Grant Requirement Reminders Michigan State Police Emergency Management and Homeland Security Division

Grant Requirement Reminders
Michigan State Police
Emergency Management and
Homeland Security Division
Ms. Jackie Reese, Audit Unit Manager
Mr. Richard Sheaffer, Auditor
Overview
• High risk topics
• Grant requirements
• Review, monitor and document
• Resources
http://www.michigan.gov/emhsd
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High Risk Topics
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Suspension and Debarment
Equipment Inventory
Subrecipient Monitoring
Support for Salaries and Wages
Professional Services
http://www.michigan.gov/emhsd
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High Risk Topics (cont.)
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Dual Compensation
Conflict of Interest
Sole Source Procurement
Contract Monitoring
http://www.michigan.gov/emhsd
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Suspension and Debarment
44 Code of Federal Regulation (CFR) Part 13.35
Grantees and subgrantees must not make any award
(subgrant or contract) to any party which is debarred or
suspended or is otherwise excluded from or ineligible for
participation in Federal assistance programs.
UPDATE:
www.epls.gov has been replaced with www.sam.gov.
http://www.michigan.gov/emhsd
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Equipment Inventory
44 CFR Part 13.32 (d)(1 & 2)
(1) Property records must be maintained that includes:
description of the property, a serial number or other
identification number, the source of the property, who holds
title, the acquisition date, and cost of the property, percentage
of federal participation in the cost of the property, the location,
use and condition of the property, and any ultimate disposition
data including the date of disposal and sale price of the
property.
(2) A physical inventory of the property must be taken and the
results reconciled with the property records at least once
every two years.
http://www.michigan.gov/emhsd
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Subrecipient Monitoring
Office of Management and Budget (OMB)
Circular A-133 Section 400 (d)
Identifies pass-through entity responsibilities including:
• Identify Federal awards; advise of rules and
regulations; monitor activities; ensure subrecipients
meet audit requirements; issue management decision;
consider adjustment of records; and ensure access to
records.
http://www.michigan.gov/emhsd
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Support for Salaries and Wages
2 CFR 225, Appendix B (8) (h) (3)
• Where employees are expected to work solely on a
single federal award or cost objective, charges for their
salaries and wages will be supported by periodic
certifications that the employee worked solely on that
program for the period covered by the certification.
• Certification must be signed by employee or direct
supervisor and completed at least semi-annually.
http://www.michigan.gov/emhsd
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Support for Salaries and Wages (cont.)
2 CFR 225, Appendix B (8) (h) (4)
• Where employees work on multiple activities or cost
objectives, a distribution of their salaries or wages will
be supported by personnel activity reports or
equivalent documentation which meets the standards
in subsection (8) (h) (5).
http://www.michigan.gov/emhsd
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Support for Salaries and Wages (cont.)
2 CFR 225, Appendix B (8) (h) (5)
• Personnel activity reports must meet the following:
○
○
○
○
Must reflect after-the-fact distribution of the activity.
Must account for the total activity compensated.
Prepared at least monthly
Must be signed by the employee
http://www.michigan.gov/emhsd
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Professional Services
2 CFR Part 225, Appendix B (32)
• Costs of professional services rendered by persons
who are members of a particular profession or posses
a special skill, and who are not officers or
employees of the governmental unit, are
allowable…(Bolding added)
http://www.michigan.gov/emhsd
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Dual Compensation
DHS Grant Guidance
• In no case is dual compensation allowable. That is, an
employee of a unit of government may not receive
compensation from their unit or agency of government
AND from an award for a single period of time (i.e.
1:00 PM to 5:00 PM) even though such work may
benefit both activities.
http://www.michigan.gov/emhsd
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Conflict of Interest
44 CFR Part 13.36 (b) (3)
• Grantees and subgrantees will maintain a written code
of standards of conduct governing the performance of
their employees engaged in the award and
administration of contracts.
http://www.michigan.gov/emhsd
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Conflict of Interest (cont.)
44 CFR Part 13.36 (b) (3)
• No employee, officer or agent of the grantee or
subgrantee shall participate in the selection, or in the
award or administration of a contract supported by
Federal funds if a conflict of interest, real or apparent,
would be involved. Such a conflict would arise when:
(i) The employee, officer, or agent, (ii) Any member of
his immediate family, (iii) His or her partner, or (iv) An
organization which employs, or is about to employ,
any of the above, has a financial or other interest in
the firm selected for award.
http://www.michigan.gov/emhsd
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Sole Source Procurement
44 CFR Part 13.36 (c) (4) (i)
•
Procurement by non-competitive 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:
○
○
The item is available only from a single source;
The public exigency or emergency for the requirement will
not permit a delay resulting from competitive solicitation;
○ The awarding agency authorizes noncompetitive proposals;
or
○ After solicitation of a number of sources, competition is
determined inadequate.
http://www.michigan.gov/emhsd
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Contract Monitoring
44 CFR 13.36 (b) (2)
•
Grantees and subgrantees will maintain a contract
administration system which ensures that contractors
perform in accordance with the terms, conditions,
and specifications of their contracts or purchase
orders.
http://www.michigan.gov/emhsd
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Contract Monitoring (cont.)
44 CFR 13.36 (f)
• Grantees and subgrantees must perform a cost or
price analysis in connection with every procurement
action including contract modifications.
http://www.michigan.gov/emhsd
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Review, Monitor and Document
• Review grant requirements, grant guidance, code of
federal regulations, rules and regulations, and omb
circulars.
• Monitor grant performance, subrecipients, contracts,
reporting, grant requirements, etc.
• Document, document, document!
• Note: Lack of adequate documentation may result
in questioned costs.
http://www.michigan.gov/emhsd
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Resources
44 CFR Part 13
•
http://www.ecfr.gov/cgi-bin/textidx?tpl=/ecfrbrowse/Title44/44cfr13_main_02.tpl
2 CFR Part 225
•
http://www.ecfr.gov/cgi-bin/textidx?tpl=/ecfrbrowse/Title02/2cfr225_main_02.tpl
OMB Circular A-133
•
http://www.whitehouse.gov/sites/default/files/omb/assets/a133/a133_revi
sed_2007.pdf
http://www.michigan.gov/emhsd
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Resources (cont.)
EMHSD Information Bulletin 11-02
•
http://www.michigan.gov/documents/msp/compliance_with_grant_require
ments_369178_7.pdf
Past MSP-EMHSD Presentations
•
http://www.michigan.gov/msp/0,4643,7-123-1593_3507_41574--,00.html
Sample Equipment Tracking Form
•
http://www.michigan.gov/msp/0,4643,7-123-1593_3507_41574-214684-,00.html
http://www.michigan.gov/emhsd
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Questions?
http://www.michigan.gov/emhsd
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Contact Information
Ms. Jackie Reese, Audit Unit Manager
Phone: (517) 324-2330
Email: [email protected]
Mr. Richard Sheaffer, Auditor
Phone: (517) 333-4624
Email: [email protected]
http://www.michigan.gov/emhsd
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