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Home My WebLink About13-18 Financial Policies City of Port Angeles 5.GRANT COMPLIANCE 5.1 Grant Management: 5.1.1 Each department of the City manages their own grants and assigns a gGrant mManager (grant official), subject to City Manager approval. The gGrant mManager is responsible for performing a financial analysis to review whether the grant is cost effective, with approval by the Department Director to go forward with the request. 5.1.2 The gGrant mManager forwards the signed grant agreement to the Finance Department for inclusion in the Budget and also the Capital Facilities Plan if the grant is funding a capital project. Finance staff are responsible for setting up a work order with a separate job order for each grant task listed. If the grant is funding a capital project, Finance will provide the project and work order numbers in existence for that capital project. Operating and capital grant work orders are set up in relation to the reporting requirements of the grant, typically listed as tasks. 5.1.3 Grant spending is contingent on meeting a fair bidding process, providing full and open competition consistent with the standards of purchasing set forth in this Financial Policy, and State and Federal regulations. As defined by OMB Guidance § 200.318 General procurement standards. 5.1.3.1 The City cannot place unreasonable requirement on firms in order for them to qualify to do business; 5.1.3.2 The City cannot require unnecessary experience or excessive bonding; 5.1.3.3 The City cannot consider noncompetitive pricing practices between firms or affiliated companies; 5.1.3.4 The City cannot consider noncompetitive contracts to consultants that are on retainer contracts; 5.1.3.5 product to be offered; or describe the product or performance or other relevant requirements of the procurement such to exclude those products; 5.1.3.6 The City cannot require procurement in a manner that prohibits the use of products or statutorily or administratively imposes a state or local geographical preference in the evaluation of bids, except in the case where the grant or Federal statutes mandate or encourage such an action. 5.1.34 The gGrant mManager is responsible for maintaining the official, permanent grant file of record, and ensures that all requirements of the grant agreement, State laws, State archives record retention, City policies, and the Federal Super Circular are followed, as applicable. Grant funds used for capital require keeping all records for at least 10 years before transferring to the State archives for appraisal value, with most having a much longer retention period due to the length of the asset life. The City Clerk can assist in determining the record retention requirements. 5.1.45 The gGrant mManager submits payment requests on a timely basis and sends a copy to the Finance Department. The Finance Department ensures that grant funds are requested and received on a timely basis and are spent on the intended program or project and can be backed up with have proper documentation. 17 | Page 10/16/2018H - 2 Financial Policies City of Port Angeles 5.1.56 The gGrant mManager is responsible for meeting bid requirements and checking for debarment on all project vendors prior to signing a contract with those vendors. The debarment check includes keeping a written record on file of the page researched online, noting the date checked and initialing the information. This written record should remain in the project file for access by the State auditors. If the grant covers multiple years, the debarment checks need to be completed annually. Please refer to Section 9 Purchasing Policies. 5.1.67 The grant accountant in the Finance Department is responsible for the preparation of the Schedules of Expenditures of Federal and State Awards as part of the annual Financial Statements. 5.1.78 Failure of City staff to comply with grant requirements may adversely affect the City and as such disciplinary action may be taken per the City of Port Angeles Personnel Policy & Procedures Manual, and/or the Employee Union Contract. 5.1.9 Grant Managers and all employees shall be responsible to maintain arms-length transactions (non-related or not in self-interest) transactions when accepting bids and making payment or using grant related monies. 5.1.9.1 Disciplinary action for non-compliance of this sections shall include up to Angeles Personnel Policy & Procedures Manual. 5.1.9.1.1 Employees are any person receiving a check from the City for work completed where the City withholds employment taxes. 5.1.9.2 Conflicts of interest or financial interest by an employee shall fall into this section. 5.1.810 Council accepts and signs authorizes all grants with the exception of those grants assigned to City employees by the City Council., and those grants under $25,000. 5.2Federal Funds Sub-Recipients and Vendors 5.2.1 Sub-recipients and Vendors The City Official in the department responsible for the contract is responsible to ensure that awards and/or payments are not made to any party who is debarred or suspended or otherwise excluded from or ineligible for participation in federal assistance programs. Prior to signing a contract with a sub-recipient or vendor the City Official responsible for administration of the contract is responsible to ensure that sub- recipient or vendors are eligible to receive federal funds. 5.2.2 Contract Requirements for sub-recipient When the City contracts with a sub-recipient who distributes federal funds, the sub-recipient is subject to the Single Audit Act. Contracts with sub-recipient will include the language addressing the following: 5.2.2.1 The secondary recipient of the federal funds should be referred to in the contract as a "sub-recipient" once it is determined that they are a sub-recipient, not a vendor. 5.2.2.2 Single Audit requirements should be defined for sub-recipient as follows: 5.2.2.2.1 The sub-recipient must comply with the Single Audit Act of 1984 as amended. 5.2.2.2.2 The sub-recipient must permit the City and/or independent auditors access to their financial records. 18 | Page 10/16/2018H - 3 Financial Policies City of Port Angeles 5.2.2.2.3 The sub-recipient maintain accounting records that will enable identification of all federal funds received and expended by catalog of federal domestic assistance number (CFDA#). 5.2.2.2.4 If a Single Audit is required, a copy of the audit report is submitted to the City, within the time limit set forth in the Single Audit Act. 5.2.2.2.5 If a Single Audit is not required, the City is allowed to perform a fiscal review of the sub- 5.2.2.2.6 If a sub-recipient is debarred or suspended from participation in federal programs during the contract period, the contract is voided. 5.2.2.2.7 The sub-from Federal Procurement and Non- sub-grants. 19 | Page 10/16/2018H - 4