Grant Compliance and Management
Upon funding approval, the project should begin operations immediately to allow the needed time required to begin documenting how the funds are utilized within the guidelines of the funding agency. The primary individual responsible for the management of the program is the Project Director/Coordinator during the funding period. For additional guidance reference the Programmatic and Fiscal Management Checklist for Funded Programs (See Forms). The key to grant funded management is planning, allowing for extra time to complete requests, addressing problems before a crisis, and leaving a paper trail of activities. Finally, be creative, innovative, and action oriented.
Roles and Responsibilities of College Offices
During the development, implementation, and maintenance of each project, the primary offices that may be involved are: the President, the Vice President of Institutional Advancement, the appropriate Dean, Fiscal Affairs, and the Grants Office. The primary person responsible for coordinating with all these offices is the Project Director/Coordinator who will facilitate communication about the project and solicit support from the appropriate offices at the College. The President is the only person who can commit the college to receiving and using grant funds.
Pre-Award/Grant Development Officer Responsibilities
- Preparing a proposal and assisting in budget development.
- Convening an appropriate group of individuals to develop and write grant proposals.
- Facilitating the mechanics of the planning process of proposal development.
- Providing information concerning the College and community and assistance in developing statistical data to support the grants proposal’s idea.
- Providing information on potential sources of funds
- Reviewing early drafts of the grant to include the proposed budget.
- Coordinating final packaging of the grant for submission.
- Providing grant writing workshops for interested College faculty and staff.
Grants Accountant/Financial Services
- Handles post-award administration of grants, financial reporting, financial record maintenance, and preparation of monthly, quarterly, and annual fiscal reports.
- Provides cash management, including preparation of reimbursement requests and draw-down of funds.
- Insures that grant funds are expended in compliance with grantor agency regulations and interacts with outside agencies, internal and independent auditors and financial monitors.
Post-Award/Grant’s Compliance Officer
- Reviewing grant for general compliance and oversight.
- Monitoring the budget for proper use of funds. Ensures compliance with agency requirements regarding purchasing regulations, equipment inventory, and closing documents.
- Processes award documents, drafts sub-agreements, MOU’s, and similar documents.
- Works directly with the business office to coordinate reporting, audit responses, and other grant-related activities.
- Provides direct assistance in the formulation and implementation of College policies and procedures as they affect the administration of grant projects.
- Assists with analyzing, interpreting and applying Federal, State, Local Government, and private funder’s statutes, rules, and regulations regarding grant administration and implements related college-wide processes.
- Serves as a resource for staff and project managers during the project development process focusing on allowable expenditures and the project budget.
- Conducts monthly monitoring meetings with grant project managers to review fiscal and performance activities and provides information to project managers to adjust spending.
- Develops trainings and provides oversight to facilitate the preparation of reports and documentation required by grantors.
- Monitors Time and Effort reporting.
The Roles and Responsibilities of the Project Director/Coordinator
The Project Coordinator is the day-to-day supervisor of the funded project. The position and responsibilities will be determined and specified by the supervisor and is subject to change prior to, during, and/or after the proposal submission/award. This individual may have been the program initiator, or could be a current employee who has been assigned the responsibility for implementation of the project, or an outside applicant.
Managing the Budget
The Project Coordinator is responsible for reconciling quarterly budget reports in cooperation with the Grants Compliance Officer and Grants Accountant. Grant expenditures must be monitored on a regular basis. The Project Coordinator should monitor the budget monthly by comparing the percentage of time elapsed in the grant period and percentage of the total budget spent. This will prevent returning unexpended funds or over-expenditures, and will help ensure that the objectives of the project will be met.
Close Out and Evaluation
Final reports are the responsibility of the grant Project Coordinator. Close out of the funded program is as important as the development of the program. The continuation requests and/or final reports will usually include a narrative description of the project accomplishments for each objective in the methodology. Any objectives not accomplished during the funding period, as well as any changes in the programmatic component of the project will require explanation. Copies of this final report will be provided to the funding agency, the appropriate Vice President, the Grants Accountant, the Grants Compliance Officer, and other appropriate areas for the College, within 45 or 90 days after the project completion. Timely filing of final reports may have an effect on future funding possibilities. To ensure the proper close out procedure has been completed, please reference the Program Closeout Checklist (See Forms).
Purchasing requests for equipment must be submitted to the appropriate Supervisor. Once a purchase request has been approved, it will then be forwarded to the Grants Compliance Officer for review. Policies of the State of Texas and College of the Mainland require Board approval of purchases greater than $50,000. All purchases must go through the bid process that exceed $5,000 unless otherwise available under an Inter-Local Agreement or State Contract per Texas Education Code 44.031 and COM Purchasing policy BH local. When equipment is coming from a sole source supplier, a bid is not required. It is suggested that major purchases such as equipment be completed at the beginning of the project period to avoid costly delays.
Purchases of supplies and services must be submitted to the appropriate Supervisor using a purchase requisition form. Once a purchase request has been approved, it will then be forwarded to the Grants Compliance Officer for approval. After the purchase request has completed the approval process the Grants Accountant will validate that sufficient funds are available.
Grant funded positions will be paid according standard payroll practices of the College. All funded positions must complete Time and Effort reports (See Forms) to document grant related activities. These reports will be completed on a weekly basis and submitted to the Grants Office at the end of each month.
Hiring of grant funded personnel will be completed based on the policies and procedures of College of the Mainland. Recruitment of potential staff can begin, or current employees may be offered a position “contingent upon grant funding.” Personnel hired in positions funded by an external agency will agree that if such funding is discontinued or reduced to the point where the position cannot be funded, the College will have just cause to discontinue employment. Personnel hired in positions either completely or substantially financed by external funding agencies must also agree, that earned vacation must be taken prior to expiration of the contract and that benefits are only in effect during the time of their employment, as stated in the contract for employment.
The grant proposal, the terms of the grant award, the Grants Office, and the College of the Mainland Policy Manual will provide a great deal of information needed to implement and manage the grant funded project. The grant proposal includes a list of objectives and a time line to serve as a guide for reaching milestones. The terms of the grant are the specific laws and/or rules which you must follow in the implementation and management of the project. These laws, rules, and regulations are specific to the funding agency, whether it is federal, state, local, corporate, or private. This manual includes the names of phone numbers of College of the Mainland personnel who can assist during different periods of the project, samples of commonly used forms, and information from the Finance Office, Purchasing, and Human Resources. The Policy Manual provides information on college regulations and policies.
13 ways to ensure compliance
The following list of suggestions is based on “true experience.” It is included in this manual for two reasons: 1.) to prevent similar mishaps, and 2.) to provide guidelines for successful grants management. Questions regarding items on the list should be directed to the Grants Office.
Get the Letter of Award
The letter of award (also known as a NOGA – Notice of Grant Award) is received after the negotiated budget is approved and assures the college that the grant has been funded. The letter will contain information such as the grant number, the duration of the grant period, and the awarded amount. Nothing – no promises, no people, or no anything – can be spent or contracted until this letter is in hand. Letters of award may be followed by a separate contract. If not, the final submitted proposal becomes the contract of performance. However, once the budget is negotiated, it is possible to advertise for personnel with the phrase, “contingent upon grant funding” in the job description and advertisements. If the Letter of Award will be arriving after the grant’s beginning date, get a promissory letter so that you may begin working on the grant project.
Get Off to a Good Start
The first weeks and months of a grant are critical. Most of the paperwork is completed during this time. The budget is activated, timelines and objectives are adjusted, and personnel are hired. A grant that starts well, runs well. Delays in any startup activities cause problems throughout the entire grant period, resulting in needless complications – particularly with personnel and spending the money – and can have a negative impact on completion of grant objectives. With a good start, a grant should be running efficiently within 30 days of the funding date.
For a new Project Director/Coordinator or a newcomer to the college, the sheer volume of information can be daunting. The grant project is important, and it is important for the grant to run smoothly. This manual provides a beginning. The people and places that form the grant networks are there to help.
Give Credit to the Funding Agency
A credit line should appear listing the agency’s full name on any piece of printed materials whether news release, brochure, or major product. If verbal presentations are given to community groups, the funding agency should be credited there as well. A sample of all printed materials should be submitted to the Grants Office prior to purchase to ensure compliance with funding agency requirements.
Provide Lead Time
The grant project affects district and college services. Give people advance notice of your needs concerning grant-related issues.
Keep Up With the Budget
Grant funds represent the end result of stiff competition with other colleges and entities. Awarded funds are an investment by a public or private entity in the college’s future. The college will be held accountable for its stewardship in using these funds.
Plan Carefully for Grant-Related Meetings
Make a written agenda available to participants prior to the meeting. Use effective group management techniques to keep the meeting on track and to use time well. Follow up with meeting summaries and action on necessary items. Recording the meetings is also a good idea.
Address Problems Before They Become a Crisis
Any large project has the potential for going awry. Contact supervisors and the Grants Office when things begin to go off track to find early solutions.
Don’t Lobby, Don’t Politic, Don’t Entertain, and Don’t Support Religious Activities
All of these interesting activities are strictly prohibited with external funds. That includes using staff time for any of these items. Support letters for legislation cannot come from project staff. Food for receptions will have to come from college operational funds, if available and approved in advance, unless specified in the grant proposal.
Don’t Travel Out-of-State Without It
Some funding agencies require prior approval for all out-of-state travel. Check both the college and the funding agency’s travel policies and procedure before you go out-of-town and, especially, out-of-state.
Keep Track of Time, Money, and Records
One of the hallmarks of an excellent Project Director/Coordinator is paying as close attention to the financial side of the grant as to the program side. Both aspects of the grant require careful monitoring if the total program is to be successful. Meeting the program objectives is only half the job.
One of the best checks on the progress of a grant is the comparison between the percentages of the time elapsed and the percentage of the total budget spent. For example, if a grant has 80% of the time period expired and only 30% of the money spent, it is in “deep and serious trouble”. The college likely will have to return unspent funds to the agency, and the objectives of the program may not be met. Sometimes, percent discrepancies indicate that expenditures are not being charged to the proper grant account. Check budget printouts carefully so that institutional dollars are not expended on an externally funded project.
Contacting Funding Agency Personnel
Only the Grants Office staff, or individuals designated by that office, is authorized to contact funding agencies. College of the Mainland has several projects going simultaneously. Often the question can be answered by college or Grants Office Staff. Funding agency personnel could be inundated with the same questions repeatedly from every sector of the college and would conclude, rapidly, that the grants act was not together.
Cultivate a “Sixth Sense” About Improprieties
If any planned action causes hesitation or even a second thought, check. In this case, permission is the best route. Impropriety can be extremely expensive – personally, professionally, and financially.