FY25_Grants_Admin_Manual_-_FINAL.pdf

CITY OF ST. PETERSBURG, FLORIDA

GRANTS ADMINISTRATION

MANUAL

Updated and maintained by the Budget and Management Department in collaboration with the Finance Department FY2025: October 2024

Contents

FOREWORD

INTRODUCTION AND BACKGROUND

What is a Grant?

What are We Agreeing To?

Who Can Help?

What is Your Responsibility?

CHAPTER 1: APPLYING FOR A GRANT (see also Appendix D)

Finding Funding

Grants.gov

Agency Websites and Listservs

Financial and Technical Assistance for Florida Municipalities

Grant Finder and Grant Tracker (eCivis) CSP Decision to Apply Procedures

Grants Working Group Writing the Proposal

Grant Writing Assistance

Grant Guidelines

Unique Entity Identifier (UEI)

Submitting the Proposal

Mayor’s Letters of Support to External Organizations for External Grant Applications

CHAPTER 2: RECEIVING AND MANAGING THE GRANT

Types of Funding Source

Types of Award Funding

Cost-Reimbursable

Advance Funding

Fixed Price/Per Diem Receiving & Managing the Grant

Acceptance of the Award

City Council Approval

Project and Award Setup

PTAEO Number String

The Grant Release Checklist

Establish the Grant Files

Expenditure Documentation

All Awards: Allowable Costs and Assigning Project Charges

Federal Awards: Allowable Costs - Required Written Procedures

Time and Effort Reporting Requirements Invoice Grantor (Revenue)

City of S t. Petersburg FY25 Grants Administration Manual i

Collecting Revenue (Cash Receipts)

CHAPTER 3: MONITORING AND OVERSIGHT

Types of Funding and Related Authority

Components of Monitoring and Compliance

Allowable Costs

Reporting

Quality Assurance & Quality Control

Subcontracting

Cost Sharing/Matching

Program Generated Income (PGI)

Support of Salaries and Wages

Fringe Benefit Rate

Equipment and Real Property Management

Fraud, Waste and Abuse

Indirect Cost Rate

Grant Close-Out

Record Retention

Important Federal Guidelines Regarding Construction Projects

CHAPTER 4: MODIFICATIONS, EXTENSIONS, OR CANCELLATIONS TO THE BUDGET OR

PROJECT SCOPE-OF-WORK

Prior Approvals

CHAPTER 5: AUDITS & FINANCIAL REPORTING

Federal Awards Single Audit

Florida Single Audit Act

Schedule of Federal and State Awards

CHAPTER 6: ROLES AND RESPONSIBILITIES

Department

Award Manager

Project Manager

Administrative Staff

Department Director Budget and Management/Grants Division

Grants Officer (GO)

Strategic Grant Writer (SGW)

Strategic Grant and Infrastructure Implementation Manager (SGIIM) Finance

Finance Department Grants Team (FDGT) Legal

Administrators

Office of City Auditor

CHAPTER 7: RESOURCES

ii

Grant Management Links

Grant Writing Tips and Guidance Links

GLOSSARY

APPENDICIES

(APPENDIX A) Grant Administration and Application

(APPENDIX B) Signature Authority

(APPENDIX C) Property Inventory & Fixed Asset Control

(APPENDIX D) Grant Process – Applying for a Grant

(APPENDIX E) Grant Process – Receiving a Grant Award

(APPENDIX F) Grant Process – Initiation of Grant Award

(APPENDIX G) Grant Process – Monitoring Grant Awards

(APPENDIX H) Grant Process – Subrecipient Monitoring

(APPENDIX I) Grant Process – Grant Close-Out

(APPENDIX J) City Council Resolution 2014-162

(APPENDIX K) Fraud, Waste & Abuse Policy

(APPENDIX L) Procurement Operations Manual: CH. 15, Uniform Guidance for Federal Awards" iii

FOREWORD

The City of St Petersburg’s (CSP) grants administration program has a centralized-decentralized system model approach which is designed to:

• Gauge all grant applications, commitments, and acceptance by the City.

• In coordination with the Grants Division, provide the resources and flexibility to subject matter experts in the various departments to search, find, and apply for grants to meet the

City’s needs.

• In coordination with the departments’ Project and Award Managers, the Grants Division, and the Finance Department Grant Team, monitor and manage the grants with three documents:

1. The Grants Manual serves as the guiding document to the City’s Grants

Administration Program,

2. The City’s Grants Administration and Application Policy outlining the City’s policy for grants, and

3. A How-to Grant Manager’s Step by Step Guide on tracking and managing grants through the citywide e-business Oracle software system.

INTRODUCTION AND BACKGROUND

The City actively seeks grants that will enhance and optimize City services, programs, and infrastructure. The purpose of this manual is to describe the policies and procedures of the CSP associated with:

• The identification and development of grant proposals to external public and private funding sources,

• Receipt and management of externally funded grant awards/financial resources,

• To define the roles and responsibilities of CSP employees pertaining to the management of external funding and compliance with prescribed grant and City requirements, and

• Establish quality assurance and quality control processes for grant administration.

This manual is designed to assist CSP personnel create efficiencies, avoid duplication of efforts, maximize human resources on projects that potentially interface across departmental lines, eliminate

"process" questions relating to proposal development and award management, and to maintain accurate grant records for the City. It includes the procedures necessary for:

• Identifying grant/external funding opportunities

• Applying for grant/external funding

• Accepting grant/external funding

• Tracking the grant/external funding revenues and expenditures

• Monitoring sub-recipients

• Closing out the grant/external funding

What Is A Grant?

Grants awarded to the City are financial assistance from an external entity to carry out a public purpose of support or stimulation. Funds can either be dispensed directly by the granting agency to the City, or in certain situations may be passed through another entity - such as the state, federal, or other governmental and non-state entities.

"Grants" can be in the form of: loan contracts, loan guarantees, cooperative agreements, joint participation agreements, contract for services, private and business contributions, interlocal agreements, as well as other types of contractual documents. Grant awards can also be provided in non-monetary supports provided to CSP that provide value. Examples may include equipment, technical assistance, services, etc.

What Are We Agreeing To?

When the City applies for and receives a grant, it agrees to administer the funding according to the granting agency’s (Grantor) terms and conditions. Accounting properly for grant expenditures and providing program documentation and evaluation is critical to our success in getting and sustaining grant awards.

Who Can Help?

The Grants Division team of the Budget and Management Department and the Finance Department’s

Grants Team (FDGT) oversee the acquisition and administration of grants executed by the City and assist City personnel in all grant-related matters. The Grants Division is comprised of the following personnel Strategic Grants and Infrastructure Implementation Manager (SGIIM), Grant Officer (GO), and Strategic Grant Writer (SGR).

What Is Your Responsibility?

Departments and staff throughout the CSP are active participants in the life cycle of grant acquisition and administration. During application development, assigned department staff shall serve as subject matter experts. Once awarded funds, it is the responsibility of assigned department staff to manage the project appropriately and accurately, external funding, and reporting requirements per grantor agreements and guidelines and the policies and procedures of the City of St. Petersburg. Staff designated as the Project Manager and Award Manager serve as the subject matter experts throughout the life cycle of the grant application and hold primary responsibility for administration of the grant award and related agreement(s).

All CSP staff are responsible for being aware of and following the Grants Administration and

Application Policy which serves as the guiding document grants administration. This policy included below in its entirety below.

City of St. Pete rsburg FY25 Grants Administration Manual

CHAPTER 1 : APPLYING FOR A GRANT

(ALSO SEE APPENDIX D)

CHAPTER 1: APPLYING FOR A GRANT

Section A: Finding Funding

Departments and staff throughout the CSP are active participants in the life cycle of grant acquisition, including the location of available funding opportunities. Grant opportunities which may benefit the

CSP may be identified throughout all CSP departments, including the Grants Division. Below are common, non-exclusive, methods used by CSP staff to locate grant opportunities.

• Grants.gov http://www.grants.gov/

Grants.gov is the clearinghouse for all federal grant opportunities and allows organizations to electronically find and apply for more than $400 billion in federal grants and ultimately manage grant funds online through a common web site. Subscribing to Grants.gov will provide you perpetual notice of grant opportunities from federal agencies – simply visit the website and sign up for its email newsletter and email grant opportunities.

• Agency Websites and Listservs

Many agencies have listservs to which interested parties can subscribe to receive the latest grant opportunities and information. Simply visit the respective agency’s grants office website and subscribe per instructions.

• Financial and Technical Assistance for Florida Municipalities

This periodical is compiled by the Florida League of Cities, Inc., and contains data on grants, loans, technical assistance, and other resources available to Florida municipalities. Contact the

Budget and Management Department to obtain this reference.

• eCivis

In addition to the Grants Division’s routine grants search efforts, it is the responsibility of the departments’ subject matter experts to use their professional sources for grant searches.

Designated department representative may also utilize the eCivis search engine on a regular basis to find grants appropriate for the City.

Identify funding opportunties

Grants Working Group authorizes grant application submittals

Grant application process

City Council accepts and allocates grant funding

City of St. Pete rsburg FY25 Grants Administration Manual http://www.grants.gov/

Section B: CSP Decision to Apply Procedures

Following the identification of a grant opportunity, CSP staff shall contact the Grants Division when considering applying for a grant, or participating in a collaborative grant application, to discuss the project scope, application development resources required, potential impact on operations, competing projects, financial considerations, post award reporting requirements, and other grantor agency policies/procedures.

Grants Working Group Approval must be obtained from the CSP’s Grants Working Group prior to submission of any application or renewal to external grantors that bring external resources of financial value to CSP as outlined in the City Administrative Policy for Grants Administration and Application. The Grants

Working Group authorizes the submittal of external grant requests on behalf of the City of St.

Petersburg. Unless otherwise noted, it meets the second Monday of each month. The Grant Officer will send a monthly reminder for submissions. The membership of the Grants Working Group is outlined in the Administrative Policy for Grants Administration and Application. In addition to Grants

Working Group approval, grant related estimates of future ongoing contractual replacement or annual maintenance expenses associated with the grant exceeds $100,000, or includes new CSP positions, additional reporting to City Council is required.

Please note, Departments shall also inform the Grants Division in advance of any pre-application submission requirements such as Letters of Interest, Notices of Intent, etc. Information shall include, but not be limited to, CSP point of contact, owning department, grant opportunity title, granting agency, project title, and projected award amount. Grants Working Group will be provided notice of such efforts and full review is required prior to full application submission.

Section C: Writing the Proposal

Upon approval by the Grants Working Group, the submitting department serves as the subject matter expert and lead point of contact for application development. The submitting department and Grants

Division staff shall coordinate grant writing support and a timeline for application development. Grant narratives may be prepared by the 1) department, 2) Grants Division staff, 3) external grant writers under contract with the CSP, or a combination of the above-named resources. The Grants Division is available to provide support and coordination of grant applications, however it is the submitting department’s responsibility to support application development and submit the grant proposal application.

Successful grant writing includes planning, searching for data and resources, writing, packaging a proposal, submitting a proposal to a grantor, and follow-up. The Grants Division staff in the Budget and Management Department may provide assistance in the preparation of the grant application as well as budget formulation and will assist in obtaining answers to questions that the department may have.

Tips for a successful application:

• Read all grantor funding opportunity guidelines for specifications about required information and how the grant proposal should be arranged.

• Follow all guidelines as specified.

• Structure, attention to specifications, concise, enthusiastic, and persuasive writing and a reasonable budget with justification narrative are the critical elements to be considered during the writing stage.

• Visit the Grant Writing Tips & Guidance page on the CSP website at https://www.stpete.org/residents/grants___loans/guide_to_grants.php for useful tips on successful grant writing.

Grant Writing Assistance As noted above, grant application support needs shall be communicated to the Grants Division for review and assignment as early in the process as possible. The SGIIM, or designee, will review the request for support, funding opportunity, etc. to assess the most appropriate grant writing support, to include internal grant writing based on availability. If external grant writing resources are determined appropriate, Grants Division staff will coordinate with the submitting department to contact and select an external grant writer from the City’s approved list of grant writers. In instances where external grant writing resources are required, at least five weeks’ notice is needed to allow for development and processes of related Task Order. The Grants Division and submitting department shall coordinate on the development of associated Task Order including cost, deliverables, and timeline.

Grant Guidelines Grant application guidelines identify what to include in the respective grant proposal. Therefore, it is critical to thoroughly read and follow grant application guidelines. Grant guidelines typically identify:

• Submission deadlines, including various submission requirements such as Letters of Interest, Notice of Intent, etc.

• Grantee eligibility

• Proposal format: forms to use, page limitations, page margins, line spacing, etc.

• Budgets and budget justification narrative

• Funding goals and priorities

• Award levels

• Evaluation process and criteria

• Point(s) of contact

• Any other submission requirements

Unique Entity Identifier (UEI):

The CSP has been assigned a UEI by the federal government. As of April 2022, UEI is used by the federal government to identify entities for the purpose of government awards and within financial systems. The CSP UEI is often needed at the time of grant submission. The City has the following

UEI:

Citywide Grants: LARHMJNJAKS4

Housing Grants: LAX8CUV176X5

Airport Grants: N9B90GZD7YQ5

If the City plans to issue a contract or sub-award, those entities must also be registered in SAM.gov and have a UEI number.

Submitting the Proposal It is the responsibility of each respective department to ensure the grant application is internally approved and signed by an authorized representative of the City

City of St. Pete rsburg FY25 Grants Administration Manual https://www.stpete.org/residents/grants___loans/guide_to_grants.php http://sam.gov/

(Appendix C – City Administrative Policy for Signature Authority).

The Grants Division shall complete a review of grant applications in advance of final review and approval by the CSP authorized representative. Whenever possible, it is recommended this review occur no less than one week prior to the grant application deadline. Copies of application budgets shall also be provided to Finance during the development process and prior to application submission.

Upon completion of these reviews and any related edits, the submitting department and the Grants

Division’s Grants Officer will coordinate a grant application review before obtaining authorized signature. (Appendix F – Grant Process, Applying for a Grant). The departments or Grants Officer will then forward the proposal to the Assistant City Administrator for signature and have the signed document returned to the department for submittal to the granting agency. The Grants Officer will support the department in coordinating application submittal. Application submissions shall only occur after review and approval by the Grants Division and the Assistant City Administrator.

Based on the grant application guidelines, either the Assistant City Administrator will submit the application, or the Assistant City Administrator will designate authority for the department to submit the application. It is the department's responsibility to submit the proposal to the granting agency before the submittal deadline.

Mayor’s Letters of Support to External Organizations for External Grant Applications The City partners with and supports legal and fiscally sound external organizations in grant applications which furthers the City’s goals and mission. The Mayor may provide letters of support to such organizations. These requests shall be made through the CSP website. Requests will be forwarded to the Grants Officer for review and coordination. Letter of Support requests shall be submitted at least three weeks prior to grant application submission deadline. The requestor shall provide a draft sample letter with the request. The Grant Officer will coordinate internal approval and execution with the Mayor’s Office and other CSP staff, as applicable. Other information necessary shall be provided with the request.

CHAPTER 2: RECEIVING AND

MANAGING THE GRANT

CHAPTER 2: RECEIVING AND MANAGING THE GRANT

Section A: Types of Funding Source

Grants have three categories of funding sources for tracking and financial reporting purposes at the CSP:

Section B: Types of Award Funding

Grant award funding may be administered in a variety of methods as determined and prescribed by the

Grantor. Types of funding awards include:

• Cost-Reimbursable: Cost-reimbursable grants are the most commonly received by the

City. Reimbursement is requested by the City after expenditures have been paid, which means that the City subsidizes the project costs until reimbursement is made by the grantor. Therefore, it is vital that correct, allowable charges are posted to the right project and award (PTAEO) and that reimbursement requests are submitted in a timely manner.

• Advance Funding: Some awards are received by the City in advance of the project being performed, completed, or before expenditures are made. However, the reporting requirements are much the same as for cost-reimbursable grants. In addition, it is probable that any remaining, unspent funds must be returned to the grantor. Advance funds normally require tracking interest revenues and either applying those funds to the project or returning them to the grantor. These requirements are discussed in 2 CFR 200.305 and detailed in the grant agreement. Contact the Finance Department’s Grants Team for assistance in receiving advance funding and monitoring interest earnings.

• Fixed Price/Per Diem: These are awards wherein the City is paid a set amount by the grantor to fulfill a project, and the City receives the full award amount regardless of whether all funds are expended – as long as the project successfully fulfills the stated objectives as proposed in the grant application. Requesting reimbursement of fixed price awards is the same as cost-reimbursable awards, except they do not require a detailed listing of expenditures and are normally reimbursed in fixed increments, with final payment received once all deliverables have been submitted and approved by the grantor.

For cost reimbursement or fixed/per diem related grants that are to be managed outside of the City’s General Fund may require an advance from the General Fund for the awarded amount. Awards in funds other than the General Fund may require an advance in order to

•Federal grants are approved and appropriated through bills passed by Congress

Federal (whether direct or indirect)

•State grants are approved by the Secretary of State

State

•Other local governments, government organizations, businesses, etc.

Other

City of St. Pete rsburg FY25 Grants Administration Manual https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/section-200.305 limit the occurrence of negative cash from Equity in Pooled Cash, which is an unauthorized advance from the General Fund. Repayment language can be standard in the grant acceptance resolution that the advance is to be repaid upon reimbursement or fixed/per diem payment from the grantor agency. Please contact the Finance Department’s

Grant Team.

Section C: Receiving and Managing the Grant

Department staff shall provide timely communication (three working days maximum) to the Grants

Officer and FDGT following receipt of the grant award notifications. The notification of an award serves as the first step in the process for CSP to receive and accept an award. During this period, a variety of actions must be taken by the department, in collaboration with the Budget and Management and Finance

Departments to complete the grant agreement and begin project implementation. Following notification of an award determination the Grants Division will coordinate a Grant Kick Off Meeting.

Grant Kick Off Meetings are designed to create a shared opportunity for involved parties to review elements that may impact award acceptance, implementation, invoicing, and compliance in the early stages of the grant implementation. Grant Kick Off Meetings may include, but are not limited to, discussions on the following:

Grant Release Checklist

• Grant Agreement

• Council Requirements

• Budget/Advances

• Compliance

• Subrecipient considerations

• Training needs (Oracle, Procure to Pay, etc.)

Meetings must occur for the project to be baselined in Oracle (cleared for spending) (see Section F: Project and Award Setup). Additional meetings may be coordinated based on the needs of an individual

Department/Grant Award. Kick Off Meetings may be waived on a case-by-case basis at the discretion of the CSP Controller.

Section D: Acceptance of the Award

Upon receipt of the grant award, the department Award/Project Manager prepares the Council agenda materials (see City Clerk's "Agenda Preparation Manual" located on the Intranet: Agenda Preparation

Manual) and routes to the Legal Department with a copy sent to the Budget and Management

Department Analyst and Grants Officer. Legal will review the agreement and materials to ensure that they comply with applicable law and CSP contractual requirements and internal policy. Budget and

Management compares the agreement to the department’s budget to determine if an appropriation is necessary, and the Grants Officer begins inputting the award into Oracle.

After Legal has completed its review of the award agreement, it prepares the document for signature by the City's authorized representative and returns it to the department for subsequent acceptance/allocation of funding by the City Council. Following City Council acceptance, the department forwards the agreement to the authorized representative for signature then submits to the grantor for full execution.

Upon receipt of the fully executed grant agreement, the original is sent to the City Clerk with a copy sent to the Grants Officer and the FDGT. (Appendix G – Grant Process-Receiving a Grant).

City of St. Pete rsburg FY25 Grants Administration Manual https://stpsp1/sites/csp/Intranet/CityClerk/City%20Clerk%20Documents/AGENDA%20PREPARATION%20MANUAL.pdf https://stpsp1/sites/csp/Intranet/CityClerk/City%20Clerk%20Documents/AGENDA%20PREPARATION%20MANUAL.pdf

Section E: City Council Approval

As mentioned in Section D: Acceptance of the Award, the department Award/Project Manager is responsible for sending the council agenda materials to the City Clerk for inclusion on the Council agenda (see the City Clerk's "Agenda Preparation Manual"). For those contracts that contain services subcontracted by external entities, the subcontract shall be included in the materials sent to Council.

After Council accepts the award and appropriates funding, the department will send a copy of the signed resolution to Budget and Management. Budget and Management will record the itemized budget for the expenditure of grant funds. After being approved by Council, two or more original copies of the contract (one for the City plus the number required by the grantor) must be sent to the

City's authorized representative for execution by the City. The signed documents will be returned to the department, and the department returns the originals to the grantor for full execution. Upon receipt of the fully executed agreement from the grantor, the signed agreement is routed to the following.

• Original to City Clerk for the official record

• One copy for department’s files

• One e-copy to the Grants Officer in Budget and Management and the Finance

Department’s Grant Team

Section F: Project and Award Setup

It is the responsibility of the department Award/Project Manager to create the project and enter it into Oracle; however, for those departments that do not routinely create projects the Grants

Officer/FDGT will provide the necessary assistance and training to create your project (see “How to

Manual” on the “U” Drive under grants; also on the Budget and Management intranet page).

Once the Grants Officer receives the Council approval accepting the grant award, the funds have been appropriated, and the Grant Release Checklist (see below) is completed an award will be created in

Acceptance Project & Award Setup in Oracle

Accounting System

Grants Release Checklist

Establish Grant Files

Grant Kick Off Meeting

Expenditure Documentation

Invoice Grantor (Revenue)

Collecting Revenue (Cash Receipts)

Compliance (Chapter)

City of St. Pete rsburg FY25 Grants Administration Manual https://stpsp1/sites/csp/Intranet/CityClerk/City%20Clerk%20Documents/AGENDA%20PREPARATION%20MANUAL.pdf file://///stpfs2msc/global/Budget/How%20to%20create%20a%20project%202019.pptx file://///stpfs2msc/global/Budget/How%20to%20create%20a%20project%202019.pptx http://stpsp1/sites/csp/Intranet/Budget/_layouts/15/start.aspx#/SitePages/Home.aspx

Oracle. Award setup will be finalized upon receipt of a fully executed grant agreement e-copy, fully executed City Council resolution or ordinance, and completed checklist. The award will be created and "baselined" in Oracle, releasing the project and award for spending. The department will prepare a Grants Release Checklist including the Terms of Award and submit to the Grants Officer (Appendix

H – Grant Process-Initiation of Grant Award).

Unless pre-spending has been authorized by the grantor, spending or encumbering eligible grant funds is prohibited until full execution of the grant agreement. Without prior approval, expenditures made before full grant execution will be ineligible for grant reimbursement and will come out of the department's current operating budget.

Award/Project Managers will need to obtain access to the following Oracle modules in order to manage and bill grantor agencies for awards and projects: Oracle GL Inquiry, Oracle Grants

Accountant, and Oracle AR Department User.

PTAEO Number String The PTAEO is the critical number string used when charging expenditures to your award. The

PTAEO should be used for all grant related expenditures and revenues; including the Procure to Pay

Cycle (at purchase requisition) and for payroll entries. Ensure the accuracy of this charge string prior to posting expenditures against the grant award. The PTAEO string consists of:

• Project (ex. 12345)

• Task (ex. 01.02.03)

• Award (ex. 12321)

• Expenditure Object Code (ex. 5650110)

• Owning Organization (Department and Division Codes) (the unit responsible for "paying" the charge). (ex. 123.1234)

**Please refer to the Grant Manager’s How-To Step by Step Guide for more information on tracking and managing grants through Oracle. This includes creating a project, creating an award, billing a grantor, etc.

Section G: The Grant Release Checklist

The Grant Release Checklist (Appendix D) is the form used for monitoring and notification processes throughout the life of the grant. The checklist is initially prepared by the department Award/Project

Manager, including the Terms of Award, and submitted to the Grants Officer with accompanying grants documents for award set up and baseline. The Grants Officer will review the award document including the Terms of Award portion that details those requirements vital to fulfill the administrative requirements of the grant.

The Grant Release Checklist will be used to:

• Identify the Project and Award Managers

• Assign the project and award numbers

• Identify the source(s) of cost sharing and/or match

• Establish the source of funding and the type of grant

• Identify the City UEI number used for grant application (including UEI for any applicable sub-recipients or vendors)

• Identify the Assistance Listing Number (ALN), formerly CFDA or CSFA number (critical for audit purposes)

• Provide appropriate grantor point of contact information

• Identify any subcontracts

• Identify key Terms of Award and deliverables required to fulfill grant administrative requirements

• Establish due dates for grant deliverables/reports

• Document allowable cost procedures

• Proposed budget by expenditure group for the grant

• Identify any fringe or indirect cost rates to be utilized by the grant

Section H: Establish the Grant Files A.

Upon receipt of the award, the department Award/Project Manager shall establish a unique grant file for each grant award. Grant Files shall be created and maintained in the following shared location and accessible by CSP staff. Grant Files shall be organized in alignment with the below file structure and naming convention to ensure consistent organization of grant records. At a minimum, the following documents must be contained in the Grant File by the grant’s Award/Project Manager.

U Drive/Grants/Grant Files: Organized by FYXX.OPPORTUNITY.GRANTOR.PROJECT TITLE.

AWARD # (Example: FY23.Resilient Florida.FDEP.Vulnerability Assessment.12345) Fiscal Year should reflect the fiscal year of when the award was first accepted by City Council.

• Grant Application Documents:

• Grant proposal/application

• Grant application budget

• Grant Acceptance:

• Grant award notice (email/letter, etc.)

• Executed agreement

• Grant Release Checklist and Terms of Award

• All modifications to the grant award, i.e., continuations, supplements, modifications

• Council agenda items and resolution(s)

• Grant Budget:

• Budget amendments/transfers

• Purchase orders and expenditure documentation (Requisitions, invoices, receipts, etc.)

• Reimbursement requests and copies of reimbursement checks/electronic Oracle screens

• Subcontract(s) (if applicable)

• Subcontract agreements

• Document UEIs for sub-recipients and vendors of grant funds. Payments may not be processed until the UEI is obtained. Department shall contact the FDGT for questions relative to exceptions for threshold amount and individuals.

• Evidence of subrecipients in-direct cost rate.

• Grant Monitoring and Reporting:

• All technical, progress, and final reports

• Reimbursement requests submitted to agencies, copies of reimbursement checks and invoices.

• Evidence and procedures of sub-recipient monitoring. property records (and disposal records if applicable)

• All written documentation pertaining to the grant, including correspondence, emails, notes (and phone log if applicable)

• Internal and external monitoring reports, including but not limited to, Quality

Assurance and Quality Control records, Corrective Action Plans, Performance

Improvement Plans, etc.

Section I: Expenditure Documentation

The grant agreement and grantor general policies establish the requirements for charging costs to the award, reporting those costs, and requesting reimbursement. Expenditure documentation should include proper approval process support (example may be a purchase order) and allowable expenditures supporting documentation. Allowable expenditure documentation support may include invoices, time sheets and work orders, as well as receipts and requisitions.

Important Reminders:

• If CSP plans to issue a contract or sub-award, those entities must also be registered in

SAM.gov and have an UEI number.

• A fully executed contract between the City and the contractor/sub-recipient shall be on file and maintained in the Grant File.

• Each Grant/Grantor may have different requirements with regard to acceptable supporting documents that serve as proof of eligible expenditures. See Federal Emergency Management

Agency (FEMA) example below:

FEMA Disaster Cost Reimbursement

Required by each Department

Labor & Usage

FEMA Labor & Equimpment Sheet (by payroll period)

Benefits rate - Resource:

already calculated Finance by department)

Equipment rate - Resource: FEMA & City

Equipment Costs worksheet

Signed Time Sheets

Payroll Data - Resource:

Payroll Earnings Report

(Internal Summarized sheet in Excel)

Vendor - Supplies

FEMA Materials Sheet

Invoice form Oracle Payables or JPM Pcard

Proof of Payment

Expenditure Detail - Resource: Oracle GMS

Reorts

(Internal Summarized sheet in Excel)

All Awards: Allowable Costs and Assigning Project Charges In order to be charged against a grant award, all costs must be eligible, which means they are:

Allowable, allocable, necessary, reasonable, and provide a direct benefit to a grant funded project.

It is vital that transactions are properly charged to the correct grant award to avoid unnecessary expenditure transfers later. Expenditure transfers on grants are audit flags that can lead to disallowable costs.

Federal Awards: Allowable Costs - Required Written Procedures For Federal awards under Uniform Guidance – allowable costs written procedures are required.

Allowable costs for Federal awards under Uniform Guidance are identified in 2CFR, subpart E- Cost

Principles, as allowable or non-allowable costs by category. The list is not exhaustive or detailed but provides Project and Award Managers guidance on basic consideration to apply all costs.

1) Authority

2 C.F.R. Part 200, §200.302(b) (7) “Written procedures for determining the allowability of costs in accordance with Subpart E—Cost Principles of this part and the terms and conditions of the Federal award.”

2 C.F.R. Part 200, §200.403 to be allowable under Federal awards, except where otherwise authorized by statute, costs must be:

• Necessary and reasonable and allocable

• Conform to cost principles or Federal award as to types or amount of cost items

• Consistent with policies and procedures that apply uniformly to federal and non-federally funded activities

• Consistent treatment as direct or indirect cost

• In accordance with GAAP (generally accepted accounting principles)

• Not included as a cost to meet cost sharing or matching requirements of any other federally- financed program

• Adequately documented

2) Subpart E -- Cost Principles

The application of these cost principles is based on the fundamental premises that the City has in place sound management practices; will follow the terms and conditions of the specific

Federal award and will determine, based on its own unique combination of staff, facilities, and experience how to assure proper and efficient administration of the federal funds.

§200.420 addresses 55 “items of cost” that receive clarification regarding allowability, in general, for using federal funds. It is not an exhaustive or minutely detailed list but provides guidance on “Basic Considerations” to apply to all costs, listed or not listed.

3) Written Procedures for Determining Allowable Costs

Written procedures such as required per 2 C.F.R. Part 200, §200.302(b) (7) are not a reiteration of the federal requirements or the policies or goals. Rather, procedures are the step-by-step process that is used to obtain the goal or the steps that are necessary to be in compliance with

City of St. Pete rsburg FY25 Grants Administration Manual https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/section-200.302 https://www.ecfr.gov/cgi-bin/retrieveECFR?gp&SID=ee51e6e5371887f36f786f8692889e8a&mc=true&n=pt2.1.200&r=PART&ty=HTML&se2.1.200_1403 https://www.ecfr.gov/cgi-bin/retrieveECFR?gp&SID=ee51e6e5371887f36f786f8692889e8a&mc=true&n=pt2.1.200&r=PART&ty=HTML&se2.1.200_1420 the federal requirement. Written procedures on Allowable Costs must address how the sub recipient is ensuring that costs on the federal grant, and ultimately claimed, are allowed under the individual Federal program and in accordance with the cost principles established in the

Uniform Grant Guidance.

The following is a list of questions to consider when documenting procedures. This is not an all- inclusive list but rather to be used in guidance when writing the step-by-step procedures.

These questions represent the types of information federal agencies would look for if the written procedures are selected for monitoring.

Written procedures for determining allowable costs are required by each federal grant.

4) Sample questions to ask when writing procedures determining the allowability of general expenditures made to a Federal grant:

• Who creates the budget for each Federal program?

• Who enters the budget for the Federal program?

• Who verifies the budget aligns with the ledger?

o How is this communicated between areas?

• Who verifies allowability of each cost under the Federal program and the Uniform

Grant Guidance?

• For each Federal program, who is the informed contact for questions?

• When cost changes occur within the program, who is notified? (changes to business or program needs)

• When cost changes are identified, what is the timeline for submitting budget amendments?

o How is this communicated between areas?

• Who verifies allowability of each amended cost under the Federal program and the

Uniform Grant Guidance?

• Who is responsible for generating supporting documentation demonstrating a cost is reasonable, necessary, or allocable if it impacts a cost’s allowability?

o Where is this documentation kept?

• Where is correspondence regarding budget reviews by the grant manager kept for each of the Federal grants?

o How is this communicated between areas?

5) Sample questions to ask when writing procedures determining the allowability of personnel salary charges made to a Federal grant:

• Who identifies each staff person with a status of single cost objective or multiple cost objective?

• How is this status determined?

o How often is this information reviewed and updated?

o Where is this information stored?

o How is this communicated between areas?

• Regarding staff with multiple cost objectives:

o How is the amount of staff person’s time budgeted on the grant determined?

o What documentation or process is used to support the amount budgeted?

▪ How often is this information reviewed and updated?

▪ Where is this information stored?

o Who verifies charged amounts against supporting documentation prior to a claim being made?

▪ How is this communicated between areas?

It is recommended that the above considerations be documented and included as an attachment to the Grants Release Checklist, as applicable.

Time and Effort Reporting Requirements

What is time and effort reporting?

The salaries and wages of any employee charged to a Federal grant must be supported by some form of time and effort documentation that accurately reflects the work performed. The subrecipient must have supporting documentation that the amount claimed on the grant reflects the amount of time the employee spent working on the grant’s objectives. The requirement to keep time and effort documentation does not apply to contracted individuals. In those situations, the contract is the time and effort documentation and should outline the time and work that will be provided to the subrecipient.

Time and effort records for employees are housed by the subrecipient and not submitted to the awarding agency. Time and effort records become subject to review during audits, monitoring, or other situations that require the subrecipient to provide evidence that time funded by the federal grant was spent working towards the grant’s objectives.

The level of detail needed for the supporting documentation is dependent on the job responsibilities of the employee. In the world of Federal grants, the employee is considered to either have a “single cost objective” or “multiple cost objectives.” It is key to know the cost objectives of the Federal grant program in order to determine if the position being charged to the grant has a single or multiple cost objective, and in turn, what type of supporting documentation would meet the standard.

Federal Time and Effort Reporting Requirements

The Uniform Grant Guidance regulates in §200.430(i) that all salaries charged to a Federal grant must be based on records that accurately reflect the work performed; and that these records are incorporated into the official records of the subrecipient. To meet this requirement, the subrecipient must have an established agency-wide system for determining that the charges are accurate, allowable, and properly allocated.

To meet this standard, each subrecipient must:

• Understand the objectives of the Federal grant program

• For each employee charged to the Federal grant program, determine and document if the position is a single cost object or a multiple cost objective

Note: While the following documentation refers to federal grants under Uniform

Guidance, CSP is able to comply with the same level of time and effort reporting for all grants due to the design of the Oracle Grants Accounting and Payroll modules.

o If 100% of the position could be charged to the Federal grant program then the position is a single cost objective (this is not based on the amount of funding actually available, if enough funds were available, could the position be 100% funded?)

o If only a portion of the position meets the requirements of the grant’s cost objective, then the position is considered to have multiple cost objectives.

Subrecipients develop a grant budget prior to the obligation period with estimates on the amount of time an individual with multiple cost objectives may spend working on the grant’s objectives. The budgeted amounts would never qualify as supporting documentation but may be used for interim accounting purposes if the system for establishing the estimates has a proven track record that budgeted amounts are close to actual amounts. The subrecipient’s system of internal controls must include processes to review after-the-fact interim charges made to the Federal grant based on budget estimates.

Short-term (such as one or two months) fluctuation between cost objectives need not be addressed as long as the distribution of salary charges to the grant is reasonable over the longer term. However, all necessary adjustments must be made so the final amount charged to the

Federal grant is accurate and supported by reliable time and effort documentation.

And lastly, just because a position could be charged to a grant, does not mean it should.

Subrecipients should analyze if the time necessary maintaining supporting documentation for a position with multiple cost objectives is worth charging as a direct cost on the Federal grant.

Section J: Invoice Grantor (Revenue)

Timely invoicing is critical to ensure that the City promptly bills the grantor for grant revenue as expenses are incurred (monthly or at a minimum quarterly). Most federal and some state grant awards are electronically transferred lines-of-credit and are "invoiced" via electronic drawdown.

Whenever possible, advance payment requests should be considered to cover anticipated cash needs for all Federal awards received by the recipient from the awarding Federal agency or pass-through entity. Recipients and subrecipients must be authorized to submit payment request as often as necessary when electronic fund transfers are used or at least monthly when electronic transfers are not used.

Invoicing a grantor is done through Oracle and records revenue and a receivable for a specific grant.

A unique PDF invoice is created to be submitted to the grantor (along with the grantors required expenditure documentation per the grant agreement). The Oracle invoice allows proper cash receipt identification upon receipt of funds from the grantor agency by the Billing and Collections

Department.

Section K: Collecting Revenue (Cash Receipts)

Most grant awards are cost-reimbursable and therefore generally supported by the City until revenues are actually collected (cash receipts). Award and Project Managers should monitor cash receipts of grant invoices through Oracle grants accounting to ensure the City has timely receipt of funds.

CHAPTER 3: MONITORING AND

OVERSIGHT

CHAPTER 3: MONITORING AND OVERSIGHT

Section A: Types of Funding and Related Authority

Federal: Federal organizations are typically considered either general support organizations or mission-oriented organizations; these funds are provided by the United Stated Government out of the funds available in the general federal revenue.

State: State organizations support research and training projects from both federal “pass- through” funds and from their own funds.

Local government and Other: Local organizations may be supporting projects from both federal and/or state “pass through” fund as well as their own funds. Other funds are typically either nongovernmental programs managed by its own trustees or directors.

Section B: Components of Monitoring and Compliance

Components of monitoring and compliance that may apply to each grant are listed below with additional background provided throughout Chapter 4.

• A-133 Awards - Pre December 26,2014

• Uniform Guidance - Post December 26, 2014

• ALN (formatly CFDA Numbers) Federal

• Florida Single Audit (CSFA Numbers)

State

• Utilize Grant Agreement for Compliance Requirements, Allowable Expenditures and Reporting

Other

Allowable Costs

Reporting Subcontracting Cost Sharing/

Matching

Program Generated

Income

Support of Salaries &

Wages

Equipment & Real Property Management

Grant Close Out

Record Retention

Construction Projects

Sub-Recipient Monitoring

Allowable Costs

Cost Transfers

Incorrectly posted charges to grant funded projects must be fixed within regulated time-constraints. Misdirected charges to federally funded projects must be transferred from the project and charged to the correct one within 90 days of the mistake, which is why routine account reconciliation is critical. Failure to transfer incorrectly posted charges in a timely manner will result in the possibility of the expense being disallowed for grant award reimbursement.

If you have any doubts or concerns regarding award expenditures, first contact the Finance

Department’s Grant Team, then the Grants Officer if further assistance is necessary. The

FDGT will periodically review awards to ensure accuracy of expenditure transactions and compliance with applicable award regulations.

See Chapter 2 for more discussion on allowable costs.

Other Expenditure Written Documentation

The City has the following written policies and procedures available for all City employees. The

City’s Administrative Policies can be found on the City’s Intranet page or with the link below:

http://stpsp1/sites/csp/Intranet/HumanResources/SitePages/Administrative%20Policies.aspx.

1. Travel Policy #040903 – included in the citywide Administrative Policy documents

2. Cash Management Procedures #040500– included within the citywide Internal Control

Document

3. Written Method for Conduction Technical Evaluations of Proposals and Selecting

Recipients – included within the Procurement Code (see CSP website)

4. Written Procurement Procedures – included within the Procurement Code (see CSP website)

5. Written Conflict of Interest Policy #010407 – included in the citywide Administrative

Policy documents

6. Written Record Retention Policy #030101 – included in the citywide Administrative

Policy documents

7. Fraud, Waste, and Abuse Administrative Policy #040701 - included in the citywide

Administrative Policy documents

8. Uniform Guidance for Federal Awards, Chapter 15 of the Procurement Operations Manual

Reporting Every award has reporting requirements specified in the grant agreement. It is critical that all reports

– technical and financial – are provided in a timely manner per the specified timeframe outlined in the agreement. During the life of the grant, the department shall notify the Grants Officer and FDGT of the date and type of any reports submitted to the grantor and archived in the Grant File (Appendix

I: Grant Process-Monitoring Grant Awards).

The purpose of grant reporting is to apprise the grantor of the progress made towards fulfilling grant deliverables. The grant agreement or a grantor's guidance manual will outline the types of reports and submittal time schedules required by the grantor. These requirements will be used by the grantor as the basis for evaluation of grant award compliance. Typically, grants require financial reports, technical progress reports, annual progress reports (for multi-year awards), and a final report at grant end.

City of St. Pete rsburg FY25 Grants Administration Manual…