Greenwood School District 50 and State Grant Procedures FY22
Account Number Structure and Detail Page 3
Accounting System Page 3
Administration Page 18
Allowability Procedures Page 19
Allowable Costs Page 19
Budget Page 19
Cash Management Procedures Page 20
Conflict of Interest Page 22
Control Procedures Page 3
District Finance Policy on UGG Page 11
Earmarking Page 21
Eligibility Page 20
Equipment and Inventory Page 8
Financial Management System Page 3
General Information Pages 2, 18
Grant Procedures Page 5
IDEA Page 23
Indirect Costs Page 19
Internal Control Memo Page 16
Internal Controls Page 4
Level of Effort (MOE) Pages 7, 21
Matching Page 21
Period of Performance Page 21
Procurement Procedures Page 20
Procurement, Suspension, Debarment Page 21
Reporting Page 22
School based Monitoring Page 10
School based Purchase Page 10
Screening and Process Page 20
Special Tests and Provisions Page 22
Subrecipent Page 22
Time and Effort Page 7,8
Travel Policy Page 22
The Federal Government’s Office of Management and Budget (OMB) has issued OMB Supercircular Uniform Grant Guidance (UGG) and related compliance supplement, codified at 2 CFR 200. UGG is intended to:
• Strengthen accountability for federal dollars by improving policies that protect against waste, fraud and abuse
• Reemphasize the importance of recipients achieving program objectives
• Shift from focus on compliance to focus on performance
• Support stronger internal controls through required written policies
As the pass through entity of federal funding, the SDE has updated the Assurances, Terms and Conditions document that is included in every federal and state grant award to subrecipients. The updated document includes, but is not limited to:
• References to UGG, replacing prior OMB Circulars, such as A 87, A 133 and others
• Time and Effort reporting
• Travel and related costs
• Record retention requirements
As a subrecipient of federal funding, Greenwood School District 50 (“the District”) is responsible for
• Managing every federal award with fidelity
• Developing internal policies and procedures to ensure effective management of the federal award and compliance with the terms and conditions of the grant award
• Having a compliant financial management system
• Establishing a budget of the costs required to manage the federal program
• Monitoring actual costs against the federal program budget
• Requesting prior approvals from the pass through entity (SDE) when changes are necessary to the federal program and related budget
• Preparing and submitting required reports on time
• Keeping abreast of changes in policies, procedures, or requirements
• Keeping the SDE informed about federal award performance and changes
It is the position of the Greenwood School District 50 Administration that the District will be in compliance at all times with the requirements outlined in the above authoritative publications and if any procedures of the District are in conflict with the requirements of the above publications then the requirements of the above publications will be followed.
Financial Management System
The District’s financial management system includes
• The District’s accounting system
• The District’s records documenting compliance with federal/state statutes, federal/state regulations, and federal/state award terms and conditions
• The District’s internal controls for accountability for and effective control over all funds, property, and other assets and resources
• The District’s written procedures for determining the allowability of costs in accordance with federal/state award
Accounting System
The accounting system encompasses the methods and records established to identify, assemble, analyze, classify, records and report the District’s transactions and to maintain accountability for the related assets and liabilities. An effective accounting system gives appropriate consideration to establishing methods and records that will:
1. Identify and record all valid transactions.
2. Describe on a timely basis the transactions in sufficient detail to permit proper classification of transactions for financial reporting.
3. Measure the value of transactions in a manner that permits recording their proper monetary value in the financial statements.
4. Determine the time period in which transactions occurred to permit recording of transactions in the proper accounting period.
5. Present properly the transactions and related disclosures in the financial statement. The District uses Infinite Visions financial software for the recording and reporting of all financial transactions.
Account Number Structure and Detail
The SDE publishes a Financial Accounting Handbook and a Funding Manual which serves as the basis for the account code structure used by the District.
Account codes consist of 18 digits – two strings of three digits followed by a string of five digits, a string of three digits and finally four digits as illustrated below:
XXX.XXX.XXXXX.XXX.XXXX
Fund Number.Function.Object.Location.Modifier
Control Procedures
Control procedures encompass those policies and procedures Administration has established, in addition to the control environment and the accounting system, to provide reasonable assurance that specific District objectives will be achieved. Control procedures pertain to:
1. Proper authorization of transactions and activities.
2. Design and use of adequate documents and records to help ensure proper recording of transactions and events, such as monitoring the use of pre numbered documents, purchase orders, and travel authorization and reimbursement process.
Internal Controls
1. Provide adequate safeguards over access to and use of assets and records, such as secured facilities and authorization for access to computer programs and data files.
2. Independent checks on performance and proper valuation of recorded amounts, such as clerical checks, reconciliations, comparisons of assets with recorded accountability, computer programmed controls, administrative review of reports that summarize the detail of account balances, and user review of computer-generated reports.
3. Reviews of expenditures to ensure allowability of costs for the fund being utilized (as described in the grant document and in the SDE annual Funding Manual), reasonableness of purchase and receipt of goods and/or services for achieving the program objectives, and availability of funds as planned in the budget. This includes reviews of salary expenditures to ensure appropriate staff are being utilized for achieving program objectives and as planned in the budget. This review is documented by sign offs by the appropriate fund manager on forms and reports such as:
a. Purchase orders
b. Check requests
c. Purchasing card transaction summaries
d. Expense reports
e. Time sheets
f. PARs and certifications
g. Invoices
h. Employee Positions and Pay reports
i. Contractor services contracts
j. Other forms and/or reports may be required in addition to those listed above.
4. Maintain an Equipment management system that includes
a. Detailed property records
b. Documentation of periodic physical inventory c. Controls to prevent loss, theft and damage
Grant Procedures
A grant represents funds requested from a federal, state or private source. The grant is a commitment from the source to provide funds for specified purposes.
For Federal grants and any State grants requiring claims: 1. Application and award:
a. The District grant coordinator completes the application form (“Plan”) in the format prescribed by the SDE, providing narrative and budget data for the programs/activities planned to utilize the funding
i. The District school principal provides narrative and budget data for the programs/activities planned for the funding allocation intended for the respective locations.
ii. The District grant coordinator reviews the narrative/budget from the school to ensure compliance with the objectives of the funding sources and the mission/goals/objectives/requirements of the District.
iii. The District grant coordinator provides narrative and budget data for the programs/activities planned for the funding, ensuring compliance with the objectives of the funding source and the missions, goals, objectives, and requirements of the District.
b. The District grant coordinator obtains required Superintendent and CFO/Director of Finance signatures and submits application to SDE.
c. The District grant coordinator answers any inquiries and resolves any issues from the SDE to enable plan approval.
d. The SDE will issue a Grant Award Notification (“GAN”) containing
i. Federal Award Identification Number (FAIN)
ii. Total amount of the federal award (SDE’s total award)
iii. The amount of the District’s allocation
iv. The District’s Data Universal Numbering System (DUNS) number
v. Period of Performance
vi. Terms, Conditions, and Assurances (may be a separate document)
vii. Signature of State Superintendent of Education
e. The District grant coordinator will ensure the District Superintendent receives the issued GAN
i. GAN requires Superintendent’s signature
ii. Terms, Conditions, and Assurances, requires Superintendent and CFO or Director of Finance signature.
f. District Superintendent’s signature on GAN indicates District acceptance of award.
i. Signed GAN must be returned to SDE
ii. Copy of signed GAN must be provided to Director of Finance for grant file
2. Grant Budget
a. The District grant coordinator will provide a complete copy of the grant plan document to Finance.
b. The Director of Finance and grant personnel will ensure the grant budget is entered into a spreadsheet in the appropriate function and object categories, based upon the program/activity expenditures in the grant plan document.
c. The District grant coordinator will review the spreadsheet and Infinite Visions general ledger to monitor budget and actual expenditures with the assistance of the Finance office as appropriate.
i. The District grant coordinator will monitor and identify any needed budget amendments or any necessary journal entries for correction of expenditure coding.
3. Grant Expenditures
a. Prior to approval for payment, the District grant coordinator will review all grant purchases (including personnel) to ensure
i. Allowability of costs for the fund being utilized (as described in the grant plan document, SDE’s Assurances, Terms, and Conditions document, and in the SDE yearly Funding Manual).
ii. Reasonableness of purchase and receipt of goods and/or services for achieving program objectives as outlined in the grant plan document.
iii. Availability of funds as planned in the grant budget.
b. Once approved and submitted for payment by the District Grant Coordinator,
i. Accounts Payable/Finance will review the expenditure package (to include, at a minimum, an invoice/travel document and purchase order/check request form) to verify that proper documentation is included for the type of expenditure
ii. Payroll will review timesheets and/or additional wage forms for use of correct pay related object codes.
4. SDE requires use of Grants Accounting Processing System (GAPS) for all federal awards
a. GAPS Budget
i. The SDE will enter the total District award allocation amount in GAPS.
ii. The District grant coordinator will enter the allocated grant budget in GAPS, in the appropriate function and object categories, based upon the program/activity expenditures in the grant plan document.
iii. Once the District grant coordinator “submits” the allocated budget in GAPS, the District grant coordinator will notify the Director of Finance of the submission.
iv. Once notified of the completion of the budget allocation by the District grant coordinator, the Director of Finance will review for function/object appropriateness and “Approve” or “Return” the budget in GAPS.
1. If “Returned” by the Director of Finance, the Director of Finance will notify the District Grant Coordinator, who must change/correct the issues identified and resubmit.
2. Once “Approved” by the Director of Finance, the SDE must “Approve” or “Return” the allocated budget in GAPS.
a. If “Returned” by the SDE, the District grant coordinator, must change/correct the issues identified and resubmit (steps iii and iv are repeated).
b. GAPS Expenditure Reimbursement Claims
i. Once the allocated budget has been approved by the SDE, the Director of Finance/Grant Coordinator can enter District expenditures, by quarter, in the GAPS system and “Submit.”
1. The Director of Finance ensures that the GAPS and approved budgets are in agreement by Function and Object Codes
2. The Director of Finance notifies the District grant coordinator of any identified issues with actual expenditures versus budget. The District grant coordinator will correct identified issues in a timely manner to ensure the District’s maximum reimbursement of expenditures.
ii. Once the Director of Finance submits the expenditure claim for the quarter, the District Financial Coordinator reviews and will either “Approve” or “Return” the expenditure claim in GAPS.
1. If “Returned” by the Financial Coordinator, the Financial Coordinator will notify the grant coordinator or the Director of Finance, who must change/correct the issue identified and resubmit.
2. Once “Approved” by the Financial Coordinator, the SDE processes the expenditure claim for payment to the District.
3. The grant coordinator and Director of Finance work together to ensure that claims match receipts/deposits to complete the grant spending cycle.
5. Maintenance of Effort and/or Excess Costs documentation: the Director of Finance is responsible for calculating and maintaining MOE and Excess Costs information. For IDEA, the Office of Special Education Services MOE Calculator will be utilized to record MOE for IDEA grants. For Title I, the Director of Federal Programs and Director of Finance will work collaboratively to ensure calculations are prepared and documented in SDE prescribed format and are retained for future reference.
6. Time and Effort Certification: Salaries and wages paid for employees who work on a single federal cost objective must be supported by periodic certifications that the employees worked solely on that activity for the period covered by certification. These certifications must be prepared semi annually (every six months) and be signed by the employee and supervisory official who has firsthand knowledge of the employee’s work. The certification form must include the single federal cost objective and the dates of the period being certified. It will be the responsibility of the Director of Federal Programs to identify employees who require a certification, collect the completed certification forms and maintain certification documentation for all grants except for Special Education, Adult Education, CATE, and McKinney Vento. The Director of Special Education, Director of Adult Education, and Technology Center Director will be responsible for identifying employees, collecting the certification forms, signing the certifications, and maintaining the certification documentation for their designated grants. The Finance Office will be responsible for identifying employees, collecting the completed certifications and maintaining the certification documentation for the McKinney Vento and JROTC grants.
A blanket semi annual certification form may be used for certain employees working on the same single federal cost objective. The blanket form should include the name of each employee, site information, period of service and the signature of the supervisory official having first hand knowledge of the employee’s work and the date of his/her signature.
For the first semester of the fiscal year, semi annual and blanket semi annual certification forms will be collected by January 31 for the prior calendar year period beginning July 1st through December 31st
For the second semester of the fiscal year, semi annual and blanket semi annual certification forms will be collected by July 31st for the period beginning January 1st through June 30th.
For employees who are paid for additional work outside of contract hours and work on a single cost objective, a timesheet may be used for time and effort reporting. The timesheet must include the employee’s name, program/cost objective, time in/out, hours worked, employee’s signature and supervisor’s signature. The grant coordinator is responsible for collecting, maintaining and reconciling timesheets.
7. Personnel Activity Report (PAR): Employees who work with different student populations (multiple cost objectives) must support the distribution of their salaries or wages by completing personnel activity reports. These reports must reflect an after the fact distribution of actual activity, must account for the total activity for which the employee is compensated, must be prepared at least monthly, coinciding with one or more pay periods, and must be signed by the employee and direct supervisor. PARs will be due by the 15th of each month for the prior month’s activity. At least quarterly, comparisons will be made of the actual costs (based on monthly activity reports) to budgeted distribution. The grant coordinator is responsible for collecting, maintaining and reconciling PARs.
Substitutes filling in for employees who are paid out of Federal funds will be charged to the same federal fund, as their duties and classroom populations will be the same as the employee completing the semi annual certification or PAR.
8. Time and Effort Documentation During Extraordinary Circumstances: Employees who continue to be paid in full or in part with federal funds during a time of alternative work and learning arrangements must keep specific documents to demonstrate the amount of time they spend on grant activities. Suggested areas of documentation include:
a. Activities or monitoring that occur as it relates to remote learning and the federal program;
b. Professional development that the employee takes to increase their knowledge to support the federal program;
c. Planning for activities and monitoring that will occur when the employee reports back to work.
d. Other activities that the employee is performing to continue compliance with the federal program.
9. Equipment: The District handles purchases for Federal and State grant expenses in the same manner it handles all expenditures. Since the controls are the same regarding federal funds, state funds, and general purchases, refer to the District’s Procurement Code for purchasing procedures and additional information. Equipment purchases with grant funds are initiated and approved by the Grant Coordinator. Grant personnel create a purchase requisition in the District’s accounting system using the grant account number and then it is routed in the system to the Grant Coordinator for approval. The Purchasing Department reviews for proper quotes or bids, if applicable, and create a purchase order. The purchasing clerk sends the purchase order to the vendor to order the item(s).
All equipment is delivered to grant personnel. When items are received, grant personnel mark the items as received in the accounting system. Accounts Payable compares the PO to the invoice and processes the payment. All applicable equipment/inventory items are logged on the Inventory Control Form by grant personnel The grant coordinator/director is responsible for identifying
equipment/inventory items, maintaining required documentation, and conducting the annual inventory. These forms are kept by fiscal year in the appropriate grant office.
Equipment purchases for $5,000 or over are maintained on the Fixed Asset/Deprecation Schedule by the Finance Office.
Equipment and Inventory Management 2 CFR Part 200
As a part of the purchasing policy and procedures, Greenwood School District 50 maintains an Equipment Management System in accordance with:
• Detailed property records
• Documentation of periodic physical inventory
• Controls to prevent loss, theft and damage
2 C.F.R §200.62 , 2.C.F.R §200.313
Disposition Policy for Materials Purchased from Federal Programs
All non-consumable materials over 100.00 are part of the inventory system for Federal Programs.
1. As an item is received, it is tagged with a district tag number and entered into the inventory system at the District Office. For large quantity purchases that require an electronic bar code system, items are barcoded and inventoried annually at the school level with the current Media Center inventory software.
2. Monthly credit card reports or purchase orders are highlighted each month with items that require an inventory tag. The tag number is written on copies of these forms and scanned for easy cross reference.
3. Check out forms are submitted to individuals in possession of inventory item. All documentation for the item is scanned with the check out form and filed electronically. (Check out form, Purchase Order, Quotes, Invoices, Credit Card Report Form, and Account Detail Inquiry)
4. Each year on a specified date by the Federal Programs Department, a reconciliation process is completed for each school. A computer generated list is provided to the principals at the school level by the district for use in the inventory.
5. End of year reconciliation reports are provided by the Media Specialist at each school for other inventoried kits or books.
6. Any missing materials will be reported on a police report for documentation of loss.
During the year, any materials that are damaged should be reported to the Federal Programs Department. The item along with the appropriate form for disposal will be sent to the District Office. Any technology equipment that is damaged will be submitted to the IT Department for evaluation and final confirmation of disposal.
10. Contracted Services: In some instances it will be necessary to contract for services to carry out a specific objective. The grant coordinator/director is responsible for developing and awarding contracts. A W 9 Form is required from all vendors before any service is obtained. Stipends for contracted services must have documentation of work performed. Specific procedures for awarding contracts that are not exempt from procurement may be found in the District’s procurement manual. All contracted services should be charged to a 300 level object. Contracts will include who will provide the services, what services will be provided, when the services will be provided and where
the services will be provided. Contracts should include a beginning and ending date on the form. Contractors/vendors will supply a detailed invoice at the end of each month with the rates/fees established in the contract and will be paid by Accounts Payable
11. District and Entity Information Management (DEIM) System: The SC Department of Education (SCDE) provides a system, which is located in the Member Center, on their website called DEIM. The District is required to assign appropriate roles to employees in DEIM. The SCDE uses the information in this system to communicate with District personnel. The Director of Finance and Director of Computing Services review and update, if necessary, the staff information included in DEIM in July of each year or when a change in personnel is made during the year.
12. School-based Monitoring
Greenwood School District 50 supports the implementation of grants through the regular monitoring and support at the school level to ensure compliance with all grant regulations through the following methods:
• Federal programs calendar with compliance information
• Enrich Portal for collection of interventionist records
• Site visits for compliance and achievement checks
Greenwood School District 50 will be in compliance at all times with the requirements outlined in the above authoritative publications and if any procedures of the District are in conflict with the requirements of the above publications then the requirements of the above publications will be followed.
Greenwood School District 50 maintains all records for five years plus the current year. Files are stored and marked with destruction dates. The school maintains their records for the current year and prior year at the school level. Each year, one set of records from a designated year will be shipped to the district warehouse and will remain until the date of destruction. The school will complete the Destruction of Records form with their submission.
13. School-based Purchasing Requests
Any expenditures that are incurred at the school level are submitted to the office of Federal Programs for review. All requests are matched against the approved project. Additionally, a review is conducted to determine if the items are:
• Reasonable in its nature, and does not exceed that which would be spent by a “prudent person”
• Necessary for the performance of the Federal Award
• Conforms to limitations/exclusions in the law or the Uniform Guidance
• Comparable to market prices for the geographic area
• If a purchase order is not required, the designee or grant coordinator will initiate the purchase. When the invoice is received, the grant coordinator or designee assigns an account number and approves the invoice. The approved invoice is submitted to accounts payable for review and payment.
• All p card purchases are compiled in a monthly report and approved by the grant coordinator. The report is submitted to the Procurement Director for review. After review, the Procurement Director records the p-card transactions to the general ledger.
• If the purchase is over $500, a purchase order is recommended (unless a p card is used). If a p-card is used, a purchase order is required if the purchase is $2,500 or over.
• A purchase requisition is created in the accounting software and then approved in the software by the grant coordinator. After approval, a purchase order is created by the purchasing clerk in the Business Department and approved by the Superintendent and Assistant Superintendent for Business.
When the item is received, it is marked as received in the accounting software by the personnel who created the purchase requisition. After the item has been received in the accounting system, accounts payable will match the purchase order to the invoice and the invoice will be reviewed and paid.
District Finance Policy on Uniform Grant Guidance
Subpart D – Post Award Requirements
A. Performance measurement – 200.301
The District will provide the grantor agency with data to measure all the required performance goals established by the grantor agency. When applicable, cost information will be provided to demonstrate cost effective practices. The District will also use the data from performance measures to improve program outcomes, share lessons learned with other District programs, and spread the adoption of promising practices.
B. Financial Management – 200.302
The District will maintain a financial management system (Infinite Visions) sufficient to permit the preparation of reports required by general and program terms and conditions of the grantor agency; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used in accordance with all local, state and federal statutes, regulations and terms and conditions of the grantor agency. The District will expend and account for all grant awards in accordance with all local, state and federal laws and procedures as required by the grantor agency.
The District will maintain a Fund Accounting system with transactions on all grant awards maintained separately and all awards clearly identified. Federal awards will include the award identification number and year, the CFDA title and number, the name of the Federal Agency, and the name of the pass through entity if any. The District will maintain effective control over, and accountability for, all funds, property, and other assets as required from the grantor agency. The District will maintain sufficient supporting documentation on all funding sources and uses. The District will maintain a fixed asset accounting system to safeguard all fixed assets of the District. The District will maintain written procedures covering the acquisition, recording, and transfer or disposal of all fixed assets and the District performs an annual inventory of fixed assets. The District will maintain budgetary accounting to identify budget variances within funding sources and funding uses for each grant award.
C. Internal Controls – 200.303
The District will establish effective internal controls over the grant award that provides reasonable assurance that the District is managing the award in compliance with all federal, state and local statutes, regulations and terms and conditions of the award.
D. Fidelity Bond Coverage – 200.304
If the District is found to lack sufficient coverage to protect the Federal Government’s interest as determined by the Federal awarding agency, the District will ascertain adequate fidelity bond coverage from bonding companies holding certificates of authority as acceptable sureties, as prescribed in 31 CFR Part 223 “Surety Companies Doing Business with the United States.”
E. Payment – 200.305
For all grant awards, the District will request reimbursement of expenditures on at least a quarterly basis unless the grantor agency provides different requirements. No advanced funding will be requested, however; some local grantor agencies fully fund their grant awards upfront and expenditures reports are filed at year end. The District will fully comply with all grantor regulations concerning payment methods.
F. Cost Sharing 200.306
For all federal grant awards, any shared costs or matching funds and all contributions, including cash and third-party in-kind contributions, must be accepted as part of the District’s sharing or matching when such contributions meet all of the following criteria:
• Are verifiable from the District’s records;
• Are not included as contributions for any other Federal award;
• Are necessary and reasonable for accomplishment of project or program objectives;
• Are allowable
• Are not paid by the Federal Government under another Federal award
• Are provided for in the approved budget when required by the Federal awarding agency; and
• Conform to other provisions of this part, as applicable
G. Program Income 200.307
The District will seek to generate program income whenever possible to defray program cost where appropriate. Any cost incidental to the generation of program income will be deducted from gross income to determine program income. Program income will be used for current costs unless authorized otherwise by the Federal awarding agency. Program income will be deducted from total allowable cost to determine the net allowable cost. Accounting for and use of program income will be verified with the Federal awarding agency for authorization when not clearly defined.
H. Revision of budget and program plans 200.308
The original budget and any revisions to the budget will be related to performance for program evaluation whenever appropriate. Prior approval from the Federal awarding agency is required for budget and program plan revisions. The District will comply with the ”Code of Federal Regulations,”
Section 200.308 part (c)(1)(i) through (viii) as needed for prior approval with the Federal awarding agency for non construction awards and with Section 200.308 part (g)(1) through (5) as needed for prior approval with the Federal awarding agency for construction awards.
I. Period of performance 200.309
Only allowable costs incurred during the period of performance will be charged to the program and any costs prior to the Federal award as authorized by the Federal awarding agency.
J. Insurance coverage 200.310
Adequate insurance coverage, (similar to other property coverage in the District), will be maintained on all real property and major equipment acquired or improved with Federal funds.
K. Real Property 200.311
Real property will be used for the originally authorized purpose as long as needed for that purpose. The District will not dispose of or encumber its title or other interest during that time. Prior to the disposal of real property when it is no longer needed, the District will obtain authorization and
instructions from the Federal awarding agency within the statute of limitations of the grant award and archival time period.
L. Federally-owned and exempt property 200.312
The District will submit an annual inventory list of all federally owned property, if any, in its custody to the appropriate Federal awarding agency as requested. If any such property is no longer needed, it will be reported to the appropriate Federal awarding agency for further utilization in conjunction with grant period and archival timelines.
M. Equipment 200.313
Equipment acquired under a Federal award will vest with the District subject to the following obligations and conditions:
• Use of the equipment for the authorized purposes of the project during the period of performance or until the property is no longer needed for the purposes of the project.
• Not encumber the property without approval of the Federal awarding agency or pass-through entity.
• Use and dispose of the property in accordance with all guidelines established by the Federal awarding agency and in the Code of Federal Regulations Section 200.313 part (3)(b), (c), and (e).
N. Supplies 200.314
Title to supplies will vest with the District upon acquisition. Upon termination or completion of the project, unused supplies exceeding $5,000 in total aggregate value will be retained and used for other Federal award projects.
• Use and dispose of the supplies exceeding $5,000 in total aggregate in accordance with all guidelines established by the Federal awarding agency and in the Code of Federal Regulations Section 200.313 part (3)(b), (c), and (e).
O. Intangible Property 200.315
Upon acquisition, title to intangible property vests with the District.
• Use of the property for the authorized purposes of the project during the period of performance or until the property is no longer needed for the purposes of the project.
• Not encumber the property without approval of the Federal awarding agency or pass through entity.
• Use and dispose of the property in accordance with all guidelines established by the Federal awarding agency and in the Code of Federal Regulations Section 200.313 part (3)(b), (c), and (e).
P. Property trust relationship 200.316
Real property, equipment, and intangible property acquired or improved with a Federal award will be held in trust by the District for the beneficiaries of the project or program under which the property was acquired or improved.
Q. Procurement Standards 200.317-327
District Procurement Policy and Procedures will apply to all Federal awards the same as non Federal funds. Please refer to our Procurement Policy for the sections referenced above covering:
• Oversight of contractor’s performance
• Conflicts of interest
• Economical approach to purchases and avoidance of unnecessary or duplicative items
• Inter governmental and inter entity agreements where appropriate
• Purchase of Federal excess and surplus property to reduce cost
• Value engineering
• Contractor awarding criteria
• Records retention and requirements (we utilize State of SC recommendations for school districts)
• Use of time and materials type contracts
• Competition of transactions, solicitations, prequalified requirements
• Methods of procurement
• Contracting with minority businesses (See also our Minority Business Development Plan)
• Procurement of recovered materials
• Contract cost and price
• Bonding requirements
• Contract probisions
R. Financial Reporting 200.328
The District will comply with all Federal, State and local annual financial reporting requirements. The annual external audit due to the SCDOE by December 1st each year will be posted to the District’s website.
S. Monitoring and reporting program performance 200.329
Federal award programs will be monitored the same as all funding sources for the District. All Federal programs are assigned a grant coordinator by and for the District with overall responsibility of the program. The District’s Finance Department also assist in monitoring of all purchases for compliance with all Federal, State and local requirements, budget compliance, and proper ledger account coding. All claims for reimbursement are reviewed and filed through the District’s Finance Department at least quarterly.
T. Reporting on real property 200.330
The District will comply with all Federal, State or local reporting requirements for real property purchased or improved with Federal award funds.
U. Sub-recipient and contractor determinations 200.331
Some Federal awards for the District may include the use of a sub-recipient or a contractor as part of the program. If the program includes the use of a sub recipient or a contractor, the District will comply with all additional requirements imposed by the Federal awarding agency. The District will follow all Federal guidance in making the determination of a sub recipient or a contractor relationship.
V. Requirements for pass through entities 200.332
If a Federal program involves a sub-recipient and the District serves as a pass-through entity, the District will notify the sub at the time of the sub award. The District will provide the sub with all of the information that is available as required in the Code of Federal Regulations Section 200.331.
W. Fixed amount sub awards 200.333
The District will request prior approval from the Federal awarding agency before providing any sub awards based on fixed amounts. The sub-award will have to meet the requirements for fixed amount awards as defined in the Code of Federal Regulations under section 200.201.
X. Retention Requirements for Records 200.334
The District will maintain all financial records and supporting documentation for a period of not less than seven years beyond the current fiscal year. Certain payroll records and others considered as permanent records will be retained indefinitely. Records in litigation will be maintained until all litigation, claims and audit findings involved have been satisfied. Records will be maintained in according with any grantor agency requirements if longer than the seven year period.
Y. Request for transfer of records 200.335
The District will comply with any Federal awarding agency’s request for transfer of records or extended record retention request as deemed necessary.
Z. Methods for collection, transmission, and storage of information 200.336
The District current archives all records in hard copy at this time. At such time the District elects to move to an electronic format, the records will be in open and machine readable formats whenever practical.
AA. Access to records 200.337
The District will provide access to all Federal, State or local authorities for all pertinent records related to the award or program. Access to District personnel will also be available as needed to facilitate this process.
BB. Restrictions on public access to records 200.338
CC. Remedies for noncompliance 200.339
DD. Termination 200.340
EE. Notification of termination requirement 200.341
FF. Opportunities to object, hearings and appeals 200.342
GG. Effects of suspension and termination 200.343
HH. Closeout 200.344
The District will complete all actions necessary to closeout a program as required by the Federal awarding agency. All closeout actions will be completed within the lessor of 90 days or sooner if required by the Federal awarding agency. The District will promptly refund any remaining unused advance or over claims due back to the Federal awarding agency. The District will account for any real and personal property acquired with Federal funds or received from the Federal Government in accordance with Section 200.310 Insurance Coverage through 200.316 Property trust relationship and 200.329 Reporting on real property.
II. Post closeout adjustments and continuing responsibilities 200.345
JJ. Collections of amounts due – 200.346
Amounts determined due back to the Federal awarding agency during the closeout process will be repaid within 90 days of demand by the Federal awarding agency.
GREENWOOD SCHOOL DISTRICT 50
FEDERAL/STATE/LOCAL GRANT AWARDS
INTERNAL CONTROL MEMO
Greenwood School District 50 (“District”) is aware of the importance of effective internal control. We consider the Committee of Sponsoring Organizations of the Treadway Commission (“COSO”) requirements while developing the internal controls for each of the District’s special revenue programs. The COSO requirements are listed below.
Internal Control Component Principles
Control environment
Risk assessment
Control activities
1. Demonstrate commitment to integrity and ethical values
2. Ensure that board exercises oversight responsibility
3. Establish structures, reporting lines, authorities and responsibilities
4. Demonstrate commitment to a competent workforce
5. Hold people accountable
6. Specify appropriate objectives
7. Identify and analyze risks
8. Evaluate fraud risks
9. Identify and analyze changes that could significantly affect internal controls
10. Select and develop control activities that mitigate risks
11. Select and develop technology controls
12. Deploy control activities through policies and procedures
Information and communication
13. Use relevant, quality information to support the internal control function
14. Communicate internal control information internally
15. Communicate internal control information externally
Monitoring 16. Perform ongoing or periodic evaluations of internal controls (or a combination of the two)
17. Communicate internal control deficiencies
Greenwood School District 50’s internal controls are the processes designed to provide reasonable assurance regarding the achievement of the district’s objectives relating to operations, reporting and compliance. These processes are affected by the Board of Trustees, district leadership and other management personnel and staff. Administration is responsible for maintaining an effective internal control system and communicating the expectations and responsibilities to all staff members as part of the internal
There is a direct relationship between the district’s objectives (operations, reporting and compliance), the components of the internal control system (listed above) and the district’s structure. Objectives represent what the district strives to achieve. Components of the internal control system represent what is required in order to achieve the objectives.
The district’s objectives relating to operations, reporting and compliance are as follows:
Operations Objectives
• Provide opportunities for the success of all students by providing a high quality and comprehensive instructional program, to include related arts and athletics
• Provide high quality, safe and secure facilities
• Implement initiatives that reinforce the use of technology as a tool for instructional improvement and improvement of student achievement
• Review/analyze, on an on going basis, the effectiveness and efficiency of the district’s operational processes for continuous improvement.
• Pursue all funding sources and effectively and efficiently utilize funds for the optimal support of vision, mission goals and the overall operations of the district.
• Maintain fiscal responsibility and stability
Reporting Objectives
• Utilize a variety of conventional and technological means to improve communication with all facets of the school and business community.
• Provide reliable, timely and transparent reporting of the district’s financial and non financial information as required by local, state and federal agencies as well as requirements by the district’s policies and procedures.
Compliance Objectives
• Maintain compliance with local, state and federal laws and regulations.
• Maintain compliance with district policies and procedures.
GENERAL INFORMATION;
Greenwood School District 50, (“the District”), qualifies for various types of federal, state, and local grants and funding based on many factors including competition, performance, and demographics. All grants and special funding programs are to be administered in accordance with the terms of the specific grant’s guidance as provided. All expenditures are to be in compliance with all provisions as provided in the grant.
ADMINISTRATION;
The program director (“Grant Coordinator”) oversees the preparation and submission of the annual budget to the appropriate grantor agency albeit the South Carolina Department of Education (“SCDE”), or another direct Federal, state, or local agency in accordance with all grantor agencies requirements. The Grant Coordinator is also responsible for the monitoring and oversight of all fund expenditures. The Finance Department works with each Grant Coordinator in preparing the budget and approves the budget for submission to the appropriate agency. The Finance Department monitors all special revenue fund activity and files reimbursement claims on all special revenue funds with the appropriate agency as required.
The Grant Coordinators prepare a project proposal and submit it to the SCDE, appropriate Federal awarding agency, or local awarding agency where required. After the proposal is approved by the awarding agency, the District can begin filing for reimbursement of expenditures. The Finance Department maintains all reimbursement requests, budget, and expenditure records. All expenditures and budget adjustments must be approved by the Grant Coordinator. The Finance Department always monitors and assists as needed with all revenues and expenditures. Initial budget loads are prepared by the Grant Coordinator and approved by the Finance Department upon notification. Budget loads and modifications take place in the GAPS system unless otherwise notified by the SCDE. The Grant Coordinator aligns staff as needed by location and works with the HR department to determine salary levels. For all other expenditures, the Grant Coordinator approves purchases. Purchase requisitions over $500 are then entered into the District’s purchasing system except for purchasing card purchases. If a purchasing card is used, a purchase requisition is entered into the purchasing system if the purchase is over $2,500. The Procurement Department reviews all requisitions and POs for accuracy and purchasing compliance. The District’s Procurement Code applies to all purchases and may require additional approval. Upon approval, the PO is forwarded to the vendor by the Procurement Department. When the supplies or goods ordered are received, proof of receipt is submitted within Infinite Visions to the Finance Department, (“AP” department). AP then matches the invoice to the approved PO and proof of receipt and processes the invoice for payment. The Grant Coordinator and the Finance Department all monitor the program expenditures for compliance to the budget and grant document. The Director of Finance completes the reimbursement for expenditures, (in GAPS if required), and forwards it to the Financial Coordinator for approval and submission, (to the SCDE via GAPS if required), for processing and payment. Funds are received under the same procedures used for receipt of all funds in the Finance Department.
