Procedures for Grants Received by the County

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APPLICATION PROCESS

  1. Official name to be used on all grant applications for the County as the applicant is County Commissioners of Charles County, Maryland.
  2. Notify the Senior Budget Analyst for program grants and /or the Budget Analyst for capital grants of plans by completing the Grant Intent Notification Form as early as possible in the planning stages of specific projects that are a potential grant application, but in no case later than 20 working days prior to any application deadline. Form should be sent electronically, no hard copies. The information can also be sent via e-mail as long as the e-mail notification includes all information requested on the Grant Intent Notification Form.
  3. Schedule a planning meeting(s) as appropriate with the Senior Budget Analyst or Budget Analyst to review drafts of the application and the application budget
  4. Budget information for technology must be requested from and meet configuration requirements of the Information Technology Department (IT) with the exception of the Sheriff’s Office which are handled through their Management Information Systems (MIS) Section.
  5. Budgets for all grants that allow indirect costs should be set at a rate consistent with the most current approved cost allocation plan. For information on the rate for a specific division, contact the Senior Budget Analyst at 301-638-2404 or Ext. 2404. Exemptions must be requested in writing.
  6. Should the grant application require a letter from the Commissioner’s office, have the authorized person from you department access the letterhead and prepare the document in electronic format so that it can accompany the grant through the signature process.
  7. Please complete the Grant Application / Proposal Processing Form, obtain Department Head approval and Partner Agency approval, if applicable. Submit form and complete application electronically to the Budget Division with a cc to the FAS Office Associate and the Fiscal and Administration Coordinator for processing a minimum of 14 days prior to submission deadline. This procedure applies to on-line applications as well. For any grant of more than $5,000, or for any grant that requires a County cash match, processing is completed to President approval/signature or Vice President approval/signature in the absence of the President of the County Commissioners.  For grants $5,000 and under where no County cash match is required, President approval/signature is not required but grant should still be sent as above for processing through the County Administrator.  Grant Application / Proposal Processing Form
  8. Application resources - The County has a Grants Resources page for information relative to preparing an application - such as demographics, per diem rates, value of volunteer time, Catalog of Federal Domestic Assistance, etc...  Email Amy Blessinger for Demographic Information.

AWARD PROCESS

  1. Send a copy of the award letter, acceptance requirements and/or other notification to the Budget Division with a Grant Award Processing Form in electronic format with a cc to the FAS Office Associate and the Fiscal Administration Coordinator. No hard copies should be processed. All applicable paperwork should be received by the Budget Division 14 days prior to submission deadline. The Senior Budget Analyst or Budget Analyst will process for approval and return upon completion to the appropriate County department.
  2. Send a copy of any special conditions, regulations, contracts, report forms, revised budgets or other requirements of the funding agency to the Budget Division.
  3. The Budget Division assigns an account number and sets up an account for each grant. No expenses may be incurred until an account is in place. This process will vary depending upon the source of grant funds and the department monitoring the program.
  4. Once accounts are established, the Department responsible for implementation of the grant should verify budget against the respective accounts. If no budget is established, please prepare a budget amendment increase in the County's financial system. If a budget has already been adopted or previously entered, please align to the award with a budget amendment in the County's financial system. Attach a copy of the grant award (at a minimum the budget page and signature page) along with a copy of a budget performance report as of the current date and current fiscal year as a  backup for the budget amendment request.

GRANT IMPLEMENTATION

  1. Fiscal Related:
    a. Fiscal records must be maintained at the program department and the Department of Fiscal and Administrative Services.
    b. All encumbrances, purchases, and payments are processed and submitted in accordance with County fiscal procedures.
    c. All grants will be reconciled at year end by the Senior Budget Analyst for program grants and Budget Analyst I for capital grants. Grant revenue will then be deferred or returned to the appropriate funding agency where applicable.
    d. All grants are subject to audits by the County Internal Audit staff and any audits which the funding agency may require.
    e. Any revenue collection received in conjunction with the grant must be paid to Charles County Government and be processed through the Department of Fiscal and Administrative Services. Therefore, all grant reimbursements must be made payable to Charles County Government/Accounting, 200 Baltimore Street, La Plata, MD 20646.
  2. Carryover Budgets:
    a.  Once the fiscal year is complete and all expenses have hit the grant accounts and all grant draws have been processed through account receivable via a billing request, the County Department responsible for oversight of the grant should prepare budget amendments for all grants eligible   for carryover. This would apply to multi-year awards as well as grants awarded on a Federal Fiscal Year basis.
    b.  The budget amendment should be entered in to the County's financial program. Reason budget amendment is requested should state the following: Align budget to include carryover funds from grant award #____________________. Reason for availability of budget funds should state the following: 
    Grant award is for the period of XX/XX/XX to XX/XX/XX and a balance of $XXXX.XX is remaining as unspent funds.
    c.  Be sure to attach a copy of the grant award (at a minimum the budget page and signature page) along with a copy of a budget performance report as of the last day of the fiscal year, 06/30/XX for backup of proof of funds.
  3. Personnel Related:
    a. Positions for any personnel to be hired with grant funds must be posted and filled according to County Personnel Policies and Procedures with the exception of the Sheriff’s Office. Sheriff Office positions hired with grant funds are done in conjunction with the Sheriff’s Office Personnel Policies and Procedures.
    b. Employee(s) must be advised that grant-funded positions are only funded for the duration of the grant funding.
    c. Grant-funded positions must be rated and ranked through the county's classification process with the exception of the Sheriff’s Office. Grant funded positions assigned to the Sheriff’s Office are rated and ranked through the Sheriff’s Office classification system.
    d. Contractor or Employee: Employment status: Determine whether someone is an independent contractor or employee - refer to HR on all hiring issues. IRS Guidance
  4. Computer/Technology Related:
    a. All computer related equipment and software purchases must be approved by the IT Department with the exception of the Sheriff’s Office. All Sheriff’s office computer related equipment and software purchases must be approved by the Sheriff’s office MIS section.
    b. Equipment will be ordered by the IT Department or Sheriff’s Office MIS section under the grant account allowing sufficient time for delivery and arrangements made for installation.
  5. Relative to procurement of goods or services and subrecipients:
    a. Procurement of goods or services must be made in accordance with purchasing and procurement policies set forth in Chapter 203 of the Charles County Code as well as any conditions outlined in the grant agreement / guidelines. County Code on Procurement
  6. Procurement Summary:
  1. $25,000 and over aggregate value requires competitive bidding. Small Local Business Enterprise (SLBE) firms receive a preference when bidding on formal solicitations up to $500,000.
  2. For Blanket PO - whatever the Blanket PO Amount has been established at is the limit of purchase.
  3. Over $5,000 to $24,999 need to acquire 3 competitive pricing quotes. All procurements less than $25K are reserved for qualifying SLBE firms subject to the following limitations:
  • There must be at lease three (3) registered SLBE firms qualified to submit bids or proposals.
  • If the lowest SLBE quote received is deemed to be 10% or more above the lowest non-SLBE's quote, then the commodity/service may be procured from a non-SLBE Firm.
  • $5,000 or less - requires only one quote or price. Departments are strongly encouraged to utilize Minority Business Enterprise (MBE) registered firms and SLBE firms for one quote purchases. Directories of SLBE and MBE registered firms are available on the County's Purchasing Division website as well as further information on the procurement process. Procurement

 b. Federally funded grant procurement of goods or services must also comply with conditions outlined under Procurement Standards within 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR 200. The managing department should also refer to all grant award conditions. Subrecipient and contractor determinations can be found within 2 CFR 200.331 Link: Subrecipient and vendor determination.
Link to Determination Checklist:  CCG Subrecipient-and-Vendor-Determination-Checklist

c.  Subrecipient agreements: If Charles County Government is a Prime Grant Recipient and is awarded a new Federal grant greater than or equal to $30,000 as of October 1, 2010, the County is subject to the Federal Funding Accountability and Transparency Act (FFATA) sub-award reporting requirements as outlined in the Office of Management and Budgets guidance issued August 27, 2010. The County is required to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. 

If your department enters into an agreement with a sub-recipient for greater than or equal to $30,000 and the original grant award was a direct award from a federal granting agency, please have the sub-recipient agency complete the FFATA form and return to the Senior Budget Analyst within 15 days of subaward to ensure timely reporting. The form is due to the Senior Budget Analyst within 15 days so that the County can meet the FFATA reporting deadline. Based on FFATA guidance, the prime awardee (in this case the County), must report information related to a subaward by the end of the month following the month the subaward or obligation was made. For example:
Example 1:
The County awards subaward on October 1, 2013
The County must report subaward information by November 30, 2013

Example 2:
The County awards subaward on October 31, 2013
The County must report subaward information by November 30, 2013
For further information go to https://www.fsrs.gov/#a-faqs.

If a subaward is initially funded at less than $30,000, the County does not have to report the subaward to the Federal Funding Accountability and Transparency Subaward Reporting System (FSRS). However, if the County subsequently provides additional funding to increase the subaward amount to $30,000 or more, the subaward must be reported in the FSRS.

d.  Verification of Suspension or Debarment - For any contract/subrecipient agreement supported with federal funds, a verification of suspension or debarment should be completed prior to award of the contract or subrecipient agreement. To check the subrecipient organization or vendor against the Excluded Parties List (EPLS), you will need the organization/vendor name, DUNS, and/or CAGE Code. Verification is intended to prevent waste, fraud and abuse in Federal procurement and non-procurement actions. E-mail a request to the Senior Budget Analyst with the following information:  name of subrecipient organization, DUNS, and CAGE Code if available. The Senior Budget Analyst will search for confirmation that the subrecipient is registered with SAM.gov and if any exclusions are listed. The Senior Budget Analyst will print the results of the search and forward to initiating department contact to be included with any subrecipient agreement.

Utilize this information to determine if the organization/vendor should not be considered for award. If no suspension or debarment is in effect, the result will be: Has Active Exclusion? No 

e.  A Risk Assessment of a subrecipient organization should be completed by the pending subrecipient organization and review by the County Department overseeing a grant prior to entering into a subrecipient relationship. Have the pending subrecipient organization complete the Risk Assessment Form. A risk assessment form completed by the subrecipient ensures the County can assess the risk of the County prior to approval for subrecipient status.

f.  Once approved for subrecipient status and upon award of a grant, a subrecipient agreement should be process for signatures utilizing the Subrecipient Agreement Processing Form.

 g.  Any grant related contracts should be processed with a Contract Processing Form. Contract Processing Form

h. To maintain proper accounting controls over capital assets, all capital assets purchased with grant funding should be made in accordance with the County’s Capital Asset Accounting and Control (CAAC) Procedures. Please refer to the following SOP's found on the County's intranet site for guidance.

6.  Relative to Reporting:

a.  Programmatic and fiscal reporting are the responsibility of the grantee department and must be filed in accordance with the funding agency’s format, content requirements and deadlines. Requests for grant funds or reimbursements must be processed through the Senior Budget Analyst or Budget Analyst for Capital Grants to ensure accurate financial reporting and accounting in within the County's financial system. Reporting should be processed utilizing the Grant Reporting Processing Form. All reporting should be forwarded via email in electronic format. No hard copies. 
b. Time and effort for Part Time personnel and Full Time Personnel, up to a grade 117 and up to a grade E15, spent on the grant project should be based on signed time sheets. Time sheets must be signed by the employee and their respective supervisor and be retained for auditing purposes. For any employee grade 118 and above as well as 16E and above who are not required to complete a time sheet, any worked to be tracked for a grant must be done through a time and effort log and certified to be eligible for reporting on a grant. For additional information on distribution of time and effort for federal awards, please refer to 2 CFR 200.430, Compensation - personal services.
c. Copies of all reports, budget revisions and evaluations must be sent to the Senior Budget Analyst or Budget Analyst for Capital Project Grants, which ever is applicable, when submitted to the funding agency.