HomeMy WebLinkAbout5317 RESOLUTION NO. 5 3 1 7
A RESOLUTION OF THE CITY COUNCIL OF THE
CITY OF AUBURN, WASHINGTON, APPROVING .
AND ADOPTING THE CITY OF AUBURN GRANT
MANAGEMENT POLICY
WHEREAS, the City regularly receives federal grant awards for a variety
of purposes; and
WHEREAS, the federal Office of Management and Budget (OMB) has
issued new uniform guidance to streamline the federal grant process; and
WHEREAS, OMB's uniform guidance requires nonfederal entities to have
certain written policies and procedures to address the management of grant
award funds; and
WHEREAS, these requirements aim to reduce the risk of fraud, waste,
and abuse of federal funds.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF AUBURiV,
WASHINGTON, HEREBY RESOLVES as follows:
Section 1. That the Grant Management Poliey, as set forth in the draft.
administrative policy and procedure a copy of which is attached hereto, marked
as Exhibit "A" and incorporated herein by this reference, is approved and
adopted, and the Mayor is authorized to execute this Resolution.
Section 2. That the Mayor is authorized to implement such policy, as an
administrative policy and procedure of the City, under index number 100-25, and
the Mayor is further authorized to take such other action as may be necessary to
carry out the directives of this legislation.
Resolution No. 5317
November 16, 2017
Page 1 of 2
Section 3. That this Resolution shall take effect and be in full force
upon passage and signatures hereon.
d�
Dated and Signed this �`�day of� , 2017.
CITY OF AUBURN
ANCY B S, MAY
ATTEST:
'�..
� _ _ _-
Danielle`E. Daskam, Gity Clerk
APPROVED AS TO FO '
,,
F .
,�
� ' I . ' , City Attorney �.
Resolution No. 5317
November 16, 2017
Page 2 of 2
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cirxoF * ��.,�� * 14DIVIINISTRATI�IE
�
� POLICY AND PROCEDUI�E
� WASHII�TGTON
TITLE: SUBJECT: FINANCE
GRANT MANAGEMENT
ADMINISTRATIVE POLICY INDEXNUMBER: �OO-Z�J
EFFECTIVE DATE SUPERSEDES PAGE PREPARED BY: MAYOR'S APPROVAL
11/1/2011 1 oF 10 FINANCE
� DEPARTMENT
1.0 PURPOSE
To establish and maintain policy and internal controls that provide reasonable assurance
that Federal awards are being managed in compliance with all Federal regulations and
with the terms and conditions of the award. The City of Auburn will follow the Uniform
Guidance, the Local Agency Guidelines (LAG) distributed by the Washington State
Department of Transportation (WSDOT) for Federal Highway Administration (FHWA)
funding, and other specifie grant requirements or guidance documents published by the
Federal Granting Agency such as the United States Departmenfi of Housing and Urban
Development (HUD) and the Federal Aviation Administration (FAA) as applicable.
2.0 ORGANIZATIONS AFFECTED
AII departments/divisions receiving Federal Awards.
3�0 REFERENCES
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Awards — Title 2 Code of Federal Regulations (2 CFR 200); State and Local
guidelines will also apply based on awarding organization.
4.0 POLICY
4.1 General: This poliey describes the procedure for the administrative responsibility
of awards received as grants (or grant-like loans such as low-:interest loans
provided by the Washington State Publie Works Board). The City, through
designated staff and City officials, solicits and accepts awards from a variety of
organizations for funding City programs and projects. Awards frequently require
close coordination between different City departments and adherence to strict
guidelines and requirements. This policy outlines the procedures and
departmental roles and responsibilities to centrally coordinate and track citywide
efforts in grant management and administration.
4.1.1 The Department that is requesting and/or administering the grant award
shall be responsible for maintaining accurate and current information and
complying with the general and specific guidelines and requirements of the
grant award. This will include:
� o being knowledgeable of grant award requirements,
• ensuring the City complies with said requirements,
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ADMINISTRATIVE GRANT MANAGEMENT PAGE
POLICY AND PROCEDURE ADMINISTRATIVE POLICY 10D-25 2 OF 10
e providing accurate information to the Finance Department in the
preparation of reports and requests for reimbursement of eligible
costs, and
• maintaining the proper written and electronic documentation and
financial records consistent with said requirements.
4.1,2 In the event more than one Department is involved in requesting or
administering a grant award, fhe Departments involved will agree upon a
designated lead Department. The lead Department will have overall
responsibilities for administering the grant award consistent with this policy.
4.2 Internal Controls: The City of Auburn will maintain effective internal control over
the Federal Award providing reasonable assurance that the City is managing the
Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award.
4.2.1 The City will take prompt action when instances of noncompliance are I',
identified including noncompliance identified in audit findings.
4.2.2 The City will take reasonable measures to safeguard protected personally
identifiable information and other information the Federal awarding agency
or pass-through entity designates as sensitive.
4.2.3 The City will follow the process workflow outlined in section 6.1.
4.3 Certification: To assure that expenditures are proper and in accordance with the
terms and conditions of the Federal award and approved project budgets, the
annual and final fiscal reports or vouchers requesting payment under the
agreements must include a certification, signed by an official who is authorized to '
legally bind the non-Federal enfity, which reads as follows: "By signing this report,
I certify to the best of my knowledge and belief that the report is true, complete,
and accurate, and the expenditures, disbursements and cash receipts are for the
purposes and objectives set forth in the terms and conditions of the Federal award.
I am aware that any false, fictitious, or fraudulent information, or the omission of
any material fact, may subject me to criminal, civil or administrafive penalties for
fraud, false statements, false claims or otherwise."
4.4 Advance_Pavmerifs and Reimbursements: Payment mefhods must minimize the
t"ime elapsing between t�ansfer of funds from the United States Treasury or the
pass-through entity and the disbursement by the City of Auburn whether the
payment is made by electronic transfer, or issuance or redemption of checks, �
warrants, or payment by other means.
4.4.1 Advanced payments must be limited to the minimum amounts needed and
be timed to be in accordance with the actual, immediate cash needs of the
City to carry out the purpose of the approved program or project, Any
advanced payments must be consolidated to cover anticipated cash needs.
4.4.2 The City shall minimize the time elapsed befinreen receipt of federal aid
funds and subsequent payment of incurred costs.
4.5 Allowable Costs: Federal awards will meet the following general criteria in order
to be allowable except where otherwise authorized by statute.
TITLEt INDEX NO:
ADMINISTRATIVE GRANT MANAGEMENT PAGE
Poucvari�PRocE�uRE ADMINISTRATIVE POLICY 100-25 3 OF 10
4.5,1 Be necessary and reasonable for the performance of the Federal award.
4.5.2 Conform to any limitations or exclusions set forth in these principles or in
the Federal award as to types or amount of cost items.
4.5.3 Be consistent with policies and procedures that apply uniformly to both
Federally-financed and other activities of the City.
4.5.4 Be accorded consistent treatment. A cost may not be assigned to a Federal
award as a direct cost if any other cost incurred for the same purpose in like
circumstances has been allocated to the Federal award as an indirect cost.
4.5.5 Be determined in accordance with generally accepted accounting principles
(GAAP).
4.5.6 Not be included as cost or used to meet cost sharing or matching
requirements of any other Federally-financed program in either the current
or a prior period.
4.5.7 Be adequately documented.
4.6 Procurement: When procuring goods and services under a Federal award, the
City will follow 2 CFR§200.318 General Procurement Standards through §20D.326.
Contract Provisions or City of Auburn purchasing procedures (Auburn City Code
Chapters 3.10, 3.12, and 3.14), whichever is more restrictive.
4.6.1 Contracts for more than the simplified acquisition threshold currently set at
$150,000 must address administrative, contractual, or legal remedies in
instances where contractors violate or breach contract terms, and provide
for such sanctions and penalties as appropriate.
4.6.2 Contracts and sub-grants of amounts in excess of$150,000.00 requires fhat
the City will comply with all applicable standards, orders or cegulations
issued pursuant to the Clean Air Act and the Federal Water Pollution Control
Act.
4.6.3 The City will monitor procurements to avoid duplicative purchases. The City
will continue to enter into inter-entity agreements to realize cost savings for
shared goods and services when possible.
4.6.4 The Gity will verify and document that vendors are not suspended or
debarred from doing business with the Federal government.
4,7 Single Audit Act: The City, as a recipient of Federal funds, shall adhere to the
Federal regulations outlined in 2 CFR §200:501 as well as all Federal and State
statutes and regulations.
4.8 Glosure: A project agreement end date will be established in accordance with 2
CFR §200.309. Any cost incurred after the project agreement end date ace not
eligible for Federal reimbursement.
_ . __
4:9 Code of Conduct: The purpose of the Code of Conduct is to ensure the efficient;
fair and professional administration of federal grant funds in compliance with 2
CFR §200.112,2 CFR§200.318 and other applicable federal and state standards,
regulations, and laws.
TITLE: INDEX NO:
ADMINISTRATIVE GRANT MANAGEMENT PAGE
POLICYANDPROCEDURE qDMINISTRATIVE POLICY 100-25 4 OF 10
4.9:1 The Code of Conduct appiies to all elected officials, employees or agents
of the City engaged in the award or adminisfration of contracts supported
by federal. grant funds.
4.9.2 No elected official, employee or agent of the City shall participate in the
selection, award or administration of a contract supported by federal grant
funds if a eonflict of interest, real or apparent, would be involved. Such a
conflict would arise when any of the following has a financial or other
interest in the firm selected for award:
o The City employee, elected official, or agent; or
m Any member of their immediate family; or
s Their partner; or
• An organization which employs, or is about to employ any of the
above.
4.9.3 The City of Auburn's elected officials, employees or agents shall neither
solicit nor accept gratuities, favors, or anything of monetary value from
contractors, potential contractors or subcontractors.
4.9.4 To the extent permitted by federal, state or local laws or regulations,
violation of these standards may cause penalties, sanctions or other
disciplinary actions to be taken against the City's elected officials,
employees or agents, or the contractors, potential contcactors,
subcontractors or their agents. Any potential conflict of interest will be
disclosed in writing to the Federal awarding agency or pass-through entity
in accordance with applicable Federal awarding agency policy.
5.0 PROCEDURES
The purpose of these procedures is to ensure inter-departmental coordination in the
identification of grant opportunities, to ensure consistency in the management of grants
the City receives, and oversight in management and compliance with the guidelines and
restrictions as required by the grantor.
5.1 Grant Application
5.1.1 Request to Applv. Prior to submitting an application for an award, the
Department pursuing the grant award shall obtain the required approval
signatures (i.e. Department Director, Mayor).
5.1.2 Legal Review. If necessary, the responsible Department will review the
grant and grant appiication wi#h the City's Legal Department to identify any
potential legal issues that the City should be aware of.
5.1.3 Submittal of Award Application. Once approval or direetion is received to
pursue the award, the !Department charged with the responsibility for
implementing the award will prepare the necessary application paperwork
and, if necessary, seek approval of the City Council.
5:2 Grant Award, Obliqation and Manaaemenf
TITLE: INDEX NO:
ADMINISTRATIVE GRANT MANAGEMENT PA�E
POLICYANDPROCEDURE ADMINISTRATIVE POLICY 100-25 5 OF 10
5.2.1 Award Review and Acceptance. Once the award is received, the
responsible Department will accept the award only if the grantor's terms and
conditions can be satisfactorily met by the City. Administrative and
Legislative acceptance of an award will be subject to the following
limitations:
o Department Directors may approve awards up to and including
$10,000.00.
o Mayoral approval is required for awards befinreen $10,001.00 up
to and including $50,000.00.
• Council approval is required for awards of$50,001.00 and up.
5.3 Project Number. The responsible Department will requestthe Finance Department
establish a project number. The purpose of the project number is to enable the
accurate accounting of revenues and expenses related to the project. No project
can be started or executed without a project number.
5.4 Reportinq. The responsible Department will serve as the single point of contact
with the grantor and will be responsible for the preparation and submittal of reports
to the grantor and for complying with the guidelines and requirements of the award.
The responsible Department will maintain a detailed project folder that will contain,
at a minimum, all official correspondence concerning the award ineluding City
memoranda, resolutions or ordinances; award letter; grantor guidelines and
restrictions; written communications befinreen the City and the grantor including
copies of emails and any other documents necessary for the effective
management of the award.
5.4.1 The Finance Department will be the responsible department in preparing
the necessary financial information for reimbursements and any reports that
are necessary for reimbursements.
5.5 Matches—Citv budget identified. Some awards prescribe a matching requirement
in which the City must provide a financial match to qualify for the award. In the
event of a required match, the responsible Department will work with the Finance
Department to ensure sufficient budget is identified, and if necessary, to request a
budget amendment.
5.6 Award Compliance - Issues. Periodically, compliance issues associated with
award guidelines and conditions may occur. The Department charged with
administering the award will be responsible for keeping the Mayor and Finance
Department informed of any award compliance issues and resolution undertaken
to address the issue. Resolution will be documented in the Gity's grant award files.
5.7 Loans. Loans represent a strategic means for the City to leverage its limited cash
resources to fund programs and projects. However, as a loan represents a liability
that must be repaid by the City, the responsible Department will coordinate with
the Finance Department to ensure sufficient resources are available to repay the
loan. If necessary, a budget amendment will be prepared to appropriate resources
to repay the loan.
_ .
TITLE: INDEX NO:
ADMINISTRATIVE GRANT MANAGEMENT PAGE
POLICYANDPROCEDURE ADMINISTRATIVE POLICY 100-25 6 OF 10
6.0. Process Flow Chart
Figure 6.1 generally describes the process under which awards will be tracked.
� TITLE: � INDEX N0:
ADMINISTRATIVE GRANT MANAGEMENT' P"�E
POLICY AND PROCEDURE ADMIN'ISTRATIVE POLICY 100-25 7 OF 10
Figure 6.1: Process Flow Diagram
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TITLE: ' INDEX NO;
annniNisTRATive GRANT'MANAGEMENT PA�E
POLICYANDPROCEDURE ADMINISTRATIVE POUCY 100-25 8 OF 10
Figure 6.1: Process Flow Diagram (continued)
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TITLE: INDEX NO: pAGE
npnniNisTRnTive GRANT MANAGEMENT
POLICYANDPROCEDURE ADMINISTRATIVE POLICY 100-25 9 OF 1.0
7.0. Glossary
The following is a summary of key references and terms used in this policy.
References
Title 2 of the Code of Federal Regulations (2 CFR 200). Developed by the Office of
Management and Budget (OMB), this guidance establishes uniform administrative
requirements, cost prineiples, and audit requirements for federal awards. The
requirements aim to reduce the risk of fraud,waste, and abuse of federal funds and places
heavy emphasis on written pol.icies and procedures. The focus of fhese polieies and
procedures should be to ensure that those in the organization who earcy out the_objectives
of the award understand:
• The federal statutes, regulations, and terms and conditions of the award
• How to evaluate and properly monitor compliance
o The steps to take if non-compliance is identified
For further information, refer to:
https://www.gpo.gov/fdsys/pkg/CFR-2017-title2-vol1/pdf/CFR-2017-title2-vol1-
part200.pdf
Specific state and local regulafions may also apply. These regulations can vary based.
upon the unique conditions and circumstances of each grant award. City staff should
take due care in determining the speci�c sta#e and local applicable regulations that apply
to their respective project and to appropciately document, understand, and comply with
the conditions and restrictions within these regulations.
Terms ,
Award —An award refers to financial resources provided to the City in the form of a loan,
grant or contract from a federal, state, regional or local government or private for-profit or
non-profit entity.
Award Compliance — This term refers to the general and specific requirements and
provisions that must be satisfactorily met by the City and demonstrated to the awarding
agency. Fulfilling the award requirements as provided by the awarding agency is
important as variances thereto can become subject to an audit finding.
Department — This term refers to any, singular or in combination, of the City's operating
Departments.
TITLE: INDEX NO:
AOMINISTRATIVE GRANT MANAGEMENT PAGE
POLICY AND PROCEDURE ADMINISTRATIVE POLICY 100-25 10 OF 10
Finance Department—This term refers to the City's Finance Department,
General_and Specific Audit Requirements— General audit requirements refers to federal,
_ - - _
state and local audit compliance requirements. Speeific audit requirements typically are
specific to individual awards and can va.ry in complexity based upon the awarding agency.
The responsible department should take due care to carefully review and comply with the
general and specific requirements of the award in question.
Program or Project — This term refers to the Cify operating program or capital facilities
project that is supported by the award.
Responsible Department — This term refers to the City operating department that is �
designated as the lead City department responsible for managing the program or project
funded by the award.