VCOM Institutional Policy and Procedure Manual

VCOM Policy and Procedure

Policy #U027

Non-federal Entity: State, local government, Indian tribe, institution of higher education (IHE), or not for profit organization that carries out a Federal award as a recipient or sub-recipient. Pass-through Entity: Non-federal entity that provides a sub-award to a sub-recipient to carry out part of a federal program.

3. P ROCEDURES 3.1. Identification

The college will identify, in its financial system, all federal awards received and expended, and the federal programs under which they were received (CFDA title and number, award identification and year, name of federal agency, and name of pass-through entity if applicable). 3.2. Reporting and Records The college will provide accurate, current, and complete disclosure of financial results of each federal award or program in accordance with 2 CFR § 200.327. Reports will be made in a timely manner and as indicated by the federal awarding agency. The college shall monitor and report program performance to the federal awarding agency as required. The source and application of federal funds will be recorded and will contain information on authorizations, obligations, unobligated assets, and expenditures, as well as any income or interest if applicable. These records and supporting documentation will be maintained by both the VCOM Business Office and the Office of Research Administration. 3.3. Internal Controls To show control and accountability for all funds, property, and other assets related to federal awards, the college will manage each federal award in compliance with federal statutes, regulations and terms of the federal awarding agency. The Office of Research Administration, together with the Business Office, will compare expenditures with budget amounts for each federal award on a routine schedule. These reports will be recorded in the college’s financial management system. The Business Office will ensure payments on federal awards are prompt with minimal time elapsing between transfer of funds (from United States Treasury or pass-through entity) and the distribution of the funds. The Office of Research Administration has written procedures for this process that meet requirements of 2 CFR § 200.305. As prescribed in Subpart E – Cost Principles under 2 CFR Part 200, for a given cost to be charged to a federal award the cost must be allowable, reasonable, and allocable. Procedures for determining these requirements are in VCOM Policy on Costing Principles for Sponsored Projects. Should any issues of noncompliance arise, such as those identified in audit findings, the college will take prompt action to investigate and manage. The college will take reasonable measures to safeguard protected personally identifiable information and other information the federal awarding agency or pass-through entity designates as sensitive (consistent with applicable federal, state, and local laws regarding privacy and obligations of confidentiality).

VCOM Policy on Financial Management of Federal Funds

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