narrative development, the Project Coordinator and the Grants Office identify all costs related to the proposed project including: direct costs paid by the grant (salary/wages, fringe benefits, travel, supplies, consulting fees, etc.); matching funds paid by the College or other project partners; cost sharing paid by the College or other project partners; in-kind goods or services contributed by the College or other project partners; and allowable administrative fees or F&A (facilities and administrative) costs. Salaries and Wages Per Title 2 CFR Part 220, Cost Principles for Educational Institutions (A-21), salaries and wages paid with grant funds must be consistent with institutional policies and procedures and uniformly applied across the campus. Non-credit instructors for sponsored programs are hired per the College s hiring procedure: Post the position to allow for the generation of interested applicants; Interview qualified applicants; Hire the most qualified candidate; and Pay the current adjunct rate. To provide consistency and prevent claims of discrimination, Human Resources reviews all documentation and concurs with the advance placement of all new employees. If a posting does not produce qualified applicants and the position becomes hard to fill, it may be in the interest of the sponsored program to purchase the required skills by seeking an outside consultant/vendor who can perform the needed work. The Project Coordinator works with the responsible grant accountant to bid, as necessary, and purchase those services. For current employees, Grants Office staff will request salary and wage rates from Human Resources. Total salary for a full-time employee is divided by 2,080 hours to determine an hourly rate, if needed for a proposal. If a proposal budget will include a position to be hired, that position must be classified by Human Resources and assigned a starting salary. If required for the proposal, the Grants Office will work with the appropriate HR Representative to develop a job description. Computers, printers, scanners, and other technology required for grant-funded projects must be included in the project budget. The Grants Office will contact the Vice President of Information Technology and/or the designated Data Center Supervisor for pricing and guidance when technology is added to a project budget. The Grants Office will draft the project budget and provide it to the Project Coordinator for review and confirmation. The Grants Office will also provide the budget, prior to submission, to Fiscal and Compliance Services for review of the following: salary figures with appropriate breakout by calendar, fringe benefit rates, yearly increases to wages, allowable costs, and correct use of the F&A rate. The grant accountant initials that the

11 11 budget can go forward. The assigned grant accountant will review, discuss as needed with the Grants Office, and return an initialed copy to the Grants Office within three business days. The Grants Office provides the budget and its cover page, the Budget Summary, to the Project Coordinator* for signature. Additionally, the Grants Office will: obtain the signature of the appropriate chair or manager*; obtain the signature of the appropriate dean, Associate VP, or VP*; obtain the signature of the appropriate Cabinet member*. *Forms are returned to the Grants Office after each signature and the Grants Office obtains the next signature in the process. For submission, budget figures will be transferred into the format requested by the sponsor. The Grants Office also writes the budget justification in narrative form.

12 12 Cost Sharing Cost sharing or matching is the portion of total project costs provided by the College. The terms cost sharing, match, and in-kind are often used interchangeably to describe those funds. The amount required can be described as a ratio (1:1), or a percentage (50%) or as significant or substantial. As appropriate, the College counts faculty and staff time and fringe benefits, teaching software and materials, facilities, and other costs that contribute to the total project cost. Expenses can be cash items the College purchases or in-kind items the College has in place and donates. Contributions counted as cost sharing for federal grants must meet all of the following criteria: are documented in the College's records; have not already been counted as contributions for any other federal grant; are necessary and reasonable to accomplish project objectives; are allowable under OMB Circular A-21, Cost Principles for Education Institutions; are not paid under another federal award, except where authorized by federal statute to be used for cost sharing or matching; and are included in the approved budget when required by the awarding federal agency. F&A Costs as Cost Sharing or Match Unrecovered facilities and administrative costs may be included as part of cost sharing or matching with the prior written approval of the awarding federal agency or with the approval of a federal sponsor s section of the Code of Federal Regulations (CFR). If allowable, the Grants Office will calculate the difference between the College s rate and the rate the sponsor allows. That difference will be counted as cost sharing and added to the proposal budget.

13 13 Administrative Fee

14 14 Facilities and Administrative (F&A) Cost Rate F&A costs are those incurred for common or joint objectives and therefore cannot be identified readily and specifically with a particular grant-funded project, an instructional activity, or any other institutional activity. (OMB Circular A-21) F&A costs are broad categories of costs: "Facilities" is defined as depreciation and use allowances, interest on debt associated with certain buildings, equipment and capital improvements, operation and maintenance expenses, and library expenses. "Administration" is defined as general administration and general expenses, departmental administration, grants administration, student administration and services, and all other types of expenditures not listed specifically under one of the subcategories of Facilities (including cross allocations from other pools). Use of Rate When allowable, the Grants Office will apply the rate to salaries and wages in proposal budgets. If the full rate is not allowed and there is a cost sharing requirement, with sponsor approval, the Grants Office will calculate the difference between the College s rate and the rate the sponsor allows. That difference will be counted as cost sharing. When the full rate is used, office supplies, postage, local telephone costs, and memberships will not be included in proposal budgets. Clarification of office supplies and postage is provided with the following examples.

15 15 CSCC Office Supplies [53000] Office Supplies Outside [53010] CSCC Office Supplies [53000] Office Supplies Outside [53010] CSCC Classroom Supplies [53100] Classroom Supplies Outside [53110] CSCC Classroom Supplies [53100] Classroom Supplies Outside [53110] Postage [59010] Postage [59010] College IS entitled to take full F&A rate College IS NOT entitled to take full F&A rate College IS entitled to take full F&A rate College IS NOT entitled to take full F&A rate College IS entitled to take full F&A rate College IS NOT entitled to take full F&A rate Cannot purchase pens, paper clips, file folders, note pads, and ink cartridges for administrative purposes. Ask Chair or Director to purchase those items from an Operating Budget account. Can purchase pens, paper clips, file folders, note pads for administrative purposes. Can purchase file folders, pens, markers, crayons, scissors, etc. for program participants use. Can purchase ink cartridges used primarily to produce program materials. Can purchase file folders, pens, markers, crayons, scissors, etc. for program participants use. Can also order pens, paper clips, file folders, note pads, and ink cartridges for administrative purposes. Cannot pay for postage other than programspecific major projects. Ask Chair or Director to purchase those items from an Operating Budget account. Can pay for postage for program specific major projects and items such as mailing completion certificates, participant surveys, and instructions to parents, etc. F&A Costs as Cost Sharing or Match Unrecovered facilities and administrative costs may be included as part of cost sharing or matching with the prior written approval of the awarding federal agency or with the approval of a federal sponsor s section of the Code of Federal Regulations (CFR). The Grants Office will calculate the difference between the College s rate and the rate the sponsor allows. That difference will be counted as cost sharing. Waiver of Rate Use of the full F&A rate in a proposal budget is waived when: the sponsor does not allow use of the rate; and the sponsor limits F&A to a lower rate (for example, the U.S. Department of Education offers 8%) Only the President has the discretion and authority to waive the full rate because a proposal would not be competitive.

16 16 Financial Conflict of Interest Disclosure This statement is included in the Proposal Routing Form that is routed by the Grants Office and signed by the Project Coordinator. By signing below, I certify that: 1. The attached proposal is complete in its technical content, adheres to the rules of proper scholarship including proper attribution and citation of all text and graphics, and meets the specifications outlined by the sponsoring agency. 2. If the attached proposal is awarded and accepted by Columbus State Community College, I will conduct the project according to the terms and conditions of the funding agency and the policies of Columbus State Community College, and meet the requirements of the award including stewardship of funds and submission of all required project or technical reports. 3. If the proposed activity involves the use of human subjects, human materials, vertebrate animals, biohazards, or radioactive materials, I understand it will be necessary to obtain appropriate review and approval prior to beginning the project. 4. Check one of the following: I do not have any significant or other financial interests related to this project. I am disclosing the following significant financial interests (check all that apply) and attaching supporting documentation (in an envelope marked Confidential ) that identifies the business enterprise or entity involved and the nature and amount of interest. Significant financial interests are defined as interests of greater value than $10,000 or an equity ownership of more than 5% held by an investigator or the investigator s spouse or dependent children. Salary or other payment for services (consulting fee or honoraria) Equity interests (stocks, stock options, or other ownership interests) Intellectual property rights (patents, copyrights, and royalties from such rights) Other significant financial interests of the investigator that possibly could affect or be perceived to affect the results of the research or educational activities funded or proposed for funding. Further, I agree: To update this disclosure during the term of the award on an annual basis, or as new reportable interests are obtained. To cooperate in the development of a conflict of interest resolution plan, should one be needed. To comply with any conditions or restrictions imposed by the Columbus State Community College to manage, reduce, or eliminate actual or potential conflicts of interest or forfeit the award. Signature: Project Coordinator Signature: Co- Project Coordinator Date Date

17 17 Hard Match Account The College maintains funds that can be used when cash is required for cost sharing. A request for hard match funds will be made at the time the proposal budget is drafted by completing the Hard Match Request form. The Grants Office will complete and sign the form and route it to the Associate Vice President, Academic Affairs. The Associate Vice President will review and sign the form, then return it to the Grants Office. The Grants Office will document the amount of hard match approved on the Budget Summary and retain a copy of the signed Hard Match Request form. The original Hard Match Request form will be sent to the Supervisor, Fiscal and Compliance Services. The Grants Office and Fiscal and Compliance Services will maintain an Excel spreadsheet in the Grants Administration folder on the shared drive. The Grants Office will add each commitment of hard match to the spreadsheet. Upon award, Fiscal and Compliance Services will record the account number assigned to the hard match funds. The responsible grant accountant will track expenses against that account. If a proposal that includes a hard match commitment is denied, the Grants Office will adjust the spreadsheet to show the available balance of funds. A separate spreadsheet will be maintained for each fiscal year. Any balance in the hard match account at the end of the fiscal year is returned to the general fund. Each fiscal year begins with a new allotment of hard match funds.

18 18 Sample Hard Match Request Form

19 19 Proposal Signatures Signatures on proposal documents indicate that appropriate supervisors and administrators are informed and approve of upcoming proposal submissions and accompanying budgets. Two standard internal documents are completed and signed when a proposal is submitted: 1. Proposal Routing Form This document captures the following information about the proposal: Project Coordinator/Co-Project Coordinator and contact info proposal title brief description of the project importance of the project sponsor information additional project data source, purpose, status, human subjects project requirements type of award conflict of interest disclosure 2. Internal Budget This document captures budget amounts by: expense category each year of the project total cost from the grant match, cost sharing, or in-kind contributions from the College or project partners. The Grants Office provides the Proposal Routing Form, internal budget and its cover page, the Budget Summary, to the Project Coordinator* for signature. Additionally, the Grants Office will: obtain the signature of the appropriate chair or manager*; obtain the signature of the appropriate dean, Associate VP, or VP*; obtain the signature of the appropriate Cabinet Member*. *Forms are returned to the Grants Office after each signature and the Grants Office obtains the next signature in the process. Some applications require documents or cover letters signed by the President of the College or the Executive Director of the CSCC Foundation. The Grants Office will obtain these signatures. For electronic submissions, these are scanned and uploaded or attached to submissions as directed. Authority to submit through electronic portals such as grants.gov or the National Science Foundation is assigned to the Grants Office.

20 20 Proposal Tracking Electronic submission portals generate a confirmation message that a proposal was received. When a proposal is submitted as an attachment, the Grants Office will request an confirmation of its receipt. Messages or documents confirming delivery will be saved and added to the hard copy and/or electronic files. Proposals sent by certified mail or courier will be tracked using the tracking number provided on the address label. Messages or documents confirming delivery will be saved and added to the hard copy file.

21 21 Post-Award Process

22 22 Proposal Award When the Grants Office receives a fully executed agreement or other documentation of an award, it initiates the internal award process. Internal Award Letter The Grants Office prepares and signs an internal award letter addressed to the Project Coordinator. The letter includes the project title, the amount of the total award, and the sponsor. At the bottom of the letter is a table that includes the log number, the period of the award, and the amount of match or cost sharing, if applicable. The signed original is sent as a hard copy to the Project Coordinator and copies are placed in the hard and electronic files of the Grants Office. Electronic copies are distributed to the following offices/designated persons for the stated purpose: Fiscal and Compliance Services President Senior Vice President for Academic Affairs, or appropriate Vice President Associate Vice President, Dean or Director Chair or Manager CSCC Foundation Marketing and Communications Human Resources Information Technology Documentation of award; establish account Information; future reference Documentation of award; project will proceed Documentation of award; project will proceed Documentation of award; project will proceed Information; future reference Information; possible internal/external news story Documentation of award; hiring may occur Documentation; possible technology purchase Post Award Management Form The Grants Office also completes the Post Award Management Form that condenses information from the agreement that is used by Fiscal and Compliance Services for invoicing and reporting. A copy of this form is also provided to the Project Coordinator and copies are placed in the hard and electronic files of the Grants Office. Award Document Folder Each Project Coordinator receives a labeled folder that contains the Internal Award Letter and the Post Award Management Form, a copy of the fully executed agreement, awarded budget, and other important documents such as invoices and reporting forms. Initial Award Meeting At the same time the Internal Award Letter is distributed, the Grants Office will schedule a meeting, as needed, to include the Project Coordinator, responsible grant accountant, and assigned Grants Office staff. That meeting will introduce College processes used in grant implementation and administration.

23 23 Proposal Denial The Grants Office needs documentation of denial and will request one of the following: Original letter of denial from the funder Copy of the letter of denial if the original cannot be located Copy of an containing a denial message The Grants Office will provide documentation of denial to Fiscal and Compliance Services. In the Grants Office database, the status of the proposal will be changed from Pending to Denied. The date of denial will be entered. The proposal file will be marked Denied on the front cover and filed in the Denied section of the hard copy files. The Program Coordinator or the Grants Office will request proposal review feedback from the funder. Feedback will be retained in the file for use if the proposal is resubmitted.

24 24 Award Agreements and Sub-Award Agreements All original agreements for awards resulting from grant or contract proposals will be forwarded to the Grants Office. The process for review and signature of agreements has several steps. 1. The Grants Office will document receipt of an agreement by date stamping the back of the signature page. 2. The Grants Office will review and edit as needed all agreements to ensure that the following are included and/or correct: a. name and address of Columbus State Community College b. scope of work c. award amount d. payment method and schedule e. name and contact information for Project Coordinator and/or cost center manager f. name and title of signatory Agreements must have a supporting Scope of Work and a Budget. If a Scope of Work or Budget is not included, the Grants Office will assist in developing them. The Grants Office will also correct obvious typos, misspellings, or other grammar and wording as appropriate. Finally, as appropriate the Grants Office will add a reference to the federal circulars for higher education. Whenever possible, the Grants Office will work with electronic documents to hasten the signature process. 3. The Grants Office will provide the edited original to Legal Counsel for legal review. Legal Counsel will request changes to the agreement as appropriate. The Grants Office will edit the agreement to incorporate the changes and provide them to the funding sponsor for review and comment. If the Grants Office is not successful in negotiating a term or condition, the Grants Office will contact Legal Counsel to continue the negotiations until the agreement is accepted by all parties. 4. When negotiation is complete, the Grants Office will obtain appropriate signatures on at least two original agreement documents. The Grants Office will attach a cover memo requesting signature, if needed, and return the agreements to the funding sponsor. The memo will also request the return of one original to the Grants Office. The Grants Office will forward the fully executed original to Fiscal and Compliance Services where it will be maintained. The Grants Office will maintain a copy of the executed original in hard and electronic files. 5. Paper and electronic copies of the fully executed original agreement will be provided to the Project Coordinator as well as the appropriate chair/director and dean/associate VP or Sr. VP. Sub-Award Agreements When the College is the prime awardee and issues sub-awards, those documents are drafted by the Grants Office. Sub-awards include a Scope of Work developed with the Project Coordinator as well as a budget for the sub-awardee. The Grants Office communicates with the potential sub-awardee regarding content, terms and conditions.

25 25 They are reviewed by Legal Counsel prior to distribution for signature. The Grants Office is responsible for updating/renewing sub-award agreements as appropriate. The process will begin two months prior to the ending date of the sub-award agreement. All sub-awards issued by the College are subject to Sub-Recipient Monitoring and sub-grantees are responsible for fiscal requirements such as the following: post and maintain the project expenditures, sub-award funds, and any and all interest income earned in a separate segment, division, unit, or cost center account; maintain an accounting system in accordance with generally accepted accounting principles and Office of Management and Budget (OMB) Circulars Title 2 CFR Part 220 (A-21) and Title 2 CFR PART 215 (A-110), or A-87 and A-102 (whichever are applicable), as well as other applicable local, state and federal statutes, regulations, directives, and guidelines; utilize generally accepted accounting procedures to assure proper fiscal and management practices to deposit and account for sub-award funds; maintain separate accounting records for each sub-award, program income, and any other fiscal matters relating to the sub-award budget; and support all disbursements for obligations and expenses with contracts, invoices, vouchers, and other data, as appropriate.

26 26 Budget: Use, Tracking and Adjustments For grants, budgets are established using the budget that has been approved by the funding agency. The budgets are entered in the Colleague system by the responsible grant accountant. Budget figures are entered using the project ID and account numbers assigned to the project. These are entered into the Projects Accounting module. As expenses are incurred, budgets are monitored to ensure the costs do not exceed the budget amount. If a budget modification is needed, and it does not require prior approval by the funding agency, the following steps are taken: 1. Grants Office revises internal budget with Project Coordinator; 2. Grants Office provides revised budget with justification/explanation to assigned grant accountant within Fiscal and Compliance Services; 3. Responsible grant accountant makes adjustments to the budget entered in Projects Accounting as indicated above. If prior approval is needed, budget changes are not made until approval has been received. Typically, the Grants Office will work with the Project Coordinator to request prior approval in writing from the funding agency. This documentation is needed prior to making changes in the internal budget posted in Colleague. All budget changes are made in the system by the responsible grant accountant.

27 27 Closeout Grant projects and accounts are closed out by following a checklist of necessary tasks to ensure that all program and fiscal requirements have been met. Closeout occurs when an extension of the funding period is not an option. The final program report is prepared by the Project Coordinator and an e-copy is provided to the Grants Office and Fiscal and Compliance Services. Contact the Grants Office if assistance is needed in writing the report. The responsible grant accountant will confirm that all expenses have been charged to the approved budget categories and are reasonable, allocable, and allowable and occurred during the period of performance. The requirements for closing a grant are normally identified in the guidelines provided by the sponsor. For federal funds, additional guidance is given in 2 CFR 215 (OMB A110) and includes: Submit, within 90 calendar days after the completion date of the award, all financial, and other reports as required by the terms and conditions of the award. Liquidate all obligations incurred under the award not later than 90 calendar days after the funding period ends or the date of completion as specified in the terms and conditions of the award. Invoice for or draw down allowable reimbursable costs. Refund any balances of unobligated cash the sponsor has advanced or paid, and that are not authorized by the sponsor to be retained by the College for use in other projects. (See Residual Funds) Adjust cost sharing, upward or downward, after closeout reports are received. Account for any real and personal property acquired with federal funds or received from the federal government in accordance with OMB A-110 or specific guidance provided by the sponsor. Responsible Grant Accountant and Project Coordinator 1. Meet 60 days prior to the end of a grant. 2. Review account activity and encumbrance balances for closeout. 3. Confirm that all goods and services purchased with grant funds are received and/or completed prior to the end of the grant period of performance. 4. Notify HR, Cost Center Manager, and Dean regarding termination of grant funding for personnel assigned to the project. Complete appropriate paperwork. 5. Request HR to add an end date to any grant-funded position(s) so that payroll charges will end. 6. Ensure all Time and Effort reports are completed. 7. Initiate payroll changes for staff who will be assigned to other projects or budgets. 8. Inventory all equipment and review disposition instructions of the specific grant award or consult 2 CFR 215 (OMB A110). 9. Review the retention requirements and file all documentation pertaining to the grant. Follow the College s records retention policy unless the grant award specifies a longer period. Grant Accountant 10. Review and liquidate account balances for all encumbrances on project budget. 11. Review any grant account activity after the end date for compliance and prepare final closing adjustments. 12. Assess final F&A costs. 13. Review equipment disposition instructions and take appropriate action. 14. Return unexpended funds to sponsor if necessary. 15. Prepare and submit final financial report; provide copy to Project Coordinator.

28 16. Place an end date on the project once all expenditures have been paid. Add an X to the project ID to identify it as a closed project. 17. Review file to ensure all required documentation is included. 18. Follow and complete the Closeout Checklist. 19. Retain the completed Checklist in the project file. 20. Notify Grants Office when closeout is complete. Project Coordinator 21. Prepare and submit final program report to sponsor. Provide an e-copy to the Grants Office. 22. Review file and ensure that any documents with original signature are forwarded to the Grants Office. The Grants Office will copy or scan documents as appropriate and provide originals to Fiscal and Compliance Services where they will be maintained. Grants Office 23. Enter the word CLOSED next to the log number of the project in the database. 28

29 29 CLOSEOUT CHECKLIST Log #: Project Account: Project ID: Project Coordinator: Department: Sponsor: Start Date: End Date: Amount of Award: $ Due date for final reports: Grant Accountant Name: Phone: Budget Reconciliation: Compare sponsor-approved budget with ending balance Check for budget variances Confirm re-budgeting by line item is allowed by sponsor Locate required prior approvals Consider any restrictions on re-budgeting Review Expenditure Activity: Reconcile any account overdraft Confirm expenses are allocable Confirm expenses are necessary and reasonable to the performance of the project Confirm expenses occurred within the project period Determine that expenditures were treated consistently as a direct or indirect cost Confirm expenditures are adequately documented? Ensure expenditures are consistent with College policies and procedures? Confirm all expenditures are allowable based on the terms and conditions of the award and sponsor s policy and guidelines Resolve any unallowable expenditures Clear all balance sheet items (e.g., travel advances) in accordance with College procedures Review object codes exempt from F&A costs and handle appropriately Determine if F&A costs are accurately captured Determine expenditures properly tracked by task order or project number Gather any supplemental documentation required for the final financial report or invoice Provide any additional documentation required by the sponsor Put a Project end date on the Project IDs associated with the grant to ensure that no further expenditures are recorded in the fund after the award end date Request HR to add an end date to any grant-funded position(s) so that payroll charges will end. Close any open purchase orders. Specify and verify applicable cost sharing Verify all sub-recipients and sub-contractors have been paid and documentation is on file Verify all outstanding Time and Effort reports are signed and submitted Ensure that all reports have been submitted Project Closeout Date: Grant Accountant Initials: cc: Grants Office and Project Coordinator

30 30 Computers and Other Technology Purchases When a grant that includes technology is awarded, the VP of Information Technology and the designated Data Center Supervisor will be notified to prioritize those purchases. To initiate the purchase of these items using grant funds, the Project Coordinator contacts the designated Data Center Supervisor and advises the assigned grant accountant of this action. After purchase, the College s IT Department will support grant-purchased computers and technology. At grant closeout the grant accountant will discuss with the sponsor the disposition of computers and other technology purchases.

31 31 Consultant or Vendor Agreements Agreements to secure the services of a consultant on a grant-funded project are created for the services described in the proposal narrative and budget. Consultants are independent contractors and not employees of the College. Consultant vs. Employee Determination Prior to making the decision to hire a consultant, Project Coordinators need to determine whether the individual is considered an employee or a consultant/independent contractor. The following checklist can assist Project Coordinators in making this determination. The more criteria met, the more likely the individual should be considered a Columbus State employee, even if temporary or part-time. Contact the Grants Office or the responsible grant accountant for additional guidance in determining if a consultant or vendor agreement is necessary and appropriate. The Project Coordinator or Columbus State Community College: Provides instruction about when, where, and how to work Provides the workstation, tools, materials, supplies Can terminate, assign, or discharge the individual Can terminate the contract without risk of lawsuit for breach Pays the individual a salary rather than payment based on work completed Can be in a continuing relationship, however frequent or irregular Has the legal right to control both the method and results of work Provides training to the individual Hires other employees to assist the individual with the job Integrates the individual into the project staff Sets the individual's work schedule The individual: Performs the work as part of the university's customary line of business Assumes no financial risks Has no other clients for the same services Makes no attempt to acquire other clients Makes no profits or losses Has no investment in the business It is the sum of the circumstances rather than any one criterion that determines the proper relationship employee or consultant. Consultant or Vendor Agreement After the decision to hire a consultant or vendor has been made, the Project Coordinator uses the College s standard Legal Office Vendor Contract. Additionally, the Project Coordinator develops a Scope of Work, completes a Bid Waiver as appropriate, and completes a Legal Office Contract Routing and Approval Form. All are described below. Scope of Work The scope of work lists and describes all essential and technical requirements for the work to be performed, including the items listed below as appropriate: Objective or purpose Period of performance (work must begin and end within the period specified in the agreement)

32 Consultant or vendor responsibilities, tasks, and expected results Detailed description of services in regard to performance, quality, and timeliness requirements (include required or acceptable levels of performance on each specific task measured in terms of accuracy, response time, and speed) Description of deliverables Quality assurance standards of services and deliverables (meets certification requirements, graphic standards, etc.) Workload requirements (describe levels or amount of effort) Description and estimated costs of any reimbursable expenses Personnel requirements (minimum qualifications or skill level) Format and timeline for periodic and final reports and/or other deliverables The Project Coordinator monitors the work and verifies that the work is being performed according to the requirements of the agreement. Inform the Grants Office when the consultant or vendor is not performing the contracted work. Bids and Bid Waiver The competitive bidding process applies if the aggregate total of the consultant agreement fee is $10,000 on a federally-funded contract and $25,000 or more on other types of sponsored programs. Naming potential vendors or consultants in a grant proposal does not exempt them from the bidding process. (However, U.S. Department of Labor is an exemption in that it has determined that partners named in a proposal can be viewed as sub-awardees.) The nature of some vendors or consultants may make them eligible for a Bid Waiver as either a Sole or Single Source provider. Sole source means there is absolutely no other vendor to provide the work. Single source means that although other entities do the work, particular expertise or previous experience with similar contracts makes a vendor the best choice. In these cases a Bid Waiver is completed, signed and submitted with a vendor contract to the grant accountant. When a grant is awarded for multiple years, the Bid Waiver can be completed using the amount of the vendor contract over the life of the grant. However, there is an approved budget for each year of the award and the vendor contract cannot exceed the amount budgeted for any year. In Colleague, the vendor requisition is completed for one year at a time. The initial requisition equals the amount for the vendor budgeted in Year 1 and the purchase order will have an end date of 30 days after the end of the first year of the contract. Once a budget is determined for Year 2, the same purchase order will be increased for that amount and the date will be extended to 30 days after the end of the second year of the contract. Contract Routing and Approval Form This form allows users to confirm that the contract is complete and ready to move forward. Human Subjects Any consultant or vendor engaged in research involving human subjects should contact the Columbus State Community College Institutional Review Board (IRB) Administrator for guidance before entering into a consultant agreement. 32

33 33 Consultant/Vendor Contract Process Responsible Step in Process Grants Office* or Completes College s Legal Office Vendor Contract adding Scope of Project Coordinator Work, period of performance, and amount to be paid. Determines if vendor is registered with the College; if not completes Vendor Registration Grants Office* or Completes and attaches Bid Waiver as appropriate and Contract Routing Project Coordinator and Approval Form Grants Office* or Obtains signatures per Signature Approval Protocol, 9/1/2010 Project Coordinator Grants Office* or Forwards all signed documents to responsible grant accountant Project Coordinator Grant Accountant Checks payment against grant budget; forwards to Purchasing Purchasing Creates Purchase Order for services *Grants Office will complete these tasks for novice Project Coordinators. Consultant Invoicing Procedures The consultant/vendor completes and signs an invoice to request payment of the billable fee. The consultant/vendor sends the original signed invoice to the Project Coordinator who reviews and signs the invoice and forwards it to the Cost Center Manger or other designated approver. The last approver of the invoice is the responsible grant accountant who must receive the invoice with original signatures. Other Important Considerations All consultant invoices and reimbursement requests must be received within 30 days after the end date of the consultant agreement. The Project Coordinator monitors the work of the consultant and approves all consultant invoices and fee reimbursements in a timely fashion. Contact Information For assistance in preparation of the standard vendor contract, contact the Grants Office. Contact the responsible grant accountant for invoice and reimbursement questions. For all other consultant agreement procurement questions, contact the Purchasing Supervisor,

34 34 Food Purchases Some sponsors will approve food purchases (meals, snacks, beverages) as appropriate costs for the project. These expenses are included in the award budget/justification as well as the proposal narrative. Project Coordinators prepare a memo for each fiscal year that is routed and signed according to the Purchasing Signature Approval Protocol. Up to $4,999: One signature Cost Center Manager. $5,000 and over: Two signatures the Cost Center Manager and Cabinet member with oversight of the division. This memo is provided to the Purchasing Supervisor and copied to the responsible grant accountant in Fiscal and Compliance Services.

35 35 Personal Reimbursement For grant-funded projects, the College discourages personal reimbursement. All purchases made with grants funds are handled through purchase orders, blanket purchase orders, College check, use of the College s credit card, or gift cards. See the College s Purchasing Procedures and Purchasing Signature Approval Protocol.

36 36 Program Income Sponsored programs receiving program income must account for such income in a manner that will permit its identification and treatment consistent with the requirements of the federal sponsor. Accounting of program income applies to: a. program income or any excess funds earned or generated through the program during the life of the award; or b. program income earned or generated under the program until final disposition of equipment purchased with program funds. Program income from projects supported by federal agreements will be accounted for in accordance with federal awarding agency regulations or the terms and conditions of the agreement. Program income will be used to further eligible projects or program objectives. At the time of proposal submission, the anticipation of program income must be indicated in the proposal. If program income becomes a possibility during the performance of an agreement, the Grants Office and Fiscal and Compliance Services will be notified immediately by the Project Coordinator.

37 37 Purchasing See the College s Purchasing Procedures. Also, see Vendor Registration. Purchasing Signature Approval Protocol The College s purchasing procedure, 9-03(H)(1) notes that a purchase of goods services, materials, supplies, leases or rentals, is authorized by the college when a purchase order is issued by the Purchasing/Accounts Payable Office. A purchase order is a legal agreement between the college and a vendor. A purchase order is issued after a requisition has been posted and approved. College procedure 9-03(H)(9) calls for each Division to establish a signature approval structure for purchases. To insure a consistent internal control for the authorization of all purchases of goods, services, materials, supplies, leases or rentals, the college has established an authorization protocol that is consistent across divisions. Purchasing Authorization and Signature Approval Protocol Effective September 1, 2010 (Notations in blue have been added for the benefit of grants administration.) Cabinet is comprised of the President, the Senior Vice President and Chief Financial Officer, the Senior Vice President for Academic Affairs, the Vice Presidents, and the Executive Dean of the Delaware Campus. For purposes of this Purchasing Authorization and Signature Approval Protocol, the Executive Director of the CSCC Foundation has equivalent signature/approval authority. In some instances, College Policy or Procedure allows a Cabinet member to delegate approval authority to a designee. Such designations must be sent to Purchasing and Office Services in writing and specifically note the authority that is being delegated and to whom. Such delegation of authority can be made only to a Cost Center Manager who is a direct report to the Cabinet member. Cost Center Managers are defined by title and include the following: Cabinet, Associate Vice Presidents, Deans, Directors (Director II, Director I, Assistant Director), and Chairpersons. Cost Center Managers are administrators and have budget responsibility for their cost center(s). While Supervisors may assist with budget development and management, they do not have direct budget responsibility and do not have Cost Center Manager authority or responsibility. Initiators are employees who create a requisition (in Colleague) or create a Request for Payment to Outside Vendor form. Any employee can initiate a payment request or requisition. In many cases, the initiator is an Administrative Assistant, Office Associate, Teaching Assistant, or Project Coordinator who enters the relevant information in Colleague or prepares the Request for Payment to Outside Vendor form for the approval of the Cost Center Manager. A Cost Center Manager cannot initiate and approve a payment request or requisition. If a Cost Center Manager initiates a request for payment or requisition, the Cost Center Manager s supervisor must be the approver. Effective September 1, 2010, purchases of goods, services, materials, supplies, leases or rentals must be approved as follows: Purchase Orders: Purchase Orders (POs) are legally binding documents, and are generally used for goods, services, materials, supplies, leases or rentals. By law, the College s Chief Financial Officer has to certify that funds are available for a purchase, and this certification occurs through the requisition/purchase order process. It is very important to use the Colleague requisition process as opposed to the Request for Payment

38 to Outside Vendor form. Purchasing can be contacted for assistance if a vendor will not accept a purchase order. It is understood that some purchases for grants do not fit the College s routine and preferred practices. It can be challenging to resolve them yet a Project Coordinator must take steps to avoid using personal reimbursement. Contact the responsible grant accountant immediately after award for assistance in resolving purchasing needs with Purchasing. There are two types of purchase orders: Purchase Orders ( Regular POs) are used for one time purchases that will be invoiced once. Blanket Purchase Orders (BPOs) are used for recurring purchases with a vendor over the fiscal year - when multiple invoices will be billed against the BPO. BPOs are commonly used in situations where low cost items are frequent purchases from a single vendor such as maintenance and supply items. The advantages are calling in orders and requesting multiple shipments over a period of time without going through the requisition/approval process each time. To indicate a BPO, click on the drop down menu in the "Priority Field" and select Blanket Purchase Order Option. Type the statement, This is a Blanket Purchase Order, as a line item in the body of the purchase order. Call Purchasing at x2443 for additional clarification on how and when to use a Blanket Purchase Order. A requisition in Colleague is the means by which a purchase order is generated. Requisitions for purchases of various amounts must be approved as noted in the chart below. The person who initiates a requisition is responsible for identifying the required approvers. Amount Up to $9, Required Approval to Commit to a Purchase Required approval: Cost Center Manager (Chairpersons, Directors); Note: Cost Center Manager cannot initiate and approve $10,000 $49, Required approval: Cabinet Member who oversees the Division or Associate Vice Presidents/Deans when designated by the Senior Vice President for Academic Affairs $50,000 and over (*) President and Cabinet Member who oversees the Division (*) excludes approval by President for institutional expenditures that have been budgeted (such as utilities and payroll tax remittances) and purchases related to contracts that have been authorized by the President. In these instances, the Cabinet member is responsible for the authorization. Each Cost Center Manager is accountable for receiving and reviewing invoices against a regular PO (using the Purchase Order Receiving [PORC] mnemonic in Colleague) to insure that the goods/services that were received were delivered as expected, and have been appropriately billed. BPOs must have individual invoices approved since the BPO is for recurring expenditures. Each invoice must be reviewed and approved by at least an Administrator or Supervisor to insure the receipt of goods 38

39 39 and/or services billed. While a Cost Center Manager can delegate this review, s/he is accountable for it occurring responsibly. The College ends its Fiscal Year on June 30 and closes purchase orders on July 31. However, for grants that do not have a June 30 ending date, the purchase order can stay open by inserting the needed date into the comments section of the requisition. Typically, the date will be 30 days after the project ending date to allow time to receive invoices for items purchased the last month of the grant. Grants crossing over multiple years need a new purchase order for each year of the project; a purchase order cannot stay open for two or three years. Other Types of Expenditures: A variety of expenditures have additional or different approval protocols. Below are some of the more common expenditure categories that require special handling: Contracts By College Procedure, contracts for purchases of goods, services, materials, supplies, leases or rentals, and grant agreements require two signatures, and can only be signed by Cabinet members (or the President s or a Senior Vice President s designee) and direct reports of Cabinet members. Any contract that exceeds $50,000 must be signed by a Cabinet member and the President. Contracts that do not bind the College financially but create other legal obligations, such as clinical affiliations and other partnerships, must be signed by a Cabinet member (or the President s or a Senior Vice President s designee). Signatures on renewals of such existing contracts or agreements can be delegated to a Cabinet designee. Externally Funded Grants and Contracts Expenditures for externally funded grants and contracts (typically, federal or state funded) require approval by the responsible grant accountant in addition to required approvals per this Protocol. Required approvals for these grant and contract proposals, and the related grant agreements and contracts subsequently executed must be coordinated with the Grants Office. Any items purchased with grant funds must be initiated using the grant account number. It is unacceptable accounting practice to purchase from a general fund account and then move expenses to a grant account.

40 40 Food and Beverage must be pre approved by the Cabinet member who oversees the Division, or the Senior Vice President for Academic Affairs or designee. Employee Travel must be pre approved by Deans in Student Affairs and Academic Affairs divisions, and by the Cabinet member who oversees other Divisions. Travel requests for Deans will be pre approved by the appropriate Sr. Vice President or his/her designee. International travel must also be pre approved by the Cabinet member and President. Capital Equipment Guidance is provided annually for the capital equipment budget process. Items approved through the Cabinet level are authorized for purchase. Each Cabinet member is responsible for establishing with Purchasing how s/he would like to handle approvals of requisitions for items that have been approved and budgeted. Minimally, approval by a Cost Center Manager is required. Internal Vendors Compliance with required approvals by Cost Center Managers and/or Cabinet members also applies to purchases from internal vendors such as the Bookstore; Print Services; non credit classes and seminars; and office supplies through the College s approved supplier. Competitive Bid Processes Bid requirements established in the College s Purchasing Procedure 9 03 (H) (8) and related procedures must be observed. The Grants Office and Fiscal and Compliance Services will address competitive bids in the pre-award proposal development process, identifying possible Sole or Single Source purchases. However, all bid waivers will be approved by Purchasing. Exceptions to this authorization protocol must be approved by the Cabinet member who oversees the Division and communicated to Purchasing in writing. Assistance The Purchasing team is always available to assist in the application of this protocol.

41 41 Purchasing Credit Card and Gift Card Procedures Credit Card Guidelines for Card Use The College s credit card may be used for: purchases related only to College business; vendors who will not accept the College s purchase orders and/or checks; international purchases of essential items related to course work or technology; and emergency purchases of goods or services needed to correct or prevent an emergency health, environmental or safety hazard that would impede normal College operations. Procedure for Care Use Have grant account funds available at the time of the credit card purchase; and Contact Purchasing with vendor contact information, online order website, and items to be ordered. Authorized Purchasing/Business Services staff will place orders. Business Services will make the final decision regarding appropriate use of the card. Items Prohibited for Purchase 1. Personal items 2. Live animals 3. Controlled substances requiring DEA license 4. Employee relocation and relocation-related expenses 5. Items for resale 6. Any travel related expense, including registrations 7. Food items 8. Donations to charitable organizations 9. Hazardous materials 10. Weapons or ammunition 11. Cash advances Pre-Paid Visa Cards Program Purpose Columbus State Community College s Pre-Paid Visa card program is designed to utilize a more efficient and cost effective procurement process for small dollar purchases for goods related to course and/or program work. This will allow the authorized users to purchase approved commodities directly from vendors who will not accept the College s purchase orders. General Guidelines All purchases should be done in a manner consistent with the policies and procedures of College Policy The authorized user will be held accountable for the card, including appropriate purchases as well as the loss or theft of the card. No personal charges may be made with the card. A personal purchase is defined as anything that is not purchased for use and ownership by the College. It is a violation of College policy to affect ANY personal purchase with the pre-paid Visa card, whether or not the cardholder intends to reimburse the College for the purchase. Card usage for any personal expenses is strictly prohibited. Fraudulent use or abuse of the pre-paid Visa card will result in immediate termination of privileges to use the pre-paid Visa card. It is important to understand, when using the pre-paid Visa card, individuals are authorizing the commitment of

42 College funds and are accountable in the same way they would be held accountable for authorizing a requisition or check request. In addition, individuals are prohibited from using their personal reward cards to receive reward points for making purchases at the various stores that have advantage cards. Cards should not be requested more than two business days in advance of the purchase. Management of Pre-Paid Visa Card Cost center managers are important to the proper administration of the Pre-Paid Visa Card program. Each prepaid Visa card will be signed in and out and by the authorized users. When requesting a pre-paid Visa card, the authorized user will have to complete and submit the Pre-Paid Visa Card Request Form. When returning the pre-paid Visa card, the authorized user will have to complete and submit the Pre-Paid Visa Card Purchase Report Form. Request Forms Sample forms are provided on the next two pages. Complete and follow directions for use. Returns, Credits, and Disputed Items In the unlikely event the authorized user needs to return an item, please contact the Accounts Payable/Purchasing Office. Recordkeeping and Statement Reconciliation The authorized user must maintain all original receipts for all purchases made with the pre-paid Visa card. All original receipts are to be attached to the pre-paid Visa card purchase report form. The original receipts, prepaid Visa card purchase report form, and the pre-paid Visa card are to be returned to Cashiers Office, Rhodes Hall 2 nd floor, by the close of the next business day after the approved purchase is completed. It is important to remember that the original receipts are the only original documents the College possesses to substantiate these financial transactions. Sales Tax Procedures Columbus State is tax exempt, therefore no sales tax should be charged on the purchases being made with the pre-paid Visa card. If sales tax is charged, the cardholder should contact the vendor for a credit. The vendor may request a sales tax exemption by using a Blanket Certificate of Exemption. A copy should be printed ahead of time and presented at the time the cardholder is ready to check out. Please note the tax exemption form is not for personal use. Security The pre-paid Visa card should be treated with the same level of care as a personal charge card. When the card has been checked out, storage of the card should be in a secure location, accessible to only the one who checked out the card. The card account number should be secured and not posted at a desk or any other location. The pre-paid Visa card is the responsibility of the person who checked it out and should not be given to anyone else. 42

43 43 Obtain this form from Purchasing/Accounts Payable Office Rhodes Hall 215 PRE-PAID VISA CARD REQUEST FORM Employee Agreement Return this completed to the Cashiers Office in Rhodes Hall 2 nd Floor form in order to pick up a pre-paid Visa card from. I hereby request a pre-paid Visa card. As a pre-paid Visa card user, I agree to comply with the following terms and conditions regarding the use of the pre-paid Visa card: I understand that I am being entrusted with a valuable purchasing tool and will be making financial commitments on the behalf of Columbus State Community College. I will strive to obtain the best value for the College. I understand and agree to use this pre-paid Visa card for approved purchases only related to course or program work. I understand and agree that this pre-paid Visa card is not to be used to make personal purchases. I understand that Purchasing/Accounts Payable will audit the use of this pre-paid Visa card and report and take appropriate action on any discrepancies. I will follow the established procedures for the use of the pre-paid Visa card. Failure to do so may result in either revocation of my use of the pre-paid Visa card or personal liability for the value of the card. If the pre-paid Visa card is lost or stolen, I agree to notify the Purchasing/Accounts Payable Office immediately. I understand that I will have to sign out the pre-paid Visa card and return it to the Cashier s Office Rhodes Hall 2nd floor. I understand that all cards need to be returned even if there is no remaining balance on a card. I understand and agree to bring the completed Employee Agreement form (no more than 2 business days in advance of the purchase) to the Cashiers Office when signing out the pre-paid Visa card and the Prepaid Visa card report form (within 1 business day after purchase) to the Cashiers Office when signing in the pre-paid Visa card. Employee Name (please print full name; identification required) Employee Signature Date Dept (building/room) Ext. Anticipated Purchase Date: Approved Spending Limit: Account # Project Id: Cost Center Manager (please print full name): Cost Center Manager Signature: Date Grant Accountant Approval Signature(for project accounts only): Date Business Purpose: Cashiers Office Use Only: Number of pre-paid Visa cards signed out Pre-paid Visa card # & current balance: Total dollar amount of pre-paid Visa cards signed out Date Signed out Signature

44 44

45 45 Reporting Time and Effort The federal government requires a time and effort report when an individual is compensated by or has agreed to contribute time to a federally-sponsored project. All Project Coordinators who manage staff for grant-funded programs are responsible to certify the amount of effort they and their employees spend on the program. Definition of time and effort reporting Effort is defined as the amount of time spent on a particular activity. It includes the time spent working on a sponsored project in which salary is directly charged or contributed (cost-shared or in-kind effort). Individual effort is expressed as a percentage of the total amount of time spent on work-related activities (instruction, frontline services, administration, curriculum development, etc.) for which the College compensates an individual. Effort reporting is the mandated method of certifying to the granting agencies that the effort charged or costshared to each award has actually been completed. The difference between effort reporting and payroll distribution Payroll distributions and effort reports are not the same thing. Payroll distributions are the distribution of an individual's salary. Effort reports describe the allocation of an individual's actual time and effort spent for specific projects, whether or not reimbursed by the sponsor. Thus effort reporting is separate from and can be independent of salary charges. Effort is not just a verification of the salary or payroll distribution. Cost-shared or contributed effort must be included in effort reports. Federal requirements regarding effort reporting 2 CFR Part 220 (formerly OMB A-21), Cost Principles for Educational Institutions, is the federal government's summary of cost principles for colleges and universities. It defines what costs are allowable and allocable to federal grants and other "assistance" agreements. 2 CFR Part 220 (Section J.10) sets forth criteria for acceptable methods of charging salaries and wages to federally sponsored projects. 2 CFR Part 220 requires a payroll distribution system that directly charges salaries to appropriate projects. In addition, 2 CFR Part 220 requires that institutions develop a mechanism to determine or confirm how individuals actually expend effort during a specified time period. These effort reports must be performed on a regular schedule and must be certified by individuals who have first-hand knowledge of 100 percent of the employee's compensated activities. In most cases, that would be the employee or the employee's direct supervisor. Documenting time and effort ALL grant-funded employees, salaried or hourly, who are paid with federal funds, must complete and submit Time and Effort Reports. The Grants Office will provide to the Project Coordinator an electronic version of the Time and Effort Form for each grant-funded CSCC employee. Forms for non-employees of the College will be generated and distributed to the non-employees by the Project Coordinator.

46 Funder requests to document time and effort more often than quarterly, such as monthly, will be negotiated and documented in the terms and conditions of the agreement. The transmitting the electronic form(s) to the Project Coordinator will reflect the reporting cycle. All Time and Effort forms are to be completed electronically or by hand according to the stated reporting cycle. When the Project Coordinator is also a grant-funded employee, the Project Coordinator will sign on the Signature line. The immediate supervisor will review and sign the form on the Project Coordinator signature line and return the form to the Project Coordinator. In cases where grant-funded employees have an on-site supervisor, the employee will complete, sign, and date the form and give it to the on-site supervisor for review, signature, and date. All on-site supervisors and other grant-funded employees will provide the completed forms to the Project Coordinator for review, signature, and date. Forms for non-cscc employees must be completed, signed and sent to the Project Coordinator no later than five working days after the end of each reporting cycle for review, signature, and date. In signing the forms, the Project Coordinator attests that the stated work was completed in that time period. The Project Coordinator must send all completed Time and Effort forms to the responsible grant accountant no later than 10 working days after the end of each reporting cycle. Note: Some Project ID numbers change each year. Contact the responsible grant accountant to ensure that the correct ID is used on the form when the project year changes. Reporting Time and Effort as Cost Sharing Faculty and staff time budgeted as cost sharing must also be documented. In addition to completing a Time and Effort Form, individuals must track the hours (Excel spreadsheet, Word document) they spend in tasks related to the Scope of Work (meetings, preparation, delivery, etc.) and provide it to the responsible grant accountant. The grant accountant will determine the reporting cycle for cost sharing documentation. Upon receipt of the forms, the responsible grant accountant will calculate the dollar value for reporting. All Time and Effort forms are maintained by Fiscal and Compliance Services. 46

47 47

48 48 Residual Funds As directed by sponsor guidelines or the signed agreement, the College will return unspent grant funds. However, when the sponsor does not want the funds returned or does not provide guidance on unspent funds, the College will keep the funds and adhere to the following guidelines: 1. The funds will be used for a purpose that aligns with the intent of the grant-funded project. 2. Expenditure of funds will have defined start and end dates. 3. The Grants Office will work with the Project Coordinator to draft an internal budget for the expenditure of funds. 4. The Grants Office will complete the Authorization to Retain Residual Funds form. The form will be signed by the Project Coordinator and the respective Chair/Director and Dean/Associate VP/Sr. VP. 5. If a different Project Coordinator will manage the residual funds, that person as well as the respective Chair/Director and Dean/Associate VP/Sr. VP will sign the form. 6. The signed form, internal budget, and any related documentation (see form) will be provided to Fiscal and Compliance Services.

49 49 Responsible Conduct in Research According to the Office of Research Integrity of the U.S. Department of Health and Human Services and the Office of Investigations of the National Science Foundation (NSF), research misconduct means fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results. Fabrication is making up data or results and recording or reporting them. Falsification is manipulating research materials, equipment, or processes, or changing or omitting data or results such that the research is not accurately represented in the research record. Plagiarism is the appropriation of another person's ideas, processes, results, or words without giving appropriate credit. Research misconduct does not include honest error or differences of opinion. For Columbus State, research misconduct applies to the administration of grants for research, instruction and training, public service, evaluative testing, and other scholarly and creative activities conducted under the direction of College faculty and staff and funded by external sponsors. Some sponsors, such as the National Science Foundation, have a process requiring a grantee to bear primary responsibility for prevention and detection of misconduct. NSF relies on a grantee to promptly: 1. Initiate an inquiry into any suspected or alleged misconduct. 2. Conduct a subsequent investigation, if the inquiry finds substance. 3. Take action necessary to ensure the integrity of research, the rights and interests of research subjects and the public and the observance of legal requirements or responsibilities. 4. Provide appropriate safeguards for subjects of allegations as well as informants. This requirement is passed on to sub-awardees of NSF grants, such as Columbus State. It is a requirement that the College educate Project Coordinators and appropriate grant-funded personnel about the nature of research misconduct. Upon notice of a funded award, the Grants Office will refer the Project Coordinator and appropriate grantfunded staff to the guidance for online training in Responsible Conduct of Research. Training must be completed within 45 days of the grant award date. The training site automatically provides evidence of training completion to the Grants Office.

50 50 Vendor Registration Part of the Purchasing process is to register vendors who will be paid by the College. Project Coordinators must provide vendors a Vendor Registration Form and ensure it is completed, signed, and returned. Project Coordinators provide the Vendor Registration Form to Purchasing as soon as it is completed. The form is not attached to a contract as it delays the registration process. Once registered, vendor payments can be issued against invoices. For sub-awardees, the Grants Office will provide the form at the time the sub-award agreement is routed for signature. Subsequently, the Grants Office will ensure the form is provided to Purchasing.

51 51 Process Toolls

52 52 Database Log number The Grants Office maintains an MS Office Access database to track and monitor proposal submissions and awards. The database stores relevant information on all grant-funded projects and produces queries and reports. Accountants in Fiscal and Compliance Services have read-only access. Database entry begins with a proposal. The Grants Office manually assigns a log number to each proposal that consists of the current fiscal year and sequential numbering starting with 1. For example, log numbers would be , , , etc. Log numbers are assigned to new projects. When a project budget extends over three years, each year of the project does not require a new log number. However, when one cycle of funding ends and the project is offered a new round of funding, the new funds are identified with a new log number. Initial Entry Other information entered at the time of proposal includes the following: Program Coordinator s name and department; same for any Co-Program Coordinators Sponsor Submitting organization Proposal title Brief summary Amount requested Cost sharing amount committed, if applicable F&A amount and rate, if allowed by sponsor Date submitted Pending status (checked) Comments, if needed CFDA (Catalog of Federal Domestic Assistance), if applicable Database Maintenance As proposals are awarded or denied, the database is updated. If a proposal is denied, the status is changed from Pending to Denied. Date of denial and other appropriate comments are entered. If a proposal is awarded, the status is changed from Pending to Awarded. Date of award, amount of award, project period, reporting dates, and other appropriate comments are entered. Entries to the database will be made in a timely manner.

53 53 Grants Office Files Hard Copy Files The Grants Office will prepare a sectioned file folder for the project that will follow this format: original Proposal Routing Form on top of (OTO) original Budget Summary OTO yearly budget sheets OTO any budget related information cards or documents related to mail or courier service (taped to file) copy of internal award letter OTO copy of signed agreement OTO correspondence related to negotiation/signature of agreement or other correspondence related to award management, most recent on top copies of program reports, most recent on top or other correspondence related to proposal development, most recent on top final proposal OTO documents related to proposal development OTO RFP or proposal guidelines Proposal Development Form Each project file will be labeled in this manner: Label colors change at the start of a new fiscal year Saler, Christine Assessment for Culinary Arts; US FDA Hard copy files are maintained in file drawers divided into sections labeled Pending, Awarded, and Denied. Files are also grouped by cost center manager by year depending on volume and arranged in log number order, highest (front) to lowest (back). Per the Records Retention for Public Colleges and Universities in Ohio Manual (2009), files will be maintained for four years or longer if the agreement so stipulates. Electronic Files Each project has on electronic file on the K drive.