EPA Publication Number 202K09001
EPA Contract Number EP-W-08-042
Learner Manual - Module 4
Grants Management Systems
TRIBAL, U.S. TERRITORIES AND
INSULAR AREAS ADMINISTRATIVE
AND FINANCIAL GUIDANCE
MANUAL FOR ASSISTANCE
AGREEMENTS
"A Nation is a stable, historically developed community of people
who share territory, economic life, distinctive culture, and language.
Office of Environmental Justice, U.S. EPA
U.S. Environmental Protection Agency
Updated August 2013
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Module 4: Grants Management Systems
This manual was originally developed by the U.S.
Environmental Protection Agency for Tribal Nations,
but content also pertains to U.S. Territories and Insular
Areas. Exception: U.S. Territories and Insular Areas are
treated as states under Part 31 (and also under Part 35,
Subpart A for PPGs, unlike Tribes that are covered
under Subpart B).
Contents
MODULE 4: GRANTS MANAGEMENT SYSTEMS
REQUIRED SYSTEMS 3
Standard Industry Classification (SIC) codes 5
SYSTEMS IMPLEMENTATION 6
INTERNAL REVIEW AND APPROVAL PROCESSES 8
Administration 9
Grants Management 9
Finance 10
Accounting 10
Human Resources 11
ORGANIZATIONAL POLICIES AND PROCEDURES 12
Organizational Chart 12
Documentation Process 13
Internal Controls 14
ATTACHMENT TO MODULE 4 16
Answers to Quizdom Actionpoint Questions 16
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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Module 4: Grants Management Systems
Module 4: Grants Management Systems
Tribal, U.S. Territories and
Insular Areas Administrative and
Financial Guidance for
Assistance Agreements
Module 4:
Grants Management Systems
Module 4: Grants Management Systems
Lkxrtiment the source of funds
Determine how funds nre
being used
Guide how money is controlled
* Trarfcingand importing
Required Systems
Guide the project
Guide the people working on
the project
Assure ttccoiifl lability
Identify roles and
responsibilities
Delegate authority
Monikir progress
.Assess results
Required Systems
Why do we need grants management systems?
Administrative systems guide the project and the
people working on it to assure accountability.
Administrative systems identify roles and
responsibilities for the delegation of authority, to
monitor progress, and assess results. Financial
systems help to document the source of funds and
determine how funds are being used.
Financial systems guide how we control the
money. They tell us:
Where the money comes from
Who is authorized to spend it
How expenses are tracked and reported
A successful grants management system requires
the grantee to:
1. Have written policies and procedures,
2. That conform to federal requirements, and
3. Provide internal controls to ensure
policies and procedures are followed.
Responsibilities Timeline: Management
What is the most important reason why we
need administrative systems?
A. To assign personnel to specific tasks
B. To document the awards process
C. To ensure accountability and consistent
progress
D. To evaluate personnel according to EPA
standards
E. All of the above
Why do we need financial systems?
A. To document the source of funds
B. To determine how the funds are being used
C. To comply with regulations
D. Because there are so many objectives and costs
to track
E. All of the above
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 4: Grants Management Systems
One Financial System
Seoarate
Accounts
Separate
Accounts
Separate
Accounts Tribal Nation
Why are financial systems so important?
The source of funds (where the money comes
from) is especially important when a Tribal Nation
has multiple funding sources: EPA, Bureau of
Indian Affairs (BIA), Indian Health Service (IHS),
U.S. Department of Agriculture (USDA), Housing
and Urban Development (HUD).
When a Tribal Nation accepts an assistance
agreement award from any federal agency, it must
set up a separate set of expense and revenue
accounts to track those funds. The funds received
from EPA need to be reported separately from
funds generated through Tribal businesses and
other federal assistance agreement awards. If funds
are not reported separately, it could jeopardize the
Tribal Nation's ability to receive future funds.
Why are administrative and financial
systems so important?
A. Written policies assure consistent
management
B. Each award needs to he tracked separately
C. Written procedures ensure control of all
awards
D. Regulations require these systems
E. All of the above
Improve Your Grants Management System
Some grants can be revised to provide funds for
system improvements.
Ask your EPA Project Officer for details.
Object!
Compute rand so
Hie Clerk
XFTE % of Total Funds
15%
2S% 10%
30% 45%
100% 30%
ii.OUO
$22.300
$15,000
Sample Budget Summaiy. Financial Systems Upuiaje
Can we use award funds to develop or improve
grants management systems?
Yes, especially if you have a General Assistance
Program (GAP) grant. Tribal Nations need to have
administrative and financial systems in place to
properly implement grants and provide accurate
reports to EPA after an assistance agreement is
awarded.
Does your Tribal Nation want to improve
administrative and/or financial systems?
Does your Tribal Nation have a General
Assistance Program (GAP) grant?
A revision can be made to some assistance
agreement awards, which allows a Tribal Nation to
use part of the funds and work hours to assist in
developing, implementing, or improving the Tribal
Nation's grants management systems. If your
Tribal Nation applies for a General Assistance
Program (GAP) grant, and you want to improve the
administrative and/or financial systems, explain
what you wish to do in the work plan. The EPA
Project Officer must approve adjustments and
revisions to your Tribal Nation's General
Assistance Program work plan.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 4: Grants Management Systems
How can General Assistance Program award
funds be used on grants management
systems?
A. To develop new components
B. To develop new strategies
C. To improve existing systems
D. Only when written into the GAP work plan
K.
Record Keeping is Crucial
Having up-to-date and accurate information is
critical for managing financial accounts, and:
Forms the basis for providing information to
decision makers
Allows for the comparison of budgets with actual
expenditures
What is the value of a record keeping system?
A Tribal Nation needs to know how funds are
being used. Tribal Nations need to know:
Which programs or projects are the funds
being applied against?
Who or which organization within the Tribal
Nation is using the funds?
Who requested and who authorized the
expenditures?
Are the funds being spent according to the
EPA-approved budget?
Are the funds spent in accordance with
applicable federal cost standards?
Are the funds being spent within the agreed
upon budget?
For example, Standard Industry Classification
(SIC) codes are used by accountants as reference
codes for line items.
Good management is all about the paperwork.
Table 1: Standard Industry Classification (SIC) Codes
Standard Industry Classification (SIC) codes
The following standard industrial classification codes may be relevant
on EPA funded projects.
Activity
Construction
SIC Code
Industrial buildings 1541
Heavy construction water/sewer 1623
Other heavy construction (non-residential) 1629
Concrete work 1771
Excavation work 1794
Equipment/Supplies
Services
Manufacturers
If items purchased from manufacturer
Office furniture 2521, 2522, 2531, 2441, 2424, 2591,'<
Office supplies (paper, etc.) 2676, 2677, 2678
Computer/Office 3571, 3572, 3575, 3577, 3578, 3579
Lab equipment 3826, 3829
599
Retail Equipment/Suppliers
Courier services
Local trucking
Travel agencies
Telephone services
Clean-up (oil spills, pesticides)
Furniture sales (office)
Office equipment
Computer
Office supplies
Motor Vehicle Supplies
Wholesale sales
Parts
Tires
Dealers
Gasoline
Motor Vehicle Services
Rental (cars)
Rental (trucks)
Motor vehicle repairs
Computer Services
Rental
Maintenance
Professional Services
Engineering services
Architects
Surveyors
Accountants
Testing laboratories
Miscellaneous Services
Hotels
Photocopying
Pest control
Janitorial
4215
4212
4724
4822
4959
5021
5044
5045
5046
5012
5013,5015,5531
5014
5511
5541
7514
7513
7532-7539
7377
7378, 7379
8711
8712
8713
8721
8734
7011
7334
7342
7349
Air conditioning/heating service and repair 7623
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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Module 4: Grants Management Systems
Tribal Nations can see from the explanations and
examples provided that having up-to-date and
accurate information is critical for managing the
Tribal Nation's financial business. Grants
management systems help to ensure that what the
Tribal Leaders have agreed to is being
accomplished in an effective and efficient manner.
Systems facilitate communication while
providing checks and balances for effective
internal control.
Tribal Leaders I Administrators
!! nance Office
Grants
Management
Team
Systems Implementation
How should we structure our administrative
systems?
Administrative systems establish methods for
compliance with grant requirements through:
Operational effectiveness and efficiency
A workable system of internal controls
Updates to written grants management
policies and procedures, as needed
Effective checks and balances
Separation of duties
Clearly defined lines of authority
Adequate administrative systems provide accurate
and reliable information. In a system of checks and
balances, duties are separated and assigned to
trained and experienced personnel. Administrative
personnel typically include Tribal Leaders, a
general manager, a grants manager, and a financial
officer.
Tasks can be monitored and reminders provided by
other groups, so reports are accurate and filed on
time. Division of responsibilities prevents total
control of funds by one group or individual.
Supervisors in each department regularly review
the work in other departments to ensure all
essential functions are performed as proposed.
Linear or
Hierarchical
Systems
A linear or
hierarchical
system does
not provide the
necessary
internal
control.
Each
department is
separate from
the other.
Communicatio
n flows in only
one direction
(usually from
the top down).
Decisions are
made by a
single
individual.
Circular or Flat
Systems
A circular or flat
system of control
provides checks
and balances
necessary for
effective internal
control.
Work is processed
by three people to
avoid errors.
All departments
work together
sharing information
vital to project
success.
Information flows
in all directions
facilitating the
decision making
process.
Decisions are made
based on input from
teams of people.
Figure 1: Administrative Systems Control
Communication between all groups or individuals
involved in the grant is very important to ensure
the systems are set up properly. Administrative
personnel should meet periodically to discuss the
grant and determine if the systems are working
properly and update the written policies and
procedures when necessary.
Having a comprehensive administrative and
financial system in place will greatly enhance a
Tribal Nation's ability to achieve award objectives.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 4: Grants Management Systems
A financial system should:
Provide accurate and complete disclosure of
financial results
1 Adequately identify source and use of funds
Establish effective controls and accountability
for all grant assets, including:
= Cash
0 Accounts Receivables
= Equipment
= Buildings
Etc.
A financial system should: (continued)
Compare actual expenditures to the budgeted
amounts
Ensure applicable Office of Management and
Budget cost principles are followed
Maintain adequate support documentation
Maintain adequate cash management
procedures
How do we set up grants management systems?
The systems explained in this training manual are
systems that a Tribal Nation should have, not only
to report on EPA and other federal government
projects, but also to administer the Tribal Nation's
financial resources effectively and report back to
Tribal Leaders.
EPA does not require a Tribal Nation to install,
implement, or purchase any specific accounting,
management, financial, budgeting, integrated
system, or information technology. However, EPA
does require there be a financial management
system that:
Provides accurate and complete disclosure
of financial results
Adequately identifies source and use of
funds
Establishes effective controls and
accountability for all grant assets, including
cash, supplies, equipment, buildings, etc.
Is able to compare actual expenditures to the
budgeted amounts
Ensures applicable Office of Management
and Budget cost principles are followed
Maintains adequate support documentation
Maintains adequate cash management
procedures
EPA reviews a Tribal Nation's written policies and
procedures to help determine the adequacy of the
system. The intended use of this training manual is
to identify and describe the elements a Tribal
Nation's business and financial operations must
have in order to apply for and accurately report on
the financial activities of each EPA assistance
agreement awarded to them.
For example, a financial policy and
procedure might authorize the
environmental program director to review
accounting entries to ensure accuracy. The
person that makes deposits should not be
the same person that balances the accounts.
Trust, but verify.
Learner Notes
Please take a few minutes to do Activity
4.a (found online at www.petetribal.org).
You will search the Appendix to locate
key information, such as federal codes,
goals and objectives for administrative and
financial guidance, checklists, surveys, the
onsite questionnaire, and examples of
policies and procedures. Knowing where
to find the information is "half the battle"
when managing federal grants.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 4: Grants Management Systems
Which systems are required to comply with
federal and EPA regulations?
A. Administrative and financial systems
supported by written policies and procedures
B. A computerized accounting system supported
by standardized financial forms
C. Separate financial systems for each award
D. Formal evaluation systems
E. All of the above
Internal Review and Approval Process
Kveryune must agree and sign their approval
Internal Review and Approval
Processes
What policies and procedures are needed?
A Tribal Nation should have written policies and
procedures that identify responsibilities in the
process. A single individual should be responsible
within each process for granting approval or
concurrence on official documents by signing his
or her name.
For many Tribal Nations, the process will require
approvals or concurrence from Tribal Leaders,
program administration, financial and budget
personnel, and/or human resources. This process
may take a few weeks or more.
Learner Notes
The administrative and financial structures
described below are generalized examples.
Individual Tribal Nations may structure
their systems differently.
Human Subjects at Risk
Tribal Nations may find the Institutional Review
Board (IRB) internal review process to be a
helpful grants management strategy.
A written policy on research involving human
subjects is required for all EPA projects.
The National Science Foundation (NSF) has
expanded the definition of "risk". NSF now
requires proposals to go through an internal review
process. An Institutional Review Board (IRB) is
established by the grant recipient to review
proposals before they are submitted. An IRB will
determine if there is human risk involved in the
project. This process assures that research
involving human subjects protects those subjects
from risk.
Human Risk now includes any "soft or social
science" (personal) questions, such as those found
on an average survey. Any questions that can be
traced back to the person responding are now
covered under the definition of Human Risk. The
expansion of this definition protects personal and
community information from misuse made possible
by new technologies. With advancements in
computer science, it is now possible to trace
seemingly disparate information back to the person
interviewed.
An Institutional Review Board is developed by the
grant recipient. Tribal Nations may find the
institutional review board, internal review process
to be a helpful grants management strategy. For
NSF and EPA the IRB process requires a written
policy. A written policy might include:
The Tribal Nation does not
conduct research involving
human subjects and is
therefore exempt from the
Basic Health and Human
Services Policy for Protection
of Human Research Subjects
as stated in 45 CFR 46.101.
No human beings will be at
risk from involvement in this
EPA project as determined
by an Institutional Review
Board.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 4: Grants Management Systems
Administrative Unit
Grants Management
klcnlilx ur;ip|>ru\v p.irtic.s iv.xpmisihk' fur:
- Writing
Reviewing
c Approving
> Signing
.\pplicjtinns. anards. ond amendments
Cummunicuting with EPA
Administration
What should an administrative unit do to ensure
the application approval process flows smoothly?
Part of the administrative unit's role in the
application approval process is to identify or
approve parties responsible for writing, reviewing,
approving, and signing applications, awards, and
amendments, and communicating with EPA.
Administrative approval should clearly indicate
which individuals within the Tribal Nation's
leadership have authority to approve a funding
assistance application.
1 Monitor und overscv uwcjixls once they are
received from EPA.
> Ensure compliance \\ith EPA's "terms and
conditions''.
Authorized Certifying Official
Named on the award document
Responsible for ensuring compliance with
federal regulations
This approval process is usually tied to the
administration functions in the organizational
chart, which identifies departments with
responsible parties listed first. The designated party
is the Authorized Certifying Official named on
the award document. The Authorized Certifying
Official is responsible for ensuring compliance
with federal regulations.
Grants Management
What is the role of grants management?
Grants management's role is to monitor and
oversee awards once they are received from EPA.
Management procedures ensure compliance with
EPA's "terms and conditions".
Grants Managers are typically responsible for:
Ensuring compliance with EPA "terms and
conditions"
Submitting programmatic progress reports to
EPA
Regularly communicating with the EPA
regional office personnel
Tracking, monitoring, and reporting on
environmental results
Establishing and obtaining approval of a
quality action plan (QAP if required).
Your region may refer to this as a:
Quality Assurance Project Plan
(QAPP),
Quality Management Plan
(QMP), or
Tribal Quality Action Plan
(TQAP).
Larger Tribal Governments may have a Grants and
Contract Analyst or Administrator to coordinate
administrative requirements.
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Module 4: Grants Management Systems
Ensure proper tracking of:
» I-'unds received und disbursed
» Costs incurred
I'iiymentsmade
Establishing new accounts, reports, and cost
centers
Finance
What is the role of the finance department?
Financial policies and procedures are important to
ensure that program and financial personnel within
a Tribal Nation are informed about proposed
projects and can ensure proper tracking of funds,
received and disbursed, costs incurred, and
payments made (e.g., establishing new accounts,
new reports, and new cost centers).
The finance department ensures policies and
procedures comply with EPA regulations for cash
management and closeout of awards after the
performance and budget periods. Reports are
scheduled and completed on a regular basis.
An internal auditor, audit staff, or Tribal
Administrator arranges an independent audit of the
accounting and financial management process,
cash receipts and payments, and safeguarding of
assets. This assures their internal controls are
maintained for all assets.
The Chief Financial Officer (sometimes the
Treasurer) is responsible for:
Establishing:
o Accounts
o Cost centers
Tracking:
o Funds (received and disbursed)
o Costs incurred
o Payments made
Complying with EPA regulations
Submitting financial status reports
Arranging Audits
o Filing OMB A-133 single audit
statements
Safeguarding assets
Closing out awards
Accounting
The budget and accounting process ensures:
1 Award funds
1 I' rog ra min com e,and
Matching funds are:
Identified
Authorized
' li-d I'd. .mil
Limitations placed mi usu%r
Accounting
How does the budget and accounting function
work within the finance process?
Some Tribal nations maintain a separate
accounting department. The budget and
accounting process ensures award funds,
program income, and matching funds are
identified, authorized, accounted for, and
limitations placed on usage. Someone other than
the finance department should be involved in the
budget and accounting process.
At least monthly, environmental directors should
review the budget as entered in the accounting
system and accounting entries made to the funds
for which they are responsible. If the budget and
accounting review process is separate from the
financial process it gives Tribal Leaders assurance
that it is within the Tribal Nation's resources to
complete the project and use of project funds is
beneficial to the Nation.
Accountants:
Make entries in project accounts
Ensure expenditures are reasonable,
allowable, and allocable
Provide monthly budget statements
Learner Notes
Some Tribal Nations have separate finance
and accounting departments. If so, policies
and procedures need to be clearly defined
so that each department knows what must
be done and who is responsible.
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Module 4: Grants Management Systems
Human Resources
Written policies and procedures establish:
Salary ranges and standards for each position
c Inscribing the
Duties
KesponsihilitiLS. und
Actions expfctf d
Which administrative unit ensures proper
tracking and reporting of award funds?
A. Administration
B. Grants Management
O. Finance
D, Accounting
E. I lumun resources
Human Resources
Which functions could human resources manage?
The human resources department ensures that the
costs associated with the project's human capital
are identified correctly and appropriate costs are
charged to the project.
Written policies and procedures establish salary
ranges and standards for each position, describing
the duties, responsibilities, and actions expected.
Also, when there are new employees to be hired, a
Tribal Nation can plan a recruiting strategy.
Human resource policies and procedures establish
standards for each project position, such as:
Salary ranges
Recruitment
Hiring and firing
Benefits
Duty and responsibility descriptions
The human resources process manages personnel
functions, such as employment, and may include
payroll, leave, benefits, conflict of interest, travel
policy, etc., even if the finance units do not.
Human resources personnel may manage functions,
such as:
Payroll
Authorizations and vouchers
Signature routing
File initiation and maintenance
Conflict resolution
Which administrative unit manages
personnel?
A. Administration
B. Grants Management
C. Finance
D. Accounting
E. Human resources
Which administrative unit approves a party as
the authorized certifying official?
A. Administration
B. Grants Management
C. Finance
D. Accounting
E. Human resources
Which administrative unit monitors
progress and compliance?
A. Administration
B. Grants Management
C. Finance
D. Accounting
E. Human resources
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Module 4: Grants Management Systems
Which administrative unit ensures budgetary
records are accurate?
A. Administration
B. Grants Management
C. Finance
D. Accounting
E. Human resources
Organizational Policies and Procedures
Organizational Policies and
Procedures
What written organizational policies and
procedures are necessary for proper grants
management?
A Tribal Nation should have the following policies
and procedures documented in their management
systems. Nations may choose to have additional
written policies and procedures in place. Only the
basic ones are described in this manual.
Policies and procedures described in this manual
include:
Application review and approval process
Documentation process for financial and
programmatic recordkeeping
Internal controls for protection of EPA
funds
Personnel and payroll processes
Time and effort tracking, monitoring and
reporting; conflict of interest
disclosure; and codes of conduct
Financial management
EPA-Electronic Funds Transfer
enrollment and processing functions
Procurement (equipment, supplies, and
services)
Organizational chart with administrative
policies for checks and balances and
internal controls with defined lines of
authority
Personnel and payroll processes
are described in Module 5.
Organizational Chart
Organizational Chart
How can an organizational chart help?
Internal control policies should include an
approved organizational chart showing various
responsibility centers within the Tribal Nation. The
chart aligns with administrative procedures for
checks and balances on internal systems with
clearly defined lines of authority.
An organizational chart is helpful to have when
initiating the grant application process. It helps to
identify key personnel and show EPA that the
Tribal Nation has the ability to properly manage
the grant.
One benefit of having an updated
organizational chart is to ensure better
communications and understanding
within a Tribal Nation's organizations.
Additional benefits may include
teaching visitors and federal agencies
how the Tribal Nation's government is
organized. The organizational chart also
helps to educate others on a Tribal
Nation's cultural values.
If a Tribal Nation does not have something
showing responsibilities and workflow, it becomes
more difficult for the organization to ensure proper
procedures and processes are followed by the
individuals involved in applying or accepting
responsibility for EPA funds. However, an
effective system enables personnel to work
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 4: Grants Management Systems
together, within and between departments, to
ensure work is complete and of good quality.
Learner Notes
Activity 4.b (found online at
www.petetribal. org) asks you to sketch an
organizational chart for your Tribal
Nation's administrative and financial
systems. Knowing who is responsible for
what makes work a lot easier.
Documentation Process
Demonstrates
how funds are:
° Controlled
! tisbni ;ed
»Safeguarded
Include records
from project
development up
to and including
the final closeout
letter
Documentation Process
What kind of documentation process needs to be
in place?
A paper trail of all required documents with
signatures should be kept on file and made
available to anyone concerned. Once a Tribal
Nation accepts an award, they agree to provide
documentation to EPA demonstrating how funds
are controlled, disbursed, and safeguarded.
A signature sheet (similar to the sample pictured
below) should be circulated with the application
package. Official signatures indicate the enclosed
EPA assistance agreement application has been
reviewed and approved.
What does an organizational chart do?
A. Delineate various responsibility centers vvithin
the Tribal Nation
B. Facilitate communications and understanding
within a Tribal Nation's organizations
0. Educate others about how the Tribal Nation's
government is organized
D. Show that a Tribal Nation has the
capabilities to manage an EPA grant
E. All of the above
Signature Sheet
Authorized Certifying Official
Grruils M.iiiagcment
Finance
Accounting
Human Resources
Circulate a signature sheet with the application
package to ensure department heads have
reviewed and approved the project plan.
Documentation of procedures and policies may
include:
Official written policies detailing the
procedures listed in the application review
and approval process
Official file(s) showing all documentation
starting with the:
Initial application
Additional guidance received from EPA
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 4: Grants Management Systems
Official signed assistance agreement
award document granting funds to the
Tribal Nation
Revisions or adjustments to the award
Official file(s) holding all documentation,
both programmatic and financial, once the
assistance agreement is received from
EPA and accepted by the Tribal Nation
The documentation process should include records
from project development up to and including the
final closeout letter. Records must be kept for at
least three years and possibly up to ten years
following receipt of the closeout letter.
remedied immediately. It won't have time to
become a bigger problem.
Keep all documents
pertainingtoa single
project together.
Folders in the grants management file include
anything with a signature, such as:
Narrative
Budget
Budget modifications
Communications with EPA officials
Partnerships with sub-awardees and
contractors
Progress reports
Financial status reports
Closeout
Keep records safe. Don't rely on forensic
accounting to recreate files. Backup all paper
copies with electronic versions and store backup
files in an off-site location. In the eyes of federal
agencies, "If you don't have documentation,
then it never happened."
EPA recommends you email a summary of your
understanding after a face-to-face or phone
conversation. This way both parties have a record
of what was discussed and any decisions that were
made. If there is any misunderstanding, it can be
Documentation should:
A. Include written policies and procedures
B. Demonstrate hem funds ure managed
C. Track programmatic progress
1). Maintain financia] and accounting rixoixls
E. All of the above
Internal Controls
Ensure funds are:
c Protected from:
Waste
Fraud
Abuse
Mismanagement
° Managed by trained personnel using accurate and
reliable accounting practices
° Managed in a way that complies with all
applicable laws and regulations
Internal Controls
How do we protect the funds?
All award recipients should have administrative
and financial policies and procedures in place to
provide internal controls that reasonably ensure
funds are protected from:
Waste
Fraud
Abuse
Mismanagement
Managed by accurate and reliable
accounting practices and personnel
Managed in a way that complies with
all applicable laws and regulations
These policies and procedures are especially
important once an EPA assistance agreement is
accepted by a Tribal Nation. These policies and
procedures are necessary to show that actual
practices of the Tribal Nation are being carried out
as prescribed in the "terms and conditions" of the
award document.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last U pdated April 2013 Page 14 of 18
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Module 4: Grants Management Systems
Examples of Internal Controls
Signatures
Duplicationof services
Audits
Training
Oversight
Authorization
Trip reports
Copies of Invoices
Monthly recondliationof
Inventory
Follow-up emails
Tagging of equipmentand
supplies
Regular meetings
Date and initial stamps
Checks andbalances
Monthly review of general ledger
program records
Establish a policy for effective communication and transition consistency
Reflection
Consider your own systems:
What policies and procedures
are in place to comply with
EPA's cash management
requirements?
How can you improve on
current protection practices?
Do you use an internal or
external auditor to
independently review
accounting and financial
management processes, cash
receipts and payments and
safeguarding of assets?
Conflict of Interest Policy
Grant recipients must have a
conflict of interest policy
that clearly defines
disciplinary actions and/or
consequences for non-compliance.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
Page 15 of 18
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Module 4: Grants Management Systems
Attachment to Module 4
Answers to Quizdom Actionpoint Questions
Question (bold font indicates correct answer)
What is the most important reason why we need administrative systems?
A. To assign personnel to specific tasks
B. To document the awards process
C. To ensure accountability and consistent progress
D. To evaluate personnel according to EPA standards
E. All of the above
An administrative system ensures the Tribal Nation's award projects address the goals
and objectives stated in the work plan and continue to make sufficient progress toward
achievement.
Why do we need financial systems?
A. To document the source of funds
B. To determine how the funds are being used
C. To comply with regulations
D. Because there are so many objectives and costs to track
E. All of the above
Documenting the source of funds and how the funds are used help a Tribal Nation
comply with EPA regulations that require tracking the many objectives and tasks
involved in an award project and the costs required to accomplish the objectives.
12
Why are administrative and financial systems so important?
A. Written policies assure consistent management
B. Each award needs to be tracked separately
C. Written procedures ensure control of all awards
D. Regulations require these systems
E. All of the above
The funds received from EPA need to be reported separately from funds generated
through Tribal businesses and other federal assistance agreement awards. Systems
facilitate communication while providing checks and balances for effective internal
control.
16
How can General Assistance Program award funds be used on grants management systems?
A. To develop new components
B. To develop new strategies
C. To improve existing systems
D. Only when written into the GAP work plan
E. All of the above
If yourTribal Nation has a General Assistance Program (GAP) grant, you may use part of
the funds and work hours to assist in developing or improving grants management
systems.
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Module 4: Grants Management Systems
Which systems are required to comply with federal and EPA regulations?
A. Administrative and financial systems supported by written policies and
procedures
B. A computerized accounting system supported by standardized financial
forms
C. Separate financial systems for each award
D. Formal evaluation systems
E. All of the above
Administrative and financial systems must be in place but they need not be
computerized, formally evaluated, or separate from other systems serving the Tribal
Nation. Establish one system with separate accounts for each federal award.
35
Which administrative unit ensures proper tracking and reporting of award funds?
A. Administration
B. Grants Management
C. Finance
D. Accounting
E. Human resources
37
Which administrative unit manages personnel?
A. Administration
B. Grants Management
C. Finance
D. Accounting
E. Human resources
39
Why administrative unit approves a party as the authorized certifying official?
A. Administration
B. Grants Management
C. Finance
D. Accounting
E. Human resources
41
Which administrative unit monitors progress and compliance?
A. Administration
B. Grants Management
C. Finance
D. Accounting
E. Human resources
Last Updated April 2013
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Page 17 of 18
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Module 4: Grants Management Systems
Which administrative unit ensures budgetary records are accurate?
A. Administration
B. Grants Management
C. Finance
D. Accounting
E. Human resources
Your Tribal Nation may have different names for each of these administrative
responsibilities and the personnel charged with implementing policies and procedures.
The essential functions remain and acceptance of an EPA assistance agreement award
means you agree to manage those functions in accordance with EPA rules and
regulations.
49
What does an organizational chart do?
A. Delineate various responsibility centers within the Tribal Nation
B. Facilitate communications and understanding within a Tribal Nation's
organizations
Educate others about how the Tribal Nation's government is organized
Show that a Tribal Nation has the
capabilities to manage an EPA grant
All of the above
An organizational chart facilitates communications and understanding within a Tribal
Nation's operating organizations.
C.
D.
E.
55
Documentation should:
A. Include written policies and procedures
B. Demonstrate how funds are managed
C. Track programmatic progress
D. Maintain financial and accounting records
E. All of the above
Documentation is extremely important. Keeping records of all plans and activities
enable a Tribal Nation to explain how the award was used.
Last Updated April 2013
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Page 18 of 18
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