1 PURPOSE
Grant funds received by the City of Marysville support essential programs and services the City provides to the community. These funds allow the City to extend pre-existing services, introduce new initiatives, gain technological advances, and subsidize programmatic staffing. While providing a financial benefit to the City, these programs also contain specific requirements for compliance by the City. This directive aims to develop, implement, and maintain meaningful grant oversight and coordination for the City, thereby increasing grant-related revenue, limiting the City’s exposure to grant-related liability, and improving the efficiency and impact of programs and services funded through grants. This directive establishes the responsibility for ensuring contract compliance and provides pre-award, post-award, and close-out processes as defined below.
POLICY
All employees of the City having grant management or accounting responsibilities shall conduct all related activities in compliance with rules and guidelines set forth by this policy and by their respective department grant procedures.
Every grant opportunity and award shall follow the procedures outlined in this policy. Grant programs with approved policies and established procedures that require review by the City Council-appointed board, commission, or committee will follow the approved policies for that program and all applicable federal and state laws, grant requirements, and City policies.
ADMINISTRATIVE PROCEDURES
GOALS
1. To set forth the importance of grant programs in accomplishing City goals and objectives.
2. Establish general concepts, definitions, and frameworks for seeking and managing grant programs.
3. Identify roles and responsibilities in managing grant programs.
4. Establish criteria for evaluating the benefits and costs of grant programs.
5. To set forth the City’s policy in complying with Single Audit Act requirements.
GENERAL CONCEPTS AND FRAMEWORK
1. The City will aggressively pursue grant funding from federal, state, and other sources, consistent with identified City goals and objectives.
2. The City will only seek grants when sufficient staff resources are available to administer the program effectively, comply with grant requirements, and successfully perform the grant work scope.
3. Indirect costs of administering grant programs will be recovered to the maximum extent feasible.
4. Department Heads are primarily responsible for seeking grant opportunities, preparing practical grant applications, and successfully managing grant programs after they have been awarded.
CONFLICT OF INTEREST
City officials and employees should be diligent in identifying potential conflicts of interest when working in any capacity with any proposed or funded grant involving the City. No officer or employee of the City shall have any interest, financial or otherwise, direct or indirect, or have any arrangement concerning prospective employment that will or may be reasonably expected to bias the design, conduct, or City of Marysville
Grant Accounting Policy
Adopted: July 2, 2024
2 reporting of a grant-funded project on which he or she is working.
The Department Head for each grant-funded project shall ensure that city officials or employees and nongovernmental recipients or sub‐recipients avoid any action that might result in or create the appearance of a conflict of interest in the use of project funds.
DEFINITIONS OF TERMS
a. Catalog of Federal Domestic Assistance (CFDA) – Publication that includes information related to all Federal programs, including the program title, description, history, and assigned number (CFDA number).
b. Data Universal Numbering System (DUNS) – The nine-digit number that Dun and Bradstreet, Inc. (D&B) established and assigned to identify entities uniquely. A non-Federal entity is required to have a DUNS number to apply for, receive, and report on a Federal award. The Federal Government uses the DUNS number to track how Federal money is allocated. The Finance Department manages and obtains DUNS numbers for the City of Marysville. c. Employer Identification Number (EIN) – The nine-digit number the Internal Revenue Service assigns. The EIN for the City of Marysville is 94-6000368. d. Federal Awards – Grants of Federal financial assistance (grants, loans, loan guarantees, property, etc.) and Federal cost-reimbursement contracts that the City receives directly from the Federal awarding agency or indirectly through a pass-through entity. e. Funding Source – The originating Federal, State, or other agency providing the grant. A passthrough grant from the State shall always have a Federal agency as the Funding Source. f. Grants – The overall encompassing term for an award of financial assistance, including cooperative agreements, in the form of money, property in lieu of cash, professional services, staffing, or other financial assistance paid or furnished by the State, County, Federal government, or other entity to carry out a program in accordance with rules, regulations, and guidance provided by the grantor entity/agency.
g. Grant Administrator – Individual assigned daily responsibility for ensuring that the grant is administered in accordance with all grant requirements and that all applicable documentation is maintained. If the position is not filled, the responsibilities default to the Finance Director. h. In-Kind – A contribution of equipment, supplies, or other tangible resource, as distinguished from a monetary grant. Some organizations may also donate space or staff time as in-kind contributions.
i. Pass-through Entity – A non-Federal entity that provides a sub-award to a subrecipient to carry out part of a Federal program.
j. Program Income – Income from fees for services performed, from the use or rental of real or personal property acquired with grant funds, from the sale of commodities or items fabricated under a grant agreement, and from payments of principal and interest on loans made with grant funds (where authorized).
k. Sub-recipient – A non-Federal entity that receives a sub-award or sub-grant from a pass-through entity to carry out part of a Federal Program.
l. Schedule of Expenditures of Federal Awards (SEFA) – A supplemental schedule to the financial statements an organization must produce when it is subject to the single audit requirement. It is an essential document for planning and conducting the organization's audit. It also assures those agencies that award financial assistance that their programs or grants were included in the audit.
m. Unique Entity Identifier (UEI) Number – A number issued by the System for Award Management (SAM) to identify businesses and other entities that do business with the Federal Government.
The UEI has replaced the DUNS number as the authorized identifier for the Federal Government.
ROLES AND RESPONSIBILITIES
The following shall govern responsible parties for activities surrounding the submittal, implementation, 3 maintenance, reporting, and other related duties for grant-funded projects by or on behalf of the City.
The entire development of a project or program requires the assistance and support of all affected parties.
City Council
1. Approves grant management policies.
2. Approve all grant applications that require additional City resources or obligations (matching funds) that are not budgeted and delegate receipt and contract execution to the City Manager or designee if delegation is allowed by the grantor agency.
City Manager
1. Receives grants and executes related contract documents when delegated by the Council.
2. Develops, recommends, and maintains grant management policies.
Finance Director
1. The Finance Director is responsible for the oversight of the City of Marysville's financial activity.
In this role, Finance has the authority to create and/or review financial reports generated by recipient departments, work with the City Attorney to identify and investigate issues that may arise concerning the management of City grants and provide general oversight of other grant financial related issues, including the proper budgeting and accounting for grants and other responsibilities indicated throughout this policy.
2. Finance is responsible for creating a grant fund and/or project number, which is used to recognize grant revenue and expenditures in the department or division’s budget.
3. Coordinates preparation and distribution of single audit reports. Ensure that the City’s policy regarding single audit act requirements is implemented.
Grant Administrator
1. The Grant Administrator is responsible for general management and administration of the City's grant activities, including annual Citywide grant management planning and goals; facilitation of departmental grant planning and collaborative grant submittals; grant training and technical assistance for City staff; ensuring that departments track and report departmental grant activity; maintenance of grant policies and procedures, grants manual; ensuring the promotion of grant opportunities; and identifying and investigating issues that may arise concerning the management of City grants.
2. The Grant Administrator monitors documentation for compliance with grant requirements and serves as the Project Manager for specified interdepartmental grants and federal appropriations.
3. Provides technical assistance to Department Heads in preparing grant applications, submitting reports, maintaining records, and the administrative process.
4. Maintain financial and other records in accordance with grant requirements.
5. Complete and submit required reports, including requests for funds.
6. Monitor grant expenditures and receipt of revenues.
7. Complete grant closeout, including.
a. Notify affected departments that the project is completed and schedule a “close-out” meeting if necessary to resolve any final procedural issues.
b. Ensure final receipt of grant revenues.
c. Prepare and submit any required financial grant close-out documents. d. Review the grant file for completeness.
e. Retain all necessary program and financial records for the period required by the grantor agency.
f. Resolve any audit findings.
4 Department Heads (Directors/Project Managers)
1. Develop systems for maintaining ongoing information regarding grant availability within their functional areas of responsibility.
2. Evaluate benefits and costs of specific grant programs on a case-by-case basis:
a. Purpose of the grant program and its consistency with identified City goals and objectives. b. Ongoing impacts of the grant program after it is completed. c. Responsible for preparing the grant application or performing work scope if approved. d. Amount of indirect costs to be recovered from the grant, e. Total program costs, including portion funded through grant revenues and any required City contribution.
f. Source of funding for any required City share.
g. Compliance and audit requirements, paying particular attention to areas where the grantor’s administrative procedures differ from the City’s.
3. Prepare grant applications.
a. Work with the grantor agency to identify special program requirements and develop strategies for preparing a successful grant application. b. Complete grant application documents.
c. Coordinate with affected departments as necessary.
d. For grants requiring unbudgeted additional City resources or obligations, prepare a Council agenda report requesting authorization to seek grant funding. This report should describe the grant program's conformance with this policy, including the cost/benefit analysis results. e. For other grants, submit the grant application subject to the following conditions:
i. It will not add regular staffing.
ii. Any matching funds or in-kind contributions are already available within existing resources, and no additional appropriation of unreserved, undesignated fund balance or working capital is required.
iii. At the grant's conclusion, there will be no ongoing commitments or obligations to continue the program.
iv. The grant program's purpose is consistent with current City plans, policies, and goals.
4. Administer grant programs if awarded.
a. Provide the completed Grant Information Checklist (Exhibit A) to Finance Department. b. Notify affected departments of grant awards.
c. Coordinate on-site management reviews by the grantor agency during the grant term. d. Ensure compliance with grant requirements, paying special attention to areas where the grantor’s administrative procedures differ from the City’s. e. Perform the grant work scope.
f. Project Managers will reconcile proposed reimbursement requests with the appropriate General Ledger information before submitting reimbursement requests.
5. Complete grant closeout.
a. Complete the grant work scope.
b. Notify affected departments that the project is completed and schedule a “close-out” meeting to resolve any final procedural issues.
c. Prepare and submit any required grant close-out documents. d. Review the grant file for completeness.
e. Retain all necessary program and financial records for the period of time required by the grantor agency.
f. Coordinate any on-site management reviews or audits after the grant is completed. g. Resolve any audit findings.
PRE-AWARD PROCEDURES
LETTER OF SUPPORT REQUESTS FROM EXTERNAL ORGANIZATIONS
External organizations frequently seek support from the City for grant applications they intend to submit 5 to a grantor. Requests for such support are often made to department staff or directors, who may need to be informed whether other City departments are competing for the same grant opportunity.
Additionally, there may be other reasons why providing a letter of support would not be in the City's interests.
REQUESTS FOR LETTER OF SUPPORT PROCEDURE
Letters of support for a grant application prepared by an external entity for which the City is not a collaborating partner shall be coordinated by the Department Head in consultation with the Grant Administrator, Finance Director, and City Manager before submission to the requesting organization.
1. The department must decide whether to support a request from an external organization for a letter of support for a grant application it intends to submit to a grantor.
2. The Department Head is responsible for consulting with the Grant Administrator, Finance Director, and the City Manager, documenting the information and reasoning behind the decision, and ensuring that no potential liabilities to the City will be incurred due to their action.
3. If the Department Head decides they support the request and would like to provide a letter of support, they must provide the Grant Administrator with the name, mission, and activities of the requesting organization, the name, and description of the proposed project, and whether the City will have future obligations.
4. The Grant Administrator will ensure the City is not in competition or is likely to compete for the same grant opportunity by comparing the request to pre-application reporting received from City departments.
5. If the City is likely to be in competition with the same grant opportunity, the request for a letter of support shall be denied.
6. If approved, the Department Head may supply the appropriate letter of support and provide a copy to the Grant Administrator.
AUTHORIZED WRITTEN SIGNATURE
1. This policy aims to identify who may approve and provide authorized written signatures on grant applications and subsequent grant agreements. This shall be done well in advance of grant submission due dates to avoid last-minute delays or problems that could cause the grant deadline to be missed.
2. This written signature authority is different from the electronic signature authority granted to specific department individuals to submit an online grant application or quarterly reports, as indicated in the Section below.
3. There are four authorized grant application signers: the City Manager, Finance Director, Department Head, and Grant Administrator.
4. Authority over a specific grant project or program, grant application, or grant agreement may be delegated in writing to address circumstances that warrant delegation or provide efficiency.
5. If a grantor requests a signature other than what is defined above, a copy of this policy may be provided to grantors as documentation authorizing that person to sign.
AUTHORIZED ELECTRONIC SIGNATURE
Many federal and state grant programs require or offer the option of submitting grant applications and reporting through the Internet. This policy identifies the procedure for providing authorized electronic signatures.
AUTHORIZED ELECTRONIC SIGNATURE PROCEDURE
1. All grant applications submitted through the Internet shall comply with the standard policies and procedures described in this policy.
2. The individual submitting the grant must be designated as an authorized electronic signatory by their Department Head.
6 3. The Department Head shall email the Grant Administrator notifying authorized electronic signature status for each designated staff person he/she selects. This shall be done well before grant submission due dates to avoid last-minute delays or problems that could cause the grant deadline to be missed.
GRANT SEEKING PROCESS
To coordinate the City's grant activities effectively and support the City's strategic priorities, the Grant Administrator must have knowledge of prioritized department needs for the various departments that can be met through grants. This knowledge will allow the Grant Administrator to identify the potential for parallel or redundant submissions, as well as areas for potential collaboration among departments, plan for submission of proposals to regular cyclical grant opportunities and be pre-positioned to assist the departments in the submission of proposals to those opportunities when they arise.
The grant-seeking process has three components: (1) the development of a departmental grant-seeking plan, (2) pre-application assessment and review, and (3) application submission.
GRANT APPLICATION
This policy encourages the pursuit of grant opportunities that ensure each grant application submitted by or on behalf of the City supports the City’s strategic priorities and is aligned with an established City priority. It also ensures that matching funds are available if required by the grantor and that the means for continuing the project or program after the grant period ends have been given realistic consideration.
The department submitting the grant application is responsible for ensuring that the pre-application assessment factors noted below have been evaluated and completed before the grant submission.
PRE-APPLICATION ASSESSMENT & REVIEW
This process ensures that possible costs to the City are identified and considered as early as possible.
PRE-APPLICATION ASSESSMENT & REVIEW PROCEDURE
The department considering a grant application is responsible for a pre-application assessment, in which the following factors shall be evaluated in consultation with the Finance Director, Grant Administrator, and City Manager. Pre-application assessment shall be done well in advance of grant submission due dates to avoid last-minute delays or problems that could cause the grant deadline to be missed.
1. Financial
a. Total anticipated project cost.
b. Match requirements and sources.
c. Administration and Indirect Recapture Amounts.
d. Program income considerations.
e. Staffing requirements (including salary and benefits increases for multi-year grants). f. Documentation of a clear continuation plan. Departments must develop continuation plans (plans for sustaining grant-funded programs if funding is reduced or terminated) before applying for grants. These plans must reflect the potential for loss of funding and the subsequent loss of grant-funded positions or program components. Departments must plan responsibly for either termination or reduction of the program or seek to secure alternative funding sources.
2. Programmatic
a. Alignment with the City's strategic priorities and department’s business plan. b. Provision or expansion of services to address critical needs. c. The department's capacity is to administer the financial and administrative aspects of the grant.
7 APPLICATION SUBMISSION
1. The department submitting the grant application ensures that the pre-application assessment factors noted above have been evaluated and completed before submission.
2. The department is responsible for obtaining the required authorized written signature, as noted in this policy, at the time of application submission and for submitting the grant application to the grantor by the grant application due date.
3. The department shall prepare a council agenda item for City Council approval to submit a grant application if the grantor requires it at the time of submission.
4. A copy of the completed application must be submitted to the Grant Administrator to confirm that the grant is recorded in the Grants Tracking Spreadsheet for status tracking and reporting to the City Council.
POST-AWARD PROCEDURES
AWARD NOTIFICATION AND ACCEPTANCE
Grant agreements are legal contracts. The City is responsible for carrying out the project and activities associated with a grant to accomplish its objectives while adhering to all the terms and conditions prescribed by the grantor. Failure to do so increases the City's exposure to legal liability and compromises current and future grant funding. Therefore, the City carries a significant legal and ethical responsibility when accepting grant funding.
The award notification, review, and acceptance process have two components: (1) award notification and (2) City Council approval to accept the award if not included in the prior application staff report.
Under no circumstances should work outlined in the grant application Scope of Services begin prior to the award of the grant and completion of the executed agreement(s). The Grant Administrator will inform parties that this step has been completed and that work may begin under the grant agreement.
AWARD NOTIFICATION PROCEDURE
All departments that receive a grant award shall date stamp, duplicate, and forward a copy of the award notification, the grant agreement or contract, and any memoranda of understanding to the Grant Administrator within two days of receipt. A completed Grant Information Checklist (Exhibit A) shall also be supplied to the Finance Department.
COUNCIL APPROVAL TO ACCEPT AWARD PROCEDURE
This policy ensures that the City Council formally approves each award granted to the City. a. If the City Council has not previously authorized the approval of the Grant, the Department Head shall prepare the Resolution, if required, and the appropriate staff report and fiscal analysis statement requesting City Council authorization for the City Manager to execute the Grant Agreement and related documents along with the appropriate budget adjustments. b. Once the proper City Officials have executed the document, the Department Head will forward it to the Grantor.
c. The appropriate department shall receive the fully executed original Grant Agreement (executed by the City and the Grantor).
d. The Department Head must provide an original of the fully executed grant agreement to the City Clerk’s Office and Grant Administrator when the fully executed grant award is returned to the City by the grantor.
USE AND RECEIPT OF GRANT FUNDS
This policy ensures that the City of Marysville appropriately uses and receives grant funds. Violations can result in a range of penalties, including suspension of future funds from the grantor, return of all funds associated with the award, including those already expended, and civil and criminal penalties. 8 1. All departments receiving grant funds shall adhere to City Financial Policies and Procedures and Office of Budget Management fiscal procedures.
2. No grant funds shall be disbursed until a project has been established in an appropriate finance fund, the Council approves any sub-grant awards, consultant agreements, and contracts, and the required documentation is complete.
3. If grant revenues and expenditures have not previously been identified in the annual budget, the department head shall submit a budget appropriation request to the Council through a staff report. All grant budget appropriation requests shall be submitted in a timely manner to keep the budget current with respect to the grant's financial status.
4. Modifications to the budget associated with a grant-funded project that alters the grant amount or moves funds from one budget line item to another must adhere to City policy and procedures for budget modifications and grantor requirements and be approved by the Finance Director.
Copies are to be provided to the Grant Administrator.
5. Grant funds awarded to the City of Marysville shall not be used to supplant an existing expense so that current funds can be diverted to another use unless such use of grant funds is explicitly identified as allowable in writing by the granting entity in the grant award.
6. All income resulting from a grant-funded project or program shall adhere to City Policy and Procedure and be managed and maintained as established in the award letter, grant agreement, contract, special conditions, or other document generated by the granting entity.
7. All procurement and contract activity associated with grant-funded projects or programs shall follow the procedures outlined in Chapter 2.76, Purchases, of the Marysville Municipal Code.
To ensure compliance, Finance must receive a copy of the grant agreement and/or documentation specifying grantor purchasing requirements.
8. All property acquired through grant funds shall follow the procedures outlined in the City Capital Asset Policy and Inventory Management Procedure.
9. All grants and any related matching fund revenues and expenditures shall be recorded in the grant project. Any revenues or expenditures that occur in another program/project that apply to a grant or that are used as a match shall have a journal entry made to put the revenues or expenditures in the appropriate grant project with a detailed explanation, including original G/L date and batch information. Revenues received should only be deposited into an expenditure account if an item purchased was returned.
10. Grant project managers are ultimately responsible for adherence to the stipulations outlined in the approved grant award/contract to ensure that allowable expenditures are incurred.
DAILY ADMINISTRATION OF THE PROGRAM
a. The Department Head shall manage awards in accordance with 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, applicable State laws and regulations, City policies, and corresponding contractual agreements. b. The Department Head may delegate daily responsibilities for administering the grant/award to a Grant Manager. However, the Department Head retains overall responsibility for the grant/award.
c. If the grant has subrecipients:
i. The Department Head, with assistance and support from the Grant Administrator, shall perform a risk assessment for each subrecipient before passing along awarded funds, in accordance with 2 Code of Federal Regulations (“CFR”) §200.331, “Requirements for passthrough entities,” and formulate a risk mitigation plan based on identified risk factors. ii. The Department Head, with assistance and support from the Grant Administrator, shall perform subrecipient monitoring in accordance with §200.330, “Subrecipient and Contractor Determinations,” and §200.331, “Requirements for Pass-Through Entities,” and document such monitoring.
d. All grant-related procurement activities must be conducted in accordance with all applicable City policies, state, and federal laws and regulations (e.g., Davis-Bacon Act). 9 REPORTING AND REIMBURSEMENT REQUESTS
a. The Department Head shall initiate the reporting process to allow time for review by the Grant Administrator and Finance Director. Reporting shall be submitted to the Grantor in the timeframe specified by the grant/award agreement.
b. The Department Head shall prepare reimbursement requests and submit them to the Grant Administrator and Finance Director for review. The Grant Administrator will assist the Department Head in ensuring reimbursement requests meet eligible expense and procurement requirements. Reimbursement requests shall be submitted to the Grantor in the timeframe specified by the grant/award agreement.
c. The Finance Director shall review all reports and reimbursement requests prior to submission to ensure they agree with the general ledger and assist when needed. The Finance Department shall place the reconciliation in the grant folder in the designated record management system.
RECEIPT OF GRANT FUNDS
When grant funds are received, the Grant Administrator or the Finance Department, whoever first identifies payment has been made, shall notify other necessary staff of the receipt. The Finance Department shall determine the correct deposit coding. The funds shall be deposited in accordance with routine deposit procedures.
PROGRAM INCOME
Program income shall be accounted for as authorized by the Federal or State agency. Program income is usually deducted from total allowable costs to determine net allowable costs (i.e., Program income reduces the amount of money the City may be reimbursed with Federal funds). Costs financed by program income only count toward satisfying a matching requirement if they are expressly permitted in the terms of the assistance agreement. Program income does not include interest on grant funds, rebates, credits, discounts, or refunds.
REAL PROPERTY & EQUIPMENT
a. Special rules apply to real property and equipment purchased with grant monies. When purchasing goods and services under a Federal grant award, the City is required to follow the provisions of the Uniform Guidance, Procurement Standards (2 CFR §200.318 through §200.326). Where thresholds differ between the City and Federal procurement policies, the City will follow the most restrictive rule. These rules will be detailed in the regulations or documents about the specific grant.
b. Department Heads shall also adhere to the City’s Inventory Management Procedures outlining maintaining inventory listings of equipment purchased through grant funds. c. The Grant Administrator or Department Head shall provide the Finance Director with the necessary documentation authorizing disposal and record this documentation in the grant folder and the designated record management system.
DOCUMENTATION MAINTENANCE
Timely and accurate documentation is an essential element of grant compliance. When available, the assigned staff shall store documentation in the designated record management system.
1. The Grant Administrator manages a centralized record management system for City grants.
2. Administering departments are required to maintain a complete file of award records and supporting documentation for each grant award.
SUB-RECIPIENT MONITORING
The Department Head, with assistance and support from the Grant Administrator, shall perform a risk assessment for each sub-recipient before passing along awarded funds, in accordance with 2 Code of Federal Regulations (“CFR”) §200.331, “Requirements for pass-through entities”. 10 GRANT REPORTING
Grants awarded to the City may require that progress, programmatic, and financial reports be submitted to the grantor. Accurate and timely reporting is critical to maintaining a good relationship with the grantor. Late or inaccurate reports may negatively impact current or future funding.
GRANT REPORTING PROCEDURE
a. Recipient departments must prepare timely and accurate progress, programmatic, or financial reports as the grantor requires.
b. Copies of all financial status and final reports prepared for submission to the grantor shall be provided to the Grant Administrator and Finance Director, along with the associated grant name and year, at the time of submission to the grantor.
c. The Finance Director will review the financial reports for content and quality and address any issues with the recipient department to better assist with future reports. d. The Grant Administrator will review any programmatic reports for content and quality and address any issues with the recipient department to better assist with future reports.
GRANT FILE MANAGEMENT, ACCESS AND RETENTION
The City Manager, Finance Director, Grant Administrator, or designee may review the files, activities, equipment, and facilities and interview relevant personnel and contracted entities of any City of Marysville project or program funded with grants awarded to the City.
1. FILE MANAGEMENT PROCEDURE
All department and master files associated with a grant award must maintain a file structure that includes the following five sections with clear separations between different fiscal years unless otherwise directed by the grantor:
a. Submittal (e.g., application guidance and a copy of the application) b. Research (e.g., statistical and other information used in preparation of and support of the grant)
c. Award (e.g., award letter, council agenda item, grant agreement, grant amendments, modifications, extensions, cancellations and terminations, and anything else related to the award)
d. Finance (e.g., account set up. purchase orders, invoices) e. Reports (e.g., reports to granting entity and evaluation components)
2. FILE RETENTION PROCEDURE
The City of Marysville maintains records for at least five years following the closure of its most recent audit report. If any litigation, claim, negotiation, audit, or other action involving grant records has been started before the expiration of the five years, the records must be retained until the action is completed and all issues that arise from it are resolved or until the end of the regular five-year period, whichever is later.
a. Grantors may require retention periods over five years. Departments must ensure they comply with retention requirements specified by each grantor. b. Retention requirements extend 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. c. Source documents include copies of all awards, applications, and required recipient financial and narrative reports. Personnel and payroll records shall consist of the time and attendance reports, personal activity reports, or equivalent documentation for all individuals reimbursed under the award.
11 GRANT CLOSEOUT
Upon completion of each grant award's grant term, the recipient department shall alert the Finance Director to place the fund and/or project in a no-posting status.
GRANT CLOSEOUT PROCEDURE
1. Upon completion of each grant period, the recipient department must prepare a memorandum for the Finance Director and Grant Administrator that identifies the grant's name and project number and describes the final disposition of the funds and required activities.
2. Upon reviewing the memorandum and satisfying any discrepancies, the Finance Director will update the accounting system and confirm grant closeout with the Grant Administrator.
3. The grant closeout memo shall be placed in the master file.
SINGLE AUDIT ACT REQUIREMENTS
The City is subject to the financial and compliance requirements of the Single Audit Act of 1984, which applies to all local and state governments spending more than $750,000 in federal financial assistance during a fiscal year. The purpose of the Act is to:
1. Improve the financial management and accountability of state and local governments regarding federal financial assistance programs.
2. Establish uniform requirements for audits of federal grants.
3. Promote efficient and effective use of audit resources.
4. Assure that federal departments and agencies rely upon and use audit work performed during a single audit rather than performing it themselves.
5. Under this Act, federal grants are included under an inclusive single audit program incorporated into the City's annual audit and financial report preparation process. During the audit, tests are made to determine the adequacy of the internal control structure, including that portion related to federal financial assistance programs, as well as to determine that the City has complied with applicable laws and regulations.
CITY’S POLICY REGARDING THE SINGLE AUDIT APPROACH
For federal grants included in the scope of the City’s single audit approach, it is the City’s policy that all financial and compliance issues have been met through the single audit, and follow-up audits to determine these issues are not necessary unless specifically related to findings or recommendations included in the single audit report. As noted above, the purpose of the Act is to establish uniform audit requirements, promote efficient use of audit resources, and assure that federal agencies rely upon audit work already completed; its purpose is not to audit local agencies twice. Accordingly, the City will strongly resist any efforts by federal agencies to duplicate audit work already performed in complying with Act requirements.
As such, whenever federal grantor agencies request final audits, the managing department should notify the Finance Department to ensure a consistent response.
GENERAL PROVISIONS
The City of Marysville reserves the right to change, modify, amend, revoke, or rescind all or part of this directive in the future.
12 EXHIBIT A
City of Marysville
Grant Information Checklist
(to be submitted to Finance Department)
Grant Identification Number: ________________________________________________________ Federal CFDA Number (if applicable): _________________________________________________ Program Title: ____________________________________________________________________ Federal/State Grantor: _____________________________________________________________ Pass-Through Grantor: _____________________________________________________________ Award Amount: ___________________________________________________________________ Term of Grant: ____________________________________________________________________ Nature and Purpose of Grant: ________________________________________________________ _________________________________________________________________________________ Method of Funding (Reimbursement, Advance, etc.): ____________________________________ Matching Requirement: ____________________________________________________________ Contact Person for Grant (City and Grant Agency):______________________________________ List Subrecipients: ____________________________________________________________________ Finance Department Use Only
Fund - Department - Account (Expense) Number in General Ledger: ________________________ Revenue Account Number in General Ledger: __________________________________________