blm ca l15as00117 questionnaire 2015 must.docx

BLM CA L15AS00117

DEPARTMENT OF THE INTERIOR

FINANCIAL ASSISTANCE EVALUATION QUESTIONNAIRE

The questionnaire is to be used during the financial assistance business process as a tool to assist staff with evaluating recipients during desk reviews or on-site monitoring visits. The questionnaire must be maintained in the award file.

I. Organization Policies and Procedures

A. General Information /Policies and Procedures.

Many of these questions have “Yes” or “No” answers. For “Yes” answers, please provide the specific-reference to your policies and procedures. Please explain all “No” and “Not Applicable” answers. Please provide a copy of the policy, procedures, or section thereof that supports your response to the questions marked with an asterisk – (*).

Note: Title 43 CFR Part 12 Administrative and Audit Requirements and Cost Principles for Assistance Programs; OMB Circular A 122 (now codified as 2 CFR Part 230) references apply to Non Profits, Hospitals and Educational Institutions; OMB Circular A 87 (codified as 2 CFR 225) references apply to States, Local Governments and Indian Tribes; and OMB Circular A 21 (codified as 2 CFR 220) references apply to Educational Institutions.

Note: These are checked with the most logical correct choice (check for any changes)

Pink: Add all authorized reps here to cover all agreements

Yellow: Prompts to check what answer should be

Green: Agreements that require matching only

Blue: Recipient has sub agreements/contracts only

1. Who or which office(s) in your organization is/are responsible for reviewing, approving, and signing applications, awards, and amendments?

– Authorized Representative

2. Who or which office(s) in your organization is/are responsible for monitoring and overseeing assistance agreements once received?

– Authorized Representative

3. (*) Do you have a current Organizational Chart? Show or explain any Yes No N/A non-profit or for-profit organization(s) and/or entities you’re affiliated with.

4. How does your organization keep up-to-date on federal regulations, legal decisions, OMB Circulars, etc.?

Research and updates from federal staff

5. Does your organization have provisions for seeking written prior approvals Yes No N/A for specific revisions, from the awarding agency under certain conditions?

6. OMB Circulars require organizations receiving federal assistance agreements to have written policies and procedures for the following areas. Do your policies and procedures address the items described below?

a. Personnel, including qualifications for each position, duties and Yes No N/A responsibilities, salary ranges, EEO, annual performance appraisals, types and levels of fringe benefits, and standards of conduct governing duties and responsibilities including disciplinary actions for not adhering to the standards, for employees engaged in the award and administration of contracts. (OMB A 122/2 CFR Part 230, Appendix B, paragraph 8; OMB A 87/2CFR Part 225, Appendix B, section 8; OMB A 21/2 CFR Part 220, Appendix A, section J.10);

b. (*) Time reporting, tracked to each project; (OMB A 122/2 CFR Part 230 Yes No N/A Appendix B, paragraph 8.m; OMB A 87/2 CFR Part 225, Appendix B, Section 8.h; OMB A 21/2 CFR Part 220, Appendix A, section J.10);

c. Redistributions (Chargeback’s); (i.e., other organizational department Yes No N/A costs; written, established rates required);

d. Payroll processing and internal controls; (OMB A 122/2 CFR Part 230, Yes No N/A Appendix B, paragraph 8.m; OMB A 87/2 CFR Part 225, Appendix B, Section 8.h, OMB A 21/2 CFR Part 220, Appendix A, section J.10);

e. Overtime (if allowed); OMB A 122 /2 CFR Part 230, Appendix B, Yes No N/A paragraph 8,f; OMB A 87/2 CFR Part 225, Appendix B section 8; OMB A 21/2 CFR 220, Appendix A, section J.10);

f. (*) Vacation and Sick Leave (if offered by your organization); (OMB Yes No N/A A 122/2 CFR Part 230, Appendix B, paragraph 8g; OMB A 87/ 2 CFR Part 225, Appendix B, section 8.d; OMB A 21/2 CFR 220, Appendix A, Section J.10f;

g. Compensatory time (if allowed). (OMB A 122/2 CFR Part 230, Yes No N/A Appendix B, paragraph 8.d);

h. Equipment and property purchases including cost and price analysis, Yes No N/A purchase, use of, inventory and disposition of at the end project.

(A cost analysis is the review and evaluation of each element of cost to determine reasonableness, allocability, and allowability when you do not have other proposals to compare costs against. A price analysis may be accomplished in various ways, including the comparison of price quotations submitted, market prices, and similar indicators, together with discounts).

i. (*) Electronic Funds Transfers (EFT) drawdowns from DOI Bureau/Office Yes No N/A accounts.

Does your policy address who is authorized to request payment from the Federal government, what procedures are used to verify that the request are accurate, and when drawdown of funds will occur;

j. Receipt and deposit of advance payments; Yes No N/A

k. Records retention; Yes No N/A

l. (*) Travel, authorizations, vouchering after the trip and, if required, trip Yes No N/A reporting;

(OMB A 122 / 2 CFR Part 230,Appendix B, paragraph 51; OMB A 87 / 2CFR Part 225, Appendix B, Section 43; OMB A-21 / 2 CFR 220, Appendix A, Section J 53);

m. (*) Procurement Standards for supplies, expendable property, equipment Yes No N/A real property and services. Standards for contracting, purchasing, consultant agreements, sub-awards or grants (if applicable, especially for monitoring sub awardees) and other types of awards that transfer federal funds outside of your organization;

n. (*) Provisions for utilizing Small Businesses, Minority Owned Firms, Yes No N/A Women’s Business Enterprises, and Labor Surplus Area Firms (where possible);

o. (*) Program Income. Is it identified, authorized, accounted for, and are Yes No N/A limitations placed on its use;

p. Cost sharing, matching, and In-Kind contributions. Is it identified, Yes No N/A accounted for and reported;

(OMB A 122 / 2 CFR Part 230, Appendix B, Paragraph 12; and OMB A 87 / 2 CFR Part 225, Appendix B, Section 12; OMB A 21 / 2 CFR 220, Appendix A, Section J.15 (b))

7. Do you have the following documents for each financial assistance award?

a. Original application and certifications; (SF 424, 424A, et al.) Yes No N/A

b. Work plans and/or statement of work; Yes No N/A

c. Initial award and all amendment documents; Yes No N/A

d. Request for and approvals of scope and/or budget changes; Yes No N/A

e. Financial Status Reports and reimbursement requests, if applicable; Yes No N/A

f. Payment requests backed up by financial records to support the request; Yes No N/A

g. Progress reports; Yes No N/A

h. Contracts / Subgrants; Yes No N/A

i. Purchases; Yes No N/A

j. Consultant agreements; Yes No N/A

k. Correspondence and approvals, including emails to and from DOI Yes No N/A Bureau Office Heads.

II. Accounting and Financial Management

These questions have “Yes” or “No” answers. For “Yes” answers, please provide the specific reference to your policies and procedures. Please explain all “No” and “Not Applicable” answers. Please provide a copy of the policy, procedure, or section thereof that supports your response to the questions marked with an asterisk – (*).

A. Accounting

l. Does your organization have an accounting manual? The 43 CFR Yes No N/A requires certain accounting practices / procedures addressed in the questions below to be written.

2. Does your organization’s accounting and financial management system(s) Yes No N/A follow Generally Accepted Accounting Principles (GAAP)?

(OMB Circular A 122 / 2 CFR Part 230, Appendix A, Paragraph A.2.e; OMB A 87 / 2 CFR Part 225, Appendix B, Section 8, OMB Circular A 21 / 2CFR 220, Appendix A, Section J)

3. Does your organization’s accounting and financial management system(s) Yes No N/A provide accurate, current and complete disclosure of the financial results of each federally-sponsored project or program (i.e. each award is accounted for separately), and produce financial reports in accordance with the requirements of 43 CFR Part 12.60?

4. Does your organization’s financial management system(s) provide records Yes No N/A that adequately identify the source and application of funds for federally- sponsored activities, such as authorizations, obligations, unliquidated obligations, assets, outlays, income, and interest?

5. Does your organization’s financial management system(s) provide Yes No N/A effective control over, and accountability for all funds, property, and other assets, including ensuring that all such assets are used solely for purposes authorized by the awards?

6. (*) Does your organization have written policies and procedures to ensure Yes No N/A that costs are reasonable, allocable, and allowable?

(OMB Circular A 122 / 2 CFR Part 230, Appendix A, Section A, OMB Circular A 87 / 2 CFR Part 225, Appendix A, Section C; OMB Circular A 21 / 2 CFR 220, Appendix A, Section C)

7. Does your organizational monitor allowable costs to ensure they are charged Yes No N/A to the grant within the specified period?

8. Does your financial management system(s) report and provide for a Yes No N/A comparison of outlays or grant project expenditures, with budget amounts for each grant project/award or have the capability to do so?

9. Does your organization have budgetary controls to preclude incurring Yes No N/A excess expenditures?

10. Does your accounting system have provisions for reviewing Yes No N/A and monitoring project budgets and program plans, and reporting and rectifying deviations that may occur in them?

11. Do you have a current audit? Yes No N/A

12. If your organization expended more than $500,000 of Federal funds in the Yes No N/A most recent fiscal year, did you obtain an audit in accordance with OMB Circular A 133?

13. If your organization had an A 133 audit performed, were there any Yes No N/A findings, material weaknesses or reportable conditions identified?

If there were, briefly explain or provide a copy of the findings section and your corrective actions taken.

14. If your organization requests reimbursement for indirect cost under the Yes No N/A grant award, does your organization have an approved indirect cost rate?

(OMB Circular A 122 / 2 CFR Part 230, Appendix A, Section C and D; OMB Circular A 87 / 2 CFR Part 225, Appendix E or OMB A 21 / 2 CFR 220, Appendix A, Section G)

15. (*) Does your organization have written procedures for drawing grant Yes No N/A funds and issuing payments? Note: Payment requests should be restricted to immediate needs, i.e. drawing down funds 3 to 5 working days in advance of disbursements.

16. What type of accounting and financial management system(s) does your Yes No N/A organization use? Name of automated system(s)

17. Are accounting records supported by source documentation? Yes No N/A

B. Personnel/Timekeeping (Ref: OMB Circular A 122/ 2 CFR Part 230, Appendix B, Section 8, OMB Circular A 87/ 2 CFR Part 225, Appendix B, Section 8 or OMB Circular A 21 / 2 CFR 220, Appendix A, Section J, Paragraph 10)

1. Does your organization have written payroll policies and procedures? Yes No N/A

2. Do your employees record: actual hours worked directly on all projects, Yes No N/A indirect or administrative time not charged directly to a project, and leave taken?

3. For those employees required to work away from the office, are actual Yes No N/A hours worked documented?

4. Do payroll registers and reports match up with costs for each employee Yes No N/A whose compensation is charged to an assistance agreement?

5. Are timesheets required to be signed by the individual or supervisor? Yes No N/A

C. Personnel/Payroll

Many of these questions have “Yes” or “No” answers. For “Yes” answers, please provide specific reference to your policies and procedures. Please explain all “No” and “Not Applicable” answers.

Does your organization’s written policies and procedures provide for the following controls for the payroll function?

1. Does the policy provide adequate separation of duties? Yes No N/A

2. Are salaries and wages rates established, authorized, and approved in your Yes No N/A organization to ensure equity?

3. Does your payroll process ensure that all deductions from employee’s Yes No N/A salaries authorized by the employee, and proper?

4. How are payrolls distributed? Yes No N/A

5. If checks are distributed manually, are there sufficient controls to ensure Yes No N/A that payroll checks are distributed to the correct employee?

D. Travel (Ref: OMB Circular A 122 / 2 CFR Part 230, Appendix B, Sections 51, OMB Circular A 87/ 2 CFR 225, Appendix B, Section 43 or OMB Circular A 21 / 2 CFR 220, Appendix A, Section J, Paragraph 53) Many of these questions have “Yes” or “No” answers. For “Yes” answers, please provide the specific reference to your policies and procedures. Please explain all “No” and “Not Applicable” answers.

1. Does your organization have written travel policies and procedures? Yes No N/A

2. Are internal controls in place to ensure that employees follow your Yes No N/A organization’s travel policy, i.e. levels of review prior to authorizing payment and that the travel was associated with the specific project?

3. Are internal controls in place to ensure that travel and time reporting Yes No N/A support the employee’s activities while on travel?

4. Do the policies and procedures include provisions to ensure that travel Yes No N/A costs is allowable, allocable, and reasonable?

E. Matching, Cost Sharing, In-Kind Contributions and Program Income. Title 43 CFR Part 12.64 – 12.65 provides criteria on the acceptability, purpose, and types of contributions made in relation to cost sharing or matching purposes, and the support for such. Also, addresses is the accounting for Program Income related to the Federally funded projects.

Many of the questions below have “Yes” or “No” answers. For “Yes” answers, please provide the specific reference to your policies and procedures. Please explain all “No” and “Not Applicable” answers.

1. Does your organization currently have a Matching, Cost Sharing, and/or Yes No N/A In-Kind costs included in any active awards or anticipate any of these types of costs in the foreseeable future?

No______ (Skip this entire section) Yes _______ Please complete the rest of this section.

2. Do any of the matching costs come from another federal grant(s)? Yes No N/A (If “Yes”, it must be authorized in the terms and conditions of the assistance agreement)

3. Are these costs identified in the approved grant project budget? Yes No N/A

4. Does your organization track, record, report and verify these costs? Yes No N/A

5. Are all matching costs verifiable from accounting records and valued Yes No N/A according to applicable OMB Circular cost principles?

Circular A 122 / 2 CFR Part 230, Appendix B, Paragraph 8 and 12; OMB Circular A 87 / 2 CFR Part 225, Appendix B, Paragraphs 8 and 12 or OMB Circular A 21/ 2 CFR 220, Appendix A, Section J Paragraph 15 refer to donations, contributions and program income.

6. Has any program income been used to satisfy the recipient’s contribution Yes No N/A for any current award or added to the funds committed for the project?

7. Is there a term and condition in the award that permits the use of program Yes No N/A income for match requirements or for adding it to the funds committed to the project?

8. If there is no term condition, has the program income been deducted Yes No N/A from the total allowable project cost?

F. Procurement/Contracts/Subagreements

Many of these questions have “Yes” or “No” answers. For “Yes” answers, please provide the specific reference to your policies and procedures. Please explain all “No” and “Not Applicable” answers. Please provide a copy of the policy, procedure, or section thereof that supports your response to the questions marked with an asterisk – (*).

1. Does your organization have written procurement policies and procedures? Yes No N/A

2. Has your organization awarded contracts or subagreements under any of Yes No N/A the award agreements being reviewed? (Agreements refer to sub grant(s).

Subgrant(s) mean an award of financial assistance in the form of money, or property in lieu of money, made under a grant by a grantee to an eligible subgrantee, subrecipient or by a subrecipient to a lower tier sub recipient. This includes financial assistance when provided by contractual legal agreement, but does not include procurement purchases of goods and services.)

3. Were contracts awarded in accordance with your organization’s contracting policy and does this policy comply with 43 CFR Part 12, as described below?

a) (*) Contains a written code of conduct that addresses conflict of interests Yes No N/A and disciplinary actions.

b) Provides for competing transactions in a free and open manner. Yes No N/A

c) Provides for: a review to avoid unnecessary purchases, a review of lease Yes No N/A vs. purchase alternatives (when appropriate), conducting solicitations with a clear scope of work and bidder requirements, conserving natural resources, and utilizing small, MBE and WBE firms when possible.

d) Requires performing and documenting a cost analysis for sole source Yes No N/A procurements.

(A cost analysis is the review and evaluation of each element of cost to determine reasonableness, allocability, and allowability when you do not have other proposals to compare costs against.)

e) (*) Requires performing and documenting a price analysis for competitive Yes No N/A bidding and small purchase procurement actions.

(A price analysis may be accomplished in various ways, including the comparison of price quotations submitted, market prices, and similar indicia, together with discounts.)

f) Requires documenting the basis for all procurement selections, Yes No N/A justifying a lack of competition and basis for award cost and price.

g) Discusses purchases/agreement/contract cost thresholds (small purchases Yes No N/A vs. major procurements) and personnel required to approve procurements.

h) Has provisions that no contract or sub award will be entered into with Yes No N/A parties that are debarred, suspended, or excluded from

Federal assistance programs.

4. Do any of your organization’s contracts for grant project exceed the Yes No N/A Federal small purchases threshold, ($100,000)?

5. If “Yes”, did DOI Bureau/Office request to review the contract Yes No N/A prior to award?

6. If “Yes”, did DOI/Bureau Office provide written comments? Yes No N/A

7. Does your organization use a pre-qualified list of persons, firms, or Yes No N/A products to acquire goods and services?

8) Did your organization follow its procurement policies to place and update Yes No N/A vendors on the list?*

9) Has your organization established an affirmative procurement system Yes No N/A for recycled materials and compliance with environmental statutes?

10) Does your organization have internal control processes to ensure that Yes No N/A only required goods and services are acquired in quantities needed?

11) Does your organization have internal control processes to ensure that Yes No N/A only acceptable goods and services are paid for by the accounting/finance department?

12) Does your organization have guidelines for documenting its contract files? Yes No N/A

13) Has your organization awarded contracts to consultants under current Yes No N/A assistance agreements?

14) Are internal controls for consulting agreements in place to ensure that Yes No N/A your organization does not charge financial assistance agreements more than the authorized direct salary cap?

15) Do your consulting agreements specify the services to be provided, Yes No N/A engagement duration, reporting requirements, work location, and pay rates including base rate, fringe benefits, and overhead?

G. Property Management

Many of these question have “Yes” or “No” answers. For “Yes” answers, please provide the specific reference to your policies and procedures. Please explain all “No” and “Not Applicable” answers.

1) Does your organization have written property management policies Yes No N/A procedures?

2) Has your organization purchased capital equipment on any of its active Yes No N/A assistance agreements?

Yes _____ (Please complete this section) No ____ (Go to Section I)

Equipment, under the Federal Guidelines, is equipment that is considered tangible items with a useful life greater than one (1) year and greater than $5,000 in value. Recipients may have limits that are different than the Federal Guidelines. That is acceptable as long as the limits are not greater than the Federal Guidelines.

i. (*) Do you have a current Organizational Chart? Show or explain any Yes No N/A non-profit or for-profit organization(s) and/or entities you’re affiliated with.

3) Does your organization have an inventory control system? Yes No N/A

4) Does your organization maintain property records that identify equipment Yes No N/A purchased, either entirely or partially, with Federal funds?

5) Does your organization perform a property inventory at least every two (2) Yes No N/A years? Date of last inventory: _____________________________

6) Does your organization maintain records of property dispositions? Yes No N/A

I. Internal Controls

Many of these questions have “Yes” or “No” answers. For “Yes” answers, please provide the specific reference to your policies and procedures. Please explain all “No” and “Not Applicable” answers.

1. Does your organization have policies and procedures to ensure compliance Yes No N/A with the cash management requirements in 43 CFR?

a. Does your organization have an internal auditor or audit staff or someone Yes No N/A that provides for an independent review of the accounting and financial management process, cash receipts and payments, and safeguarding of assets?

2. Does your organization have policies and procedures to ensure compliance Yes No N/A with closing out assistance awards after the performance and budget periods?

3. Does your organization have a process in place to ensure compliance with the Programmatic Term and Conditions in the following areas?

a. Submitting programmatic progress reports; Yes No N/A

III. Transaction Testing

A minimum of three non-consecutive draws from different grants will be selected for review. The draws will be from a specific time period being reviewed.

(*) As the recipient, you will be required to provide documents (invoices, timesheets, contracts, ledger excerpts) that identify and support the selected funds drawn.