The definition of a grant for purposes of this policy is as follows: An award of financial assistance in the form of money or property by a funding source including the federal government, state government, other local governments, non-profit agencies, and private businesses and citizens that the County of Muskegon (the County) Board of Commissioners has the power to accept or reject.
- The purpose of the grant procedures outlined in this document is:
- To ensure proper oversight of all funds appropriated to the County.
- To minimize the County's risk of non-compliance with grant requirements.
- To ensure proper administration and accounting of all grants.
- Assurance of internal compliance controls that meet the expectations for federal grant funding administration provided by OMB Super circular 2 CFR 200.
For the purposes of this policy, it's important that definitions of grant management staff be defined as well. Both the Grants Policy, as well as the compliance supplement specifically refers to three categories of employees within a department. Terms listed below are specific to grant award activity, defined in OMB Supercircular 2 CFR 200. A department may use different employee classifications, it's imperative that each department identify the following three equivalents on the Grant Processing Request Form to ensure compliance and accountability:
- Program Coordinator refers to federal grant award management staff, the employee coordinating and executing any grant related activities as documented in the federal grant contract.
- Program Supervisor refers to any employee overseeing federal award grant management staff, this may be a supervisor, director or elected official.
- Department Analyst refers to any employee responsible for the accounting of federal grant awards, this may be specific to larger departments, or it may fall within the budget staff of the Accounting Office.
All federal grant awards will require that all three staff members responsible for the management and administration of the award are listed prior to Board acceptance.
This policy is applicable to any County program, department, Elected Official, or division that uses the County's central accounting system and is part of the same internal control structures as the County primary government ("Departments"). This includes component units outside the primary government, such as the Land Bank Authority and the Office of the Drain Commissioner, who are subject to the primary government's internal controls. (This policy does not apply to the Muskegon County Road Commission, a component unit of the County whose governing board is responsible for establishing and maintaining its own separate internal control structure.) This policy covers program activities including the preparation and submission of grant applications to agencies outside the County government for funds, materials, or equipment to be received and administered by the County or by an agency for which the County acts as fiscal agent. The goals and objectives of the County Departments should be established early in the planning process and should not change based on changes in the availability of different funding sources sought and received. If grant polices and regulations conflict with regulations and policies of the County, the federal and state regulations will prevail unless less restrictive than County policies-where County policy prevails.
No grant award will be accepted that would incur management reporting costs greater than the grant amount. Such costs include, but are not limited to, indirect costs, overhead and any other items needed to administer the grant. Any unapproved submittal by any County program, department, Elected Official, or division in violation of these grant procedures shall not bind the County.
The County Administrator authorizes the Office of Grants Coordination (OGC) to promulgate any procedures that minimize the County's risk for non-compliance with grant requirements and for providing support to requesting agencies. The OGC will maintain a supporting documentation file for all grants in order to facilitate management reporting and overall monitoring.
For Federal Grant Awards, the initiating Department is responsible to ensure compliance with the Federal Office of Budget and Management (OMB) general requirements and any other state and/or federal requirements specified in the grant conditions. All County programs, departments, Elected Officials, and divisions shall submit any/all grant information required by the OGC to carry out its oversight responsibilities.
Grant Application Procedures
The County program, department, Elected Official, or division desiring to submit a grant application soliciting funds will prepare the request as outlined by the grantor's requirements. A grant application will be reviewed by the Department(s) seeking the grant in order to make an independent assessment of all financial aspects of the application to ensure funds availability. The department applying for the grant is responsible for developing projections of all initial and ongoing direct and indirect costs associated with the grant program including but not limited to:
- Staff wages and fringes
- Needed assistance for computer systems
- Office space
- Systems furniture
- Office equipment
- Office supplies
- Computer software and hardware
- Telephone charges
- Allocations of indirect costs
Upon the Department completing its financial assessment, the Department shall prepare and submit a completed Intent to Apply Form (Appendix A) to the OGC. A purpose of this notification to the OGC is to ensure that Departments are not competing within and outside of the County's organizational structure. Any parties interested in applying for grant awards must follow the outlined approval process below:
- Grants over $25,000, federal grants, or any grant requiring cash or in-kind matching funds must be pre-approved by the County Board of Commissioners.
- Any County program, department, Elected Official and staff seeking grants over $25,000, federal grants or any grant requiring cash or in-kind matching funds must submit a motion to the appropriate committee and the Board of Commissioners requesting approval to submit the grant application.
All grant award acceptances must have approval from the appropriate Board committee and the County Board of Commissioners, under the provisions of this policy. This action will involve preparation of a Board of Commissioners agenda item for consideration at the next meeting of the appropriate committee and a subsequent County Board meeting. Due dates and deadlines for agenda item submission may be found on the County website.
In the event that a grant application is denied by the grantor, a copy of the letter of denial shall be forwarded to the OGC for its records. Grants that require a local match must be coordinated through the OGC. If a local match is to be provided by the County government, such funds must (a) be identified in the budget to provide the match, or (b) provided by a budget amendment.
Most grants require the submission of a program cost budget. The OGC should review this p0rtion of the grant request prior to submission. Grant applicants should contact the OGC to request a technical review of grant proposal budgets.
Grant Acceptance Procedures
Whenever possible, requests for acceptance of a grant of a recurring nature should be submitted to Budget staff for Board of Commissioners approval through the annual budget process. The grant award letter/acceptance agreement (notification received detailing the amount of the grant awarded, grant assurances and special conditions, and the guidelines that must be followed to comply with the grant requirements) will be forwarded to the OGC, who will review the grant award for reporting requirements, special conditions, and deadlines related to administering the grant.
Upon OGC approval, Departments shall prepare Board agenda materials for the appropriate committee and Board of Commissioners approval for acceptance and signature of grant contracts. Upon obtaining a copy of the Board action approving a grant, the Accounting Office will assign a chart of general ledger accounts to the grant and the applicable Department will be notified of the GL account code. For reimbursable grants, all reimbursement requests should be copied and forwarded to the Accounting Office, noting the applicable account code for the receipting of the funds. The initiating Department will notify the Treasurer's Office (with copy to Accounting Office) of such anticipated receipts of revenue for those reimbursements made to the County.
Notifying Budget Staff
Departments should notify the Budget staff if:
- There is a subsequent alteration in the funding configuration.
- There is a subsequent alteration in the County's financial obligation.
- Grant award funds may be carried forward into the next fiscal year; official notification and budget amendment to carry forward dollars would be required.
- There is any notification that the grant will be terminated.
Departments are responsible for ensuring that all funds are expended or encumbered prior to the end of the grant award period.