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Page 2 Policies and Procedures – Federal Awards Administration Overview Purpose – This manual has been prepared to document the policies and procedures for the administration of federal awards of the City of Arden Hills (the “city”). The Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles and Audit Requirements [34 CFR Part 80, 2 CFR Part 213 and Part 6 of the Office of Management and Budget (OMB) UGG - Uniform Grant Guidance Compliance Supplement] require all sub-recipients of federal funds to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Written policies and procedures are part of the necessary internal controls and are required as a precondition to receiving federal funds. These policies and procedures are intended to be sufficiently comprehensive to adequately meet such requirements. However, in no case are these policies and procedures intended to supersede or limit federal or state laws or regulations, or the provisions of individual grant agreements. Hierarchy of Authority – In the event that conflicting guidance on the administration of Federal awards is available, the city has deemed Federal guidance to be most authoritative, followed by other State or local agencies. Revisions – Guidance provided by the Federal government through the OMB UGG - Uniform Grant Guidance Compliance Supplement are expected to be updated each year. Such updates are considered by the city as they become available and policies and procedures will be revised accordingly. The City Administrator, Public Works Director, Finance Director, and designees are authorized and required to establish and document policies and procedures to ensure compliance with the provisions of federal and state regulations and the provisions of grant agreements. Such policies and procedures are documented herein, and will be reviewed and updated as necessary, but not less than once every three years. Training – City finance personnel and its program administrators of Federal awards will be provided the necessary training through various mechanisms, such as: (1) reviewing monthly State Aid Financial Status Report Updates, accompanying State aid payments, (2) consulting with the city’s auditors as needed for clarification, (3) participating in various training opportunities, such as those offered by appropriate professional organizations, (4) reviewing legislative updates from multiple sources, (5) membership and participation in meetings of the Governmental Finance Officers Association (GFOA), (6) certification of respective positions by the GFOA i.e.: Finance Director, (7) coordination and collaboration with individuals performing similar job functions at similar municipalities. Compliance Failures – Compliances failures, whether noted internally by management or through the external audit process, will be addressed immediately by reviewing the reason for the failure with responsible personnel and devising an improved process to encourage compliance in the future. General Accounting and Financial Management It is the policy of the city to comply with all statutory, regulatory, and contractual requirements in the conduct of, and accounting for, its financial operations. The official books of record for the city will be maintained subject to the following provisions: 1. The city will account for its operations in accordance with the Generally Accepted Accounting Principles (GAAP) applicable to local units of government. 2. The city will comply with all applicable circulars issued by the Office of Management and Budget (OMB), including, but not limited to: a. OMB Circular A-87 – Cost Principles for States, Local and Indian Tribal Governments. b. OMB UGG - Uniform Grant Guidance – Audits of States, Local Governments, and Non-Profit Organizations (the Single Audit Act).