Administrative Regulation 2.18-3

ADMINISTRATIVE REGULATION:   AR: 2.18-3 DATE APPROVED: August 25, 2020
SUBJECT: Guidelines for Grant Administration ORIGINATING DEPARTMENT: County Administration

POLICY:
It is recognized that the successful acquisition of grants can play an important role in assisting in the cost of Citrus County’s community projects and services.

The following guidelines are designed to establish a uniform approach for the evaluation of all funding opportunities and to ensure that all grants awarded to Citrus County, Florida are effectively and efficiently applied for, executed, allocated, monitored and administered. This Administrative Regulation (AR) shall also provide a policy for grant reporting, record keeping and final reports. 

This policy is in collaboration with the specific procedures as outlined by the Department of Management and Budget (DMB) Grants Centralization Policy and the centralized Citrus County departments included therein, and the Citrus County Grants Administration Manual (Grant Manual) for all other Citrus County Departments. In addition to the Standard Operating Procedures (SOP) and forms as identified by the Clerk of Court Financial Services Department (Finance).

GRANT OPPORTUNITIES:
Any County Department or its agents can submit inquiries or formal letters of interest for grant opportunities which may be offered by regional, state, federal, or private entities. Such inquiries or letters shall be approved by the Department Director or their designee prior to submittal.
  1. Upon receipt of grant application packages or submittal details, the grant will be evaluated by the department to determine whether to proceed with an application or pre-application for Centralized Grant Departments.

    Evaluation should include, but not limited to the following items.
    1. What type of grant? (Competitive, Pre-qualified, Public/Private Partnership, etc.)
    2. Does the opportunity require matching funds or other resources, such as in kind? If so, from where are those funding sources, including County cash match or County in-kind requirements being committed?
    3. How will this grant benefit current County needs? Does it fit into the five-year plan and/or the Capital Improvement Plan?
    4. Does the benefit of the potential grant award outweigh the County resources required to apply for and administer the grant?
GRANT APPLICATIONS:

Board of County Commission (BOCC) approval is required for any grant submittal initiated on behalf of Citrus County, Florida, that requires a grant match or where the granting agency requires that the submittal of an application be officially authorized by the BOCC. Such approval shall be obtained through the standard agenda process and should be submitted through the agenda software.

County Administrator approval is required for any grant submittal initiated on behalf of Citrus County, Florida, that does not require a grant match; where the project, equipment or study etc. is funded 100% by the granting agency. The County Administrator is the only staff person authorized to sign applications, cover letters binding the County, agreements/contracts, letters of intent, or memorandum of understanding unless specified differently through BOCC action. County Administrator approval/signature must be facilitated through the appropriate mechanism as identified through the DMB Grants Centralization Policy, where applicable, or the Citrus County Grant Administration Manual. 

GRANT ACCEPTANCE:

When a grant is awarded, the grant agreement, contract or Notification of Award (NOF) must be authorized by the appropriate authority depending upon the match requirements as indicated above in the application process. If BOCC approval is required, after Legal review and approval, grant contracts should be submitted in agenda software. If prior grant contract approval was obtained by the Board during the application process through previous BOCC action, this section does not apply. If County Administrator approval is required, the grant agreement, contract or NOF must be submitted through the appropriate process.

Following BOCC or County Administrator approval of the grant award, Finance will set up the grant fund. The departments will be responsible for sending to Finance the Grant Information and Control Form with a copy of the partially executed agreement, contract or NOF. For Grants Centralization, the Grants Division will submit a Grant Overview to Finance along with the supporting documents for fund set-up. Upon receipt of the fully executed original agreement, contract or NOF, the original shall be sent to Finance. 

GRANT EXPENDITURES


All grant expenditures shall be governed by the County’s existing Administrative Regulations (AR) for procurement in addition to specific grant requirements and Grant Manual. Grant funded expenditures should be facilitated through the Purchase Order process.

All expenditures pertaining to the grant agreement should be made from the grunt fund. However, if grant expenditures are posted to the General Ledger prior to the grant budget adoption, upon fund set up they should be transferred via budget transfer/resolution. Should the grantor not execute the agreement or determine that expenditures are not appropriate, the expenditures will be paid from the General Fund or Department Operating Fund.

GRANT COMPLIANCE ROLES & RESPONSIBILITIES

Grant Project Manager
The Grant Project Manager is the primary person responsible for project activities on a grant funded project as delineated by the grant agreement. Although some tasks may be delegated, the Grant Project Manager is the chief accountable person and bears responsibility for the overall administrative, programmatic and fiscal conduct of the grant award, for meeting terms and conditions of the award, and for representing the project to the granting agency. This person is designated by the Department Director within the relevant department to handle the various on and off-site activities of the project.

*Some granting agencies will inter-mingle the project manager/compliance manager on the contract agreement. For the Grants Centralization Policy departments, when this occurs and the Grants Administrator & Compliance Manager’s name is required; the above roles and responsibilities still apply.

Administrative Staff
Administrative staff members are those persons who are typically responsible for certain delegated duties to provide assistance to Grant Project Managers. Administrative staff may include Fiscal Specialist, Accounting Clerk, Administrative Coordinator or other identified staff and are a critical element in the successful management of grant awards.

Department Director
The Department Director is the executive manager with programmatic and fiscal responsibilities for a designated department. This individual ensures adequate staff and infrastructure are provided for the appropriate conduct of project management, grant award management, and supervises staff members within the department who serve as Grant Project Manager and administrative staff identified as key members on projects and grant awards. Ultimate grant compliance and verification rests with the Department Director. It is the Department Directors responsibility to remediate identified internal control deficiencies within their respective department on a timely basis.

Grants Division
The Grants Division of DMB is the management division that provides support and monitoring for the Centralized departments throughout the many and varied steps of the grant life-cycle. These include the administrative, fiscal and programmatic conduct of the grant agreement and for meeting other terms and conditions of the award. For the purpose of this AR, the Grants Division applies to those departments under the Grants Centralization Policy.

GRANT MODIFICATIONS

In the event that a grant funded project requires modifications to the established time table, contract and/or budget it shall be the grant project manager’s responsibility to coordinate review and approval through the appropriate mechanism below.

Modifications deemed to be non-substantial, those that do not affect the grant budget, must be approved by the County Administrator. County Administrator approval/signature must be facilitated through the appropriate mechanism as identified through the DMB Grants Centralization Policy, where applicable, or the Citrus County Grant Administration Manual.

Modifications to Board executed agreement, contracts or NOF that require BOCC approval, modifications which require the allocation of additional County resources, not previously budgeted, or when BOCC approval is required by the granting agency, must be submitted in agenda software unless directed otherwise by the County Administrator and/or County Attorney’s office. Board approved resolutions addressing modification approval by Chairperson are exempt from this procedure unless additional County resources are required. The grant project manager shall be responsible for assuring that all impacted parties are made aware of the modifications. Upon receipt of the fully executed original amendment, the department shall submit a grant amendment sheet and the executed original amendment to Finance or the Grants Division, where applicable.

GRANT TERMINATION

When a grant funded project does not meet BOCC goals and objectives, scope of work cannot be achieved and or funds can no longer be spent and must be returned, the grant project manager shall seek Department Director direction. If the Department Director concurs with the assessment, a formal memorandum outlining the grounds for termination or un-allocating of funds shall be submitted to the County Administrator and the County Attorney, through the Grants Division, where applicable, for approval.

Grant awards that do not meet BOCC goals and objectives whereby the granting agency has provided an agreement or if a BOCC approved agreement/contract has been fully executed and upon review of the formal memo by the County Administrator and the County Attorney the grant agreement must be submitted in agenda software as an agenda item for grant termination. The grant project manager shall notify all impacted parties, DMB and Finance of the final action.

GRANT PROJECT CLOSEOUT


The grant project manager shall complete all necessary final reports and submit to the granting agency(s) prior to file closure. In addition, will coordinate closure of all contracts, payment for services, required documentation and financial review or audit with granting agency. All existing policies and procedures in the Grant Manual or the Grants Centralization Policy, where applicable, must be followed as well as all other County policies/procedures in place that are not specifically addressed in the manuals.

For grant agreements where the scope of work has been achieved and there are remaining/unused funds, upon completion of the grant activity, a closeout request must be submitted to Finance or DMB (if under Grants Centralization Policy) along with a closeout Journal Entry/Journal Voucher (JV) to return any interest or remaining match funds and/or direction on where to return any unused granting agency funds. All grant related close-out JVs will be submitted to the Finance for approval.

GRANT RECORD KEEPING


The grant project manager or the Grants Division, if applicable, is responsible for keeping the grant records for the duration, as outlined in the grant funding agreement, of all grant activity, correspondence, billing, and other related documents as required by the granting agency.

The completed grant project file shall be retained by the implementing department or Grants Division, where applicable, in accordance with applicable Federal, State and specific granting agency requirements for record keeping. The original contract and amendments shall be retained by Finance in accordance with applicable Federal and State retention schedules.

FEDERAL AWARDS

Federal Awards must follow all existing policies and procedures set by the Federal Agency’s Awards Policies and Procedures, the Grant Manual or the Grants Centralization Policy, where applicable, and all other Citrus County policies/procedures in place that are not specifically addressed in the manuals. Where policy conflict exists, the most stringent policy will apply.

Federal Transit Awards must follow all existing policies and procedures in the Federal Transit Administration Awards Policies and Procedures Manual and all other Citrus County policies/procedures in place that are not specifically addressed in the manual.

FOOTNOTES & REFERENCES RELATED TO AR's:   Supersedes AR 2.18-2 dated September 13, 2016; AR 2.18-1 dated September 8, 2015; AR 2.18 dated February 24, 2015, AR 13.10 dated October 26, 1999; AR 13.10-1 dated September 9, 2008.