The College shall produce and comply with procedures to develop and manage grants. Grant development procedures must ensure all applicable College departments are aware of and agree to the commitments outlined in the proposal and mitigate the risk of inappropriately committing the College’s resources. The grant management procedures must enable the College departments to comply with funders’ regulations and restrictions as well as mitigate risk to the College.

445.005 GRANT ADMINISTRATION

Grant Preparation Guidelines

Grant Submission Guidelines

1. All faculty and staff will review grant requests with their unit deans or heads prior to submission if a proposal will result in any of the following:

• Significant commitment of College space, equipment, or other facilities;
• A commitment of College resources (cash or in-kind) to meet cost sharing or matching requirements of the funding agency;
• Any significant faculty or staff release time or overload;
• An obligation that the College will a ume and continue funding personnel or activities that the grant will fund initially;
• Creation of new organizational unit or degree program during the grant period or after the funding expires.

2. Matters to consider in the proposal preparation stage include:

• Classified staff hired under "soft money" may have bumping rights over other personnel when the soft money is gone.
• Step increases, salary adjustments, etc., must be anticipated and provided for within the funds obtained.
• Payroll taxes and fringe benefits (and their increase) must be anticipated and provided for within the funds obtained.  The potential cost of unemployment compensation also needs to be provided by the grant.
• Other units may need to be involved in meeting the commitments of the grant.  If so, a preliminary prior agreement with those units is nece ary.
• There is the expectation by the State of Washington that no state funds will be used in underwriting activities/programs that are funded by other sources.  Ordinarily, all indirect costs (overhead) such as accounting, utilities, security, etc., must be provided for within the budget of a grant/outside-funded activity.
• Expenditures for travel and related costs and any purchases of supplies, materials, and equipment funded by the grant are governed by the rules of the State of Washington.    
• Specifically what time and effort reporting is required for the personnel funded by the grant.
• The amount of indirect cost (overhead) to be charged in the contract.

3. After the proposal is completed, faculty/staff will submit a hard copy to the Director of Grants Development.  The Formal Proposal Review and Sign-Off Sheet will then be completed prior to submitting the proposal to the funding agency. (See “Grant Proposal Guidelines,” Page 5, on the College Intranet.) This form will be returned to the Director of Grants Development after all signatures have been obtained.

4. The Director of Grants Development will submit a copy of the proposal, budget, and Formal Proposal Review and Sign-Off Sheet to the vice president of administrative services and the associate vice president of planning and institutional effectiveness. This ensures that the proposal and budget reflect the grant policies and financial procedures established by the College.

5. The proposal will also be reviewed, with signature required, should any of these activities occur:

• If the proposal includes the purchase or use of technology, senior administrator of information technology services will review and initial the Formal Proposal Review and Sign-Off Sheet.
• If the proposal involves human subjects/animals, the date of Institutional Review Board (IRB) approval is required on the Formal Proposal Review and Sign-Off Sheet.
• If the proposal involves hazardous materials, the environmental health and safety manager will review and initial the Formal Proposal Review and Sign-Off Sheet.
• If the proposal requests funds to hire new personnel, Business Services will review and approve the budgetary costs.

6. The Director of Grants Development will notify faculty/staff when the Formal Proposal Review and Sign-Off Sheets is complete and will coordinate efforts to ensure that the proposal is submitted according to the funding agency’s application guidelines. Copies of the proposal will be distributed to the appropriate vice presidents, executive deans, and deans.

Grant Award Negotiation and Acceptance

1. Negotiation of the final grant contract will be coordinated by the Grants Development Office. The Director of Business  Services and the grant manager/project director will also be involved in the process.
   
   
2. Upon notification of a grant award, faculty/staff responsible for the grant (grant project director) will notify their dean, vice president/executive dean and the Director of Grants Development about the grant award.
   
   
3. The Director of Grants Development will provide the grant project director with the Clark College Award Acceptance Form, which will be filled out prior to the acceptance of any grant award. (See “Grant Proposal Guidelines,” Page 6, on the College Intranet.) This form will be returned to the Director of Grants Development after all signatures have been obtained, along with any award documentation and the project budget. The Director of Grants Development will work with the grant project director to complete the award acceptance checklist at the bottom of the Clark College Award Acceptance Form.

Grant Implementation and Monitoring

1. If the grant project director is required to sign a grant agreement/contract provided by the funding agency, the grant project director will submit the grant agreement to the Director of Grants Development, the Director of Business  Services, their dean and vice president/executive dean to review prior to submission to the funding agency. This is to ensure that the grant agreement does not commit the project director or College to extensive legal commitments or other binding arrangements. The Director of Grants Development will notify the grant project director when the agreement is approved by all parties, and assist the grant project director with submission of the agreement if necessary.
   
   
2. Upon receipt of a signed grant agreement/contract, the grant project director will submit copies to the Director of Grants Development, the Director of Business Services, the unit dean, and the appropriate vice president/executive dean along with the project budget. The Director of Grants Development and Accounting Services will schedule a meeting with the grant project director to establish a grant account and discuss  the details of managing the grant budget.
   
   
3. The implementation and day-to-day operation of the grant program is the responsibility of the grant manager/project director.
   
   
4. Periodic and final reports and evaluations are the responsibility of the grant manager/project director. The Grants Development Office can assist the grant manager/project director in compilation of data and information.
   
   
5. Fiscal monitoring of the grant is the responsibility of the grant manager/project director who will be assisted by the grants budget analyst.

• Assignment of Account Code – A unique account code will be assigned by the grants budget analyst and transmitted to the grant manager/project director. The grants budget analyst will enter budget allocations into this account code per the signed grant or contract. The grants budget analyst will meet with the grants manager/project director as soon as the account is established to provide information about all financial aspects of the grant or contract. Expenditures may not commence before the account code is assigned or before the start date stipulated in the letter of authorization.
• Making Grant Expenditures – All grant expenditures are to be made and processed in accordance with the personnel and purchasing policies and procedures that govern expenditure of state funds. All expenditure documents are to be signed by the grant manager/project director and the appropriate Office of Instruction or Student Affairs dean or Administrative Services director or designee before forwarding to Human Resources or Purchasing Services for processing the grant manager/project director is to ensure through Human Resources that personnel charged to the grant are on correct account codes.
• Monitoring Grant Expenditures – The grant manager/project director will receive a monthly budget status report on the grant or contract, which includes the grant budget, detail expenditures, encumbrances, balances, and collections to date, to be used for grant management purposes. The grant manager/project director is to bring to the attention of the grants and budget analyst any observed errors or discrepancies in a timely manner.
• The College will not request advance payments for grant expenditures, but will bill after the fact, ensuring all expenditures are appropriate before requesting funds.
• Grant Billing—Interim Payment Request – The grants budget analyst will prepare all necessary billing documents, including interim and final billings, following the end of the applicable fiscal period. Once the billing documents have been reviewed by the grant manager/project director, the grants budget analyst will submit the billing to the appropriate agency, monitor receipt of payments, and follow up on any outstanding billings.
• Federal Grant expenditures must follow the Uniform Administrative requirements, cost principles and audit requirements for Federal awards.
• All non-payroll federal grant expenditures must be an allowable, allocable, reasonable and necessary as defined by 2 CFR §200 subpart E, any special provisions that are required by the grantor and the funding agency and college policies.  
• When making a non-payroll federal grant expenditure, the proper approvals will be followed in order to ensure that the expenditure is an allowable cost:
  • Project Director and/or Principle Investigator
  • Grants Accountant (Business Office)
    • The grants accountant will review and ensure that it is an allowable, allocable, reasonable and necessary for the grant.
  • Purchasing Department
    • The purchasing department will ensure that the purchase is in compliance with state and college regulations.
    • The purchasing department will ensure that the vendor/contractor has not been debarred or suspended by any federal department or agency.
• Some expenditures that are not allowed in a federal grant
  • Entertainment costs for amusement, diversion and social activities are unallowable
  • Cost of alcoholic beverages are unallowable
  • Costs incurred by advisory councils or committees are unallowable
  • Advertising and public relations are generally not allowable
• If there is a question about whether a cost will be an allowable expense, please contact the grants accountant in the business office before starting the purchase process.
•  Federal Grants that include Participant Support
• Participant support refers to the direct costs of transportation, per diem, stipends, and other related costs for participants or trainees (but not employees) in association with federal grants including NSF-sponsored conferences, meetings, symposia, training activities and workshops. Funds provided for participant support may not be used by grantees for other categories of expenses without the specific, prior written approval of the cognizant Federal Program Officer. In addition, Federal grants, including NSF, generally do not allow indirect costs to be calculated on participant support costs.
• In cases where federal grants and/or NSF grants include participant support, the Business Services office will create a separate account specifically for grant’s participant support that will include participant support costs as follows; cost of transportation, per diem, stipends and other related costs for participants or trainees (not Clark employees). In order to charge direct costs for participant support for an event, there must be the following documentation:
  • An agenda
  • Participant sign in sheets
• Participant Support costs can include food, if it is purchased for work sessions. Work sessions must have an agenda and sign-in sheets.

6. Amendments – Any grant or contract amendments will be processed in the same manner as the original grant or contract.

7. Completion – A number of basic subjects need to be addressed when a funded project/grant is completed:

• Final report as required by the funding agency:  The grant manager/project director is responsible for the non-financial content of the final report. The grants budget analyst will prepare the final financial report and submit to the grant manager/project director for inclusion in the final report.
  
  
• Disposition of assets (such as equipment) acquired under the project:  Assets will be transferred or disposed of according to the grant/contract provisions. Assets retained by the College will be accounted for by College policies.
  
  
• Audit of funds, if required, and the reconciliation of funds within the account. Provisions for over/under expenditure must be made: The grants budget analyst will reconcile all revenues and expenditures for the final fiscal report. Over expenditures must be covered by the unit managing the grants/contract. Under-expended balances will be returned to the granting agency. All financial records will be available for an audit by the granting agency as necessary.
  
  
• Records retention: All files will be kept in accordance with State of Washington records retention schedule unless  the granting agency requires a longer retention period.
  
  
• Grant-funded personnel: The grants manager/project director will work with Human Resources to facilitate the transition of employees funded by the grant prior to the end of the grant period.
  
  
• Closing the grant/contract account code: The grants budget analyst will close the account code once all revenues and expenditures have been processed and the final report submitted.

8. Accounting For/Use of Indirect Costs Recovered – All indirect cost recovery will be credited to accounts established by Accounting Services. Actual indirect cost charges will be initiated against the grant by the grants budget analyst at the time the grant budget is established or as provided in the grant's instructions.  The Executive Cabinet will approve uses/transfers of monies accumulated in the indirect cost recovery account.

Time and Effort Reports

Time and effort reports are after-the-fact records that reflect how faculty and staff spent the time for which they were compensated by the College. Time and Effort reporting is the federally mandated method of certifying that the salary and benefits charged to a grant is accurate and is used to support such charges.

Any faculty or staff who are compensated in part or in full by grant funds, including those whose efforts are used to satisfy either a required or a voluntary match, or are used in the determination of indirect costs must complete a time and effort report. Time and effort reports are to be completed and submitted at least quarterly.

When a grant is initially received, budget allocations may be made in the assigned account for all categories of expenditures, including salaries and benefits, based on the grant budget and depending on the Time and Effort reporting method used. Personnel Action Forms authorizing payment to employees will reflect these allocations. Prior to the end of each fiscal year, adjustments to the payroll expenditures to match actual time worked will be processed if the variance between the initial budget estimates and the actual allocation of time worked is more than 5%.

Time and Effort Reporting Methods:

After-the Fact Activity Report System:

• Is the primary method of recording Time and Effort at the College and must be used by classified staff;
• Allows but does not require entering the initial estimates of time in the Financial Management System;
• Must account for 100% of employees compensated time;
• Must be completed at least monthly;
• Must correspond to one or more pay periods;
• Does not require the residual category (not grants) be documented in detail (lump-sum balance is allowed);
• Must be signed by either the employee or other responsible individual with knowledge of the employee’s activity;
• Form used must include a statement to certify hours (“I/we certify that to the best of our knowledge the above allocation of time expended performing Federal, State and other program duties is true and accurate.”)
• Requires that the College have a suitable means of verifying the accuracy of the time and effort reports (i.e. calendars, file notes).

Plan Confirmation System:

• Can be used by exempt staff or faculty after approval by the Director of Business  Services;
• Requires entering the initial estimates of time in the Financial Management System;
• Must express  activities as percentages of total compensated activity based on reasonable estimates; percentages must reflect reasonable estimates of time or effort provided;
• Must reflect all activity and only activity for which the employee is compensated;
• Must have documentation to support the Time and Effort percentages recorded (i.e., calendars, course listings);
• Must have the ability to monitor and adjust work plan in the system. Significant work plan changes must be recorded in the College’s systems using Personnel Action Forms and/or salary and benefit transfers (adequately supported);
• Must be signed by either the employee or other responsible individual with suitable means of verifying work was performed (usually first-hand knowledge);
• Form used must certify the reasonableness  of salary charges in view of the work performed once each quarter (“I certify to the best of my knowledge and belief that the salary percentage distribution for the grant projects shown above is reasonable in relation to the work performed.”)

Maintenance of Records

The office which is responsible for managing the grant will collect and maintain the Time & Effort reports for six (6) years. The office which is responsible for managing the grant will use the monthly reports to maintain a schedule of time worked on the grant(s) to monitor the 5% variance requirement and to provide a list of employees paid by the grant for internal and external auditing purposes. Forms required for Time & Effort Reporting and Tracking are available on the College ClarkNet under Business Services Forms.

Annual Evaluation

The College’s Internal Auditor will perform an annual evaluation to ensure the integrity of the Time and Effort reporting system.

Revised Policy/Procedure Approved by Executive Cabinet

February 16, 2010
September 15, 2015
February 9, 2016