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12-14-2020-R
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12-14-2020-R
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Page 10 <br />Additional Federal Awards Compliance Requirements <br />A number of the Federal awards received by the city are passed-through the State of Minnesota. Management will <br />consider both the OMB UGG - Uniform Grant Guidance Compliance Supplement and any applicable compliance <br />requirements as set forth by the State of Minnesota. <br />General Information <br />Source of Information – Each year the Federal government (Office of Management and Budget) issues a <br />comprehensive document on the compliance requirements each grant recipient is obligated to follow in general terms, <br />along with program-specific guidance on various grant awards. Each of the requirements identified is considered <br />individually in this manual. <br /> <br />The following pages document the policies and procedures of the city related to compliance with such procedures, as <br />applicable. In each year that the city is subject to a single audit, applicable compliance requirements are expected to be <br />tested in detail by the city’s independent auditors. <br /> <br />Objectives – The objectives of most compliance requirements are generic in nature. While the criteria for each <br />program may vary, the main objective of the compliance requirement is relatively consistent across all programs. As <br />such, the policies and procedures of the city have been based on the generic sense of the compliance requirement. For <br />selected compliance requirements, this manual addresses the specific regulations applicable to individual grants. This <br />is not intended to imply that a program is not subject to such policies if it is not specifically mentioned here. It is the <br />intention of the city that all Federal awards are subject to the following policies and procedures. <br /> <br />Controls over Compliance – In addition to creating policies and procedures over compliance with provisions of <br />Federal awards, the city has implemented internal controls over such compliance, generally in the form of <br />administrative oversight and/or independent review and approval. In order to document these control activities, all <br />independent reviews must be signed/initialed and dated. <br /> <br />Documentation – The city will maintain adequate documentation to support both the compliance with applicable <br />requirements as well as internal controls over such compliance. This documentation will be provided to the city’s <br />independent auditors and/or pass-through grantor agencies, as requested, during the single audit and program audits. <br />Activities Allowed/Un-allowed and Allowable Costs/Cost Principles <br />Source of Governing Requirements – The requirements for activities allowed or un-allowed are contained in program <br />legislation, Federal awarding agency regulations, and the terms and conditions of the award. The requirements for <br />allowable costs/cost principles are contained in the A-102 Common Rule (§ .22), OMB Circular A-133 (2 CFR section <br />215.27), program legislation, Federal awarding agency regulations, and the terms and conditions or the award. <br /> <br />In order to ensure compliance with these requirements, the city has implemented the following policies and <br />procedures: <br />1. All grant expenditures will be in compliance with OMB Circular 2 CFR 200, Subpart E, State law, city policy, <br />and the provisions of the grant award agreement, which will also be considered in determining allowability. <br />Grant funds will only be used for expenditures that are considered reasonable and necessary for the <br />administration of the program. <br /> <br />2. Grant expenditures will be approved by department heads/program managers initially through the purchasing <br />process and again when the bill or invoice is received. This will be evidenced by signature or initials and date on <br />the invoice or by an approval documented via email. Accounts payable disbursements will not be processed for <br />payment by the Finance Department until necessary approval has been obtained. <br /> <br />3. Payroll costs will be documented in accordance with OMB Circular A-87 as described in the section of this <br />manual titled “Payroll and Timekeeping”.
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