EPA Publication Number 202K09001
EPA Contract Number EP-W-08-042
Learner Manual - Module 5
Administrative System Components
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 5: Administrative System Components
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 5: ADMINISTRATIVE SYSTEM COMPONENTS.
ADMINISTRATIVE SYSTEM COMPONENTS 3
Personnel 3
The Payroll Process 4
Benefits 6
Travel 11
PROCUREMENT AND PURCHASING 14
Price and Cost Analysis 19
Property Management System 22
COST SHARING, MATCHING, AND IN-KIND CONTRIBUTIONS 25
Cost Share 25
Match 25
In-Kind Contributions 28
Documentation 28
Waivers 29
PROGRAM INCOME 29
RECORDS MANAGEMENT AND RETENTION 30
ATTACHMENT TO MODULES 32
Answers to Quizdom Actionpoint Questions 32
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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Module 5: Administrative System Components
Module 5: Administrative System Components
Tribal, U.S. Territories and
Insular Areas Administrative and
Financial Guidance for
Assistance Agreements
Modules:
Administrative .Si sii-m
Components
Administrative System Components
What are some of the most important
administrative requirements to be addressed in
our written policies and procedures?
Personnel and payroll, along with financial policies
and procedures, need to be in place and in writing
in order to comply with the requirements of an
EPA award. Written personnel and payroll policies
and procedures can be used for good management
of a Tribal Nation as well as for EPA awards.
Module 5: Administrative System Components
- Module i: The Grant
Acplicaasn Process
ModuleiAssistance
Agreements
:.i:
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Module 5: Administrative System Components
Personnel working on the award or
subaward(s)
Qualifications for each position
Duties and responsibilities
Salary ranges
Conflict of Interest Disclosure forms
The Tribal Nation's Equal Employment
Opportunity (EEO) policy*
Annual performance appraisals
Types and levels of fringe benefits
Standards of conduct governing duties and
responsibilities (also called "Codes of
Conduct")
Disciplinary actions for not adhering to the
standards
*Though Tribal Nations may be exempt from many
aspects of the Equal Employment Opportunity
policy, they are required by federal law to follow
and enforce sexual harassment law.
For example:
It is the Tribal Nation's
policy to ensure Equal
Employment Opportunity for
all employees and applicants
regardless of their race,
color, religion, sex, age,
national origin, and sexual
orientation, mental or
physical disability.
Discrimination and sexual
harassment policies are
strictly enforced. In
accordance with federal
guidelines, the Tribal Nation
maintains an affirmative
employment and
disadvantaged business
enterprise outreach
program.
Personnel regulations are explained in the OMB
Circular A-87, Sections Compensation for
personnel services provided in the Appendix. The
OMB Circular A-87 can be downloaded at
http://www.whitehouse.gov/omb/circulars/a087/a87_200
4.pdf.
Reflection
Pause a moment to consider your own
situation.
Do your personnel policies
include all of the above
information?
Do your policies provide
adequate separation of duties?
What information do you need to
add to your files?
How can this additional
information benefit your Tribal
Nation?
Payroll
The Payroll Process
What requirements should be addressed in
payroll policies and procedures?
Most Tribal Nations have a centralized payroll
department. This is a good internal control and is
useful for a Tribal Nation in protecting its funds
from fraud, waste, and/or misappropriation.
The payroll department should have in place
written policies and procedures detailing:
How employees get paid and how often
they are paid
The information needed on the time sheets
When to turn time sheets in and to whom
Supervisory review of timesheets
Proper allocation of pay and benefits
Pay grades
Deductions
W-4s and I-9s
Fringe benefits
Employer and employee paid benefits
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 5: Administrative System Components
Allocating Personnel Time
Hours Worked and Documented on Timesheet
100%
40hrs
20% 5OK 30% 10% 9O%
Shrs 20hrs 12hrs 4hr5 36 h
EPA EPA PPG NSF EPA Tribal
Semi-Annual Reporting Timesheets Timesheets
:
No one project can be funded for more than 100
percent of personnel time. If a project is funded
by multiple sources, the total funding from all
sources cannot exceed 100 percent of the time
allocated in the grant budget.
The payroll department should also have
information regarding how the financial
information from the payroll system is used in a
Tribal Nation's overall accounting system. When
there is no central payroll department, the same
rules apply for each program handling their own
payroll.
Grants must be charged actual hours worked. If pay
is based on budget hours, accounting must
reconcile the actual payroll expended with budget
hours predicted.
The Appendix contains the OMB Circular A-87,
Section 8.h regulations for payroll processing and
internal controls.
Reflection
Consider your own situation again.
Does your organization have written
payroll policies and procedures?
How does your payroll
process protect project
funds?
Are salaries and wage rates
established, authorized, and
approved in your organization to
ensure equity?
Does your payroll process ensure
that all deductions from employee's
salaries are:
Authorized by the employee?
Properly applied?
How are payrolls distributed?
If checks are distributed
manually, are there sufficient
controls to ensure that
payroll checks are distributed
to the correct employee?
How might your system be
improved?
Sample Timesheet
Which of the following is the most important
requirement of an EPA payroll processing
system?
A. Pay grades
B. Timesheets
C. Internal controls
D. How employees are paid
E. Ml of the above
How should time sheets be prepared?
Time sheets for staff are required when and if
employees are charging their time and effort to
more than one funding source. An employee
charging time to a single funding source only
requires a signed certification prepared at least
semi-annually.
Each employee's time sheet must show:
Employee name
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 5: Administrative System Components
Department/ department charge code
Hours worked on the project(s), by date
Tasks performed
If an employee works on more than one project
during the pay period, list the actual hours
worked on each project (not estimated or
allocated hours). Do not fill out timesheets in
advance of hours worked, even if you work the
same hours each week. The payroll department
should have "charge codes" that are issued to the
departmental managers to ensure proper charging.
The procedures should include where the
manager/time keeper submits approved time sheets
for payroll processing.
Grant recipients may use their own time
sheets. The following is a model.
Grantees without their own forms are
encouraged to adopt this form.
Learner Notes
Activity 5.a (found at www.petetribal.org')
asks you to examine the sample timesheet
on the previous page. Sick leave is paid
out of fringe benefits accrued. (See the
bottom left-hand corner. 1
Appendix document OMB Circular A-87, Section
8.h contains the regulations for time reporting.
Which of the following does not need to be
included on personnel time sheets?
A. Employee's name
B. Employee's social security number
C. Hours worked and on which project
D. Department/project budget codes
E. Department for which the employee works
Personnel time sheets track work by the:
A. Employee's social security number
B. Hours worked and on which project
C. Inventor}" codes and dates
D, Project name and task responsibilities
E. A]] of the above
Fringe Benefits
Fringe benefits are services,
privileges, or compensation
to employees in addition to
salary, such as:
= Social security contributions
(pederii !nsi£znceCQnEibuooQ5."£t- PICA)
E Worker's compensation
^ Retirement plans
= Insurance
Benefits
What are fringe benefits?
Fringe benefits are services, privileges, or
compensation to employees in addition to salary,
such as:
Social security contributions (Federal
Insurance Contributions Act (PICA) tax)
Worker's compensation
Retirement plans
Insurance
And perks, like membership dues to a
health club or professional organization.
All fringe benefits are charged to the grant as a
single line item.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 5: Administrative System Components
Table 1: Sample Timesheet
Example Tribe Environmental Protection Program
Employee: Jane Doe
I.D. No.: 9876
Department: Grants Management
Primary Program: EPA Grant and Loan Projects
Program/Activity
106WQ
Air Pollution
GAP
Pesticides
Non-federal activity 1
Non-federal activity 2
Indirect activity
Total Regular
Annual
Sick
Comp
Holiday
Admin
School Act.
LWOP
Sun
11/9
0
Begin Balance
Hours Earned
Hours Available
Hours Used
Ending Balance
Mon
11/10
5
3
8
Tue
11/11
8
8
Annual
120
80
80
0
80
76
Wed
11/12
8
8
Thu
11/13
6
2
8
Sick
80
4
84
8
0
Comp
0
0
0
0
Supervisor
Fri
11/14
8
8
Sat
11/15
0
Pay Period:
Beginning Date:
Ending Date:
Sun
11/16
0
Mon
11/17
0
8
Tue
11/18
5
3
8
11/09/11
11/22/11
Wed
11/19
8
8
certify that the time distribution presented above is a true and accurate accounting of
fate "Doe
Employee
fae 'pew
Thu
11/20
8
8
Fri
11/21
8
8
Sat
11/22
0
(input beginning date)
Total
Hours
48
18
0
0
6
0
0
72
0
8
0
0
0
0
0
Payroll
Allocation %
67%
25%
0%
0%
8%
0%
0%
100%
These hours are allocated
based on allocation of regular
hours.
activities/programs I worked during the pay period.
11/23/2011
Date
11/24/2011
Date
Last Updated April 2013
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 5: Administrative System Components
According to the OMB Circular A-87, Section 8(d):
d. Fringe benefits.
(1) Fringe benefits are allowances and services provided by employers to their employees
as compensation in addition to regular salaries and wages. Fringe benefits include, but
are not limited to, the costs of leave, employee insurance, pensions, and unemployment
benefit plans. Except as provided elsewhere in these principles, the costs of fringe
benefits are allowable to the extent that the benefits are reasonable and are required by
law, governmental unit-employee agreement, or an established policy of the
governmental unit.
(2) The cost of fringe benefits in the form of regular compensation paid to employees
during periods of authorized absences from the job, such as for annual leave, sick leave,
holidays, court leave, military leave, and other similar benefits, are allowable if:
(a) they are provided under established written leave policies;
(b) the costs are equitably allocated to all related activities, including Federal awards;
and,
(c) the accounting basis (cash or accrual) selected for costing each type of leave is
consistently followed by the governmental unit.
(3) When a governmental unit uses the cash basis of accounting, the cost of leave is
recognized in the period that the leave is taken and paid for. Payments for unused leave
when an employee retires or terminates employment are allowable in the year of
payment provided they are allocated as a general administrative expense to all activities
of the governmental unit or component.
(4) The accrual basis may be only used for those types of leave for which a liability as
defined by Generally Accepted Accounting Principles (GAAP) exists when the leave is
earned. When a governmental unit uses the accrual basis of accounting, in accordance
with GAAP, allowable leave costs are the lesser of the amount accrued or funded.
(5) The cost of fringe benefits in the form of employer contributions or expenses for social
security; employee life, health, unemployment, and worker's compensation insurance
(except as indicated in section 25, Insurance and indemnification); pension plan costs (see
subsection e.); and other similar benefits are allowable, provided such benefits are granted
under established written policies. Such benefits, whether treated as indirect costs or as
direct costs, shall be allocated to Federal awards and all other activities in a manner
consistent with the pattern of benefits attributable to the individuals or group(s) of
employees whose salaries and wages are chargeable to such Federal awards and other
activities.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 5: Administrative System Components
Vacation and Sick Leave Policy
Personnel vu>rkinjji un n fedeuil assislanee
agreement project cunnol be the < >nl\ perse mnel
within the Tribal Naliun recemii}; leave benefits.
' If EPA project personnel j;el leu\e Itenefits,
e So must evenime else on the payroll.
What's included in vacation and sick leave
policies and procedures?
Vacation and sick leave are considered to be part of
employee benefits. Written procedures should
contain sufficient detail, such as:
Valid categories of leave time
Time sheet codes for charging various
categories of leave
How leave is authorized
The amount each person receives
How the leave is earned
How leave is charged
How leave is allocated to programs and
projects
Policies and procedures must ensure fair and
equitable charges when more than one funding
source is involved. The area of leave is a very
personal item. The proper handling of leave is
important and helps maintain morale within an
organization.
If vacation and sick leave are fringe benefits
offered to employees working on assistance
agreements, everyone working for the Tribal
Nation must receive vacation and sick leave.
Personnel working on a federal assistance
agreement project cannot be the only personnel
within the Tribal Nation receiving leave benefits.
A policy might read:
The Tribal Nation offers all employees
the opportunity to earn paid vacation
and leave time. Vacation and leave are
accrued at the rate of one day for each
month worked. Paid leave covers
vacation, illness, personal and family
necessity. The maximum number of
days earned per year is 12.
Leave may be carried over to the
following year, but an employee may
not accumulate more than 90 days.
Sick leave lasting more than five days
requires a doctor's note explaining
the illness and any actions taken.
Vacation must be requested in
writing at least one week before the
scheduled leave. Leave is not
approved until the request is signed
and returned to the employee.
Accumulated leave will be paid when
an employee quits the job but not if
the employee is fired.
The Appendix contains OMB Circular A-87, which
explains fringe benefit regulations.
A grantee can provide leave for personnel working on a
federal assistance agreement project even if other
employees do not get leave.
A. True
B. False
(". It depends on the "terms and conditions" of
the award
D. It depends on the type of award granted
E. Yes, when so stated in the Tribal Nation's
payroll policy.
Overtime Compensation
Overtime rates should be:
- Written in the polio) and procedures handbook
<- 1 Mailed so t ha I n< > abuse < >mirs a ml sufficient
funds ure available
Compensation of time may be granted when
funds are not available - "comp time"
How should we handle overtime hours?
Policies and procedures for overtime
compensation, along with overtime rates, should be
spelled out in sufficient detail so as to protect a
Tribal Nation's resources. The use of overtime
should have sufficient controls in place to
reasonably ensure that overtime is not abused and
there are sufficient funds to complete the tasks and
projects.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 5: Administrative System Components
For example:
/t ;'s the policy of this Tribal
Nation to reduce to a minimum
the necessity for overtime work.
All overtime must be approved in
writing in advance by the
immediate supervisor and the
General Manager. If a supervisor
assigns an employee overtime,
the employee must work the
additional time.
Overtime compensation shall be
paid to non-exempt employees
when they work in excess of an
eight hour day or a forty hour
work week at one and one half
times the employee's normal
rate of pay. Non-exempt
employees required to work on a
scheduled holiday will be paid
double their regular rate of pay
for any hours worked. Paid time
off for holidays, jury duty,
vacation, sick leave or any leave
of absence will not be credited as
a regular work day for
computation of weekly overtime.
All employees classified as
exempt from overtime
compensation understate and
federal law shall not be eligible
to receive overtime
compensation, unless prescribed
by law. Exempt status will be
indicated in all appropriate
position descriptions, and
employees will be notified of
their status when hired or upon a
change in status as approved by
the General Manager and the
Council.
What about employees who give more than
100%?
Compensatory time is a method of paying people
for working above and beyond their regular work
duties when there may not be any funds to pay for
overtime. The procedures for giving "comp" time
should be handled in the same manner as overtime.
Written procedures should detail:
Who is eligible
How compensatory time is earned and
tracked
How compensatory time is used (usually
through time off for extra time worked)
Plan ahead. Do not wait until you find you need a
policy. Make it part of the Tribal Nation's regular
payroll process. For example:
Wo employee is entitled to
take "comp time" for hours
worked outside of his or her
regularly scheduled work
day or work week.
Non-exempt employees shall
accrue overtime
compensation pursuant to
Article II, sections 2, and
Article IV, section 7. An
adjusted work schedule can
be arranged upon mutual
agreement of the employee
and the supervisor where for
one particular day, the hours
are changed to meet certain
situations.
Exempt employees shall not
accrue overtime or
compensatory time.
Table 2: Sample Compensation Policy
Non-Exempt Exempt Employee
Employee
Pay Rate
Overtime
Compensation
Policy
Sample
Compensation
Schedule 40 hours
per week
Salary $480 per week
Overtime Overtime compensated
compensated at
time and a half
45 hours
40 x $10 per hour =
$400
5x$15= $75
$400 + $75 =$475
as arranged with
supervisor
45 hours
$480
Plus 2-hour leave on
Friday of the following
week
The cost principles for wages, salary, and fringe
benefits are in the OMB Circular A-87, Section 8
(Compensation for personal services). A copy is
provided in the Appendix.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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Module 5: Administrative System Components
Expenses musl he
in the budget and
reasonably priced.
Travel
What requirements should be addressed in travel
policies and procedures?
Travel is a vulnerable area for most Tribal Nations.
A Tribal Nation needs to have travel policies and
procedures in place that treat all employees in the
same manner. This means employees working on
EPA award project(s) will follow the same travel
procedures as individuals working on non-federally
funded project(s).
Travel expenses must be budgeted in the
assistance agreement and approved in the
award document before they can be covered.
Expenses must be in the budget and reasonably
priced.
Plan ahead!
Travel to conferences may be allowed under a
Tribal Nation's travel policy but may not be
allocated to an EPA award because there is no plan
for conference travel in the work plan or the
budget.
Equipment and travel budgets are subject to
statutory law and therefore must be preapproved
with the Project Officer. If equipment or travel is
not in the budget, then its cost will not be
reimbursed.
o A list of allowable costs that can
be reimbursed by the Tribal
Nation
o A list of required receipts
Explanation of how employees learn
which reimbursement requests are
allowed and which are not
o Explanation of how employees
learn which costs are allocable to
an assistance agreement (a cost
may be allowed under a Tribal
Nation's travel policy, but not
reimbursed under a specific EPA
award)
Travel Costs
Ifyuu du iiu L luivi* a millfii lnivi*l jjulR'y*
v llir Gmtrrul Services AduiiiiisUMilKm (GSA) su
What if we don't have a written policy related to
travel costs?
The Tribal Nation must establish its own travel
policies. If a Tribal Nation does not have a written
travel policy related to travel costs, they may use
the GSA allowable cost rates and amounts
established by the General Services Administration
(GSA) as guidance for developing policies. View
the travel cost guidelines and scan other offerings
on the GSA website, http://www.gsa.gov/.
Travel authorizations, vouchering after the trip, and
trip reporting are explained in OMB Circular A-87,
Section 43, which is provided in the Appendix.
Example forms are provided in Module 8.
Travel policies provide a detailed written
procedure for travel approval and expense
reimbursement including:
Travel authorization and approval of trips
prior to taking them
Travel vouchers detailing the costs of
various travel-related expenses when
requesting reimbursement
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 5: Administrative System Components
Table 3: Sample Travel Authorization Form
Travel Authorization
Department: Grants Office Authorization No. 9876543
Name: Jane Doe Title: Project Manager
Date: 09'15/08
You are authorized to travel as indicated below and to incur necessary expenses in accordance with Tribal Rules and Regulations.
Places of Travel
From: Somewhere, ST
Purpose:
Hotel Rate:
Per Diem Allowance:
Period of Travel:
To: Washington, DC
Initial meeting EPA grant
Maximum $300.00 per day
$60.00 per day ($15 breakfast, $15 lunch, $30 dinner)
Beginning 10/01/08
Ending .0/02/08
Mode of Travel
Common carrier D Extra fare D Tribal-owned Vehicle D
Privately owned Vehicle 0 At mileage rate: $0.52 per mile*
Estimated Costs
/ hereby certify that travel is advantageous to the Nation.
Transportation:
Per Diem:
Miscellaneous:
Hotel Rate:
TOTAL
$119.60
$75.00
$15.00
$300.00
S629.20
Charged to account #: 0000 123
Private car
(approximately 230 miles)
Meals
Internet Services
's stay
Signatures:
Jane Doe
Requester 's Signature
Title
James Stone
Authorizing Officer 's Signature
John Fern
Fiscal Officer 's Signature
Table 4: Sample Travel Voucher
Staple
Receipts
Here
DATE
10/01/08
10/02/08
NAME
ADDRE
SS
TRAVEL EXPENSE CLAIM CITY
SS#/or
VN#
DESTINATION
From: To:
Somewhere,
ST
Washington,
DC
Washington,
DC
Somewhere, ST
TRIP
PURPOSE
Initial Meeting
EPA grant
MILEAGE
Miles
CHARGE
Amount*
$ per mile $0.52
117
117
$60.84
$60.84
IV
Breakiast
0.00
15.00
:EALS
Lunch
15.00
15.00
Dinner
30.00
HOTEL
200.00
Jane Doe
1234 Rural Route 2
Somewhere, ST 12345
SS2938475
MISC.
Explain
Internet
EXPENSE
Amount
15.00
TOTAL
TOTAL
$320.84
$90.84
$411.68
I hereby certify that the above expenses were
incurred and the amounts are correct and should
be paid from the appropriate fund. BUDGET CODE IN-STATE
BUDGET CODE OUT-OF-STATE
SIGNATURE Jane Doe
Claims must be submitted within 90 days of trip and all
claims for the current fiscal year should be submitted
in time to be paid in that fiscal year. APPROVED BY James Fern
01-00-0000123**
DATE 10/05/08
DATE 10/06/08
...Travel forms are described in greater detail in Module 8...
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Module 5: Administrative System Components
Travel policy example:
A Travel Authorization (TA)form must be filled out by all individuals traveling with Tribal
Nation's funds to receive payment for travel and per diem. Airline reservations will be
made at the lowest possible fare. Receipts are required for all reimbursable expenditures.
Per Diem is paid by the full and half day and is intended to cover lodging and meals while
on official business for the Tribal Nation. Per Diem amounts are based on federal per diem
rates for federal and non-state programs and state rates for state programs. Any expenses
incurred without prior approval may not be reimbursed; it is solely at the discretion of the
General Manager. Expenses other than lodging and meals may be reimbursed as allowed
under federal and state per diem regulations. Such expenses include lodging taxes, taxi,
and parking costs, official phone charges, and laundry. A trip report should be required
reflecting all reimbursable expenses.
Travel advances and per diem payments will be made promptly to employees engaged in
official business. Air travel will be arranged by and purchased directly through the Tribal
Nation's designated agent. All employees will be required to fill out a Travel Authorization
form which must be approved and signed by the traveler's immediate supervisor and the
General Manager. 10% of travel advances will be withheld pending the completion of a
Trip Report which shall be completed with 10 days of traveling on official business. To be
entitled to compensation for travel costs, employees must also adhere to the following
policies and procedures:
a) Attend all trainings, workshops or other official business for which travel costs and per
diem has been provided.
b) Employees traveling on trips that begin and end on the same day will be entitled to one
half the normal per diem rate regardless of the time spent or place traveled to during the
day.
c) Any employee that attends to official business under the influence of drugs or alcohol
will forfeit their per diem for that day. If an employee misses the majority of any business
for which she or he has been authorized to travel for, the employee may be required to
repay all costs associated with the travel and may be subject to further disciplinary action
as provided under these policies. Repayment decisions shall be made by the Council upon
recommendation of the General Manager.
d) Any employee that develops a pattern of violating subsection (c) above will be
prohibited from traveling for the Tribal Nation for a period of time to be determined by the
Council and may be required to pay back per diem and travel costs for any trip where
documented abuses have occurred.
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Module 5: Administrative System Components
Procurement and purchasing are
explained more fully in Module 8.
Reflection
Take a few minutes to consider your
assistance agreement award's budget.
Does it authorize travel?
Does your organization have
written travel policies and
procedures?
Are internal controls in place to
ensure that employees follow the
Nation's travel policy?
o Are there levels of review prior
to authorizing payment?
o How do you ensure that the
travel was associated with the
specific grant project?
o Are internal controls in place to
ensure that travel and time
reporting support the
employee's activities while on
travel?
o Who determines that the travel
is necessary?
o How does your organization
ensure time sheets completed
during travel are accurate (e.g.,
comparison with itinerary filed
before travel, receipts, meeting
agendas)?
Reimbursement of travel expenses for personnel
working on federal awards are handled the same as
those for other employees of the Tribal Nation.
A. True
B. False
C. II depends on Lhe "terms and conditions" of
the award
D. It depends on the type of award granted
E. Only when so stated in the Tribal Nation's
travel policy
The Tribal Nation's travel policies must comply with the
U.S. General Services Administration's (GSAI allowable
costs.
A. True
B. False
C. It depends on the "terms and conditions" of
the award
D. It depends on the t}y>e of award granted
E. Only when costs are not addressed by the
Tribal Nation's policies
Procurement and Purchasing
When awarding subgrants, conlruuis, or
subcontracts, Indian Tribe or Indian Intertribal
Consortium are required , to Lhe extent feasible,
to give preference to Indian organizations and to
Indian-owned economic enterprises.
ttuiclunce is provided in the document entitled
Purchasing Supplies, Equipment, and Services
Under EPA Uranis i<> Local Government,
Procurement and Purchasing
What needs to be in our procurement and
purchasing policies and procedures?
There are many requirements for procuring or
purchasing goods and services under assistance
agreements. According to the Indian Self
Determination Act (40 CFR Part 31.38), to the
extent feasible, a Tribe must give preference to
Indian organizations and Indian-owned economic
enterprises when awarding subgrants and
subcontracts. The Tribe must also require, to the
extent feasible, that preferences and opportunities
for training and employment in connection with the
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administration of tribal contracts or grants be given
to Indians.
For example:
It is the policy of the Tribal
Nation to purchase only
those goods and services
that are needed and
necessary to support
approved business
operations and programs
and which are considered
necessary and allowable
under all grants and
contracts which the Tribal
Nation may administer. It is
also the policy of the Tribal
Nation to maximize program
and service delivery by
purchasing goods and
services at the lowest
possible cost and whenever
possible from Indian-owned
businesses.
To help Tribal Nations obtain the best products,
goods, or services at the most economical price,
EPA has developed extensive guidance.
Purchasing Supplies, Equipment, and Services
Under EPA Grants to Local Government is
provided in the Appendix.
Procurement standards are explained for:
Supplies, equipment, and services
Contracting and subcontracting
Competition
Cost and price review
Purchasing methods
Reviews and audits
The following procurement regulations are also
provided in the Appendix.
40 CFR 31.36 contains procurement
standards for contracts and subawards.
40 CFR 31.32 contains the requirements
for equipment purchase, use, and
disposition.
40 CFR 31.33 contains the requirements
for purchase of supplies, title, and
disposition.
American Recovery and Reinvestment Act
The American Recovery and Reinvestment Act
requires recipients of federal funding to report use
of funds to the federal government beginning July
15, 2009. This includes all subawards, subgrants,
contracts, and subcontracts. For details visit
Recovery.gov at http://www.recoverv. gov/.
Learner Notes
This is a great time to clarify the
differences between easily confused terms.
Take a few minutes to do Activity 5.b
(online at www.petetribal.org). Work
together first, then check the Glossary in
your Appendix to see how well you did.
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Subawards and Subcontracts
Costs to do the work Payments made to someone
else to do the work
Contract
Subcontract
Subaward
Subgrant
The grant recipient controls The other party controls the
when, where, and how the work decision-making process.
is completed.
Remember compliance requirements under FFATA!
What is the difference between subawards and
subcontracts?
Federal grants are assistance awards. Procurements
or acquisitions require contracts.
A subaward is a subgrant, not a subcontract.
A subcontract is entered into between a
contractor and a subcontractor.
A grant recipient can enter into a contract using
grant funds. This is procurement under a grant, not
a subcontract.
Subawards and Subcontracts
Steps
Received by
Remember compliance requirements under FFATA!
How do subawards and subcontracts work?
Subawards and contracts are made by the grantee
to an eligible:
Subgrantee (subaward recipient or
subrecipient)
Subrecipient (e.g., prime contractor,
consultant)
Lower tier subrecipient by a primary
subrecipient
Subcontracts are made by a prime contractor to
other organizations.
Subawards to eligible subgrantees and recipients
are awards of financial assistance in the form of:
Money
Property in lieu of money
Contractual legal agreements that do not
include procurement of goods and services
Procurement (contract) and subgrant regulations
can be found in 40 CFR 31.36 in the Appendix.
Remember compliance requirements under FFATA!
What are the requirements for subcontracts?
Subcontracts are awarded in accordance with your
Prime Contractor's contracting policy. Like any
governmental unit, Tribal Nations have many
needs that are accomplished by contractors which
in turn may use subcontractors.
Subcontracting is one form of procurement with
special requirements. It is the grant recipient's
responsibility to ensure the Prime Contractor is
aware of the "terms and conditions" specific to the
award under which subcontracts are made.
The grantee, subgrantee, and prime contractor
policies must address:
A written code of conduct that includes
conflict of interest disclosure statements and
disciplinary actions
Competing transactions in a free and open
manner
o A review to avoid unnecessary
purchases
o A review of lease versus purchase
alternatives (when appropriate)
Conducting solicitations with a clear scope
of work and bidder requirements
Conservation of natural resources
Utilization of disadvantaged business
enterprises (whenever possible)
Both the grantee and prime contractor's contracting
policies must also address:
Performing and documenting cost and price
analyses for competitive bidding and small
purchase procurement actions
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Module 5: Administrative System Components
Documenting the basis for all procurement
selections, justifying a lack of competition
and basis for award costs
Pre-award review of the procurement when
the award or contract modification exceeds
$100,000, is not competed, or only one bid
is received
Purchase/agreement/contract cost thresholds
for small purchases versus major
procurements and personnel required to
approve procurements
Provisions that no contract or subaward will
be entered into with parties that are
debarred, suspended, or excluded from
federal assistance programs
Below is an example to help you develop your own
policies:
All contracts or agreements for
less than $5,000 and which
have been included in an
approved budget line item
may be executed by the
General Manager. Contracts
which exceed $5,000 shall be
executed by the President.
Required Information:
Business payment: All
payments to a company
or business shall require
the following information
to be recorded on the
check request prior to
payment being made:
(1) company or
business name;
(2) copy of business
license;
(3) tax ID number;
and
(4) mailing address
and phone number.
Individual Payment: All
payments to individuals
shall require the
following information to
be recorded on the check
request prior to payment
being made:
(1) individuals
name;
(2) Social Security
number; and
(3) mailing address
and phone number
(if available).
Other Information: All check
requests shall also include a
description and number of the
item(s) being purchased; the
date of the request and the
due date for requested
payment; the dollar amount of
the purchase and the program
and account coding to which
the payment is to be charged.
All vendors, subcontractors,
contractors, consultants,
students, general assistance
recipients, Council members
and any others receiving
payments should fill out a W-9
form which should be held on
file by the Accounting
Department.
Learner Notes
Typically over $100,000 paid to a single
supplier is "sole source procurement" and
must be justified in writing. The EPA
Project Officer is notified when any sole
source procurements are made. With that
much money, it is hard to justify using a
single source.
Consultants
Purchasing policy must address consulting
agreements and specify:
- Services to be provided
° Engagement duration
- Reporting requirements
Including information for FFATA compliance
° Work location
° Pay rates, including:
Base rate
Fringe benefits
Overhead
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What are policy requirements for consultants?
Purchasing policy must address consulting
agreements and specify:
Services to be provided
Engagement duration
Reporting requirements
Work location
Pay rates, including:
o Base rate
o Fringe benefits
o Overhead
For example:
Consultants may be used to
provide specialized and expert
services beyond the scope of
available staff resources when it
becomes apparent that their
expertise is essential to the well-
being of the organization. When
obtaining the services of
consultants the purchasing
provisions provided below shall
generally be followed. The
consultant's fee must be
appropriate considering the
qualifications of the consultant,
the consultant's normal fees, and
the nature of the services
rendered by the consultant. Cost
is not the deciding factor, but
rather one of several, such as
quality, timeliness, location,
previous experience, etc.
Regulations for consultant agreements are provided
in 40 CFR 31.36(j) in the Appendix.
If consultants are budgeted for in the award
agreement, the "terms and conditions" will include
a compensation rate for the current fiscal year. For
example:
Payment to consultants. EPA
participation in the salary rate
(excluding overhead) paid to
individual consultants retained
by recipients or by a recipient's
contractors or subcontractors
shall be limited to the maximum
daily rate for a Level IV of the
Executive Schedule (formerly GS-
18), to be adjusted annually. This
limit applies to consultation
services of designated
individuals with specialized skills
who are paid at a daily or hourly
rate. As of January 1, 2009, the
limit is $587.20 per day and
$73.40 per hour. This rate does
not include transportation and
subsistence costs for travel
performed (the recipient will pay
these in accordance with their
normal travel reimbursement
practices).
Subagreements with firms for
services which are awarded
using the procurement
requirements in 40 CFR 30 or 31,
as applicable, are not affected by
this limitation unless the terms
of the contract provide the
recipient with responsibility for
the selection, direction, and
control of the individuals who
will be providing services under
the contract at an hourly or daily
rate of compensation. See 40
CFR31.36(j)or30.27(b).
Consultants should be competed. EPA prefers grant
recipients obtain bids from a number of
consultants. Competition is encouraged to provide
opportunity to all available consultants and ensure
costs are reasonable.
Consultants should provide bids at an "unloaded
rate". This rate does not include fringe benefits or
overhead, such as travel, temporary lodging, and
food. Consultants can be expensive. Do not go
over the amount listed in the budget. Consultants
should be paid hourly and cannot invoice at a
loaded rate. They must be responsible for their own
fringe benefits and overhead costs.
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Questions?
Contact your EPA
Grants Specialist.
If there are any further questions, contact your
regional EPA Grants Specialist.
Disadvantaged Business Enterprises
On.mt.ees must comply with Lhe Disadvantage*!
Business Enterprise rule to use disadvantaged
business enterprises when making procurements
under grants and EPA financial assistance
agreements performed entirely within Lhe I Inked
States, whether the work is performed hy a
reeipient < « iLs prime e< mtractt>r, for e
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Module 5: Administrative System Components
Cost Analysis
Evaluation of each major cost category
Reasonableness,
° AllocabiHty, and
° Allowjbility
of each category and of the total cost
of a contract or change order.
How important is it to analyze costs before
purchasing goods and services?
A cost analysis is the evaluation of each major cost
category to determine the reasonableness of each
category and of the total cost of a contract or
change order.
Tribal Nations need to perform a cost analysis, if:
The statement of work requires contractors
to specify the elements of their proposed
total contract cost.
Competition is lacking, for:
Sole source procurements
Contract modifications
Change orders
Procurement methods are explained in 40 CFR
31.36(d), provided in the Appendix.
Cost Analysis
5950 525,000 Sfc5.0JO $562,987 S20.000 $136.732 5838,169
S1.J50 }n,300 S78.000 S9WJS8 Sii.'W $2(7.652 S1.MU1Q
S79S 521.432 55? 000 5398X00 S2J.125 S293,89t> S?(BJ42
Reflection
Pause a minute to consider your own
situation.
Does your organization have
written procurement policies and
procedures?
Has your organization awarded
contracts or subagreements under
any of your current award
agreements?
o Were contracts awarded in
accordance with your
organization's contracting
policy?
o Does your organization have
guidelines for documenting
its contract files?
o Do any of your
organization's contracts for
grant projects exceed the
federal small purchases
threshold of $100,000?
If so, did EPA request to review the
contract prior to the time that you
awarded the contract?
Has your organization established
an affirmative procurement system
for recycled materials and
compliance with environmental
statutes?
Are internal controls in place to
ensure that your organization does
not charge EPA assistance
agreements more than the
authorized amount?
Has your organization awarded
contracts to consultants under
current assistance agreements?
A cost analysis is the review and evaluation of
each element of cost to determine
reasonableness, allocability, and allowability.
Cost analysis is particularly important for sole
source procurements (when there is only one
reasonable source for the items needed). Sole
source analysis also requires justification as to why
the proposed contractor is the only one able to
perform the work due to qualifications and
experience. Your EPA Project Officer can write
you a justification.
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What is sole source procurement?
40 CFR 31.36(d)(4) explains sole source
procurement as follows:
(4) Procurement by noncompetitive
proposals is procurement through
solicitation of a proposal from only
one source, or after solicitation of a
number of sources, competition is
determined inadequate.
(i) Procurement by noncompetitive
proposals may be used only when
the award of a contract is
infeasible under small purchase
procedures, sealed bids or
competitive proposals and one of
the following circumstances
applies:
(A) The item is available only
from a single source;
(B) The public exigency or
emergency for the requirement
will not permit a delay resulting
from competitive solicitation;
(C) The awarding agency
authorizes noncompetitive
proposals; or
(D) After solicitation of a number
of sources, competition is
determined inadequate.
(ii) Cost analysis, i.e., verifying the
proposed cost data, the projections
of the data, and the evaluation of
the specific elements of costs and
profits, is required.
(Hi) Grantees and subgrantees may
be required to submit the proposed
procurement to the awarding
agency for pre-award review in
accordance with paragraph (g) of
this section.
Compare Cost Data
Travel
Subcontracting
Consultants
Indirect
TOTAL
5652.987
MU.19S
S6573
S2C6.732
$950
MA
$1,068.558
Included above
$9768
$271,402
51.250
NA
$176.432
$ 119 1OS
$10.579
$223.110
$795
SiSO.OM
$1.119.437
51.250.98?
Hired S.T.&P. Though Victors is less expensive
and uses high quality materials, they tend to
tack on fees later in the project and don't pay
their employees enough to keep good workers
on the job throughout an entire project.
What data do we collect and analyze?
To obtain the information, a Tribal Nation needs to
conduct a cost analysis and must instruct
contractors to provide cost data with their bid
proposals.
Data to be specified might include:
Personnel
Fringe benefits
Travel
Subcontracting
Indirect costs
Profit
EPA does not prescribe a form for this cost data, so
unless you have a standard form, contractors may
submit their cost data in any format. Tribal Nations
should require bidders to certify that the cost
information they submit is complete, current, and
accurate.
Cost and price analysis are explained in 40 CFR
31.36(f), which is provided in the Appendix.
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Reflection
Consider the following questions as they
pertain to your Tribal Nation's policies
and procedures.
Do your purchasing policies and
procedures require performing and
documenting an analysis for sole
source procurements based on cost,
experience, and qualifications?
Does your policy use a pre-qualified
list of persons, firms, or products to
acquire goods and services?
If so, does it follow federal
procurement policies to place and
update vendors on your list?
Does your organization have
internal controls to ensure that
goods and services are:
o Acquired in quantities
needed?
o Required for execution of
the project?
o Paid for by the
accounting/finance
department?
Price analysis is the comparison of:
A. Contractor relationship
B. Vendor proximity
0. Market price
D. Free shipping
E. All of the above
Cost analysis requires which kinds of data:
A, Totals per cost category
B. Contractor relationship
C. Vendor location
D. Free shipping
E. All of the above
is:
Property Management System
A written policy is required to comply \\ilh
regulations on:
' Equipmenttangible, non-expendable, personal
properly having a useful life greater lhan one year
andun acquisition cost of $5,000 or more per
unit
r How equipment was acquired.
= Disposition of equipment after the award period
ends or at the end of the equipment's life.
Property Management System
Why do we need o property management
system?
At a minimum, a grantee needs to have policies
and procedures to identify and control acquired
property. This is especially critical when property
is acquired under an award, whether it is part of
non-federal contributions or purchased with federal
funds. A Tribal Nation needs to be familiar with
federal requirements for property management, and
must address them in the Nation's written policy.
The Tribal Nation keeps an
inventory list of equipment with a
value of $5,000 or more or a useful
life of one year or more. The
information includes the item, date
of purchase, value, and funds used.
It is updated every time a new item
is purchased. When equipment is
disposed of, the date is noted on
the list and this information may
be given to the auditors so they
can update their depreciation or
use schedule (if any).
What are the regulations on equipment?
Equipment is tangible, non-expendable, personal
property having a useful life greater than one year
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and an acquisition cost of $5,000 or more per unit.
The Tribal Nation's definition of capital equipment
may be different than the federal definition,
provided that the Nation's definition would at least
include all equipment as defined above. The Tribal
Nation's definition of capital should be used if it is
lower than the federal guideline. For instance, a
policy would be acceptable if it identifies capital
equipment as property with a useful life greater
than one year and an acquisition cost of $3,500 or
more per unit.
Supplies are tangible, expendable, personal
property that costs less than $5,000 per unit,
including paper, ink, pens, paper clips, and other
expendable products. Supplies are items that can be
easily lost or borrowed, "pilferable" objects. They
are easy to lose track of and can be stolen more
easily than equipment. Computers are supplies
not equipment. Computers generally cost less than
$5,000 per unit. Laptops can be misplaced and
appropriated without malicious intent.
Who gets the equipment after the award period
ends?
EPA regulations as explained in 40 CFR 31.32,
govern the disposition of equipment acquired under
a grant or subgrant. (See the Appendix for 40 CFR
31.32). Property and equipment that are donated
and/or acquired under an EPA award need to be
recorded and controlled within a Tribal Nation's
accounting/property management system.
An assistance agreement will identify the
equipment that was donated or acquired
under the agreement.
The EPA Proj ect Officer will detail the
equipment disposition process to be
followed at the end of the assistance
agreement.
The Tribal Nation's policies and procedures
should also address disposition of equipment
at the conclusion of a project or at the end of
the equipment's life.
If equipment disposition is an issue, the Tribal
Nation and EPA should work out disposition
details early on in the project period. This is
important so that the closeout process will not be
delayed.
For example:
Surplus Property
All departments and program
coordinators are responsible for reporting
surplus or excess property to the Financial
Officer. Once surplus property has been
identified, the Financial Officer will
proceed to dispose of such property under
the guidelines provided below in
subsection (E).
Property Disposal
Property disposal decisions are made
through several methods.
These include:
* A date decided upon at the time the
property was acquired;
* Based upon condition and other factors
noted in annual inventory reports;
* When property is deemed by the
Financial Officer in consultation with the
grants manager to be obsolete;
* When maintenance is no longer cost
efficient;
* If the intended use is no longer valid and
there is no other application for other
Tribal programs.
It is the policy of the Tribal Nation to
make every effort to donate equipment or
other property that has been deemed by
the Financial Officer, in consultation with
the grants manager to be surplus to the
needs of program operations. Such
property shall be made available first to
other Tribal organizations, and in the
event that such equipment cannot be
donated, will be made available to staff
on a lottery basis.
The Financial Officer and grants manager
may establish a fair market value for
items of significant value. Where a price
has been placed on the property the
payment shall be made by the recipient
before the property is turned over and the
funds generated deposited into the
General Fund. In the event that staff does
not request such property, it may be
made available to the general public by
lottery, sealed bid or such other method
as the FO and grants manager may
determine is appropriate. With
concurrence by the President, such
property may be donated directly to a
worthy tribal member with a
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demonstrated need. Electronic equipment
deemed surplus will have all identifying
data removed or deleted prior to disposal.
All property will be offered as-is with no
express or implied warranty or technical
assistance as to use or set-up. In
disposing of property, the Financial
Officer shall be responsible for ensuring
that all federal, state, or other contract
and grant requirements are complied
with.
How should we handle leased property?
Leased equipment is not tracked, because the
grantee does not actually own the property.
However, grantees must ensure they follow the
details of the lease agreement. Fees or penalties for
not complying with the lease agreement cannot be
charged to the federal program.
Vehicles used by a program to do the work can be
paid for on a "user fee" based schedule rather than
purchased or leased outright. The Tribal Nation can
purchase vehicles and charge user fees to grant
funded projects as needed.
The Tribal Nation's property management
system should:
A. l>e internally conln tiled tor compliance with
federal regulations
B. Identity and inventory properly acquired
under an award
C. Include written policies and procedures
1). Kxplain equipment dispi >sili< »n alter the award
period or at the end of the equipment's
useful life
E. All of the above
Disposition of acquired property, after the
award period or at the end of the equipment's
useful life, depends on how it is:
A. Negotiated in the work plan and budget
B. Handled in the written policies and procedures
C. Valued when purchased and after use
D. Deseril>ed in the "terms and conditions" of the award
E. All of the above
Inventory Control System
Capital equipmentpurchased under a federal
award must be documented in records that:
= Identify the equipment purchased by asset
number
= Identify where the asset is physically located
c Identify7 the life of the asset and when it should be
disposed
= Detail property dispositions
date of purchase and cost 2012
Why do we need an inventory control system?
An inventory control system is necessary for
capital equipment and recommended for smaller
purchases. A property inventory should be
conducted at least once every two years. Capital
equipment purchased under a federal award must
be documented in records that:
Identify the equipment purchased; each asset
should be given an asset number so it can be
easily located.
Identify where the asset is physically located
Identify the life of the asset and when it
should be disposed
Detail property dispositions (date of
purchase and cost)
For example:
Responsibility for
maintaining an inventory
control system shall rest
with the Accounting
Department. The inventory
control system will enable
the Tribal Nation to verify
actual physical inventories
against book inventories. As
part of this system, all of the
Nation's equipment,
furniture, and hard supplies
with an expected life span of
one (1) year or more shall be
labeled and recorded in the
inventory system. A
complete organizational
inventory shall be conducted
at least annually, the results
of which shall be reconciled
to the property records.
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Below is a sample property list. It can be combined
with depreciation/asset management schedules or
the Tribal Nation can get asset management
modules from EPA.
Appendix documents 40 CFR 31.31, 31.32, and
31.36 explain the regulations for:
Equipment and property purchases
Cost analysis
Purchase and use of goods and services
Inventory
Disposition of property at the end of the
project or at the end of its life
Reflection
Consider how the following policies
and procedures help manage grants.
Does your organization have
written property management
policies and procedures?
Has your organization
purchased capital equipment on
any of its active assistance
agreements?
Does your organization have an
inventory control system?
Cost Share and Matching
The portion of allowable project costs that a recipient
contributes toward completing its project. Common to
tribal grants is a 20% cost share/match of a federal award.
20% cost share/match
Federal ihars Recipient Mateh
S 10,960 $2,000
Check the Terms and Conditions to make sure the match percent is
not a calculation against total project costs.
Cost Sharing, Matching, and In-kind
Contributions
Cost Share
How do we account for cost sharing, matching,
and in-kind contributions?
Cost Share is defined as the portion of allowable
project costs that a recipient contributes toward
completing its project - costs not borne by the
Federal Government (40 CFR Part 31.24).
In-kind services can also be added to an assistance
award by the recipient. Some examples of a
recipient's in-kind contribution to an award are:
volunteer hours, personnel hours, equipment,
supplies and so on. Recipients' may choose to meet
their cost share or match requirements through in-
kind contributions.
The award recipient must state how they will meet
the match requirements (either cash or in-kind
contributions) in the application work plan and
budget. If in-kind contributions are proposed, the
plan must explain these contributions.
Cost Share and Matching (continued)
Mandatory - when stated in the Catalog of
Federal Domestic Assistance (CFDA)
program listing
Voluntary - negotiated in the agreement and
required after signing the award
Match
Cost Share and Match are essentially the same
(and are often used interchangeably), and it can be
mandatory or voluntary.
It is mandatory when the statute or program
requires it (usually stated in the CFDA). It's usually
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required in the form of a percentage of the total
project costs ("matching" the federal costs...so if
it's 50% cost share/match, it would be 50% of the
total project cost and would match the federal share
dollar for dollar). Mandatory cost share
percentages are provided in the award document.
Voluntary cost share is exactly what it sounds
like- the recipient volunteers to provide it even
when it is not required by the program. But once
they do volunteer it and the award agreement
becomes official, they are required to provide it -
they've made a commitment.
Both mandatory match and voluntary match can
occur in the same grant. This happens when the
applicant chooses to provide more match than is
required. Offering additional match provides
leverage. It can increase an applicant's chances to
be selected for an award.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 5: Administrative System Components
Table 5: Sample Property List
Environmental Protection Department
Property Records
As of September 30, 2011
Asset
Description
Truck
Car
Copy
Machine
Fax
Machine
Computer -
desktop
Computer -
laptop
Phone
ID or
Serial
#
123456
654321
99999
Cost
$15,000.00
13,000.00
6,000.00
Source
of
Funds
EPA
EPA/
Tribe
EPA
% Fed
Participation
100%
50%
100%
Title
Held
by
EPD
EPD
EPD
Date
Purchased
06/01/11
10/20/8
01/15/08
Date
Sold
Sales
Price
Inventory
Date
09/30/1 1
09/30/09
09/30/10
09/30/1 1
09/30/09
09/30/10
09/30/1 1
Condition
New
like new
New
12000 miles; like new
23000 miles; OKcond
35000 miles; OKcond
New
20000 copies; OKcond
55000 copies; OKcond
83000 copies; OKcond
Location
EPD
EPD
EPD
EPD
EPD
EPD
EPD
EPD
EPD
EPD
Use
Brownfields
Brownfields/UST
GAP/§106
GAP/§106
GAP/§106
GAP/§106
All Env. Programs
All Env. Programs
All Env. Programs
All Env. Programs
Optional at Department Level:
Estimated Useful
Life (months)
60
Estimated Disposal
Value
$3,000.00
Depreciation. Method
SL
Depreciation for Period
$800.00
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 5: Administrative System Components
Match must be allocable to the grant.
No alcohol or other unallowable expenses
can be counted!
Leveraged match need not be stated in dollar
amounts. It is often better to provide a narrative
statement. For example, "The city of Denver has
agreed to donate transportation services (school
buses and drivers) for the duration of this project.'
Leverage funds to increase your
competitive edge.
In-Kind Contributions
Non-monetary contributions with a quantifiable
value, such as donations of:
" Time and effort = actual/market value
= Goods or services = market value
c Supplies or equipment = market value
Third-party- contributed by someone other
than the recipient or EPA
In-Kind Contributions
In-kind contributions and services can be used as
match if not from a federal agency. It is a non-
monetary contribution that can be quantified
monetarily in some way. Third-party in-kind just
means it is an in-kind contribution coming from
someone other than the recipient or grantor. This
may be a partner or someone with whom they are
collaborating.
When EPA provides in-kind services (e.g., lab
services, office space, etc.), they cannot be used as
match because they count as part of the federal
government's contribution.
In-kind contributions and services cannot be paid
for with federal funds from any program, except
health care provided under the Indian Serf-
Determination and Education Assistance Act
(ISDEA), Public Law 93-638. For an explanation
of the Serf-Determination Act, download Tribal
Self-Determination from the Indian Health Service
(IHS) at http://info.ihs.gov/TreatiesLaws/2-
TribalSelfDetermination-Jan2005.doc.
Document Worth
Cost sharing, matching, and in-kind
{contributions are gills or donations of time,
goods, and/or services made loward the project
by the Tribal Nation or other benefactors.
Track and account for all funding in the same
way, including market value of donations.
Contact your HFA Project Officer if you think
your organization may qualify for a cost share
waiver.
Documentation
Cost sharing, matching, and in-kind contributions
are gifts or donations of time, goods, and/or
services made toward the project by the Tribal
Nation or other benefactors. These contributions
must be tracked and accounted for in the same
manner as EPA funding. Accounting for third party
in-kind contributions provides an accurate record
of the true cost of the project.
For example:
Record of supplies donated by a third party
need to be kept in a separate file with:
A signed form from the third party
Description of the contribution and how
the supplies were used
A copy of the invoice from the third party,
if possible
Supplies should be valued at market value
when reporting the contribution and
cannot be paid for with any federal
funds.
Time donated by the Tribal Nation needs to:
Be recorded by the employee
Explain how much time was donated on
the project
Contain the employee's signature
State that time and effort recorded were
spent on the project
This time cannot be paid for with any
federal funds.*
* Note that a cost share or match requirement may
be met by costs borne by another Federal grant if
and only if there is a federal law permitting you to
use the other federal funds to satisfy the match
requirement under your EPA grant.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 5: Administrative System Components
Waivers
Under some grant programs your organization may
request a waiver of the cost share requirement, if
the cost share will impose an undue hardship.
Check with your EPA Project Officer to see if your
organization can and should request a waiver.
How to account for and report cost sharing,
matching, and in-kind contributions is explained in
the following documents provided in the Appendix.
40CFR31.24
OMB Circular A-87
Program Income
PROFIT & LOSS
Dcteml«T31,201i
Ordinary Income/Expense
Expense
Personnel
Fringe Benefits
Travel
Equipment
Supplies
Contractual
Constructor)
Other
Indirect
Total Expense
40,000.00
Reflection
Consider how cost sharing impacts
management of your assistance agreement
award.
Does your organization currently
have any matching, cost sharing,
and/or in-kind contributions
included in any active awards?
Does your organization anticipate
any of these types of costs in the
foreseeable future?
If you answered "yes" to either of
the above questions:
o Where do your matching costs
come from?
o Are these cost percentages
described in the "terms and
conditions" of the assistance
agreement?
o Does your organization track,
record, report, and verify these
costs?
o Are all matching costs
verifiable from accounting
records and valued according
to applicable OMB Circular
A-87 cost principles?
Program Income
What do we do if award activities actually make
money?
A Tribal Nation may at times receive income in
addition to the funds on an assistance agreement.
Program income is defined as "gross income
received by the grantee directly generated by a
grant supported activity, or earned only as the
result of the grant agreement during the grant
period." Program income includes fees from
services performed under the grant, and income
from sale of commodities or items fabricated under
a grant agreement. Revenue you receive from
sources to support the program that doesn't directly
result from grant activities is not program income.
Anticipated program income will be detailed in
the application.
Examples of Program Income:
Fees charged to register participants for a
workshop or conference during the grant
period.
Revenue realized through the sale of
products made under a grant program
during the grant period.
Membership fees charged to individuals
and organizations for grant related
activities during the grant period.
Rental or usage fees charged for use of
supplies or equipment purchased with
grant program funds during the grant
period.
Example that is NOT Program Income:
Funds donated to be used for a project, but without
restriction that services be provided in return, are
NOT program income
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 5: Administrative System Components
The handling of income will be calculated into the
total amount of the assistance award. Regulations
allow grantees various ways to dispose of program
income, including adding or deducting it from the
amount of federal funds awarded. Project Officers
include this as part of their negotiations of the work
plan and budget.
When an assistance agreement contains
program income, a Tribal Nation must account
for and track these funds in the same manner as
expended federal funds. Again, it is very
important to track the program income funds in
a separate charge code from the EPA funds.
A Tribal Nation needs to ensure that adequate
internal controls are in place to properly account
for these funds. Funds must be specifically
identified in the project budget and in Financial
Status Reports (FSRs).
Cost reports show all income and related expenses.
Which of the following is not considered
program income?
A. Fees charged to register participants for a workshop or conference
during the grant period
B. Revenue realized through the sale of products made under a grant
program during the grant period
C. Revenue you receive from sources to support the program that
doesn't directly result from grant activities
D. Membership fees charged to individuals and organizations for
grant related activities during the grant period
E. All of the above
Reflection
Consider how the following might impact
management of your assistance agreement.
Has any program income been used
as matching or contribution for any
current award?
Has any program income been
added to the funds committed for
the project?
Does the project budget allow
adding program income?
In the award's "terms and
conditions", is there a condition that
permits the use of program income
for match requirements?
If not specified in the proj ect budget
or award "terms and conditions",
has the program income been
deducted from the total allowable
project cost in your award budget?
Program income regulations are provided in the
Appendix in 40 CFR Part 31.25.
Save all
Records
Write policies
and procedures
on records
management
and retention.
Records Management and Retention
Do we need policies and procedures on records
management and retention?
Tribal Nations need written policies and
procedures that address the types of files and
documentation required for records management.
A good filing system ensures adequate
documentation. Each assistance agreement award
must have its own file kept separate from other
awards and grants. Folders can be kept in different
departments as long as a record of where they are
located is included in the master file.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 5: Administrative System Components
Thorough documentation describes the activities
conducted under an assistance agreement.
Documentation shows how activities are properly
carried out, in accordance with a Tribal Nation's
leadership and EPA/federal requirements.
Basic files needed for managing EPA assistance
agreement awards include:
The original application and certifications
including the work plan and budget
Initial award and amendment documents
Request and/or approvals for
scope/budget changes
Federal Financial Report (FFR) Standard
Form (SF) 425, if applicable
General ledger detailing revenues,
expenditures, assets, and liabilities
Support documents for expenditures
Basic files needed for managing EPA assistance
agreement awards also include:
Equipment files and usage logs
Payment requests
Progress reports
Contracts/subawards
Correspondence (letters, emails, and notes
taken during phone conversations)
The following guidelines are provided in the
Appendix.
40 CFR 31.30(a)(b)(c) address request for
and approvals of scope and/or budget
changes
40 CFR 31.41 (b) address financial status
reports and reimbursement requests
40 CFR 31.21 address payment requests
backed up by financial records
40 CFR 31.40(b) address progress reports
40 CFR 31.37 refer to subgrants
40 CFR 31.42 records retention
regulations
Records Retention
Check with your EPA Project Officer for specific
dates applied to your award.
Project Period
January 1, 2009-December 31, 2009
Closeout Records Retention
February 1, 2O10 January 1, 20O9-January 31, 2OH
Sample Retention Period
How long do we need to keep the records?
Records retention requirements depend on the
grant program. EPA policy requires that records be
retained for at least three (3) years after the award
period ends. Tribal Nations who receive Superfund
money may be required to keep records for up to
ten (10) years. The retention period can be
extended for a variety of reasons. Check with your
EPA Project Officer for specific dates applied to
your award.
Assistance agreement records:
A. Document financial activities
B. Describe program and project activities
C. Show how award activities are performed
D. Are kept separate from other grants
E. All of the above
How long must EPA assistance
agreement records be kept on file?
A. 1-2 years
B. 3-5 years
C. 5-10 years
D. It varies, usually 3-10 years. Check with your Project
Officer
E. As long as you think it is necessary
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Attachment to Module 5
Answers to Quizdom Actionpoint Questions
Which of the following is the most important requirement of a payroll processing
system?
A. Pay grades
B. Time sheets
C. Internal controls
D. How employees are paid
E. All of the above
Though all of the above are important, EPA is mainly concerned that the payroll process has
internal controls to protect award funds from fraud, waste, and misappropriation.
11
Which of the following does not need to be included on personnel time sheets?
A. Employee's name
B. Employee's social security number
C. Hours worked and on which project
D. Department/project budget codes
E. Department for which the employee works
To protect employee privacy, do not include personal information such as home address, phone
number, or social security number on time sheets.
14
Personnel time sheets track work by the:
A. Employee's social security number
B. Hours worked and on which project
C. Inventory codes and dates
D. Project name and task responsibilities
E. All of the above
The most efficient and effective way to track employee time spent working on a project is to
require personnel to fill out time sheets. Time sheets track work by the number of hours worked
on each project for which they are responsible.
19
A grantee can provide leave for personnel working on a federal assistance agreement
project even if other employees do not get leave.
A. True
B. False
C. It depends on the "terms and conditions" of the award.
D. It depends on the type of award granted.
E. Yes, when so stated in the Tribal Nation's payroll policy.
Benefits are only given to grant personnel when all personnel working for the grantee are given
the same benefits.
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Module 5: Administrative System Components
26
Reimbursement of travel expenses for personnel working on federal awards are
handled the same as those for other employees of the Tribal Nation.
A. True
B. False
C. It depends on the "terms and conditions" of the award.
D. It depends on the type of award granted.
E. Only when so stated in the Tribal Nation's travel policy
Travel expenses should be processed the same way for all the Tribal Nation's employees.
29
The Tribal Nation's travel policies must comply with the U.S. General Services
Administration (GSA) allowable costs.
A. True
B. False
C. It depends on the "terms and conditions" of the award.
D. It depends on the type of award granted.
E. Only when costs are not addressed by the Tribal Nation's
policies
The Tribal Nation must establish its own travel policies. If they do not want to have a policy related
to costs, they may use the GSA allowable costs for lodging and meals.
47
Price analysis is the comparison of:
A. Contractor relationship
B. Vendor proximity
C. Market price
D. Free shipping
E. All of the above
Price analysis compares prices quoted by possible vendors/suppliers or contractors and standard
market prices.
50
Cost analysis requires which kinds of data:
A. Totals per cost category
B. Contractor relationship
C. Vendor location
D. Free shipping
E. All of the above
Cost analysis requires the grant recipient to collect and examine as much data as possible before
making a decision on procurement or purchasing issues.
Last Updated April 2013
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Page 33 of 35
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Module 5: Administrative System Components
54
Question (bold font indicates correct answer)
The Tribal Nation's property management system should:
A. Be internally controlled for compliance with federal regulations
B. Indentify and inventory property acquired under an award
Include written policies and procedures
Explain equipment disposition after the award period or at the
end of the equipment's useful life
All of the above
C.
D.
E.
These are true for all award management and administrative systems.
57
Disposition of acquired property, after the award period or at the end of the
equipment's useful life, depends on how it is:
A. Negotiated with the work plan and budget
B. Handled in the written policies and procedures
C. Valued when purchased and after use
D. Described in the "terms and conditions" of the award
E. All of the above
Disposition of property should be negotiated during work plan and budget discussions with the
EPA project officer prior to award. The value of the property may influence negotiated "terms and
conditions", which are stated in the award document.
67
Which of the following is not considered program income?
A. Fees charged to register participants for a workshop or conference
during the grant period
Revenue realized through the sale of products made under a grant
program during the grant period
Revenue you receive from sources to support the program that
doesn't directly result from grant activities
Membership fees charged to individuals and organizations for grant
related activities during the grant period
All of the above
Funds donated to be used for a project, but without restriction that services be provided in return,
are NOT program income. Revenue you receive from sources to support the program that doesn't
directly result from grant activities is not program income.
B.
C.
D.
E.
73
Assistance agreement records:
A. Document financial activities
B. Describe program and project activities
C. Show how award activities are performed
D. Are kept separate from other award documents
E. All of the above
Records should be kept on all activities associated with an award.
Last Updated April 2013
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Page 34 of 35
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Module 5: Administrative System Components
font indicates correct ans
76
How long must EPA assistance agreement records be kept on file?
A. 1-2 years
B. 3-5 years
C. 5-10 years
D. It varies, usually 3-10 years. Check with the Project Officer
E. As long as is indicated in the "terms and conditions"
Records should be kept for a minimum of three years, but this varies by funding program. Check
with your EPA Project Officer for specific dates.
Last Updated April 2013
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Page 35 of 35
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