Post-Award Grants Management for STCC Faculty and Staff
The STCC Grants Manual details the procedures the College follows in the management of grants. Federal grants are administered in strict adherence to OMB Circular A-110: Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations. For more information, please visit: http://www.whitehouse.gov/omb/circulars/a110/a110.html
- Posts Awards Grants Management
- Post Award Action Items
- Cost Share/Match
- Time and Effort Reporting
- Administrative Services Departmental Procedures
- Download the entire Grants Manual in PDF format
The STCC Grants Management Manual delineates the procedures the College follows in the management of grants. Federal grants are administered in strict adherence to the Federal Administrative Standards 2 CFR 215, Federal Cost Principles 2 CFR 220, and the Federal Audit Regulations A-133.
POST AWARD GRANTS MANAGEMENT
Grants Management Personnel
The Grants Manager, reporting to the Director of Grants, and the Administrative Services Financial Staff (Grant Accountants), reporting to the Senior Director of Finance & Budgets, are responsible for overseeing and reporting all grant management related activity. They work as a team to support Project Directors in accomplishing their project specific goals.
- Along with the Financial Grant Coordinator and Grant Accountant, initiates Grant Start-up Meetings with all new Project Directors
- Working with the Financial Grant Coordinator and Grant Accountant, holds regular meetings throughout the course of the grant with all Project Directors
- Monitors the activities of all funded grants
- Maintains a complete programmatic file on each grant. This information should coincide with the fiscal records of each grant maintained by the College's Administrative Services Office
- Manages grant compliance issues, such as time & effort reporting and adherence to project activities funded through grants
- Serves as the College's primary liaison between institutional Project Directors and agency program officers and prepares correspondence as necessary to solicit and secure changes in grant terms and conditions
- Coordinates with Project Directors on preparation of programmatic reports as necessary
- Engages in year-to-year planning of continuing projects in coordination with appropriate College personnel
Under the Senior Director of Finance and Budgets, two positions (Financial Grant Coordinator & Grant Accountant) are responsible for the following financial aspects of grant programs:
- Along with the Grants Manager, holds Grant Start-up Meetings with all new Project Directors, advising them on start-up of grant-funded programs including development of financial and operational policies, and procedures to ensure grant compliance
- Working with the Grants Manager, attends regular meetings throughout the course of the grant with all Project Directors
- Schedules Datatel Training for Project Directors
- Monitors all grant expenditures to ensure compliance with the grant contract
- Responsible for the fiscal integrity of all grant expenditure reports
- Provides Grants Manager and Project Directors with grant expenditure reports
- Monitors all travel
- Monitors all travel expense reports
- Responsible for all grant financial audits and reviews
- Engages in fiscal projections for continuing projects in coordination with appropriate College personnel
The Project Director maintains an effective file system, which contains, at a minimum, the following:
- A copy of the proposal and the approved budget
- Copies of all budget amendments
- Personnel paperwork including contracts and time sheet copies
- Consultant contracts, invoices, and reports
- Report forms and report copies
- Files related to grant activities, such as client records, publicity, evaluation
The average length of time required for maintaining all records related to a grant for auditing purposes is seven years from the date of closing of the grant, or until a final agency audit is completed. Project Directors should never discard paper source documents without first checking with the Grants Manager.
Direct reporting by the Project Director of any fiscal information on a grant (including matching sources) without prior coordination with the Financial Staff and/or Grants Manager is not permissible.
POST AWARD ACTION ITEMS
Award Notices & Contracts
STCC receives a grant award letter from the granting agency when it has been awarded a grant. The Director of Purchasing and Business Services maintains all contracts and awards and distributes final copies of award letters and grant contracts to Project Directors, the Grants Manager, the Senior Director of Finance and Budget, and the Financial Grant Coordinator. If the award letter states that funding will be at a lower level than requested in the original application then the Grants Manager will meet with the Project Director and the Senior Director of Finance and Budgets to determine the necessary budget revisions. Additionally, the Director of Grants will review all amended budgets during this time. The new budget along with a letter accepting the grant will be sent to the granting agency.
Grant Start Up/ Progress Meetings
The Grants Manager, Project Director, and Financial Staff will schedule a start-up meeting once the grant has been awarded. During this meeting, the grant reporting deadlines will be determined and responsibilities assigned. The Financial Staff will advise the Project Director on the Datatel budget report layout to accommodate the detail necessary to that person's grant. The required personnel paperwork for each person employed, including subcontractors, will be determined. Progress meetings will be scheduled quarterly by the Grants Manager to review spending and discuss any programmatic changes or necessary budget revisions. Project Directors will be given access to the Grants Management Manual and grant management personnel contact information.
Expenditure Reports are printed off of the Datatel System and reconciled to a customized spreadsheet. All new Project Directors will receive training on this integrated system. Project Directors should review these reports quarterly to confirm they accurately reflect line item expenditures. The Financial Staff will make any necessary changes after reviewing a request for expenditure reclassification. Project Directors should utilize budget reports to monitor spending categories and overall budget expenditures.
The Grants Manager will process budget revisions according to the granting agency's requirements and specific forms.
STCC Conflict of Interest Disclosure Policy
This policy describes circumstances where employees engaged in externally-funded research or educational activities may be subject to conflict of interest and the College's procedure for insuring compliance with the disclosure policies of public or private funding sources including, but not limited to, those of the National Science Foundation (NSF) and the Public Health Service (PHS).
In addition to the Conflict of Interest Policy, new hires receive information regarding the Whistleblower Hotline and the Fraud Prevention Policy:
Most granting agencies have strict policies regarding publicity, such as requiring credit on published materials, announcements, publicity, and programs. They may even include a logo and a credit statement to be reproduced. Requirements should be reviewed with the Grants Manager and the Public Relations Office before ordering publications or scheduling off-campus public relations events.
All staff travel expenses are pre-approved by the College administration with an online college travel requisition. A voucher for reimbursement of travel costs is prepared and paid against the pre-approved purchase order. In the event that travel associated with a project is approved from a matching budget source, the association of the trip to the specific project will be reflected in the pre-approval form as the purpose of the trip. All travel will be coordinated in accordance with the College travel policy.
Draft delineation of matching or cost-sharing budget items occurs initially during proposal development between the Grants Office and Project Director. Input from College Vice Presidents, and specifically the Vice President of Administration/CFO is sought through this process. Cost-sharing/matching includes, but is not limited to:
- The time of STCC employees assigned to work on the project for which no grant resources are derived.
- STCC costs for acquisition of equipment or supplies from allowable sources that directly impact the project's activities.
- The value of donated equipment to STCC received during the period of the grant that is used for grant-specific activities.
- Institutional space
- The fair value of consultative expertise donated to the projects by industry or academic experts.
- Time & effort of grant partners
- STCC costs for research or educational materials acquired by the College during the grant period which specifically further the objectives of the grant project.
- The travel of project staff and STCC associated staff both nationally and locally to further grant-related objectives when such costs are not borne from grant funds.
- Foregoing indirect costs
- Grant awards from other sources
It is the responsibility of the Grants Office and the Financial Office to ensure that matching/cost-sharing budget items are only apportioned once against any and all grants at the institution.
Accounting for Match and Cost-Share
The Project Director, the Grants Manager and the Financial Staff will all have copies of agreed upon matching/cost-share budgets.
Employees Release Time/In-Kind Contributions
Any STCC employee whose salary is included as a match/release on a grant must provide the Grants Manager with a certification letter semi-annually over the life of the grant for time matched/released. Certification memos will be filed in the Grants Office. The rate of salaries paid to staff as match is maintained through the Business Office as payroll records.
Equipment Donations as Match
In general, the STCC Foundation serves as the conduit for receipt of all inkind equipment donations received by STCC, including those items of equipment received as match for a grant project. An Inkind Equipment Donation form is completed by the donor and the Project Director or project staff member who has communicated with an industry partner for receipt of equipment. Value of the equipment donation is specified by the donor on the form and agreed to by the STCC Foundation. Appropriate signatures are secured specifying the proposed use and practicality of the equipment donation. Files of forms on equipment donations are maintained by the STCC Foundation. In certain circumstances, principally related to the donation of new equipment, a letter from the donor may be substituted for the Inkind Equipment Donation form.
Voluntary Industry Representation/Consultation
Grant records and files maintained by the Project Director, including calendars of meetings and events, will reflect numbers of hours of advisory board meetings by project staff and industry personnel and the extent of other professional services voluntarily rendered.
The Project Director will seek to secure information in writing from volunteers as to the fair market value of their donated time. This is sometimes a problem to secure since volunteers are often reluctant to share salary information. Absent specific documentation by the industry representative as to an hourly rate of compensation, STCC uses a rate of $50 per hour (inclusive of projected industry representative fringe benefits and travel costs) as a guideline for the budgeting and accounting of industry-donated consulting services.
Equipment Match from STCC Sources
When a grant budget specifies an equipment match from STCC sources (College purchases), the Vice President of Administration/CFO must indicate, prior to the submission of the grant proposal, approval for allocation of existing departmental budget sources to the match. In the event of proposed institutional equipment matches in excess of the associated Vice President's annual budget, discussion with the STCC President will occur to establish an administrative priority for a matching budget set-aside in agreement with the Vice President of Administration/CFO, and the associated Vice President prior to proposal submission. The Vice President of Administration/CFO accepts responsibility for managing such specially-assigned matching funds as required to meet the match requirement for equipment acquisition.
Monitoring and Reporting on Subcontractor Cost-Sharing
It is the responsibility of the Project Director to monitor and report on subcontractor's promised cost-sharing. The Project Director will require an annual cost-sharing report with accompanying documentation from all subcontractors who have agreed in writing to provide cost sharing as a component of their subcontract. Subcontractor's cost-sharing reports will be included in the Project Director's annual progress reports and final project reports. All cost-sharing commitments must be met and documented before any payments to subcontractors will be released.
The Project Director will review all invoices submitted by the sub-recipient
in order to monitor sub-recipient expenditures. Should there be questions on the
invoices, the Project Director will coordinate between the Grants Manager, the Financial
Staff, and sub-recipients as applicable to rectify the situation.
Additionally, sub-recipient monitoring will take place during formal and informal visits to the sub-recipient agency throughout the course of the year if deemed necessary by the Grants Manager, or as stipulated by the funding agency.
Reporting of Matching Funds to Agencies
Reports that specify the value and sources of match contributed via institutional or donor sources will be compiled by the Project Director only after meeting with the Financial Staff and the Grants Manager to review the accounting records attributed to the match.
Time and Effort Reporting
All grant-funded full-time employees are required to submit a time and effort certification form to the Grants Manager semi-annually.
Administrative Services Departmental Procedures
The Financial Staff is responsible for monitoring all cash balances on a monthly basis. It is their responsibility to inform the Controller and the Senior Director of Finance and Budgets as to the balance of each grant. The Financial Staff will bill the appropriate agency and be responsible for any EFT/ACH drawdown as specified by the sponsoring agency.
Assignment of Department Code
Once a grant has been awarded, the Grants Manager will notify the Financial Staff of the award. The Financial staff will assign a cost center code (referred to as the source code in the Datatel Financial Module) for the new grant. The source code and the department code will be used as a unique ID on all financial documentation, e.g., purchase requisitions, payroll, travel requests. The cost center number will be used throughout the life of the grant.
Personnel Requisitions must be approved for all new full-time employees. The Project Director will fill out the requisitions with the responsibilities to meet the guidelines of the grant. The Project Director will have all requisitions approved by his or her supervisor, along with the appropriate signatures listed on the approval form. Once completed, the Human Resources office will advertise the position (if appropriate) and the position will follow the College's hiring policies.
Personnel Requisitions must be created for all part-time employees of the College paid from grant funds. The Project Director must have all requisitions approved by his or her supervisor and subsequently by the Director of EBOC (Employee Benefits and Operations Center) for hourly rate compliance and by the Director of Purchasing and Business Services. Once approved, the requisitions will then be turned into blanket purchase orders (BPOs). They are then forwarded to EBOC to create an employee ID and unique job record in HRCMS, the State's payroll system. The employee will submit weekly time slips to the Payroll Office by Thursday, 12:00 p.m. for all grant-related work. Time slips must include the employee's name, the Grant title, and hours worked, and include the employee's signature and the supervisor's signature/approval. Grant payroll payments will be reflected in the employee's bi-weekly paycheck or direct deposit payment.
Although Deans/Department Managers may become the Contract Manager, only the President, VP of Administration/CFO, Director of Purchasing and Business Services, Senior Director of Finance and Budgets, and the Controller have been granted the authority to sign a contract.
A contract must be submitted to the Business Office for all vendor contractual agreements receiving compensation/payment from grant funds. The contract should include all forms of goods and services that will be provided (travel, hours worked, supplies, etc). After the contract is signed by the contractor, the Project Director should forward the contract to the Purchasing Department for College approval/signatory. A purchase requisition can then be created on-line through Datatel/WebAdvisor. When completing the purchase requisition, the Project Director must enter the correct source and department code assigned to the grant. This number is available once the budget has been loaded on Datatel/Webadvisor by the Financial Staff. Additionally, the purchase requisition requires the approval of the Project Director's supervisor, the Director of Purchasing and Business Services, and appropriate Vice President (if applicable). These individuals will electronically approve the requisition. Once the requisition is reviewed and approved, it will be forwarded to the Business Office Buyer. The requisition is then assigned a Purchase Order number. This Purchase Order number will be forwarded to the Project Director for inclusion on all invoices processed for that particular contract.
Contracted employees and organizations (vendors) are responsible for submitting invoices for reimbursement to the College/Grant. The invoice should be addressed to STCC and include the contractor's name, address, and applicable grant information. Additionally, the invoice should indicate the number of hours worked, the rate of pay per hour, the total amount billed and a general description of the work that was performed. The invoice must also be signed and dated.
The College's purchasing department will processes all Purchase Order requests. A Purchase Requisition must be completed and submitted electronically utilizing the College's Datatel/Webadvisor System prior to purchasing any supplies, furniture, equipment, or services for the department/grant. Completing a Purchase Requisition is not the same as ordering the item; it is the first step in the process. Upon receipt of the Purchase Requisition, the purchasing staff in Administrative Services processes a Purchase Order which is sent to the vendor to actually order the product or service. A copy of the Purchase Order, which has been assigned a unique number, is located in the Purchasing Department.
The following is needed to initiate a purchase requisition:
- Vendor Information
- Vendor Name
- Taxpayer Identification No. (Obtain from your chosen vendor. All TIN #s are verified through the IRS before becoming a vendor.)
- Contact Name
- Grant Information
- Date of request
- Department/Grant Name
- Department Code (refer to Attachment C)
- Project Director's name
- Purchase Information
- Item # (if applicable, e.g., catalog item #)
- Quantity to be ordered
- Description (be specific)
- Unit cost
- Unit x Quantity cost
- Shipping & Handling
- Total Cost
- Department Chair
- School Dean/Director
- Vice President
- Director of Purchasing and Business Services
Receipt of Goods or Services and Payment
Once an order has been received by the receiving department, it is delivered to the originator of the purchase. It is the responsibility of the department to sign the goldenrod copy stating that they have received the goods that they ordered. If the order is not correct/damaged then it is the department's responsibility to contact the vendor to get the order corrected. Signing off on the goldenrod copy is stating that the purchase is in order and that payment may be made.
If the department receives the merchandise directly, they should contact the receiving department to inform them the order is complete. The receiving department will bring the goldenrod copy to the department for the appropriate signature.
Accounts Payable will not make payments without a signature on the goldenrod copy or other confirmation of receipt and approval to pay.
Disbursements of Funds before Receiving Goods
In specific cases, Project Directors will purchase goods that require payment
before goods are received. This usually happens for subscriptions, memberships,
conferences, etc. When this is required, the Purchase Order will state
Enclosed. The Financial Staff will verify if payment is required.
Purchasing Consortiums and Bid Thresholds
The College has access to purchasing contracts negotiated by the MA Department of Procurement and General Services and by the Massachusetts Higher Education Consortium. These contracts often offer the least expensive and most convenient means of ordering supplies, furniture, equipment and services. Project Directors are encouraged to take advantage of these contracts. The information is available in the Purchasing Department.
Purchases Over $10,000
The State has a bid threshold of $10,000; that is, any order for goods amounting to $10,000 or more requires the solicitation of bids from three or more qualified vendors. A key exception is that goods covered by state contracts or MHEC contract can be ordered in any amount without going out to bid. The $10,000 bid threshold requires that large purchases be planned carefully.
Bid specifications must be submitted to the Purchasing Department. The Project Director must allow at least three weeks for the Purchasing Department to put the bid out on Compass. A purchase requisition may then be written for the lowest qualified bid. It is not acceptable to avoid having to go out to bid by splitting one order greater than $10,000 into several orders smaller than $10,000. The Purchasing Department can assist you in preparing bid specifications and determining a list of vendors.
- Question: Who do I contact about questions regarding my program expenditures?
- Answer: Dean Morneau, Grant Accountant at x5167
- Questions: Who do I contact about questions regarding program reporting requirements?
- Answer: Nate Leveille, Grant Manager at x5753
- Question: Who do I contact about a funding agencies rules regarding grant compliance?
- Answer: Nate Leveille, Grant Manager at x5753 or Matthew Farmer, Financial Grant Coordinator at x6306
- Question: Who do I contact about travel, purchase orders, and personnel requisitions?
- Answer: Dean Morneau, Grant Accountant x5167
- Question: Who do I contact about budget amendments?
- Answer: Nate Leveille, Grant Manager x5753