While PDs are often eager to get their projects underway as soon as possible, receiving funding post-award may not be immediate. In this event, PDs may choose to request Advance of Grant Funds. Requesting an Advance of Grant Funds occurs when PDs ask for a percentage of the total grant funding for immediate use (usually 10%) while the contractual agreement between the college and the funding source is being processed. The PD is responsible for initiating the Request for Advance of Grant Funds form and monitoring the financial status of the Advance.

An advance is meant to be used in those instances where an anticipated award was expected to begin, but where the grant award document has not been finalized. The primary purpose of an advance should be to keep existing grant personnel employed, but exceptions could be approved, if warranted.

An advance may be requested once the college has received a written commitment from the funding source, either a Letter of Intent or an email. The notification must include the total amount of the award and the term of the grant. A copy of the notification must be submitted with the request. 

When completing the form, identify the “Purpose of Advance”. Indicate the categories of expenditure the advance will be used to cover. This could include salaries and benefits of staff, or specific operating expenses (i.e., particular software needed for the grant, educational supplies, etc.). If the anticipated funding source is federal, the assistance listing number should be included on the form. In addition, include the department’s unrestricted Banner fund and organization code, which will serve as an alternative funding source should grant funding not be received. 

Please note: If the grant award is not received, the expenditures that are charged to the grant under the advance will be applied to the department listed in the advance, which could result in a significant impact to the college.

Once Sponsored Projects is in receipt of a written commitment from the funding source, and has received the advance request, they will notify the Department of Institutional Equity and Human Resources (HR). If a written commitment from the funding source is not received, grant funded personnel will not be authorized to work on the new grant. If unusual circumstances exist which make obtaining a written commitment not feasible, an exception to this requirement may be authorized by the President or the Vice President for Administration and Finance.

Please allow at least one week to obtain all necessary approvals for the advance. Once all approvals are obtained, forward the completed advance to Sponsored Projects which will then assign a Banner fund to the grant. Please refer to the next section of this manual for information on Banner fund assignment. No college personnel are authorized to work on a grant, or purchase any goods or services for a grant, until a Banner fund has been issued.

For existing grants, if it seems likely that a grant award will not be finalized before the end date of the current grant cycle, please make certain that a completed advance is in place as soon as possible, to help ensure uninterrupted employment of grant funded personnel.

A unique Banner fund number is assigned for grant projects when Sponsored Projects has either an approved Request for Advance of Grant Funds or a fully signed grant award. Please ensure that the Sponsored Projects receives a copy of a grant award so that a new fund will be created.

A unique Banner fund number is created to set apart the financial records of a grant from the financial records of the college. Having a unique Banner fund number also allows the college to separately track all grant charges. In order to ensure compliance, all grants are assigned at least one fund number.

At least one week is required to complete the process of assigning a Banner fund. Once processed, a formal notification is provided to the PD, the PD’s supervisor, and any additional internal stakeholders for the project such as HR, Financial Aid, etc. Included in the formal notification is instructions to gain security access to the fund via the “Data Access Authorization Request Form”. Please note that the assigned Banner fund must be applied to all grant documentation (i.e., requisitions, payroll documentation, travel documentation, etc.).

No college personnel are authorized to work on a grant, or purchase any goods or services for a grant, until a Banner fund has been issued.

The PD is responsible for hiring staff in consultation with Human Resources, who can advise regarding the hiring forms needed and making sure that the PD follows institutional recruitment and hiring guidelines. All personnel policies, procedures, and forms required for hiring staff can be found on the HR webpage or by contacting HR at 825-2311 for questions on how to complete these forms and on following institutional and recruitment policies and procedures.

These forms should be completed and processed for grant staff in the same manner they are completed and processed for any other staff at CCRI. Be sure to use the assigned Banner Fund and grant name on all documentation. All of the positions requested must have sufficient funds that are approved in the grant budget to support the costs.

Staff cannot commence employment prior to the appropriate Human Resources forms being completed, signed, and approved by all appropriate officials. Please take processing time into account as you begin the hiring process. The cycle can take up to three months or more to hire an employee on the biweekly (State) payroll and can take up to two weeks or more to hire an employee on the part-time (temporary) payroll.

Note: Part-time (PT) (temporary) employees are NOT authorized to work more than 925 hours within a fiscal year. It is the employee’s responsibility to track this as it is possible for an employee to have multiple part time positions, including adjunct positions, in various departments totaling 19 hours a week or less.

It is the Department Chair, Director, or Supervisors responsibility to complete the appropriate procedures, have the employee complete the required paperwork, and then forward to HR for processing and/or have the employee go directly to HR to complete the required paperwork for processing.

Timekeeping and Payroll

The PD is responsible for timekeeping and payroll documentation. Grant positions must follow the institution’s payroll procedures. All employees (exempt and non-exempt alike) are expected to keep an accurate record of time worked and discharged.  Each employee must complete the appropriate time card or leave report, have it approved by his/her immediate supervisor(s), and submit it to the Payroll Office by the due date indicated. Please review HR’s webpage on Timekeeping for instructions and the payroll calendars.

Time & Effort Reporting

The Uniform Administrative Requirements provides guidance for time and effort certification. The internal control requirement is the basis for maintaining a time and effort certification system. The Council On Financial Assistance Reform (COFAR) believes focus on overall internal controls provides greater accountability. The non-federal entity must ensure that the total internal control system for documenting personal expenses provides proper accountability. In addition, the auditor must test these internal controls as part of the Single Audit requirements in Subpart F of 2 CFR §200.430.

CCRI has adopted an after-the-fact activity record system to provide accountability of time and effort reporting for federal grants (including state pass-through grants).

The Division of Administration and Finance maintains the time and effort records. All employees working on a grant whose payroll is paid in whole or in part from a federal grant or federally funded agreement will be required to certify time spent on the activities related to the grant. The employee completes the time and effort form and the supervisor approves the form. If an employee works on more than one federal grant, separate forms must be completed. 

The PD is responsible for managing all activities related to the grant, both programmatic and financial, and has access to all financial data for their award in Banner. The PD can use the several Banner forms and reports to review financial transactions in detail to ensure that all expenses posted to the grant fund are accurate. Discrepancies should be investigated. Sponsored Projects can provide assistance, if necessary. Depending on the funding source, OIA or Administration and Finance will be responsible for submitting any financial reports, billings, and requests to drawdown funds, to grantor. Any communication or notifications from the grant funding source regarding financial requests and requirements should be sent to Sponsored Projects in a timely fashion and will be triaged appropriately.

Programmatic Reporting

The PD is responsible for preparing and submitting all interim and final programmatic reports in accordance with funding source requirements. Reports will detail all expenditures, and provide a summary of the activities conducted, and the impact of those activities. In the event that a project is not renewed for the following fiscal year, the final report is due on the last day of the project period unless otherwise noted. Reporting requirements necessitate attention and a timely response.

The PD will refer to their grant agreement when writing these reports and prepare a narrative on the current status of the grant. If the PD requests assistance, Sponsored Projects will review the report and provide guidance. Unless otherwise stated, once the report is complete, the PD will submit it to the funding source and provide copies of all submitted reports to Sponsored Projects. Sponsored Projects will monitor the program’s overall progress and will provide support as needed if items need to be resolved, or new strategies need to be put in place.

Financial Reporting, Billing, and Drawing Down Funds

The grant agreement, and any applicable regulations or laws, will designate the reporting format, the billing or drawdown process, and the submission deadlines used by either the Division of Administration and Finance or OIA (depending on grant type). Only those expenditures that have been approved and posted into the Banner system, or in some instances accrued, will be billed or drawn down from the grant funding source.

Accruals may be processed for pending transactions if a particular grant requires an accrual basis reporting. Contact Sponsored Projects and/or the dedicated staff member managing your fiscal reporting to alert them of any expenses incurred but not yet reported. Examples of these expenses would be out-of-state travel, postage, or a pending invoice for a consultant.

The PD may request copies of any grant financial reports at any time. This process supplements the ongoing monitoring of spending by the PD. The financial transactions and spending rate of the grant should be routinely reviewed. If any issues are noted, please contact Sponsored Projects immediately.

Grant Cost Sharing Documentation

Some grants may require cost sharing (aka "matching"), which is defined as “the portion of project costs not paid by Federal funds (unless otherwise authorized by Federal statute).” The general cost sharing requirements are found in 2 CFR §200.306. Cost sharing usually consists of donated personnel, equipment and supplies, or space. Cost sharing must be budgeted for and agreed to during the grant application process. In addition, any cost sharing must be properly documented, necessary, and reasonable under a particular grant. 

However, the terms and conditions of a particular grant, and any applicable laws or regulations, will determine the allowability of cost sharing. If cost sharing is required by the funding source, the PD will be responsible for identifying the source of funds to support the project.

Third-Party In-Kind Funds

For federally funded grants, a third-party in-kind donation is defined differently than cost sharing. Third-party in-kind donations are “the value of non-cash contributions” donated by an entity separate from the college, to the college, to benefit a grant. In general, the value of donated third-party in-kind contributions may be used to meet the college’s cost sharing requirement for a grant. However, the terms and conditions of a particular grant, and any applicable laws or regulations, will determine the allowability of third-party in-kind donations qualifying as cost sharing.

Personnel Cost Documentation

If a college department is providing cost sharing for personnel, each contributing employee will be required to certify time spent on the activities related to the grant. The employee must complete the cost share time and effort form and the supervisor must approve the form. If an employee provides cost sharing for more than one grant, separate forms must be completed. For instructions, please contact Sponsored Projects.

Operating Expenses Cost Share Documentation

When using operating expenses for a cost share, the PD will need to supply the paid invoice number, amount, date paid, and Banner FOAP (Fund, Organization, Account, Program) to the Sponsored Projects on a monthly basis, which will then be verified, calculated, and reported in accordance with the grant requirements.

In accordance with 2 CFR 200.313 and CCRI's Capital Assest Account Policy, equipment is defined as tangible personal property (including information technology systems) with a useful life of more than one year and a per-unit acquisition cost meeting or exceeding the lesser of the college’s capitalization threshold or $5,000.

In addition to items defined as equipment, items considered to be pilferable items and purchased with Federal funds must be included on any inventory report regardless of the cost. Pilferable items—which are at risk of loss or theft— include, but are not limited to, computing devices, projectors, cameras, and mobile technology.

Federal Equipment and Supply Inventory Requirements

Project Directors must maintain an equipment inventory whether equipment is acquired in part or its entirety under the Federal award. 

To facilitate tracking and compliance, an equipment and supply tracker has been developed for use in maintaining accurate records and ensuring proper oversight of these purchases. This tracker collects data on each purchase including a description of the property, a serial number or another identification number, the source of funding for the property (including the FAIN), the title holder, the acquisition date, the cost of the property, the percentage of the Federal agency contribution towards the original purchase, the location, use and condition of the property, and any disposition data. Project Directors are responsible for mainitaing and updating these property records for the life of their award. 

The PD is responsible for managing financial activity in the grant. This fiscal oversight may bring to light the need for a budget modification or expenditure adjustment. If a Banner account becomes overspent, the PD should inform Sponsored Projects. Alternatively, the PD may be informed of a deficit balance in a Banner account. If a Banner account has a deficit, either a budget modification or an expenditure adjustment will be required. This can be the result of a change in project activity or changes in cost estimates from the time the original budget was developed. Depending on the requirements of the funding source, a modification may be external or internal.

An external budget modification is defined as budget modification, which requires written approval from the funding source pursuant to the terms and conditions in the grant agreement. An internal budget modification is defined as a budget modification, which does not require approval from the funding source. Both external and internal budget modifications must be approved internally, by appropriate college faculty and staff, and entered into Banner. Please allow sufficient lead-time for approval. For example, for an external budget modification, some funding sources require up to six (6) weeks for approval.

In contrast to a budget modification, sometimes an expense needs to be moved because it was not booked to the appropriate fund or account. In this instance, an expenditure adjustment will need to be completed. The PD will need to complete a “Request for Expenditure Adjustment” form to correct the charge. Any expenditure adjustment that will charge the college’s unrestricted budget must be approved by the Business Office prior to the adjustment being made.

Internal Budget Modifications

In some cases, budget modifications do not require funding source approval. Yet they need to be done to properly fund all the Banner accounts, which will be used during the grant. An internal budget modification requires the completion of an "Internal Budget Modification Form".

When an internal budget modification is necessary, the PD should initiate the process. Please complete the form and email it to Sponsored Projects where the request will reviewed. If approved, the modification will be loaded into Banner.

Please note:

• Sufficient lead-time should be provided for approval and loading into Banner.
• Any needed modification should be entered into Banner before any purchase requisition is entered which will require those funds.
• Internal budget modifications must be tracked by the PD to ensure that any budget revisions do not exceed the limits set by the funding source.
  
  

External Budget Modifications

External budget modifications (requiring approval by the funding source) may be necessary following the award of the grant or during the project period. Typically, the grant award specifies the circumstances under which an external budget modification is required. Some grants have significant flexibility to move funds between categories or accounts. Others require prior approval – an external modification – for any variance from the original budget.

External grant modifications must be completed and submitted in a timely fashion. In addition, it is essential to be aware of funding source deadlines for final spending or receipt of materials on campus. The PD must complete budget modifications and initiate purchase requisitions accordingly. Failure to meet budget modification deadlines can result in denial of the request by the funding source. An external budget modification requires completing the following documentation:

• A modified GBW to reflect the changes.
• Revised funding source budget forms as required.

Before entering information in the GBW, contact Sponsored Projects for the most recent version of the file, ensuring rates and calculations are current and accurate. 

The PD must first verify account balances using Banner and confirm the amount that must be adjusted in the budget, taking into consideration additional spending for the remaining term of the grant.

Categories of expenses vary by funding source. A PD may need to use a grant-specific matrix that links Banner expenditure accounts to the grant funding source categories to determine if a formal modification is required. Once this is determined, the PD initiates the appropriate documentation. 

When modifying the GBW, save the Excel file with a new name that includes the grant name, revision, and the current date so that the file can be distinguished from other versions of the budget for the particular grant.

Completed documentation should be forwarded to Sponsored Projects for review. Please note that certain modifications may require further approvals, depending on the grant. Once all approvals are obtained, the Sponsored Proejcts will follow up with the funding source to complete the formal approval process and will notify all stakeholders of any action taken by the funding source. If the modification receives final approval, Sponsored Projects will adjust the budget in Banner to reflect the change. If denied, Sponsored Projects will work together with the internal stakeholders to determine what actions are necessary to ensure that the college is abiding by the terms of the original grant.

The PD is responsible for obtaining a Letter of Intent or the Grant Award Notification from the funding source and ensuring that both Sponsored Projects and HR have received the this documentation If HR receives a Letter of Intent or the Grant Award Notification prior to 20 business days before the end of the grant, End of Appointment Letters will not be sent to the biweekly employees on the grant. The Letter of Intent or the Grant Award Notification must include the dollar amount and the dates of the project period.

If HR does not receive a Letter of Intent or the Grant Award Notification prior to 20 business days to the end of the grant, End of Appointment Letters will be sent to the biweekly employees via certified and first class mail. The employee's supervisor, OIA, Controller’s Office, and applicable union president will also receive notification.

Letters of Reappointment will be sent to the biweekly employees when Human Resources receives the mutually signed contract/agreement or the Grant Award Notification. For part time employees, Human Resources needs confirmation of renewal to extend employees currently working on grants.

Grant Documentation and Files

The PD should retain all non-financial grant files in one location should future audits or questions arise. The non-financial files should be maintained by the college department under which the grant operated. For example, if the grant PD reported to Academic Affairs, the non-financial files will be maintained by Academic Affairs. All financial files will be maintained by either the Division of Administration and Finance or OIA depending on the award type. All documentation will be retained according to the college’s document retention practice.

Compliance with Required Regulations

Federal and state grants have very specific regulations regarding reporting, billing, accounting practices, and grant administrative procedures. These regulations must be reviewed to determine if the college has completed what is necessary to comply with those regulations, or to identify whether any tasks remain to be accomplished and who is responsible for completing them. If any items have yet to be completed, the PD will follow up until they are finalized.

Lessons Learned

Identifying what went well and what the college could have done better is an important step in effectively managing future grant awards. Discussing issues and obtaining input from Sponsored Projects and internal stakeholders will help to highlight areas that CCRI can focus on for improvement. Issues such as the following could be discussed:

• Grant objectives achieved or not achieved;
• If any objectives were not achieved, why were they not achieved?
• Personnel and communication;
• Contractual issues;
• Grant policies and procedures that could be improved upon;
• What issues caused delays and what improvements could be made going forward?
• Were all grant funds expended? If not, why not?
• What could have been done better? and,
• Feedback received from the funding source.
  
  

Retention of Records

All documentation will be retained according to the college’s document retention practice. In addition, federally funded grants must comply with the requirements contained in 2 CFR §200.517 – Retention requirements for records. If the college’s document retention practice is not equal to the document retention requirement of a particular grant, the documents shall be retained according to whichever rule provides the longer retention period.

Audit/Post Audit

An audit is initiated when the funding agency requests a review of programmatic or financial records. Any communication regarding an audit should be forwarded to Sponsored Projects for handling once you are notified.

The Division of Finance and Administration or OIA may be responsible for supplying financial documentation if an audit is performed depending on the award type. The PD is responsible for supplying any programmatic documentation at the auditor’s request.

A PD is expected to keep all records in accordance with college policy and grant terms and conditions. In addition, the college has contracted with a vendor for long-term offsite storage of records. If long-term storage of grant records is needed, you may contact the Division of Administration and Finance to make arrangements.