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• Shows receipt of funds and costs/expenditures by source (e.g., federal, state, or local), • Match funds and related costs/expenditures are identified in accounting records (i .e. , general ledger) and reported on the Financial Invoice (BSCC Form 201 ), • Ensures all BSCC income and expenditures are separately identifiable from non-BSCC grant funds,
• Provides accurate and current financial reporting information, • Maintains an accurate accounting of all grant funds; and • Ensures a documented accounting methodology if grant funds are commingled (blended) in a single account. This methodology must distinguish/track each funding stream within the commingled account. Grantees may elect to open separate bank accounts to track grant funds; however, it is not required.
Grantees are responsible for maintaining source documentation (electronic and/or hard copy) and current accounting records that support all grant and/or match expenditures invoiced and paid to the grant program.
Financial institutions used for the deposit of grant funds must be insured by the Federal Deposit Insurance Corporation (FDIC).
B. ACCOUNTING SYSTEM BASIS
Accounting systems for BSCC grants may be on a cash, accrual, or modified accrual basis.
NOTE: Financial Invoice (BSCC Form 201) payment requests should be made only on a cash basis.
1. Cash Basis
Under a cash basis system, revenue is not recognized when it is earned, but rather only when the payment is received. Similarly, costs are recognized when they are paid, not when they are incurred.
2. Accrual Basis
Accrual basis revenue is recognized when the transaction occurs, regardless of when cash is collected or paid. Costs/expenditures are recognized and matched with the revenue of the period to which it relates, regardless of when it is paid.
3. Modified Accrual Basis
Modified accrual basis is a compromise between the cash and accrual systems used by most governmental units. Revenues are recognized either when they are received in cash (e.g., licenses or fines) or when collection of the amounts can be reasonably estimated to be received in the near future (e.g., property taxes). Costs are generally recognized jn the period in which goods and services are received or a liability is incurred.
C. SEPARATION OF DUTIES
The principle of separation of duties is based on shared responsibilities of a key process that disperses the critical functions of that process to more than one person or department. Adequate separation of duties helps reduce risk of theft or mismanagement of grant funds.
Adequate internal control provides that no one person may perform more than one of the following types of duties:
• Receiving and depositing cash receipts,
• Authorizing cash disbursements,
• Preparing checks,
BSCC Grant Administration Guide Page 50 July 2023
Docusign Envelope ID: 27D67330-B342-8F8E-8072-C93CFCD77C05 • Attaching electronic signatures or operate a check-signing machine*, • Comparing machine-signed checks with authorizations and supporting documents (or signing checks manually after personally comparing them with authorizations and supporting documents*,
• Preparing or initiating invoices; or
• Reconciling bank statements and positing to the general ledger.
If the size of the organization does not allow for separation of duties, Grantees must establish other procedures to mitigate that weakness.
*This individual should not have access to, or the control of, blank checks.
D. GENERAL LEDGER ACCOUNT STRUCTURE
Costs/expenditures of grant funds must be recorded in categories which parallel the Grant Award .
All general ledger account entries must be supported by the secondary records and original source documentation. The format of the secondary records is determined by the Grantee.
Grantees must be able to show with documentation (i.e., work sheet) that general ledger entries can be traced (reconciled) to the Financial Invoice (BSCC Form 201 ).
12. MATCH/ LEVERAGE REQUIREMENTS -------·· ··--... ---- ·-· ·- --- Matching is cost sharing. Specifically, it means the portion of a grant project's costs not covered by the awarded grant or same funding source. There are many types of match requirements, which vary across different agencies and grant awards. The required match is specified in the terms of the grant's RFP and Grant Agreement. Grantees are responsible for reading and understanding the specific, applicable match requirement. Match can also be referenced as leveraged funds.
A. CASH MATCH
Cash match, also known as hard match, is income from a source other than grant funds that is budgeted for the project by the Grantee. When used to augment the project, cash expenditures for items such as personnel, facilities, and supplies may be considered cash match, if not in violation of the prohibition on supplanting. Grantees must maintain documentation to support the claimed cash match.
8. IN-KIND MATCH
In-kind match, also known as soft match, is the project's contribution of non-cash outlay of materials or resources to support a percentage of the BSCC's Grant Award activities. It may include non-cash outlay contributed by other public agencies and institutions, private organizations, and individuals. Examples include donated office supplies, equipment, professional services, and volunteer time. In general, the value of in-kind contributions is determined by fair market value. Grantees must maintain documentation to support the claimed in-kind match.
When the terms of the grant's RFP and Grant Agreement allow for the use of volunteer services as in-kind contributions, additional measures should be followed to document the value of such services. Grantees should document actual time worked by using a time reporting system such as sign-in and sign-out sheets which are completed by the volunteer and contain the signed approval by the supervisor.
Another method is to use the volunteer staff schedule. Volunteer staff initial and indicate the days/hours worked and the supervisor signs and dates the schedules to indicate approval.
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Grantees must maintain documentation to support the claimed hourly salary rate of the volunteer services. The rate claimed should be comparable to the rates for paid employees performing similar duties. Published rates will not be allowed unless Grantees can provide evidence that the rates are comparable.
The documentation should include duty statements for the volunteer positions and the comparable paid employee positions and information regarding the hourly salary rates paid to those particular employees. The hourly volunteer rates used, multiplied by the volunteer hours worked must total the dollar amount of the in-kind contributions. This calculation and the other referenced documentation should be maintained as part of the accounting records.
C. MATCH DOCUMENTATION
The BSCC requires Grantees to adequately document that their projects have provided and properly valued their matching contributions the same way Grantees must document their use of grant funds.
D. MATCH CATEGORIES (ALLOWABLE/ NON-ALLOWABLE)
1. Asset Forfeitures
Assets from federal or state forfeiture proceedings are an allowable match if permitted by the terms of the grant's RFP and Grant Agreement.
2. Matching State/Federal Funds with State/Federal Funds State and/or federal funds can be used to match other state and/or federal funds only if all of the following conditions have been met:
• The project obtains written approval from BSCC, or the terms of the program allow this practice;
• The federal funding source does not prohibit this practice as stated in 2 CFR § 200.306; and
• The funds are to be used for grant activities and be necessary for the project's overall outcomes.
E. OVER MATCH
Unless otherwise specified, Grantees should not commit to a match percentage greater than the match percentage required in the RFP. After a Grantee's proposed budget is approved, it becomes part of the Grant Agreement and as such is subject to all programmatic requirements, restrictions, and audit requirements. After the Grant Agreement is executed, the committed match percentage cannot be reduced.
F. TERMINATION OF THE GRANT AGREEMENT
If the Grantee fails to meet the match requirement or the amount committed by the Grantee for the grant, BSCC may withhold grant funds and/or terminate the Grant Award. Please see BSCC Grant Administration Guide - Section 19. Withholding or Disallowance of Grant Funds.
G. CALCULATING THE MATCH REQUIREMENT
The Match Requirement is calculated by two methods. The amount may be based either on the total project cost or on the percent of grant funds allocated to the project. The terms of the program or its authorizing legislation will specify which method will be used. If this is not the case, the match must be calculated using the total project cost method.
1. Match Based on Total Project Cost
To calculate the match requirement, subtract the required match percent from 100 percent ( 100% ), divide the Grant Award amount by this difference to determine the total project cost, BSCC Grant Administration Guide Page 52 July 2023
Docusign Envelope ID: 27D67330-B342-8F8E-8072-C93CFCD77C05 and then subtract the Grant Award amount (the BSCC allocation) to determine the match amount. The following example below demonstrates how to calculate the amount of a ten percent match (10%) on a $50,000 allocation , based on Total Project Cost.
Example 1
Grant Award Amount =
Divide $50,000 by .9 (100 minus 10 = 90) =
Subtract Grant Award Amount
Required Match
=
=
$50,000
$55,555 (Total Project Cost)
$50,000 (90%)
$5,555 (10%)
2. Match Based on Percent of Funds Allocated
To calculate the match requirement, multiply the Grant Award amount (the BSCC allocation) by the required match percent. The example below demonstrates how to calculate the amount of a ten percent (10%) match on a $50,000 allocation, based on percent of funds allocated.
Example 2
Grant Award Amount
Percent of Cash Match
Multiply $50,000 by .10
=
=
=
$50,000
10%
$5,000 (Amount of match)
H. CHANGING THE TYPE OF MATCH
If the terms of the grant program allow for different types of match to be used, Grantees are allowed to change the type of match or leveraged funds included in the Grant Agreement once the grant budget has been approved. However, a Grantee must request the change by submitting the following forms to the BSCC:
• A completed Modification Request (BSCC Form 223.1) indicating any applicable changes in the budget categories and a written narrative describing the changes to the type of match and justification for the changes . Revised RFP budget pages may also be required.
Note: Match amounts must be separately identified on the budget pages.
I. REPORTING
Reporting of expenditure of match contributions need not be made in exact proportion to the expenditure of grant funds . However, the full match contribution must be committed on Grantee invoices before the grant expires or is terminated in order to receive all funds expended.
Cash and in-kind amounts must be reported on the Grantee Invoice (BSCC Form 201 ), as the contributions to the project occur. The percentage of match contributions reported may vary from the budgeted match percentage. If the Grantee does not contribute the required or committed match by the end of the grant, the BSCC will invoice or withhold the Grantee for grant funds paid prior to the Grantee not meeting their match obligation.
Match Funds and related contributions reported on the Grantee Invoice must be identified in the accounting records (e.g., general ledger).
Example 3 below demonstrates how the Grantee would be invoiced, or payment withheld , on the Grantee's final invoice if the Grantee did not contribute the required match by the end of the grant.
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Example 3
Budgeted Grant Funds $500,000 Actual Grant Expenditures $425,000 at end of Grant Cycle Match Requirement x10% Match Requirement x10%
Required Match based on $50,000 Required Match based on $42,500 Budgeted Grant Funds Actual Expenditures Actual Match Reported $38,000 at end of Grant Cycle
Maximum Grant Funds Allowable
based on Actual Match Reported $380,000
($38,000 I 10% required match)
Amount to be Withheld or Returned to BSCC =
Actual Grant Expenditures minus Maximum Grant Funds Allowable $45,000 or $425,000 - $380,000
J. REPORTING MATCH CONTRIBUTIONS FOR ADVANCED PAYMENT GRANTS For grants that use the advanced payment option as outlined in the RFP, all Grantee obligations, including match, should be met prior to the release of any subsequent advance payments.
13. PROJECT AND OTHER INCOME
Project Income Generated by the Use of State and/or Federal Funds: Any income you make from your award is considered project income. You can use project income to advance your program objectives or refund the income back to BSCC. Project income must be reported on the Financial Invoice (BSCC Form 201) in the box titled Project Income.
Types of project income may include the following :
• Client fees;
• Interest earned on advance payment of grant funds;
• Interest earned on generated income;
• Registration fees;
• Sale of publications, videos, and other project-generated materials; and • Asset seizures and forfeitures.
However, donations should not be considered project income. Grant funds cannot be used for organized fundraising.
Project income cannot be used to satisfy the match requirement unless specifically allowed in the terms of the program.
A. RECORDS OF RECEIPT AND DISPOSITION OF PROJECT INCOME Records of receipt and disposition of project income must be maintained in the same manner as required for grant funds. When project income is reported on the Financial Invoice (BSCC Form 201 ), the grantee must then provide an explanation on the Modification Request (BSCC Form 223.1 located within the Invoice Workbook). The grantee will indicate how the income was earned and propose how it will be reallocated. If the proposal later changes, a separate modification request must be submitted. Unless additional restrictions on the disposition of project income are contained in the terms of the program, project income must be:
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Docusign Envelope ID: 27D67330-B342-8F8E-8072-C93CFCD77C05 • Used by the project for a purpose that furthers the objectives of the project for which the grant was made, such as expanding the project, continuing the project, and obtaining equipment or other assets needed for the project; or
• Returned to BSCC.
8. INCOME EARNED BUT NOT USED DURING THE PROJECT
Unless otherwise stipulated in the award, any project income earned during the performance period but not used for the project must be refunded to the BSCC. The proportion that is refunded pertains to the ratio of federal/state funds participation as funded in the project. For example, if seventy-five percent (75%) of the grant is federal/state funds and the other twenty-five percent (25%) is from the Grantee, then seventy-five percent (75%) of the project income left at the end of the grant cycle must be refunded to BSCC and the Grantee retains the other twenty-five percent (25%). The BSCC will refund the project income to the appropriate state/federal agencies.
C. INTEREST INCOME
Interest income is defined as income earned on advances of grant funds . Interest income must be reported at the end of the funding year. The form and a check for the amount of interest income to be refunded should be attached to the final Invoice (BSCC Form 201 ). This does not apply to state agencies, including state institutions of higher education, state hospitals, or if otherwise specified in the terms of the program.
D. OTHER INCOME
In rare cases, a Grantee may receive a refund due to an over-estimate of the employer's contribution to the Public Employees Retirement System (PERS), and the contribution has been charged to a grant as an employee benefit cost. If the overpayment refund is received within the grant's funding cycle (even if the Grant Award period has ended), the Grantee may claim the refund as project income.
E. REQUESTING APPROVAL
Prior approval from BSCC is required for the use of project income. Grantees must submit in writing how the income was earned and how the project income will be used as directed in section A above. The program income must be used for the purposes and under the conditions of the RFP, Grant Agreement, or terms listed in the federal or state award.
14. AMENDMENTS, CHANGES, AND MODIFICATIONS
A. AMENDING THE GRANT AWARD
1. Definition of an Amendment
Amendments are changes to the Grant Agreement. Amendments are required in order to:
• Change the approved grant cycle, usually by extending the end date of the grant agreement;
• Change the Grant Award amount (increase or decrease); • Change the Grantee name;
The BSCC may require an amendment for a change not listed above. All amendments to Grant Agreements must be approved by the BSCC in writing.
2. Amending a Grant Agreement - General Requirements
July 2023
A Grant Agreement Amendment (Form Std. 213A) and all applicable attachments must be completed by the BSCC, approved by both parties, and fully executed by obtaining original
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signatures from the person designated by the Grantee's governing board and the authorized representative of the BSCC.
All amendments must be fully executed before the expiration of the grant agreement or end of the grant cycle.
If the written authorization from the governing board for the original Grant Agreement does not authorize amendments to the grant award, a new written authorization from the governing board must be obtained and made available for review upon request.
3. No-Cost Extensions
Grantees are required to complete their grant projects within the grant term listed in the Grant Agreement. If deemed necessary, no-cost extensions may be offered at the discretion of the BSCC.
A no-cost extension extends the grant cycle beyond the original project end date. As the phrase "no cost" suggests, no additional funding will be provided . The BSCC must obtain approval from its Board at a noticed board meeting before offering no-cost extensions to grantees, and all of the following conditions must apply:
• There is a programmatic need to continue the project, • There are sufficient funds remaining to cover the extended effort, and • The funding source (e.g., state budget appropriation, federal budget appropriation, and/or terms and conditions of federal grants) allows for the continued expenditure of funds.
No-cost extensions require the execution of a formal Grant Agreement Amendment (Form Std. 213A). The BSCC may also require additional documentation.
4. Amendments to Increase or Decrease the Grant Award
Increases (augmentations) or decreases to the dollar amount of an award are initiated and approved by the BSCC.
Before initiating an increase to the award amount, the BSCC will consider:
• Availability of funds; and
• Programmatic and/or State need.
Before initiating a decrease to the award amount, the BSCC will consider:
• Failure to comply with grant requirements;
• Failure to meet program objectives and/or service goals; and • Availability of funds.
Grantees will be notified by the BSCC in writing if the BSCC deems it necessary to change the grant award amount for any reason.
All increases and decreases to grant award amounts require the execution of a formal Grant Agreement Amendment (Form Std. 213A), which is initiated by the BSCC but must be signed by the Grantee. In addition:
• Grantees must submit a Budget Modification Request (BSCC Form 223.1 ). • Grantees must submit revised budget narrative pages.
• The BSCC may require additional documentation.
8. OTHER CHANGES/ MODIFICATIONS TO THE GRANT PROJECT
1. Non-Substantive Changes
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Docusign Envelope ID: 27D67330-B342-8F8E-8072-C93CFCD77C05 These are minor changes to a grant project, that do not affect the scope or objectives of a project and do not require amending the grant agreement. They may include but are not limited to:
• Modifications to the grant budget (Form 223.1 required) • Change in key personnel
• Change in project activities, that do not affect stated goals or objectives • Changes in operational agreements
• Changes to either physical or mailing address
Grantees must obtain approval from the BSCC before making any changes to their grant project. If you have questions, contact the Field Representative assigned to your grant.
2. Substantive Program Modifications
Substantive program modifications that affect the project scope, objectives, or specific program components are generally not allowed .
Substantive program modifications:
• Are not permissible for statutorily required program objectives; • Must be discussed, prior to submission, with your designated BSCC Field Representative. • Require a detailed narrative to explain why the change is necessary and what the outcome will be if the modification is not approved.
• Must be submitted to the BSCC by the Project Director. • Must show that the need to modify arose out of circumstances beyond the project's control , including but not limited to:
o Delays caused by acts of legislative or judicial bodies; o A strike which affects the performance of the project; or o Natural disasters affecting project performance.
• Must be approved by the BSCC in writing prior to the implementation of changes .
C. MODIFICATIONS TO THE GRANT BUDGET
A modification to the grant budget is any change to the approved budget that:
• Modifies narrative details within a budget line-item or category but does not change any budgeted dollar amounts.
• Modifies line-item dollar amounts by moving funds from one line-item or budget category to another but does not change the total grant award.
• Allocates earned project income to support approved, existing project activities.
With the exception of a project income allocation request, budget modifications that would cause the project to exceed the amount of the grant award identified in the Grant Agreement are not allowed .
1. Prior Approval
July 2023
All Modification Requests require prior approval from the designated BSCC Field Representative.
If prior approval is not obtained, the grant reimbursement may be reduced by the amount of the unauthorized expenditure(s). Unauthorized expenditures may also result in audit issues.
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2. Modification Request Procedures
Modification requests must be submitted on a Modification Request (BSCC Form 223.1) and approved before related expenditures are reported (or ordered, contracted for, etc.) on a Financial Invoice (BSCC Form 201 ). Revised budget narratives may be required for approval.
3. Where to find the Modification Request (BSCC Form 223.1) The Modification Request (BSCC Form 223.1) is located within the Invoice Workbook.
Grantees can locate the Invoice Workbook for their grant on the BSCC website by clicking Grantee Invoicing under Quick Links on the Corrections Planning and Grant Programs (CPGP) Division page: http://www.bscc.ca.gov/s cppgrantinvoicing/. Grant programs are listed alphabetically. Links to the Invoice Workbooks are located under each grant program heading.
4. Submitting the Modification Request (BSCC Form 223.1) Detailed instructions for completing and submitting the Modification Request (BSCC Form 223.1) are located on the Instructions worksheet within the Grantee Invoice Workbook. Note:
It is helpful to print the instruction page for reference before completing the Modification Request.
The Modification Request is set up for automated submission. a) Enabling Macros
There are functions with the invoice workbook that require the use of macros. A macro is a series of commands and/or functions, such as calculations, that are embedded within the excel file. In most cases, Excel will prompt the user to enable macros. When this prompt appears, click "enable."
Note: enabling macros for the invoice workbook will not compromise the security of the local system or the security of the agency's network. If the prompt to enable macros does not appear, contact your IT department to assist.
b) Microsoft Outlook
The submittal process relies on the configuration of Microsoft Outlook on a local computer.
If Microsoft Outlook is not available on the computer on which you are working, contact the assigned CPGP Program Analyst for technical assistance.
If you need further assistance with the modification process, including technical assistance, contact the BSCC Analyst assigned to your grant program.
15. GRANTEE PROJECT REPORTING --------------------------------------- The BSCC is committed to measuring the results of grant programs by requiring the use of evaluation mechanisms, evaluation plans, progress reports, and final program evaluations.
Due dates and specific requirements for these reporting requirements may vary by grant program and funding source. Requirements are detailed in each grant RFP/RFA and in the grant contract.
Grantee acknowledges awareness of and the responsibility to complying with reporting requirements by signing the grant award agreement.
A. GUIDING PRINCIPLES - IMPLEMENTING EVIDENCE-BASED PRACTICES (EBP)
1. EBP Basic Principles
EBP emphasizes measurable outcomes and ensures that services and resources are actually effective. EBP consists of three basic principles:
• Evidence that the intervention is likely to work, i.e., produce a desired benefit; BSCC Grant Administration Guide Page 58 July 2023
Docus ign Envelope ID: 27D67330-B342-8F8E-8072-C93CFCD77C05 • Evidence that the intervention is being carried out as intended; and • Evidence that allows an evaluation of whether the intervention worked.
2. Embedding EBP into BSCC Grant Projects
Evidence-based practices with an emphasis on data-driven decision making are to be embedded in all BSCC grant projects whenever possible.
The principles of EBP call for an evaluation of all program activities in order to measure impact, i.e. outcomes. In addition, it is the responsibility of the BSCC to:
• Verify that grant money is well spent; and
• Use grant results to add to the body of knowledge regarding what works.
More information regarding EBP can be found on the BSCC website, www.bscc.ca.gov.
8. LOCAL EVALUATION PLAN
The purpose of the Local Evaluation Plan, or outline of the final project evaluation, is to ensure programs funded by the BSCC can be evaluated. Refer to the appropriate RFP/RFA for program specific requirements . At a minimum, local evaluation plans shall:
• Clearly state project goals and objectives;
• Describe project components, program activities, and evidence-based practices that will used; • Provide information regarding process and outcome evaluations; • Describe outcome variables that will be measured; and • Describe the evaluation design or model that will be used to evaluate the effectiveness of the project component(s).
C. QUARTERLY PROGRESS REPORTS
Quarterly progress reports serve a vital function in the success of the grant program. They are necessary to:
• Document the project's progress toward meeting goals and objectives in accordance with the terms of the program;
• Provide a mechanism by which the Grantee can identify issues and need for technical assistance: and
• Provide the BSCC with updates on the process evaluation, as stated in the local evaluation plan.
Progress reporting periods and due dates are specified in the Exhibit A: Scope of Work of the program's grant contract. Failure to submit a report on time may result in the withholding or disallowance of grant payments, the reduction or termination of grant funds, and/or the denial of future grant funding .
Grantees must have the ability to collect the specified program activity data (e.g. number of participants, events, etc.) and report it to the BSCC on quarterly progress reports during the term of the grant performance period.
The report form and instructions are available to grantees on the BSCC's website.
D. LOCAL EVALUATION REPORT
The purpose of the Local Evaluation Report is to determine whether the overall program (including each project component) was effective. Final reports vary by grant program , but at a minimum will:
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• Include an Executive Summary
• Restate project goals and objectives
• Assess and document the effectiveness of the activities that were implemented within each individual project component, and as identified in the Local Evaluation Plan. • Describe the evaluation design or model, as laid out in the local evaluation plan, including process and outcome variables;
• Provide in-depth discussions of the final outcomes of the program (for each individual project component), and include a determination of the degree of effectiveness and/or ineffectiveness; and
• Provide a conclusion.
E. SOURCE DOCUMENTATION
Funded projects are required to participate in data collection and submit all required reports.
Grantees must keep accurate records as source documentation to support the information reported in the Progress Report.
Project records must be retained by the project for at least three years from the end of the grant award period. During programmatic monitoring and site visits, the BSCC will review these records for accuracy and compare that data to the progress reports submitted by the project.
Projects are to retain source documentation for progress reports on a quarterly basis, regardless of submission requirements. The progress reports provide project staff and BSCC with a formal process to document ongoing grant activities and project progress toward the achievement of stated program goals. All progress reports are reviewed by Program Specialists and retained in the project's award file at BSCC.
Review of Records: Acceptance of a grant obligates the project to allow employees and/or authorized representatives of the BSCC unrestricted access to inspect, copy, and audit all pertinent books, documents, papers, and records, including redacted confidential records.
16. AUDIT REQUIREMENTS AND AUDIT REPORTS
A. GENERAL
Audits are conducted to determine the fiscal integrity of financial transactions and reports, as well as compliance with laws, regulations, and administrative requirements .
All BSCC grantees, federal and state funded, are subject to the audit requirements set forth in their grant agreement and are subject to conditions of fiscal, program , and general administration to which grantees expressly agree upon accepting a grant award and signing a grant agreement.
Grantees that expend $750,000 or more in federal awards in a fiscal year must have a single or program specific audit. The Office of Management and Budget (0MB) Guidance for Grants & Agreements - 2 CFR §200.500 provides guidance on federal audit requirements, process and determining federal funds expended. A link is provided at the end of this section .
1. Are You Subject to a Federal Audit?
Yes, if during a state fiscal year:
1) A grantee expends $750,000 or more in federal awards - cumulative from all federalfunded sources - the grantee must have a single audit conducted for that year. 2) A grantee expends $750,000 or more in federal awards under only one federal program (excludes Research and Development) and the federal statutes, regulations, terms and BSCC Grant Administration Guide Page 60 July 2023
Docusign Envelope ID: 27D67330-B342-8F8E-8072-C93CFCD77C05 conditions do not require a financial statement audit, the grantee may elect to have a program-specific audit. (See 0MB 2 CFR Part 200 §200.507 Program Specific Audits.) No, if during a state fiscal year:
3) A grantee expends less than $750,000 in federal awards - cumulative from all federalfunded sources - the grantee is exempt from the federal audit requirements for that year. 4) Your BSCC grant agreement is funded exclusively through state funds - no Federal funds .
2. Are You Subject to a State Audit?
Refer to your Grant Agreement. You are subject to an audit for your state-funded grant award only when it is specifically set forth in the Grant Agreement.
3. Are You Subject to a BSCC Audit?
Yes, all BSCC grantees are subject to a BSCC audit as stated in the Grant Agreement. The BSCC will let you know if it requires that you submit a BSCC Audit.
4. Audits and Access to Records
The grantee agrees that the BSCC, the U.S. Federal Government, the California State Auditor, the California Department of Finance - Office of State Audits & Evaluations, the California State Controller's Office, or their designated representative(s) shall have the right to review and to copy any records and supporting documentation pertaining to the performance of the grant agreement. Grantee agrees to maintain and provide access to such records for purposes of examination and audit for a period of three (3) years from the end of the grant agreement, unless a longer period of record retention is stipulated. Grantee agrees to allow the auditor(s) access to such records during normal business hours and to allow interviews of any employees and subcontractors who might reasonably have information related to such records .
8. ADDITIONAL INFORMATION FOR FEDERAL AUDIT REQUIREMENTS
1. Audit Periods and Grant Cycles
The audit period is the period of time examined in the single or program specific audit. For most BSCC grants, the audit period is the state fiscal year, July 1 through June 30. For a multi-year grant, an audit is required for each grant year or performance period.
The grant cycle may differ from the audit period. For example, a grant may run in a calendar year while the single audit cycle runs on a fiscal year. The table below illustrates all audit reports and due dates for a two-year grant that runs calendar year.
Grant Cycle January 1, 2020 through December 31, 2022
Date Range Applicable Single Audit Reports (SAR) Due to SCO Due to BSCC 1/1/20 - 6/30/20 SAR 1 Year Ended June 30 , 2020 3/31/21 4/30/21 7/1/20 - 6/30/21 SAR2 Year Ended June 30, 2021 3/31/22 4/30/22 7/1/21 - 6/30/22 SAR 3 Year Ended June 30, 2022 3/31/23 4/30/23 7/1/22 - 12/31/22 SAR4 Year Ended June 30, 2023 3/31/24 4/30/24
2. Audit Costs
July 2023
The costs of audits required by, and performed in accordance with , the Single Audit Act are allowable. If the costs are not already included in a grantee's indirect cost rate, then the cost should be prorated and charged to the grant as an administrative cost based on the ratio of all of the grantee's federal grants that are being audited for that same SAR.
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Unless otherwise set forth in the grant agreement, grantees who are exempt from federal audit threshold requirement may not charge audit costs to the grant.
3. Submission of the Federal Audit Report
Local government grantees: Independent auditors prepare and file Single Audit reports on behalf of local governments to the California State Controller's Office (SCO) according to the State Administrative Manual (SAM) Section - 20070.
Got to https://www.sco.ca.gov/aud single audits.html for more information on submission requirements to SCO.
Non-governmental and Community Based Organization grantees: Grantees who meet the Single Audit threshold are required to submit Single Audit Reporting package on line to the Federal Audit Clearinghouse (FAC). To review the FAC submission requirements please visit:
https://harvester.census.gov/facweb/.
Due to BSCC: Generally, grantees must provide electronic copies of audit reports to the BSCC within 30 days of the grantee's receipt of the audit report or by the due date listed in the grant agreement.
Failure to submit an audit: A grantee that willfully fails to submit an audit as required may be deemed ineligible for future BSCC grant funds pending compliance with the audit requirements of the grant in question.
4. Grantee Responsibility for Subcontractors' Audit Requirements When grantees make subawards to subcontractors:
1) the grantee is responsible for making sure that subcontractors comply with all audit requirements per 2 CFR §200.331 (f).
2) If the subcontractor's agreement does not require an audit, or meet the Federal threshold, the grantee is still responsible for monitoring the subcontractor's activities to provide reasonable assurance that the subcontractor administers the Federal awards in compliance with the Federal conditions .
5. BSCC Audit Review - Findings and Resolution
1) When an audit is required, BSCC staff reviews the audit report only for findings pertaining directly to the federal grant programs that the BSCC administers. 2) If there are no findings related to BSCC funded programs noted in the audit report, the official grant file is noted as compliant with the audit submission requirements for that year. 3) If findings are identified, the designated BSCC Field Representative will follow up with the grantee to determine an appropriate action plan to resolve any issues. 4) Upon resolution, the official grant file is noted as compliant with the audit submission requirements for that year.
6. State Controller's Office Audit Findings and Resolution The State Controller's Office (SCO):
• Follows up on general findings such as those relating to internal controls. • Reviews and monitors the audit reports issued by external independent auditors and determines whether or not the audit reports conform to Government Auditing Standards. • Distributes copies of audit report and corrective action plan to state entities affected by audit findings .
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Go to https://www.sco.ca.gov/aud audit finding follow up.html for more information on SCO's audit follow up process.
7. The Single Audit/ Program Specific Audit Process
The audit process encompasses:
• The examination of a grantee's financial records and statements; • Federal award transactions and expenditures;
• The general management of the grantee's operations;
• The systems of internal control; and
• The financial assistance agreement received during the audit period.
An audit-reporting package includes:
• Financial statements
• A schedule of expenditure of federal funds,
• Auditor reports,
• A schedule of findings and questioned costs, and
• A corrective action plan, if applicable.
8. Scope of Audit
The Single Audit is divided into two areas: compliance and financial. The compliance component of the Single Audit covers the study and understanding (planning stage) as well as the testing and evaluation (examination stage) of the grantee with respect to Federal award usage, operations, and compliance with laws and regulations. In the financial component of the audit, the auditor must determine whether the financial statements of the auditee are presented fairly in all material respects and in accordance with generally accepted accounting principles. See Section 2 CFR §200.514.
All audits performed shall be made by an independent auditor (i.e., qualified state or local government auditors or an independent public accountant licensed by the State of California).
When obtaining audit services, the objective is to obtain high-quality audits as defined in Section 2 CFR §200.509.
9. Audit Standards
The independent auditor must conduct the audit in accordance with the requirements in 2 CFR Part 200, Subpart F, the Generally Accepted Auditing Standards (GAGAS), and in 2 CRF §200.Appendix XI-Compliance Supplement.
10. Audit Objectives
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The audit objective is to review the grantee's accountability of funds and required non-Federal contributions to determine whether the grantee has done all of the following:
• Established an accounting system with adequate internal controls that provide full accountability for revenues, expenditures, assets, and liabilities; • Prepared financial statements which are presented fairly and in accordance with generally accepted accounting principles (GAAP);
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• Submitted financial reports (Federal Financial Reports, cash reports, and claims for advances and reimbursements) that contain accurate and reliable financial data and are presented in accordance with the terms of applicable agreements; and, • Expended Federal funds in accordance with the terms of grant agreements and those provisions of Federal law or regulations that could have a material effect on the financial statements or on the awards tested.
11. Audit Resources
Office of Management and Budget (0MB) Uniform Guidance Title 2, Code of Federal Regulations , Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F - Audit Requirements is available at http://www.ecfr.gov
Department of Justice - December 2017 Financial Grant Guide Section 3.19 Audit Requirements is available at: https://ojp.gov/financialguide/doj/index.htm Governmental Auditing Standards Board (GASB) Codification of Governmental Accounting and Financial Reporting Standards is available at: https://www.gasb.org.
Generally Accepted Government Auditing Standards (GAGAS) - Yellow Book that provides a framework for conducting high quality audits. It is used by auditors of governmental entities and entities that receive government awards. The Yellow Book is available at:
https://www.gao.gov/yellowbook.
Standards for Internal Controls in the Federal Government also known as the Green Book sets standards for an effective internal control system for federal agencies. The Green Book is available at: https://www.gao.gov/greenbook.
State Administrative Manual (SAM) - Department of Finance, Sections 20000-20090 Auditing of State Agencies. The full manual is available at: http://sam.dgs.ca.gov/.
State Controller's Office - Single Audits - Local Agencies. This website contains information pertaining to single audit submissions and guidelines for audits of local government agencies and is available at: https://www.sco.ca.gov/aud single audits.html State Controller's Office - Information on 2015 Internal Control Guidelines - California Local Agencies. This guide is to assist local agencies to develop internal control guidelines to safeguard assets and prevent and detect financial errors and fraud. This guide is available at: https://www.sco.ca.gov/pubs guides.html.
State Controller's Office - Accounting Standards and Procedures for Counties (ASP) - March 2013 Edition. This manual is to ensure conformance to generally accepted accounting principles and to facilitate comparison and analysis of county financial reports on a statewide basis by minimizing differences between counties' philosophies, methods, and terminologies.
This manual is available at: https://www.sco.ca.gov/pubs guides.html.
American Institute of Certified Public Accountants (AICPA) - The AICPA sets ethical standards for the profession and U.S. auditing standards for private companies, nonprofit organizations, federal, state and local governments. More information is available at:
https://www.aicpa.org.
Financial Accounting Standards Board (FASB) the Financial Accounting Standards Board (FASB) is the independent, private-sector, not-for-profit organization that establishes financial accounting and reporting standards for public and private companies and not-for-profit organizations that follow Generally Accepted Accounting Principles (GAAP). More information is available at: http://fasb.org/.
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17. GRANTEE MONITORING AND OVERSIGHT
The Board of State and Community Corrections (BSCC) Corrections Planning and Grant Programs (CPGP) Division provides a variety of oversight activities in grant administration in an effort to fulfill the administrative, fiduciary and programmatic contractual obligations and mandates of each grant funding stream, both federal and state monies. These activities include:
• Comprehensive Monitoring Visit (CMV)
• Initial Monitoring Visit
• Technical Assistance Monitoring Visit
• Compliance Improvement Plan (CIP) Follow-up Monitoring Visit • Closeout Monitoring Visit
• Special Event - Monitoring
A. COMPREHENSIVE MONITORING VISIT
Purpose
A Comprehensive Monitoring Visit (CMV) is an on-site assessment of the administrative, fiscal , and programmatic components of a BSCC-funded project. The resulting Comprehensive Monitoring Visit Report (CMVR) provides a detailed review of the project and identifies, in limited scope, areas in which the project is and is not in compliance with the terms of the program, laws, and regulations. Each grant project will receive a CMV at least once during the applicable grant cycle.
1. Comprehensive Monitoring Visit Procedures
BSCC staff will contact the Project Director to set a mutually agreeable date for the CMV. A letter and/or email to the Project Director and Financial Officer will follow to confirm the CMV of the grant and time period to be monitored, and to document the agreed upon date of the monitoring visit. The individual(s) responsible for preparing the Invoice (BSCC Form 201), the progress report, and the oversight of grant-related activity should be available during the monitoring visit to answer questions.
The CMVR template and general monitoring expectations will be provided to the Grantee prior to the monitoring visit to assist the Grantee prepare.
The BSCC will review findings with the Grantee during the course of the monitoring, as well as at the end of the visit during an exit interview.
Exceptions to these standard procedures may occur on a case-by-case basis per assigned lead BSCC Field Representative.
2. Comprehensive Monitoring Visit Requirements and Access to Records Projects are monitored for compliance with the applicable laws, regulations, policies and program requirements.
Acceptance of the Grant Agreement obligates the project to allow BSCC staff and/or its authorized representatives unrestricted access to all project books, documents, papers, and records, (including redacted confidential records) for inspection, copying , monitoring, and auditing. BSCC reserves the right to conduct unannounced monitoring visits.
3. Scope of Monitoring
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The BSCC monitoring process complies with the intent of federal and state requirements. The process assesses programmatic, administrative, and fiscal components of the project. The review of fiscal components is not an audit and cannot be used to replace BSCC audit requirements.
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4. Comprehensive Monitoring Visit Report
The CMVR is a useful tool that helps guide the Grantee in the successful implementation and maintenance of their project. The CMVR provides a summary of the areas reviewed and identifies whether or not those areas are in compliance with applicable requirements. The BSCC will provide the CMVR to the Grantee generally 60 to 90 days after completion of the monitoring. CMVRs with significant findings will be provided to the Grantee within 30 days.
The Grantee should maintain the letter and report within the official grant file. a) No Findings Identified
If no findings are identified in the monitoring report, the monitoring process is complete. b) Significant Findings Identified
If significant findings are identified in the CMVR, the Grantee must submit a Compliance Improvement Plan (CIP) within 30 calendar days of the date of the receipt of the CMVR.
CIP instructions and submission information will be provided by BSCC staff. Extensions may be granted by BSCC staff on a case-by-case basis.
c) Compliance Improvement Plan (CIP)
The Compliance Improvement Plan (CIP) is viewed by the BSCC as a constructive, strengthening process for Grantees. Generally, monitoring findings do not affect the Grantee's funding if a CIP is implemented.
The Grantee is responsible for developing a CIP to respond to the findings identified in the CMVR, including dates for implementation. Grantees may obtain the help of BSCC staff in CIP development. The plan must be implemented, and the deficiencies resolved in a reasonable timeframe from the CMVR date.
After BSCC verifies that all CIP activities have been implemented, a letter will be sent notifying the project that all required actions are completed. The Grantee should maintain the CIP letter and corresponding documentation on file within the official grant file.
5. Corrective Action Process
In a rare circumstance when a problem cannot be resolved thru a CIP process, the matter may be elevated to the BSCC's Executive Director for further disposition or Board review.
6. Disputed Findings
If the Grantee does not agree with any finding in the CMVR or believes a CIP is not required, then the CIP response provided by the Grantee shall include an explanation and specific reasons to support the Grantee's position that the findings are in error. BSCC staff will work with the Grantee to resolve the dispute.
7. Sanctions
If the project does not complete the required activities in the CIP, BSCC may take action as appropriate including, but not limited to:
• Withhold or reduce the amount of any payments requested by the project on an invoice (BSCC Form 201 );
• Reduce the amount of the current Grant Agreement; or
• Terminate the current Grant Agreement, after providing 14 calendar days written notice to the project (unless BSCC determines that good cause exists to waive the 14-calendar day notice).
B. COMPLIANCE IMPROVEMENT PLAN FOLLOW-UP MONITORING VISIT Purpose
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As indicated above, after BSCC verifies that all CIP activities have been implemented, a letter will be sent notifying the project that all required actions are completed. The Grantee should maintain the letter within the official grant file.
C. INITIAL MONITORING VISIT
Purpose
The purpose of the Initial Monitoring Visit is to build relationships with the project staff, stakeholders/partners, and provide high-level evaluation of the project's infrastructure to include support areas such as
• Financial;
• Data;
• Referrals;
• Subcontracting; and
• Hiring.
Newly funded grant projects may receive an initial site visit prior to receiving a CMV, as determined by the BSCC staff and informed by the GPA T.
D. TECHNICAL ASSISTANCE MONITORING VISIT
Purpose
• A Technical Assistance Monitoring Visit is to make an on-site assessment of current project conditions, follow up on previous issues, respond to a Grantee request for a visit, and/or in response to complaints lodged. Technical Assistance Monitoring Visit activities may include, but not limited to, the following : Provide information that will assist the project in meeting program goals;
• Review project objectives to determine if they are achievable; • Review project activities to determine if they will reasonably result in achievement of the objectives;
• Review the project's source documentation and data collection process; • Review the project's Invoice (BSCC Form 201 ), to determine whether any adjustments are needed;
• Discuss the monitoring visit processes with project staff so they know what to expect during future visits;
• Review the progress reports to determine if they are complete and accurate; and • Review terms of the program with the Grantee.
E. CLOSEOUT MONITORING VISIT (AS NEEDED)
Purpose
The purpose of an optional Closeout Monitoring Visit is to review outcomes and project achievements, conduct exit interviews, and assess sustainability. Often Closeout activities are performed via correspondence or telephone. In all cases, a Closeout Letter will be sent to the projects once all requirements have been met and subsequent to all payments to Grantees.
F. S PECIAL EVENT - MONITORING
Purpose
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This "Monitoring" may include site visits at the request from the Grantee for special functions.
These visits may include:
• Participant graduations;
• Award ceremonies;
• Press Conferences; or
G. DESK REVIEWS - FISCAL OVERSIGHT
The desk review is an assessment of the fiscal components of a grant project funded through a BSCC RFA or RFP process. Fiscal desk reviews are completed by CPGP Program Analysts.
Upon completion of a fiscal desk review the Grantee will be provided with an email or letter informing them of the outcome. In the event a fiscal desk review identifies a concern the Field Representative and Manager will be informed and will provide direction for resolution. The record of each outcome will be filed in the grant project file.
1. Desk Review Frequency
Each grant project will receive multiple fiscal desk reviews during the grant cycle. At a minimum, two desk reviews per year will occur in the first 24-months of the grant cycle. A minimum of one desk review per year will occur in subsequent years as applicable. A fiscal desk review may be completed at any time at the request of a Field Representative or Management.
2. Components of a Fiscal Desk Review
a) Notification
Grantees will be notified by CPGP Program Analyst when they have been selected to receive a fiscal desk review. The notification will include forms and instructions regarding the documentation the Grantee must submit to substantiate the amounts claimed on a specified invoice, e.g., worksheets, invoices, receipts, and other related documents. b) Analysis
Submitted documentation will be analyzed by program and fiscal staff to assess compliance with grant program requirements and other applicable standards. c) Findings
• No concerns identified: a draft response is prepared by the CPGP Program Analyst and reviewed and approved by a Manager.
• Concerns identified: the CPGP Program Analyst informs the Field Representative and Manager. The Field Representative and Manager develop an initial response and direction for resolution.
d) Response
• No concerns identified: Grantee will receive the approved response and the grant file will be updated.
• Concerns identified: the CPGP Program Analyst will provide the Grantee with the initial response, and the CPGP Program Analyst and Manager will continue to track for resolution.
3. Fiscal Desk Review Findings
When concerns are identified the BSCC will work with the Grantee to reach resolution. The Grantee is responsible for resolving the issue but BSCC is available for technical assistance as needed. Generally, review findings do not affect the Grantee's funding if corrective action is implemented as agreed. However, failure to respond to the BSCC's request for resolution BSCC Grant Administration Guide Page 68 July 2023
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4. Questioned or Disallowed Costs Identified in a Fiscal Desk Review When costs are questioned or recommended for disallowance, and the Grantee cannot support the costs claimed through original source documents and general ledger entries, BSCC will provide an opportunity for the Grantee to substantiate the expenditure.
In cases where the expenditure cannot be substantiated, the BSCC will invoice for the disallowances and the Grantee will be required to return the funds. While the matter is under review, the BSCC may place a hold on grant funds.
5. Invoice for Repayment
The Grantee will be invoiced for costs disallowed by BSCC. The Grantee must pay the invoiced amount within 30 calendar days from the invoice date. If full payment of disallowed costs causes an undue hardship to the project, the Grantee may submit a written request to the BSCC to pay under a specified payment schedule. The term of the payment schedule shall not exceed a 12-month period, unless otherwise authorized by the BSCC.
6. Sanctions for Nonpayment
If the Grantee does not comply or is delinquent in complying with the payment requirements imposed by BSCC, a hold may be placed on any funds due to the project and/or full amount of disallowed costs owed will be due and payable. BSCC may take additional action, as appropriate, including, but not limited to, denying future grants and reducing the amount of any payments requested by the project on an invoice.
18. RECORDS -- - -------
Grantees are required to maintain accurate, complete, orderly, and separate records for each BSCCfunded grant. All grant records and documents must be adequately protected from fire, theft, cybercrime, or other possible damage or loss. When grant documentation is stored away from the Grantee's principal office, an index of the records' location(s) must be maintained, and accessibility ensured during the grant period and mandatory retention period (see subsection 1A below).
A. AUDITS/MONITORING
All Grantee books, documents, papers, and records relating to the Grant must be accessible to the BSCC or its designees, the State Controller's Office, the Department of General Services, the Department of Finance, and California State Auditor. If Grantees receive federal funds, this requirement also extends to the federal awarding agency and the OJP Office of the Chief Financial Officer, OJP Office of the General Counsel , or the U.S. Department of Justice Office of the Inspector General (or authorized representatives), for inspection and audit. 8 . RETENTION AND REVIEW REQUIREMENT
All grant records must be retained for a minimum of three years after closeout of the BSCC state or federal grant program. Check your Grant Agreement or contact your Program Analyst for your closeout end date. If the Grantee's source documentation records are retained in an e-system , those records must be retrievable during the entire grant cycle and during the three years following closeout. If an audit, investigation, review, litigation, or any other action occurs during the Grantee's record retention period, the Grantee shall retain the records until the resolution of such process, or until the end of the record retention period , whichever is longer.
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C. DOCUMENTATION REQUIREMENTS
1. Fiscal
The retention requirement extends to books of original entry, source documents, supporting accounting transactions, the general ledger, subsidiary ledgers, personnel and payroll records , canceled checks, and related documents and records.
2. Bank Statements and Reconciliation
Each month the cash balance shown in the accounting records (e.g., general ledger and/or cash disbursements register) should be reconciled with the cash balance shown on the bank statement.
3. General Ledger Account Entries
All general ledger account entries for revenues and expenditures must be supported by subsidiary records, the original source documentation, canceled checks, and bank statements. If the bank does not return canceled checks, a check stub, or an electronic copy of the front and back of the cancelled check must be retained. Source documentation includes invoices, bills, and vouchers. The format of secondary records is determined by the Grantee.
Grantees must be able to trace the general ledger entries to the Invoice (BSCC Form 201 ).
Grantees can use worksheets to document how costs/expenditures are taken from the general ledger and recorded on the Invoice (BSCC Form 201 ).
4. Duplicate Deposit Receipts
The Grantee must maintain copies of the deposit receipts. The receipts must show the source of the receipt (e.g., BSCC, county, city, United Way, donations) and filed with the applicable bank statement.
5. Canceled Checks
Canceled checks are checks written by the Grantee for the grant program that have been processed by a bank. Each month canceled checks must be reconciled with the bank statements. If a bank does not return canceled checks, an electronic copy, or the check stub must be used.
6. Vouchers
Vouchers include the following:
• Purchase orders,
• Receiving reports which show the items which are received from the vendor, and • Vendor invoices. When invoices are paid, they must be marked as PAID with the check number to prevent the likelihood of paying the same invoice twice.
7. Programmatic
The records retention requirement extends to supporting documentation, statistical records, and all other records pertinent to Grant Awards or contracts under grant-funded projects.
Grantees must retain source documents that substantiate information on required BSCC reports that include:
• Progress Reports,
• Modifications to the Grant Budget (BSCC Form 223.1 ), • Evaluation Data Reports; and
• Any other records the BSCC directs the Grantee to maintain.
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1. Functional Time Sheets
All grant-funded personnel who are directly charged to the grant (or listed as match) either in whole or in part must maintain timecards/sheets that: 1) indicate the actual time worked and their function on each BSCC project (on a daily basis); and 2) account for all the time worked by the employee during the pay period. Timecards/sheets must be signed by the employee, signed/approved by their supervisor, and should be customized to capture the various activities performed by the employee/organization. Contact your Program Specialist for examples that may be used to assist in the development of an appropriate time reporting tool.
2. Personnel Payroll Files
Personnel payroll files should include the following :
• W-2, W-4,
• Personnel action forms (i.e., approved pay rates by the governing board or appropriate personnel agency, promotions, terminations, etc.),
• Cumulative earnings record,
• Leave records,
• Employee authorized deduction forms (i.e., health insurance); and • Paid invoices submitted by employees for reimbursement of benefit expenses.
3. Personnel Files
Personnel files should include the following :
• Application forms,
• Resumes ,
• Job descriptions,
• Performance evaluations; and
• Appointment documents which include approved salary rates, benefits, and other terms of employment. Salary rates, increases and benefits must be approved by the governing board or applicable personnel agency.
E. EQUIPMENT
Equipment must be:
• Located on the project's premises or identified in a locator file that specifically identifies the location of the equipment or the name of the assigned individual, • Recorded on an inventory list, identifying items purchased with BSCC funds, • Used in accordance with the Grant Award; and
• Grantees must retain contract records for the purchase of Grant funded equipment.
F. ORGANIZATION POLICIES AND PROCEDURES
The organization should have written policies and procedures covering conflict of interest/code of conduct and fraud , along with personnel policies that cover hiring, termination, benefits, salary rates, leave, and travel. There should also be written procedures regarding the accounting and reporting functions, including, but not limited to the following :
• Cash receipts and revenue,
• Deposits,
• Cash disbursements,
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• Payroll ,
• General Ledger; and
• Equipment.
In addition, any other policies, and procedures (e.g., purchasing contracts) that relate to operating the grant program must be in writing.
G. COMMUNICATIONS
Grantees must maintain a current telephone number and internet access with an e-mail address, as well as a current postal address and physical location within the State of California.
19. WITHHOLDING OR DISALLOWANCE OF GRANT FUNDS
A. WITHHOLDING OR DISALLOWANCE OF GRANT FUNDS
The BSCC may withhold grant funds and/or disallow expenditures if the Grantee fails to comply with the terms or conditions of the Grant Agreement or this Grant Guide. This may include the following :
• Failure to submit the required progress reports in a timely manner; • Failure to submit the final reports from previous BSCC grants in a timely manner; • Failure to resolve interim or final audit exceptions on past or current grants in a timely manner; • Inadequate maintenance of accounting records;
• Failure to submit proof of bond coverage in a timely manner; • Failure to cooperate with or admit BSCC staff or other federal or state representatives to review program and/or fiscal records;
• Failure to repay or rectify costs that have been identified as ineligible for grant funding ; • Failure to adhere to the payment terms in the Grant Agreement; • Failure to provide the required match or leveraged share of the actual total project costs; • Failure to meet prescribed assurances, commitments, recording, accounting, auditing, and reporting requirements of the Grant Agreement;
• Substantial alteration of the scope of the grant project without prior written approval of the BSCC; or
• Refusal or inability to complete the grant project in a manner consistent with the terms, conditions, and program requirements outlined in the RFP (or Request for Application (RFA)), Application for Funding, Grant Agreement and all Exhibits, Attachments, Appendices , and approved modifications.
8. REDUCTION OR TERMINATION OF GRANT FUNDS
The BSCC may reduce or terminate grant funds as set forth in the terms and conditions of the Grant Agreement or for any reason that may include the following :
• If the Grantee fails to comply with any term or condition of the Grant Agreement; or, • If during the term of the Grant Agreement, the state and/or federal funds appropriated for the purposes of the Grant Award are reduced or eliminated by the California Legislature or by the United States Government, or, in the event revenues are not collected at the level appropriated, the BSCC may immediately terminate or reduce the Grant Agreement.
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C. DENIAL OF FUTURE FUNDING
The BSCC reserves the right to consider the denial of future funding to any project and its officers based on its failure to comply with any term or condition of a current or previous Grant Award , poor past performance in a previous Grant Award, or failure to cooperate with state or federal auditors/monitors.
A denial of an application for funding or for future funding shall not become final until the applicant has been afforded reasonable notice and an opportunity for a timely and fair hearing. Hearings for denial shall be conducted by an impprtial hearing officer whose decision shall be final.
20. CLOSEOUT
The closeout of a grant is the process by which a grant or agency determines that all applicable administrative actions and all required grant activities have been completed by the Grantee. BSCC staff will notify Grantees a minimum of 30 days before the end of the grant cycle to initiate the closeout process. When all administrative and fiscal requirements have been met, Grantees will receive a Final Notice of Project Closeout.
A. LOCAL EVALUATION REPORT
The Local Evaluation Report encompasses the entire grant cycle. Final payment on the grant may be withheld until the report has been submitted. This report is due to the BSCC on the due date specified in the Grant Agreement. Information about the final report can be found in Section
15. 8. FINAL PROGRESS REPORT
Progress reporting periods and due dates are specified in the Exhibit A: Scope of Work of the grant contract. Failure to submit the final report may result in the withholding or disallowance of grant payments, the reduction or termination of grant funds, and/or the denial of future grant funding.
C . FINAL REQUEST FOR REIMBURSEMENT
All expenses must have been encumbered prior to the Grant Award end date. The only "unpaid obligation" that may be listed is the audit expense. Unless otherwise noted in the grant agreement, the Grantee must submit the Final Invoice (BSCC Form 201) no later than 60 calendar days after the end of the grant cycle. If the Grantee does not submit a final invoice, the BSCC may consider the last invoice submitted as the final invoice and close out the Grant Award. Once BSCC has processed the final invoice, the grant will be closed, and no further payment can be made against the grant.
D. REPORTING REQUIRED MATCH
If your grant award has a required match, it must be reported on the invoice (Form BSCC 201) as the expenditures occur and before the grant ends. If the Grantee does not expend the total required match by the end of the grant cycle, or if it is not fully reported by the final invoice, the BSCC will invoice the Grantee for funds allocated that did not meet their match.
E. RETENTION OF RECORDS
All records relating to the grant shall be retained in accordance with Section 18.
F . AUDITS CLOSEOUT
Audits must be completed and submitted in accordance with Section 16.
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BOARD OF STATE AND COMMUNITY CORRECTIONS
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6/16/2026 2:21 :27 PM
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Jeremy Tobias
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CEO
Community Action Partnership of Kern
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Electronic Record and Signature Disclosure:
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Brent Stratton
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Electronic Record and Signature Disclosure:
Accepted: 6/16/2026 5: 15:44 PM
ID: a626c49c-871 f-4cec-9c9b-e24fe243fcd0
Jena Covey
[email protected]
RISK MANAGER
Security Level: Email, Account Authentication
(None)
Electronic Record and Signature Disclosure:
Accepted: 6/17/2026 6:20:45 AM
ID: 124fef41-ea59-4def-92ec-fd07 a3a 12feb
In Person Signer Events
Editor Delivery Events
Agent Delivery Events
Intermediary Delivery Events
Holder: City Clerk's Office
city_ [email protected]
Pool: StateLocal
Signature
Signature Adoption: Pre-selected Style
Using IP Address:
2600: 1700:f250 :3d30: 1877:b28d:81 f0 :978d
Signature Adoption: Pre-selected Style
Using IP Address: 192.119.132.24
Signature Adoption : Pre-selected Style
Using IP Address: 17 4.46.226.5
Signature
Status
Status
Status
Status: Completed
Envelope Originator:
City Clerk's Office
[email protected]
IP Address: 174.46.226.5
Location: DocuSign
Timestamp
Odocusign.
Sent: 6/16/2026 2:25:21 PM
Viewed: 6/16/2026 4:27:46 PM
Signed : 6/16/2026 4:30:07 PM
Sent: 6/16/2026 4:30:11 PM
Viewed: 6/16/2026 5: 15 :44 PM
Signed : 6/16/2026 5:16:41 PM
Sent: 6/16/2026 5:16:44 PM
Viewed: 6/17/2026 6:20:45 AM
Signed: 6/17/2026 6:22:17 AM
Timestamp
Timestamp
Timestamp
Times tamp
Certified Delivery Events Status Timestamp
Carbon Copy Events Status Timestamp
Witness Events Signature Times tamp
Notary Events Signature Times tamp
Envelope Summary Events Status Timestamps
Envelope Sent Hashed/Encrypted 6/16/2026 2:25:21 PM
Certified Delivered Security Checked 6/17/2026 6:20:45 AM Signing Complete Security Checked 6/17/2026 6:22:17 AM
Completed Security Checked 6/17/2026 6:22:17 AM
Payment Events Status Timestamps
Electronic Record and Signature Disclosure
Electronic Record and Signature Disclosure created on: 6/28/2022 10:51 :05 AM Parties agreed to: Jeremy Tobias, Brent Stratton, Jena Covey
ELECTRONIC RECORD AND SIGNATURE DISCLOSURE
From time to time, City of Bakersfield (we, us or Company) may be required by law to provide to you certain written notices or disclosures. Described below are the terms and conditions for providing to you such notices and disclosures electronically through the DocuSign system.
Please read the information below carefully and thoroughly, and if you can access this information electronically to your satisfaction and agree to this Electronic Record and Signature Disclosure (ERSD), please confirm your agreement by selecting the check-box next to 'I agree to use electronic records and signatures' before clicking 'CONTINUE' within the DocuSign system.
Getting paper copies
At any time, you may request from us a paper copy of any record provided or made available electronically to you by us. You will have the ability to download and print documents we send to you through the DocuSign system during and immediately after the signing session and, if you elect to create a DocuSign account, you may access the documents for a limited period of time (usually 30 days) after such documents are first sent to you. After such time, if you wish for us to send you paper copies of any such documents from our office to you, you will be charged a $0.00 per-page fee. You may request delivery of such paper copies from us by following the procedure described below.
Withdrawing your consent
If you decide to receive notices and disclosures from us electronically, you may at any time change your mind and tell us that thereafter you want to receive required notices and disclosures only in paper format. How you must inform us of your decision to receive future notices and disclosure in paper format and withdraw your consent to receive notices and disclosures electronically is described below.
Consequences of changing your mind
If you elect to receive required notices and disclosures only in paper format, it will slow the speed at which we can complete certain steps in transactions with you and delivering services to you because we will need first to send the required notices or disclosures to you in paper format, and then wait until we receive back from you your acknowledgment of your receipt of such paper notices or disclosures. Further, you will no longer be able to use the DocuSign system to receive required notices and consents electronically from us or to sign electronically documents from us.
All notices and disclosures will be sent to you electronically Unless you tell us otherwise in accordance with the procedures described herein, we will provide electronically to you through the DocuSign system all required notices, disclosures, authorizations, acknowledgements, and other documents that are required to be provided or made available to you during the course of our relationship with you. To reduce the chance of you inadvertently not receiving any notice or disclosure, we prefer to provide all of the required notices and disclosures to you by the same method and to the same address that you have given us. Thus, you can receive all the disclosures and notices electronically or in paper format through the paper mail delivery system. If you do not agree with this process, please let us know as described below. Please also see the paragraph immediately above that describes the consequences of your electing not to receive delivery of the notices and disclosures electronically from us.
How to contact City of Bakersfield:
You may contact us to let us know of your changes as to how we may contact you electronically, to request paper copies of certain information from us, and to withdraw your prior consent to receive notices and disclosures electronically as follows:
To contact us by email send messages to: City_ [email protected] To advise City of Bakersfield of your new email address To let us know of a change in your email address where we should send notices and disclosures electronically to you, you must send an email message to us at [email protected] and in the body of such request you must state: your previous email address, your new email address. We do not require any other information from you to change your email address.
If you created a DocuSign account, you may update it with your new email address through your account preferences.
To request paper copies from City of Bakersfield
To request delivery from us of paper copies of the notices and disclosures previously provided by us to you electronically, you must send us an email to City_ [email protected] and in the body of such request you must state your email address, full name, mailing address, and telephone number. We will bill you for any fees at that time, if any.
To withdraw your consent with City of Bakersfield
To inform us that you no longer wish to receive future notices and disclosures in electronic format you may:
i. decline to sign a document from within your signing session, and on the subsequent page, select the check-box indicating you wish to withdraw your consent, or you may; ii. send us an email to [email protected] and in the body of such request you must state your email, full name, mailing address, and telephone number. We do not need any other information from you to withdraw consent.. The consequences of your withdrawing consent for online documents will be that transactions may take a longer time to process ..
Required hardware and software
The minimum system requirements for using the DocuSign system may change over time. The current system requirements are found here: https://support.docusign.com/guides/signer-guidesigning-systern-requirernents.
Acknowledging your access and consent to receive and sign documents electronically To confirm to us that you can access this information electronically, which will be similar to other electronic notices and disclosures that we will provide to you, please confirm that you have read this ERSD, and (i) that you are able to print on paper or electronically save this ERSD for your future reference and access; or (ii) that you are able to email this ERSD to an email address where you will be able to print on paper or save it for your future reference and access. Further, if you consent to receiving notices and disclosures exclusively in electronic format as described herein, then select the check-box next to 'I agree to use electronic records and signatures' before clicking 'CONTINUE' within the DocuSign system.
By selecting the check-box next to 'I agree to use electronic records and signatures' , you confirm that:
• You can access and read this Electronic Record and Signature Disclosure; and • You can print on paper this Electronic Record and Signature Disclosure, or save or send this Electronic Record and Disclosure to a location where you can print it, for future reference and access; and
• Until or unless you notify City of Bakersfield as described above, you consent to receive exclusively through electronic means all notices, disclosures, authorizations, acknowledgements, and other documents that are required to be provided or made available to you by City of Bakersfield during the course of your relationship with City of Bakersfield.