ADMIN 040 - Federal, State & Local Government Grants
Number: ADMIN 040
Effective: September 28, 2018
Department: Business Office
Last Revision: September 28, 2018

Purpose

To provide guidelines governing federal, state, and local grant funding awarded to CWI.

Scope

Applies college-wide to the solicitation and receipt of external governmental support (federal, state, local), to include but not limited to; grants, contracts, subcontracts, collaboration agreements, and other similar mechanisms. This policy does not apply to student financial aid or sponsorships of individual students.

Definition

Conflict of Interest: A situation in which persons affiliated with a project funded by grant sources may have the opportunity or potential to influence the project's business decisions in ways that could lead to personal gain or give improper advantage to themselves, their spouses, or dependent children.

Cost Sharing or Matching Funds: In-kind contribution or a portion of the project or program cost not borne by the governmental entity as a stipulation for receiving the grant. All cost sharing or matching funds, whether in-kind or otherwise, must be formally documented and reflected in CWI’s accounting system of record.

De Minimis: Something lacking significance or importance and is so minor as to merit disregard.

External Support:  Anything of value or benefit provided for use in a project or other activity by an outside party.

Federal Funding: An award of financial assistance from a federal agency to carry out a public purpose of support or stimulation authorized by a law of the United States out of federal revenue.

Grant:  A contract, cooperative agreement, sub grant, subcontract, consortium agreement, purchase order, or memorandum of understanding is an agreement formalizing the transfer of money or property from a grantor in exchange for specified services (e.g. outreach, research, training, development, and instruction), and will require specific deliverables such as documentation of itemized expenditures or technical reporting.

Grantor: The awarding agency of a grant.

Indirect Cost Rate/Facilities and Administration Rate: Costs incurred for a common or joint purpose benefitting more than one cost objective and not readily assignable to the project.

Official Records: Required documentation including, but not limited to, applications, award letters, budgets, signed contracts, reporting, time and effort tracking, amendments, procurement and expenditure documents, and other records as needed. The central repository of official grant records is the CWI Business Office.

Pass-Through Funding: Grants received by a recipient from the government to transfer to or spend on the behalf of a secondary subrecipient. Example: Federal agency -> State of Idaho (Primary Recipient) - CWI (Subrecipient)

Primary Recipient: An entity that receives federal, state, or local awards directly from an awarding agency to carry out an activity as scoped in an award document.

State Funding: An award of financial assistance from a state agency to carry out a public purpose of support or stimulation authorized by the state of Idaho.

Subrecipient: The legal entity to which a subaward is made and which is accountable to the recipient for the use of the funds provided.

Supplanting: To take the place of or replace state, local, or College funds with federal funds. Supplanting rules apply to all categories of expenditures including, but not limited to, personnel costs, equipment purchases, and supplies and materials. For additional information on supplanting see the Supplanting FAQs.

Policy

This policy governs federal, state, and local funding support for CWI and programs. CWI will comply with all government regulations in the administration of government awards.

The role of the Business Office is to process and provide administrative oversight and to ensure the accurate and transparent accounting and reporting of grant expenditures. The Business Office maintains the official documentation for monitoring and audit purposes.

All faculty and staff participating in grant activities will abide by all federal, state, and local laws; CWI policies, and other grantor requirements.

Guidelines:

All federal, state, and local grant funding requests must follow the established grant development steps identified in the grant lifecycle. Grant requests should only be made for projects that support College initiatives, align with institutional strategic planning, and directly benefit students and/or CWI.

Requests will be submitted on a Grant Discovery Form to the Grant Manager for review by the Grant Team. The Executive Team (ET) will review and approve grant submission requests. Proposals requesting institutional financial support must be approved by President’s Cabinet. It is the discretion of the CWI President to seek President’s Cabinet and/or Board of Trustees’ review and/or approval.

Grant roles and responsibilities are outlined in the Grant Manual in the post-award section.

Staff and faculty funded under federal, state, and local grants must meet the program requirements of funding sources impacted. This includes but not limited to:

  • Time and effort reporting will be completed for all grant funded positions. If a position has been funded by a federal grant, the allocation of time and effort may not be increased unless additional duties within the scope of the grant are formally added to a job description. Grant positions are considered temporary positions and are limited to funding available, which may be discontinued at any time.
  • Grant Budget for new projects, project renewal, and grant budget modifications must be submitted through the Grants Office and verified by the Budget Office for integration into the overall institutional budget. Expenditures will be reviewed by the Senior Grant Accountant for compliance and any incidents of non-compliance will be rejected and provided back to the Primary Investigator for revision.
  • Most grants do not allow any spending on awards until after the effective date of the award as per 2 CFR 200.458. In some cases, expenditures are allowed on a grant prior to final execution of the contract. In those cases, the department assumes the responsibility of those expenditures in the event that the agreement is delayed or not executed.
  • If expenditures are denied by the primary recipient or awarding agency after the fact, the department assumes responsibility for any expenditures that have been deemed unallowable.
  • All required grant reports will be submitted to the Grants Office at least 30 days before the due date in a professional and complete manner. The Grants Office will review and submit the report to the appropriate grant authority.
  • Incidental institutional activities are generally considered activities that benefit the institution and are outside of the scope of work of a grant. A de minimis rate of 5% has been established as the maximum amount of time that can be charged to a grant without being split funded. Cumulative institutional activities above the de minimis rate will not be charged to a grant unless explicitly allowed.
  • College facilities and resources shall not be used in support of an unauthorized grant or contract.
  • Purchasing must be conducted in accordance to applicable federal law, state law, and CWI procurement policy.
  • All other requirements can be found in the CWI Grant Manual.

Any employee who applies for a grant or seeks to enter into a contract on behalf of the college must first have the prior approval. Grant agreements or contracts must be signed by the President or Vice President of Finance and Administration prior to committing to or conducting any activities under the scope of the grant or any expenditures for the grant.

Compliance

CWI is subject to oversight by awarding agencies and primary recipients, if applicable. This includes regular audits and compliance monitoring. If CWI is found to be non-compliant, the institution or persons engaged with specific grant duties may be subject to penalties including fines, criminal prosecution, civil penalties, and program termination.

Prohibited activities, include but are not limited to: conflicts of interest, supplanting, lobbying, misuse of grant funds, fraudulent representations, and unethical behaviors. A more comprehensive list can be found in the Grant Manual.

Referenced