Table of Contents: Chapter 8
[+]812 GRANTS MANAGEMENT 02/23/2018
812.1 Purpose
The intent of this policy is to provide procedures to manage subawards and monitor activities of subrecipients of programs funded by Office on Violence Against Women (OVW) and received by the City of Lee's Summit to ensure that subawards are used for authorized purposes, in compliance with laws, regulations, and terms and conditions of the award; and that established subawards performance goals are achieved.
812.2 Accounting Responsibilities
Where the performance of a program or one of its components is delegated to a subrecipient, the City, as direct recipient, is responsible for all aspects of the program including proper accounting and financial record keeping by the subrecipient. Responsibilities include the accounting of receipts and expenditures, cash management, the maintaining of adequate financial records, and the refunding of expenditures disallowed by audits.
l) Reviewing Financial Operations — The City should be familiar with, and periodically monitor, their subrecipients' financial operations, records, systems, and procedures. Particular attention should be directed to the maintenance of current financial data.
2) Recording Financial Activities - The subrecipient's award or contract obligation, as well as cash advances and other financial activities, should be recorded in the books of the City in summary form. Subrecipient expenditures should be recorded on the books of the City or evidenced by report forms duly filed by the subrecipient. Non-Federal contributions applied to programs or projects by subrecipients should likewise be recorded, as should any program income resulting from program operations.
3) Budgeting and Budget Review - The City should ensure that each subrecipient prepares an adequate budget on which its award commitment will be based. The detail of each project budget should be maintained on file by the City. The City should track actual costs compared to budgeted costs throughout the grant period.
4) Accounting for Non-Federal Contributions The City will ensure that the requirements, limitations, and regulations pertinent to non-Federal contributions are applied.
5) Audit Requirements — The City must ensure that subrecipients have met the necessary audit requirements required by the City and OVW.
6) Reporting Irregularities — The City and their subrecipients are responsible for promptly notifying OVW, the OIG, and the Federal cognizant audit agency of any illegal acts, irregularities and/or proposed and actual improper actions. Please notify GFMD at 1-888-514-8556 if any irregularities occur. Illegal acts and irregularities include conflicts of interest, falsification of records or reports, and misappropriation of funds or other assets.
7) Debarred and Suspended Organizations — The City and subrecipients must not award or permit any award at any level to any party which is debarred or suspended from participation in Federal assistance programs. Excluded or disqualified individuals and organizations can be found at www.sam.gov.
812.3 Program management and monitoring
The City Prosecutor and the Chief of Police or his or her designee will meet with all subrecipients on a quarterly basis to ensure subawards are used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. The City Prosecutor will monitor all subrecipient activities that are performed in the Courthouse, review all programmatic reports required by the subrecipient, and will conduct site visits to subrecipient sites on an as-needed basis throughout the program. The Chief of Police or his or her designee will monitor all subrecipient activities that are performed in conjunction with the Lee's Summit Police Department. The subrecipient will allow examination or provide all necessary records to ensure compliance with program activities and present quarterly reports on performance activities.
812.4 Follow-up
The City will follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass through entity detected through audits, on-site reviews, and other means.