Extracted text (via pymupdf)
26655 characters
I. PURPOSE MARICOPA COUNTY INTERNAL POLICY The purpose of this policy is to serve as the framework for Maricopa County Departments and Special Districts (Flood Control District, Library District, and Stadium District) to follow when applying for grants and negotiating the terms and conditions of the agreements and/or contracts to ensure optimum financial and administrative arrangements for Maricopa County and/or the Special Districts. II. APPLICATION This policy applies to all Maricopa County elected and appointed departments, the Flood Control District of Maricopa County, and the Maricopa County Library District, (Special Districts). Departments, Elected Officials, and Special Districts. The Board of Supervisors is authorized to jointly adopt policies applying to the Special Districts under the Intergovernmental Agreement, C-06-18-393-6-00, approved on April 11, 2018 III. DEFINITIONS A. Central Service Costs – Costs benefiting both grant and non-grant activities for inclusion as part of indirect cost in grants. The allocation is calculated in compliance with the 2 CFR PART 200 — Appendix VII to Part 200 (Federal OMB Uniform Grant Guidance). B. Cognizant Agency – The Federal agency responsible for reviewing, negotiating, and approving cost allocation plans or indirect cost proposals developed under 2 CFR PART 200 — Appendix VII to Part 200 (Federal OMB Uniform Grant Guidance) on behalf of all Federal agencies. Maricopa County’s Cognizant Agency for the Central Service Cost allocation plan is the U.S. Department of Housing and Urban Development – San Francisco Office. For the purposes of audit issues, the Cognizant Agency is the U.S. Department of Health and Human Services. C. Department – Refers to the department, office, or agency under budgetary responsibility of the Board of Supervisors, and the Maricopa County District(s) Board of Director(s), which has directhave direct oversight responsibility for the program(s) funded partially or totally with the grant funds. The elected official or department director of the Department shall act as the agent of the County for purposes of this policy. D. Department Overhead – Departmental/Special District costs incurred for both grant and non-grant programs. E. Fund Balance Report – A report created from the County’s financial systems by the Department of FinanceOffice of Budget and Finance monthly detailing a fund’s (inception to date) financial activity for each individual grant. This report should be used to ensure effective management of grant activity. F. Grantor Agency – Refers to a Federal, state, local, or private agency or organization, which provides the grant funding and/or grant funding oversight. G. Indirect Costs – Refers to those costs incurred for a common or institution-wide objective that Policy Title: ADMINISTERING GRANTS Policy Number: A2505 Current Adoption Date: 6-27-2018 Current Implementation Date: 6-27-2018 Approved by: BOARD OF SUPERVISORS Board Agenda Number: C-18-18-014-6-00 Original Adoption Date: February 1997 Policy Title: ADMINISTERING GRANTS Policy Number: A2505 Current Adoption Date: 6-27-2018MM-DD- 2023 benefits more than one grant program or project. Such costs are not readily assignable to the cost objective specifically benefited. Page 2 of 812 Policy Title: ADMINISTERING GRANTS Policy Number: A2505 Current Adoption Date: 6-27-2018MM-DD- 2023 H. In-Kind – Refers to contributions in the form of goods or services rather than in cash. I. One-time Grants – Refers to funding from a Grantor Agency which is provided for a limited duration for a specified project or program. This type of grant may be provided to start a new program or service or for a program or services which has a limited life. J. Ongoing Contributions – Refers to future contributions to be provided by the County including after the grant award has ended. K. Ongoing Grants – Refers to funding from a Grantor Agency which is expected to be provided year after year for a specified program(s) or service(s). L. Special District – Flood Control District of Maricopa County, Maricopa County Library District, Maricopa County Stadium District. M. Uniform Administrative Rules, Cost Principles, and Audit Requirements for Federal Grants (Federal OMB Uniform Grant Guidance) – The OMB has issued a final guidance regulating the management of grants. This guidance supersedes Federal OMB Circulars A-21, A-87, A-89, A- 102, A-110, A-122, A-133 and the Single Audit Act. The Federal OMB Uniform Guidance — 2 CFR Part 200 consolidated aforementioned circulars into a streamlined format improving clarity and accessibility. IV. POLICY Maricopa County and Special Districts receive funding from Federal, state, and local agencies. The following policy statements will ensure that the County or Special District is managing grants to its optimum potential. A. The Board of Supervisors or Board of Directors must formally accept all grant awards prior to any funds being expended. B. Departments/Special DistrictsDepartments will consistently negotiate grant agreements to meet County or Special District goals and policies. This includes conducting a cost/benefit study to determine the appropriateness of Maricopa County or Special District pursuing a particular grant. C. Departments must comply with all Maricopa County and Federal procurement rules and regulations as outlined in the County Procurement Policy and Federal OMB Uniform Guidance when entering into any contract agreements related to grants. Departments cannot circumvent procurement rules and regulations by including a contractor into a grant application and must disclose the method of procurement for any entities included in a grant application. D. Departments/Special DistrictsDepartments will negotiate for advance funding financial arrangements first and only accept reimbursement funding when advanced funding is not available.as the final option. E. Departments/Special DistrictsDepartments will disclose indirect costs and any matching or ongoing contributions required by Maricopa County or Special District during the award and acceptance process. F. To minimize interest expense to Maricopa County, Departments/Special DistrictsDepartments will try and negotiate a reimbursement schedule that is in alignment with this policy. Page 3 of 812 Policy Title: ADMINISTERING GRANTS Policy Number: A2505 Current Adoption Date: 6-27-2018MM-DD- 2023 Departments/Special DistrictsDepartments will closely monitor their expenditures and claim reimbursement whenever expenses exceed $100,000, or on a monthly basis, as allowable by grantor. Page 4 of 812 Policy Title: ADMINISTERING GRANTS Policy Number: A2505 Current Adoption Date: 6-27-2018MM-DD- 2023 G. Departments will utilize the County financial system to track, monitor, and report all grant financial activity. All grant activity must be closed out within 120 days of the grant end date. H. Departments are required to charge Indirect Costs on all grants unless prohibited by the grant contract. 1. Indirect Costs will always be included (applied for) in the financial section of the grant application. 2. Indirect Costs will be recovered at the maximum allowed by the Grantor or as defined on the Indirect Cost Plan that is approved by the Department of FinanceOffice of Budget and Finance. 3. Indirect Cost will be disclosed within the agenda process. I. Departments/Special DistrictsDepartments do not have the authority to negotiate a lower indirect cost reimbursement in order to increase program funding. J. Departments will expend all grant funds prior to expending any general fund appropriations, or in the case of Special Districts, before expending other Special District revenues in relation to grant programs. V. GUIDELINES This Policy shall serve as the framework for Departments/Special DistrictsDepartments to follow when applying for grants and negotiating the terms and conditions of the agreements. The Policy is not intended to discourage Departments/Special DistrictsDepartments from seeking grant funding as a means to support various services and programs. Rather, it is intended to provide consistent guidelines for grant administration to ensure optimum financial arrangements for Maricopa County or Special District and to enhance Board of Supervisors or Board of Directors acceptance of grants conforming to this Policy. Specific information and detailed procedures are contained in the Maricopa County Grant Manual, which is located at Grants Management | Maricopa County Intranet, AZ.. The Maricopa County Grant Manual may be updated by the Department of FinanceOffice of Budget and Finance, as determined necessary, to accommodate the effective administration of this policy. A. Grant Application 1. Departments/Special DistrictsDepartments are not required to obtain Board of Supervisors/Board of Directors approval prior to submitting an application for grant funding provided the grant meets the following requirements: a. Cash or in-kind matching requirements, if any, will be absorbed in the department’s operating budget appropriation; and b. Indirect Costs, if not fully recoverable, will be absorbed in the department’s operating budget appropriation; and c. Ongoing contributions required after the grant period end date, if any, will be absorbed in the department’s operating budget appropriation. In addition, the Director of the Department Directoror Special District shall certify that the grant being applied for meets the above requirements. 2. Departments/Special DistrictsDepartments that wish to apply for grants that do NOT meet the Page 5 of 812 Policy Title: ADMINISTERING GRANTS Policy Number: A2505 Current Adoption Date: 6-27-2018MM-DD- 2023 above requirements must obtain Board of Supervisors/Board of Directors approval prior to submission of the grant application. 3. Grants for the Judicial Branch in Maricopa County will be identified by the Presiding Judge of the Superior Court in an annual presentation to the Board of Supervisors. The presentation will reference the individual grants, and whether any of the provisions of the grants deviate from this Policy. If these grants are awarded and accepted by the Board of Supervisors, subsequent grants for that fiscal year from the same Grantor Agency with like provisions do not require the Board’s award acceptance of the grant. Subsequent grants from a new Grantor Agency must be transmitted to the Board of Supervisors for review and acceptance. Page 6 of 812 Policy Title: ADMINISTERING GRANTS Policy Number: A2505 Current Adoption Date: 6-27-2018MM-DD- 2023 4. Departments/Special DistrictsDepartments will provide to the Department of FinanceOffice of Budget and Finance a copy of all grant agreements which must specifically include the award amount, grant period dates, availability of Indirect Costs and the indirect cost percentage (%), matching amounts, ongoing contributions, distinction between reimbursement or advance funding, and a complete description of the grant. The provided information will be used to establish controls on the County financial system and will not be changed or modified (award period, grant award, etc.) without supporting documentation from the Grantor. B. Grant Board Agenda Requirements 1. Departments will provide the following information within the BOS agenda item: a. One time or reoccurring grant and grant type with explanation, if applicable. b. Cash or in-kind matching requirement, if applicable state amount of match and the funding source for the match must be identified. c. Indirect costs fully or partially recoverable. Indicate the amount of indirect costs not fully recoverable, if applicable. If indirect costs are not fully recoverable, the funding source for the amount not recovered must be identified. d. Future or ongoing contributions required after the grant period ends. Indicate the amounts of future contributions, if applicable. If ongoing contributions are required, the funding source must be identified. e. If the grant fulfills a mandated service that the department is required to perform with explanation, if applicable. f. If grant award is competitively bid or non-competitive with explanation, if applicable. g. If awarded, indicate the total costs (match, indirect costs, ongoing contributions, etc.) Include the total dollar amount that will be absorbed by the department operating budget and indicate funding source for the balance of costs, if applicable. 2. IGA/Grant DisclosureDiscloser a. All IGA/grant BOS agenda items are required to disclose any specific vendors or entities that are part of the IGA and/or grant application, and a.b. Indicate which procurement type was used for the vendor or reference whether the vendor was determined to use the procurement vehicle (competitive bid/sole source/competition impracticable). B.C. Funding 1. To improve cash management practices, it is the County and Special Districts’ preference to receive funding on an advance basis instead of a reimbursement basis. Therefore, every effort is to be made by Departments/Special DistrictsDepartments to obtain advance funding from the Grantor Agency. This is especially critical for one-time grant funded programs where the County or Special District is advancing funds to nonprofit subcontractors (subrecipients, vendors, etc.). 2. The Department/Special District may be requested by the Budget OfficeOffice of Budget and Finance to present the cost/benefits of accepting a grant versus not accepting a particular grant. The cost/benefit analysis must take into account if the grant-funded services are mandated and comply with budgeting guidelines. 3. One-time Grants, which are actually start-up grants for new programs or services, mustwill be submitted to the Board of Supervisors/Board of Directors for approval prior to grant application. Ongoing contribution costs, which Departments/Special DistrictsDepartments wish to continue once the grant funding has been depleted, must be will be identified and Page 7 of 812 Policy Title: ADMINISTERING GRANTS Policy Number: A2505 Current Adoption Date: 6-27-2018MM-DD- 2023 reported to the Board of Supervisors /Board of Directors at the time of consideration of award and acceptance. The Department must present analysis and information to the Board of Supervisors/Board of Directors to assist the Board in deciding whether the County or Special District should fund expenses for the project or program from other County or Special District funds following the depletion of the grant funds. C.D. Claiming Reimbursement 1. Departments/Special District will record and track grant revenues and expenditures utilizing the County financial system. 2. Departments/Special District shall submit claims to the Grantor Agency as frequently as permitted under the grant agreement. This will be no less frequent than monthly or when the expenditures reach $100,000, unless otherwise established by the Grantor. 3. At grant year-end, each Department/Special District shall close out its respective grants. This includes preparing and submitting any required final reports to the Grantor Agency and either returning excess funds or requesting final reimbursement for the grant year. All grant closing documentation will be submitted to the Finance DepartmentOffice of Budget and Finance to ensure the grants are accurately closed on the financial system within 120 days after the grant end date as represented on the County financial system. All unreimbursed costs must be identified and a plan of action defined to ensure an alternate funding source is identified and the grant is effectively closed within the 120-day timeframe. All unresolved grant balances/(deficits) after the 120-day timeframe will be reported to the County Manager by the Department of Finance and the Budget Office Office of Budget and Finance by utilizing the Fund Balance Report. D.E. Indirect Costs- 2 CFR PART 200 — Appendix VII to Part 200 (Federal OMB Uniform Grant Guidance) 2 CFR PART 200 — Appendix VII to part 200 (Federal OMB Uniform Grant Guidance) recognizes Indirect Costs as legitimate grant expenses. As such, it is the intention of Maricopa County or Special District to recover Indirect Costs at all opportunities. In order to do so, the Department of FinanceOffice of Budget and Finance will prepare the following plans on an annual basis: 1. County-wide Central Services Cost Allocation Plan – The Department of FinanceOffice of Budget and Finance is responsible for preparing and negotiating the County-wide plan with Maricopa County’s Cognizant Agency, United States Department of Housing and Urban Development (HUD). The Department of Health and Human Services is Maricopa County’s assigned Cognizant Agency regarding audit issues. 2. Whenever permitted by the Grantor Agency, grants requiring County or Special District matching funds may utilize County Overhead as a last option. All other opportunities must be exhausted to meet the In-Kind match before utilizing County Overhead. If the required match exceeds the amount of In-Kind and/or County Overhead or Overhead is not an allowable expense by the Grantor Agency the Department must inform through the award and acceptance agenda item the Board of Supervisors/Board of Directors of the estimate the relative financial In-Kind impact (2 CFR PART §200.306). 3. Departmental Indirect Cost Allocation Plan(s) are used as a means of equitably recovering Indirect Costs from both federal and non-federal grant programs. All Departments/Special DistrictsDepartments receiving grant funds can submit a written request to the Department of FinanceOffice of Budget and Finance to prepare a Departmental Indirect Cost Allocation Plan. Page 8 of 812 Policy Title: ADMINISTERING GRANTS Policy Number: A2505 Current Adoption Date: 6-27-2018MM-DD- 2023 E.F. County Departments Providing Grant Services to Outside Entities Maricopa County Departments that are allowed to perform grant financial services for entities outside of the County and are not considered to be subrecipients may recover Indirect Costs and/or user charges for the administration of grants. If these outside entities are allowed by their Grantors to recover Indirect Costs and/or charge a user fee to reimburse Maricopa County for services rendered, the monies must be deposited back to the funding source where the support services were initially provided. For example, a General Fund Department being reimbursed for grant management activities shall remit the reimbursement back to the General Fund. F.G. Purchase of Computing and Network Systems Relating to Grant Supported Programs 1. To ensure compatibility and supportability of the County computing and network infrastructure, Departments/Special DistrictsDepartments are to ensure any computer equipment is compatible with the County network prior to purchasing any desired equipment. This applies to hardware, software and communications technologies including data, voice, video, image radio telemetry and facsimile purchases under the provisions of the County’s Procurement Code. 2. Departments in the Judicial Branch of Maricopa County will determine whether the purchase will require compatibility and supportability of the County computing and network infrastructure. G.H. Department of FinanceOffice of Budget and Finance- Finance Division Responsibility While each Department/Special District has staff assigned to monitor and report the financial activities of grants, the Department of FinanceOffice of Budget and Finance will provide general and technical oversight and monitoring of all grant funds. At a minimum, the Department of FinanceOffice of Budget and Finance will: 1. Review and approve grant agenda items when they comply with County policy and the County Grant Manual. 2. Establish a Board approved grant on the County financial system when all supporting documentation is provided. 3. Make availablePrepare and provide to the Departments/Special DistrictsDepartments a monthly grant report (Fund Balance Report). This report will include inception to date financial activity for each individual grant. This report will be used to ensure the effective management and maintenance of grant activity. 4. Monitor that grant expenditures do not exceed grant awards. 5. Review individual grant balances, utilizing the Fund Balance Report, on a quarterly basis to identify Departments that are not requesting reimbursement from the Grantor Agency on a timely basis. Departments/Special DistrictsDepartments that are not regularly claiming reimbursements will be contacted by the Department of FinanceOffice of Budget and Finance. Page 9 of 812 Policy Title: ADMINISTERING GRANTS Policy Number: A2505 Current Adoption Date: 6-27-2018MM-DD- 2023 6. Communicate with the Budget OfficeOffice of Budget and Finance -Budget regardingDivision regarding fund balance and/or deficit issues. 7. Initiate the preparation of the Departmental Indirect Cost Allocation Plans by providing a copy of the current plan, detailed listing of expenditures and other supporting data. Provide support, guidance, and direction to Departments/Special DistrictsDepartments to assist them in the preparation of their Indirect Cost Allocation Plan. 8. Review Fund Balance Report for closed grants to determine compliance with fund balance/deficits. 9. Review and recommend approval of proposed grant applications when Department/Special District is not in full compliance with Grant policy. H.I. Budget OfficeOffice of Budget and Finance - Budget Division Responsibilities 1. Review and recommend approval of grant agenda items when they comply with County policy and the County Grant Manual. 2. Review and recommend approval of Department’s/Special District’s proposed grant budget. 3. Review and recommend approval of adjustments to Department’s/Special District’s grant budget as necessary. 4. Review and take action as necessary to correct any deficit in Grant Funded Budgets. 5. Review and take action as necessary to minimize lost interest earnings to the General Fund due to negative cash positions in grant funds. 6. Review and take action as necessary regarding departmental indirect cost rate plans. Ensure maximum reimbursement of all allowable Indirect Costs. 7. Consistent with Board policy, review Departments spending to ensure that Grant Funds are used before General Fund dollars, and for Special Districts, to ensure that Grant Funds are used before other Special District revenues. 8. Review and recommend approval of proposed grant applications when Department/Special District is not in full compliance with Grant policy. I.J. Department/Special District Responsibilities Each Department/Special District will ensure the following general maintenance activities are completed as defined below: 1. Comply with all provisions of this policy and follow established grant management guidance as outlined by the Office of Budget and Finance and in the Maricopa County Grant Manual. 2. Follow all rules and regulations as required by the grant contract(s) and agreement(s), and Federal OMB Uniform Guidance. 3. Utilize reporting capabilities in the County’s financial system, including the Fund Balance Report, to monitor, track, and manage grant activity. Page 10 of 812 Policy Title: ADMINISTERING GRANTS Policy Number: A2505 Current Adoption Date: 6-27-2018MM-DD- 2023 1.4. Review, reconcile and certify the monthly Fund Balance Report. Any discrepancies are to be reported to the Office of Budget and Finance within two (2) weeks of receiving the Fund Balance Report. A written response must be received by the Department of FinanceOffice of Budget and Finance to report any discrepancies. 2.5. Reconcile and close expired grants on the County financial system within 120 days of the grant end date (as entered on the County financial system). 3.6. Communicate with the Budget Office and the Department of FinanceOffice of Budget and Finance regarding grants with a negative balance (un-reimbursable expense). The Department/Special District must develop a plan of action to resolve the deficit. For Departments, the plan should only consider utilizing General Funds as a last option. 4.7. Prepare the Departmental Indirect Cost Allocation Plan in the format defined by the Department of FinanceOffice of Budget and Finance. Obtain Departmental/Special District approval of the Indirect Cost Allocation Plan and provide a complete copy of the plan with all supporting documenting to the Department of Finance and the Budget Office Office of Budget and Finance by the timeline established by the Department of FinanceOffice of Budget and Finance. 5.8. Ensure that grant expenditures do not exceed grant awards. 6.9. Comply with all reporting requirements as defined by the Grantor and County-wide Grant Policy and Manual. 7.10. Comply with all record retention requirements as defined by the Grantor. VI. RELATED DOCUMENTS: The following documents are available at the indicated site: A. Grant Manual B. Uniform Grant Guidance C. Agenda Numbers: C-18-05-013-6-00; C-18-05-014-6-00; C-18-05-015-6-00; C-18-05-016-6-00; C-18-08-045-6-00; C-18-08-046-3-00; C-18-08-047-3-00; C-18-08-048-3-00; C-06-09-283-6-01; C- 06-09-307-6-01; C-06-09-308-6-01; C-06-09-309-6-01 Revision History Version Revision Date Description of Revision 1 February 1997 Initial version 2 11-17-2004 C-18-05-013-6-00 3 5-7-2008 C-18-08-045-6-00 4 5-6-2009 C-06-09-283-6-01 5 10-30-2017 Revised version. Updated to reflect changes to the Code of Federal Regulations, County department structure, and update to County Grants Manual. Page 11 of 812 Policy Title: ADMINISTERING GRANTS Policy Number: A2505 Current Adoption Date: 6-27-2018MM-DD- 2023 6 6-27-2018 Updated the requirements for County Departments when applying for grants. 7 MM-DD-2023 Clarify language and requirements to align with County’s Grant Manual. (C-18-18-014-6-01)