SCC Grants Compliance Procedures | SCC

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SCC Grants Compliance Procedures

Department: Institutional Effectiveness
SCC Policy/Procedure Number: SPR7.9.6-2
OPR: Director of Grants and Contracts
Issued: 5/27/2022
Revised:
Approved SCC President/CEO: 6/24/2022
Reference KCTCS Policy: 5.3.6-P, 5.4.25-P, 7.9

Procedures

Once a grant award is accepted, the College accepts formal, legal responsibility to follow the rules and regulations of the grant, including requirements stated in the original request for proposal, the notification of award, and any other supplemental documentation, including the budget. Failure to comply with the terms and conditions could result in a finding of non-compliance and result in the following:

  • The College could be labeled as a high-risk grantee, which could result in suspension or termination of current grant projects, and/or impact the College’s eligibility for future grant funding (including federal financial aid).
  • Cash payments/reimbursements may be withheld until any given deficiency is corrected.
  • All or part of the costs for project activity or action that is not in compliance may be disallowed, meaning the College would have to reimburse the funding agency for disallowed costs.
  • Future awards for the project may be withheld.
  • Other legal remedies may be imposed.

For the purpose of the Grants Compliance Policy and Procedures, “project director” will include “principal investigator,” “grants manager,” “project manager,” and other titles for those individuals responsible for implementing and managing a specific grant.

Project Director Roles and Responsibilities

  • Completes project director training designated by the Department of Grants
  • Prepares and submits all project reports to funding agency by the due date and sends a copy of report to the Department of Grants
  • Oversees the daily operations of the grant project
  • Maintains compliance with all funding agency requirements and KCTCS and SCC policies and procedures
  • Communicates regularly with the Department of Grants and the Business Office
  • Facilitates strong communication with the funding agency’s program officer
  • Ensures that project meets goals described in project narrative
  • Collects Time & Effort Reports from staff, if necessary
  • Verifies completeness and accuracy of Time & Effort Certification forms
  • Initiates hiring process of staff to implement the goals of the grant
  • Procures goods and services following KCTCS and SCC policies and procedures and federal/state regulations
  • Evaluates the progress and monitors the measurable goals of the grant
  • If applicable, conducts monitoring of the sub-recipient
  • If needed, requests modifications and/or extensions, and follows the process for submitting the request as per funding agency instructions
  • Facilitates all steps for grant closeout, including retaining records according to KCTCS records retention and funding agency specifications

To meet these goals, the SCC Department of Grants will:

  • Implement procedures to promote consistent standards
  • Establish regular communication with project directors and the business office
  • Provide updated information and training regarding grants management to all project directors
  • Assist the project director with the human subjects review board (HSRB) process if project involves research with human subjects
  • Encourage project directors to proactively manage projects
  • Ensure VP of Administration is aware of grant amount, matching, and budgets, prior to submissions

Accepting the Award

  • As the Authorized Organizational Representative (AOR), only the SCC President, or president’s designee, can accept a grant award. The Department of Grants will work with the Office of the President to facilitate this process.
  • Upon receipt of award, the president or project director sends notification to the SCC Department of Grants.
  • The SCC Department of Grants obtains approval from KCTCS Legal Department (if necessary).
  • Upon approval by KCTCS Legal Department, the SCC Department of Grants obtains required signatures and returns documents to the funding agency.
  • A master grant records file is created by the SCC Department of Grants in a shared secure cloud server location accessible by the project director.

Announcing the Award

  • The project director prepares a draft press release for announcing the award inside and outside the College community and works with SCC Department of Grants and SCC Institutional Advancement to finalize and distribute the release. It is important to note that the message should focus on the work of the project and those who will benefit as opposed to the amount of the grant award. Public announcement of the award must be approved by Institutional Advancement before release.
  • Public announcements of awards must follow specific funding agency terms and conditions.
  • In addition, for certain federal grant awards (US Department of Labor, US Department of Health and Human Services, and US Department of Education), the Stevens Amendment must be followed in order to give the federal government credit for federally-funded programs. The College is required to disclose funding information on press releases, statements, requests for proposals, bid solicitations, and other documents that describe the programs funded in whole or in part with federal money. The SCC Department of Grants will provide Stevens Amendment training and will work with the project director to draft a statement to include the following information:
    • The dollar amount of Federal funds for the project and program
    • The percentage and dollar amount of the total costs of the project or program that will be financed by non-governmental sources
  • SCC Institutional Advancement will communicate with elected officials, as needed.

Grant Award Kick-off Meeting

  • The SCC Department of Grants will schedule and facilitate the initial post-award meeting/training, which will be attended by the project director and co-directors, if applicable. If appropriate, the project director’s chair, dean, or supervisor will be invited to attend to ensure department support and overview of the grant.
  • In addition, representatives from other College departments will be invited, as appropriate. These departments may include the Business Office, Human Resources, Institutional Research, Facilities, Information Technology, and/or the Office of Scholarships and Financial Aid.
  • During this meeting, the terms and conditions of the award will be reviewed. All narrative and financial reporting due dates will be reviewed at this time. The SCC Department of Grants can answer questions and arrange follow up with the funding agency’s program officer, should any questions remain.
  • The SCC PI Responsibilities Agreement will be discussed and initialed by the project director.

Grant Budget Set Up

  • The SCC Department of Grants will work with the project director and the Business Office to complete the GC1 - Grants & Contracts Accounts Internal Approval Form to set up the account codes for the grant budget. It is important to work with the SCC Department of Grants to ensure that the required accounts are used for reporting to the funding agency.
  • The project director will send a request to the Business Office to be added to the distribution list to receive the weekly grant budget summary and detail report for the grant award. This allows the project director to reconcile expenditures and remaining balances of grant funds.
  • The project director or grant personnel whose responsibilities include budget management, will establish a method of tracking grant project purchases as they are made. The SCC Department of Grants can supply a grant award budget spreadsheet template and training on the use of the spreadsheet, however the project director is free to use the tool of their choice.
  • The grant award budget accounts setup must comply with KCTCS’ chart of accounts.

Starting the Grant Master File

  • Grant files are subject to audit and must be kept in proper order.
  • The grant master file should include all administrative documents associated with applying for, administration of, and closeout of the grant contract as well as any documents necessary for record-keeping and audit purposes.
  • The master file will be set up electronically in a secure KCTCS OneDrive folder that is accessible to both the project director and the SCC Department of Grants.
  • The master file will include the following documentation:
    • Original Notice of Funding Opportunity or Request for Proposals
    • Program regulations and guidelines
    • Original proposal submission documents
    • Final revised proposal and budget, if amended
    • Original, fully-executed award documents and amendments or approvals
    • Memorandum of Understanding with partners, if applicable
    • In-kind, matching, and cost-sharing commitments included in budget
    • Project timeline, implementation timeline, or work plan from original proposal
    • Grant correspondence with the funding agency
    • Sub-grantee monitoring reports and other sub-grantee records, if applicable
    • Manually recorded project personnel timesheets, if required
    • Participant files
    • Audit reports
    • Program monitoring and evaluation reports
    • Progress and financial reports
    • Close-out documents
  • The Business Office will maintain the following documentation for grant files:
    • Invoices and copies of receipts for purchases made with grant funds
    • Time and effort certification reporting documents

Monitoring the Implementation of the Award

  • Requesting Modifications or Extensions
    • Most statement/scope of work (SOW) or budget modifications require pre-approval from the funding agency. If a project director desires to make any changes to the grant management plan, please notify the SCC Department of Grants and the Business Office. They will assist with the process of making the request and following the funding agency’s instructions for such a request.
    • Extension requests should be a last-resort measure. The goal in accepting a grant award is to complete the work and expend all funds by the grant’s end date. In some cases, an extension is warranted, but may be restricted to administrative closeout only. There may be an option for a no-cost extension. This is an extension that extends the end date of the grant. No new grant money is received and the scope of work does not change.
    • Approval for modifications or extensions is not guaranteed and must be approved by funding agency. Requests must be submitted prior to the grant end date, based the specific funding award terms and conditions.
    • Until written approval has been received from funder, costs and activities are subject to original terms and conditions of the award. Requests made after the due date may result in a reduction or loss of funds.
    • Purchasing activity after the grant end date will not be allowed to post to grant budgets.
  • Managing the Budget
    • Note that it is imperative that all grant funds are spent timely and prudently. Monitoring and tracking grant expenses is as important to the grant as completing the actual work. SCC is responsible for all grant funds awarded to the college.
    • Grant budget reports must be consistent with the project progress or narrative reports. If issues with project implementation arise that will impact the project budget, please contact the SCC Department of Grants and SCC Business Office as soon as possible and well in advance of report due dates.
    • As the project progresses, communicate periodically with the SCC Department of Grants and business office contact to:
      • Review the grant’s financial status
      • Receive help in interpreting budget reports
      • Address questions about fiscal management
      • Receive assistance with payroll procedures and forms for grant-funded personnel
      • Prepare financial reports for cost-share/matching funds, if applicable
  • Required Reporting to the Funding Agency
    • The project director is responsible for completing and submitting all required programmatic reports to the funding agency. The report must be submitted on time and all data must be accurate. The report must adhere to all requirements listed in the terms and condition of the grant. If data is required from another department such as the Office of Institutional Research or the Scholarship Office, please allow for enough time for those departments to compile the information.
    • When submitting a report to the funding agency, the Project Director must also notify the SCC Department of Grants that the report has been submitted and retain a copy in the secure KCTCS OneDrive master grant file folder.
    • The KCTCS Sponsored Projects Accounting (SPA) office is responsible for preparing and submitting all financial reports on time. The project director must provide SPA the information needed to complete the report, including submitting cost-sharing reports, if applicable.
  • Sub-recipient Monitoring
    • The SCC Departments of Grants will work with the project director, the Business Office, and the Office of General Counsel to create the sub-award agreement and to secure required signatures.
    • The project director is responsible for programmatic and financial monitoring of the sub-recipient to ensure program deliverables are met and expenditures are allowable according to funding agency requirements and KCTCS and SCC policies and procedures.
  • Records Retention
    • It is required to retain copies of the grant proposal, approved agreement, financial records documenting the receipt and expenditure of funds, and periodic required reports relating to federal and federal via state grants received by the College. The College adheres to Federal rules pertaining to retention requirements for grant agreements. See 2 CFR § 200.333 - Retention requirements for records.
    • Records are to be kept until any possible audit, under terms of the grant, is completed. For federal grants, records are required to be retained for three (3) years after the final expenditure report is submitted. State and local grants may have other requirements regarding the length of time records need to be retained. It is important to review and follow the records retention policy of the specific funding agency and terms and conditions of the award. During the retention period, the funding agency has the right to request information or access to grant records.
    • The SCC Department of Grants will archive the project director’s records, if needed.

Reviewed: 5/22/2023: non-substantive changes