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Grants

Policy and Procedures guide for Grants
*Word Format

Christi Eversole
Director of Grants & Contracts
(270) 686-4552 Office
(270) 686-4496 Fax
christi.eversole@kctcs.edu

INTRODUCTION

Congratulations on receiving your grant! This guide is intended to assist you in the administration of your grant or contract. Our goal is to minimize the time you must divert from the main focus of your project while complying with contractual, regulatory, and statutory provisions. For any questions not answered in this guide, you may receive assistance from:

Sarah Price Chief Business Affairs Officer OCTC Business Office 4800 New Hartford Road Owensboro, KY 42303 (270) 686-4501 (270) 686-4433 fax sarah.price@kctcs.edu	Eilene Neal Business Affairs Specialist OCTC Business Office 4800 New Hartford Road Owensboro, KY 42303 (270) 686-4509 (270) 686-4433 fax eilene.neal@kctcs.edu

Christi Eversole Director of Grants & Contracts OCTC President’s Office 4800 New Hartford Road Owensboro, KY 42303 (270) 686-4552 (270) 686-4496 fax christi.eversole@kctcs.edu	Terri Scales KCTCS Office of Sponsored Projects (OSP) 300 North Main Street Versailles, KY 40383 (859) 256-3284 (859) 256-3126 fax terri.scales@kctcs.edu

NOTE: All grant contractual documents, including copies of submitted proposals, original contracts, and all grant related correspondence, must be maintained in the College’s Office of Grants & Contracts. All grant financial documents must be maintained in the College’s Business Office. Finally, Project Directors will also maintain copies of contractual and financial documents.

RESPONSIBILITIES OF THE PROJECT DIRECTOR

You, the Project Director, also known as the Principal Investigator, are the most important administrator of your grant. You initiate or approve all changes to the grant or contract and check the monthly expenditure reports from the Business Office to determine their accuracy and completeness. Your grant’s Chart String, established by the KCTCS Office of Sponsored Projects (OSP), is similar to a bank account open in your name. You may draw from it during the life of the grant project. You are responsible and accountable for your account. You will want to get the most mileage out of your available funds, within the constraints provided by the funding source, the Commonwealth of Kentucky, KCTCS, and OCTC.

As the Project Director, it is your responsibility to read, understand, and implement all information and instructions sent to you from the grant sponsor, OSP, the College’s Business Office, and the College’s Office of Grants & Contracts. For your project to run efficiently and within legal requirements, OCTC has established procedures, as documented in this guide, to be used in the administration of your project.

The ultimate and professional responsibility for accurate and effective project management, e.g. project activities, project personnel, budgetary control, required reports, etc. rests with you, the Project Director. This guide was developed to assist you in your role as Project Director, so please review it thoroughly.

AUDIT READINESS

When an organization receives external funds, it is responsible for using those funds in accordance with laws and regulations. The recipient must use fiscal control and accounting procedures to ensure the proper disbursement of and accounting for these funds. The effective management of public funds should be a result of ongoing activities that ensures audit readiness, such as:

Administrative Controls – The plan of organization and procedures and records related to authorizing transactions. Maintained by the KCTCS OSP, the OCTC Business Office, and the Project Director.

Accounting Controls – The plan of organization and procedures and records concerned with assets and reliable financial records. Maintained by the KCTCS OSP and the OCTC Business Office.

Compliance with Federal, State, and Other Requirements – Examples: Charges for direct labor, reporting of financial status, treatment of grant-related income, eligibility of participants, monitoring of activities, and allowability of services. Monitored by the Project Director, the KCTCS OSP, the OCTC Business Office, and the OCTC Office of Grants & Contracts.

Records – These should include information adequate to support statements in the application document and should be retained for the required period of time. Maintained by the Project Director, the KCTCS OSP, the OCTC Business Office, and the OCTC Office of Grants & Contracts.

Internal Audits – The Project Director may request assistance from the OCTC Chief Business Affairs Officer in determining if controls are adequate after attempts have been made to establish such controls in conjunction with the OCTC Business Office.

The requirements for each grant are different, and most agencies publish guidelines for the proper management of funds – including allowable and unallowable costs. For example, the National Science Foundation, the U.S. Department of Health and Human Services, and the U.S. Department of Education all publish their policy manuals on their websites. The College’s Office of Grants & Contracts can also provide you with further assistance/reading materials to ensure audit-readiness.

ACCOUNTS

Set-Up

To establish a grant Chart String, the Project Director must complete and sign an Internal Approval Form (GC2), a copy of which is included in the Appendices section of this guide, and submit the form, along with a copy of the award notification, to the College’s Office of Grants & Contracts within two weeks of funding notification. After obtaining the remaining necessary signatures, the OCTC Director of Grants & Contracts will submit the original GC2 and backup documentation to the KCTCS Office of Sponsored Projects (OSP).

It is important to note that the Chart String must be established in order for you to spend funds through the grant. A sample Chart Sting is included on the sample Expenditure Report found in the Appendices section.

Other tips related to account set-up:

A granting agency’s budget expenditure categories may differ from KCTCS’s categories, so it is important to use care when dealing with budgetary information.

The full chart string should be recorded on appropriate documents to ensure the proper grant account is charged for expenses.

All grants will be assigned in Fund 12 and will be given a unique grant number beginning with the letters GRT (i.e. GRT 42434).

Large capital purchases are those items, such as equipment, computer software, etc., with a life expectancy of over one year and a unit cost greater than $5,000. For capital purchases meeting this definition to be made, funding must be allocated in a “Capital” line item upon initially establishing the chart string (grant budget). In the event a capital purchase need arises after the budget has been set-up, a Budget Revision Form (GC1) must be submitted with backup documentation of authorization to make the change prior to making the capital purchase.

Maintenance

Developing an Initial Spending Plan – It is important to develop an initial spending plan to ensure funds are expended in a timely manner with special attention to the project ending date. If the grant incorporates several projects, a defined budget should be developed for each project.

Monthly Reconciliation – The Project Director will receive an expenditure report and an expenditure entry detail from the Business Office each month to verify charges made to the grant. Samples of these reports are included in the Appendices section for your review. Only you, as the Project Director, can verify purchases to be charged to the grant. The expenditure report should be reconciled each month, and any changes should be processed immediately through the OCTC Business Office. Corrections are made by the Journal Entry process, as described in the following sub-section. Corrected entries will be reflected on the expenditure report during the next monthly cycle, as well as in the expenditure detail.

Accounting Corrections (Journal Entries) – To correct errors discovered through the monthly reconciliation process, a Journal Entry Form (BA6), a copy of which is included in the Appendices, shall be completed. There are two primary types of corrections – those made to payroll and those related to current expenses (e.g. supplies, materials, etc. charged to the wrong grant account). Journal Entry forms correcting payroll discrepancies will be completed by the OCTC Business Office with input from the Project Director. Corrections to current expense discrepancies are to be completed by the Project Director and submitted to the Business Office for processing. Most importantly, the Project Director and Business Office personnel will coordinate all efforts to correct accounting errors.

Other tips relating to account maintenance:

All equipment and furniture purchases over $100 must be approved by the President. An equipment purchase is defined as any equipment with a life expectance of one year or longer and a cost of $100 or more. This requirement was implemented in response to a Governor’s Executive Order. Requests should be sent to the Chief Business Affairs Officer, in advance of making the purchase, who will obtain the President’s signature.

Food purchase requests must be approved by the President, and a specific food credit card must be utilized (available in the OCTC Business Office). Please refer to the revised procedure for obtaining prior approval for food purchases at http://www.kctcs.edu/businessservices/BusPro/1.13%20Employee%20Meals%20and%20Refreshments.doc.

Grant personnel may obtain PeopleSoft access to retrieve grant-specific reports and information. If PeopleSoft access is obtained, OCTC Business Office personnel will provide the training necessary to retrieve reports to reconcile and manage grant accounts. For more information, contact the OCTC Business Office.

Grant personnel should follow the established KCTCS travel procedures when traveling for grant purposes. Employees should complete a Travel Request form to obtain in-state travel approval. Out-of-state travel must also be approved by the college President and an Out-of-State Travel Authorization form must be completed and submitted with the standard Travel Request form prior to taking a trip. Please refer to the revised travel procedures at http://www.kctcs.edu/businessservices/TravelPro.htm. A standard Travel Request form and an Out-of-State Travel Authorization form are included in the Appendices section.

A summary of “Frequently Used Budget Account Codes” is included in the Appendices section of this guide.

In the event “in-kind” or “matching” contributions are included as grant requirements, the associated budget amount must be tracked and documented, as well. A plan to document all such contributions must be developed and implemented upon notification of grant funding with the assistance of the OCTC Business Office.

Time and Effort Reporting

All grant funded employees, as well as employees donating time to a grant as an in-kind contribution (or cost share) of the college, must sign off on a time and effort report two times per year verifying the percentage of time spent and the value of compensation received. A sample of the report is included in the Appendices section of this guide.

Other tips relating to time and effort reporting:

Federal funds from one project may not be used as a cost share on another federal grant

Time and effort reports should be signed by the employee (if possible) and the employee’s supervisor. If the employee is unavailable due to no longer being employed by OCTC or for another similar reason, the employee’s supervisor should indicate the person is not available in writing on the form, sign the form, and submit it to the OCTC Business Office.

HIRING EMPLOYEES

Hiring must be coordinated with the Human Resources Director and the Chief Business Affairs Officer. KCTCS and OCTC policies must be followed in all hiring procedure. The position duties and grant specific guidelines will be incorporated into a contract, which will be signed by the grant-funded employee, his/her supervisor, the appropriate Dean, and the President. Contracts must indicate that the future of the position is dependent upon securing additional funding. The HR Director can give you complete supportive services in areas of hiring procedures, personnel benefits, termination procedures, etc. The HR Office can also assist in the recruitment, interviewing, and screening of applicants and other personnel-related activities. Important personnel guidelines include:

Equal Employment Opportunity: All faculty, administrative, professional, and support personnel, as well as student assistants, will be recruited, hired, trained, and promoted in accordance with the College’s EEO hiring policies.

Position Announcements: All new and/or regular vacant positions must be advertised in accordance with established personnel and college standards to ensure that all new members of the college family and the general public are made aware of openings.

Dual Compensation: No employee may receive double pay for the same period of time worked. For example, an employee may be paid full-time as a faculty member, but for that same time period cannot be paid also for work performed on behalf of a grant. Upon receipt of prior approval, employees may be paid in an overload capacity, which consists of the employee working hours in addition to his/her regular hours of employment. Overload hours should be documented in writing by the grant employee and Project Director.

Position Rankings: Administrative/professional and support staff positions established under contracts and grants are classified by Human Resources at KCTCS. Human Resources will assist departments by interpreting and furnishing guidelines for the administration of the compensation plans. For more information regarding KCTCS’s classification and compensation criteria, please contact the OCTC Human Resources Department.

Faculty: Employment of faculty should be coordinated with the President, the Dean of Academic Affairs, and the appropriate Program Coordinator.

Staff: Employment of staff positions should be coordinated with the President, the Chief Business Affairs Officer, and the Human Resources Director. For staff positions providing benefits, a Job Analysis Questionnaire (JAQ) must be completed by the Project Director, with guidance from the HR Director, and submitted by HR to KCTCS for approval. For staff positions not providing benefits, a New Position/Change - Temporary Form should be completed, submitted, and approved prior to hiring the employee. An employment packet for the person to be hired (temporary application, tax forms, and I-9 verification) must be sent to HR for processing. Federal law requires the completion of an I-9 Form prior to hiring an employee; therefore, these forms must be completed and submitted to the College’s HR Office prior to the employee reporting for work at the college. Copies of the JAQ and the New Position/Change - Temporary Form are included in the Appendices section of this guide. Temporary applications, tax forms, and I-9 verification forms can be obtained by contacting the OCTC Human Resources Office.

CHANGES

Budgetary

Project directors may expend funds only in the line item categories for amounts listed in the approved budget. The approved budget, whether negotiated with the agency or approved in the proposal, constitutes part of a legal contract. Federal and state guidelines are usually flexible enough to allow minor line item changes within the total budget without prior approval from the agency. Discuss these changes with the OCTC Director of Grants & Contracts and the Chief Business Affairs Officer. Major revisions requiring agency approval should also be discussed with the OCTC Director of Grants & Contracts and the Chief Business Affairs Officer prior to requesting a budget revision. In cooperation with the OCTC Office of Grants & Contracts, contact the program officer at the agency to determine the procedure and to discuss the possibility of the revising the budget.

Using the appropriate forms or format of the agency, you must formally write the requested changes. The requested changes are then directed through the campus organizational structure beginning with the OCTC Director of Grants & Contracts. Once the appropriate personnel at OCTC approve, the document is reviewed and sent to the applicable granting agency.

The request, including appropriate forms, should be sent via certified mail to the applicable agency. Agency personnel will deliberate and officially approve or disapprove the change in writing. No budget changes may be made until official written approval is obtained. This may take several weeks, so it is important to make changes as early as possible. Copies of approval letters are to be sent to the OCTC Director of Grants & Contracts and the Chief Business Affairs Officer.

When a revision is made that involves changes between budgetary line items, whether major or minor, a completed Budget Revision Form (GC1) must be submitted by the Project Director to the Office of Grants & Contracts for signature processing. After the Chief Business Affairs Officer and the President have signed the form, it is then forwarded on to the KCTCS OSP, and copies of the signed form are sent to the Project Director and the OCTC Business Office. Documentation of the change, including the reason the change is necessary, must be attached to the form. A copy of the GC1 is included in the Appendices section of this guide.

Programmatic

Program changes that modify the scope or the objectives of an approved project require prior approval from the college administration and the granting agency. Discuss the changes with the OCTC Director of Grants & Contracts. In cooperation with the Office of Grants & Contracts, contact the program officer at the agency to determine the procedure and discuss the possibility of the change. The grant contract normally details procedures to follow. It is important to follow the procedures since grant contracts are legal documents and cannot be altered without official written approval.

Using the appropriate forms or format of the agency, you must formally write the requested changes. The requested changes are then directed through the campus organizational structure beginning with the OCTC Director of Grants & Contracts. Once the appropriate personnel at OCTC approve the change, the document is sent to the applicable granting agency.

The request, including appropriate forms, should be sent via certified mail to the agency. Agency personnel will deliberate and officially approve or disapprove the change in writing. No program changes may be made until official written approval is obtained. This may take several weeks, so it is important to make changes as early as possible. Copies of approval letters should be sent to the OCTC Director of Grants & Contracts. If budgetary changes are made, the Business Office should be involved in all aspects of the change.

Project Extensions and Carryover of Funds

In certain instances, a funding agency will grant a no-cost extension to a project. If there are legitimate instances that prevented you from completing the project within the time frame of the grant, it is sometimes possible to ask the agency to extend the grant period. No additional funds will be granted; only the completion date will be officially delayed. As with program changes and requests for budget changes, no-cost extensions must be officially requested in writing and approved in writing by the funding agency. Extensions must usually be approved at least 90 days before the grant expires.

Since it is illegal to expend funds after an official grant termination date, adequate notice of an extension must be given to the college administration and applicable granting agency. Discuss the extension with the OCTC Director of Grants & Contracts and the Chief Business Affairs Officer. In cooperation with the OCTC Office of Grants & Contracts, contact the program officer at the agency to determine the procedure and discuss the possibility of the extension. Using the appropriate forms or format of the agency, formally write the requested changes. The requested changes are then directed through the campus organizational structure beginning with the OCTC Director of Grants & Contracts. Once the appropriate personnel at OCTC approve the request, the document is sent to the granting agency.

The request, including appropriate forms, should be sent via certified mail to the agency. Agency personnel will deliberate and officially approve or disapprove the change in writing. No expenditures of funds after the initial deadline may be made until official written approval of the extension is obtained. Copies of the approval are to be sent to the OCTC Director of Grants & Contracts and the Chief Business Affairs Officer.

REQUIRED REPORTS

Your grant contract or proposal guidelines will officially outline all required reports. At a minimum, most contracts require a final narrative report and fiscal report. Your responsibility as Project Director is to keep adequate records and to write and submit all required reports, including final reports, by the deadline determined by the funding agency. The final report is a requirement and often funds are withheld by the agency until the report is filed. Assistance with completing the report is available through the OCTC Office of Grants & Contracts. Likewise, the Chief Business Affairs Officer can assist with the required fiscal reports. As the Project Director, you are responsible for ensuring all reports are submitted in a timely fashion. It is important that you notify the OCTC Director of Grants & Contracts and the Chief Business Affairs Officer of all reporting requirements and make certain that each is informed of all report deadlines and receives copies of completed reports for file.

SIGNING LEGAL GRANT AND CONTRACT DOCUMENTS

Only the President of the College has the authority to sign legal grant and contract documents. When you receive official legal grant and contract documents, notify the OCTC Director of Grants & Contracts to obtain the needed signatures. All original contracts must be maintained in the OCTC Office of Grants with copies maintained by the Project Director and other applicable parties.

BUSINESS OFFICE PROCEDURES

The KCTCS Business Procedures and applicable forms, which include travel, human resources, and other important areas that may be helpful to you as a grant Project Director, can be found online at http://www.kctcs.edu/businessservices/BusProcedures.htm. Copies of KCTCS Administrative Regulations 7.9 and KCTCS Business Procedures 3.9 are included in the Appendices section of this guide.