Grant & Contract Post-Award Compliance Support · 2020. 8. 14. · Assessment. Ongoing post-award...

Resource Development, Management and Compliance, 2020

Grant & Contract Post-Award Compliance Support

Overview

The Department of Resource Development, Management and Compliance provides post-award

compliance support for grant projects that have deliverables and compliance requirements, such

as required programmatic and fiscal reporting. The Executive Director for Resource

Development, Management and Compliance and the College President have the discretion to

determine when other types of awards, contracts, or allocations may need administrative and

post-award compliance reviews or technical assistance and support throughout the contract term.

In the post-award phase, a member of the Grant Compliance team is assigned to a grant or

contract. Each member of the Grant Compliance team provides compliance support in

accordance with the South Texas College Grant & Contract Post-Award Compliance Support

Process, which includes Risk Analysis, Compliance Reviews, and ongoing technical assistance

for the Project Director (PD) or Principal Investigator (PI) and Financial Manager (FM) who

manage and implement the grant.

South Texas College Grant & Contract Post-Award Compliance Support Process Map,

Figure 1, provides a graphic representation that articulates the flow-process for the Grant &

Contract Post-Award Compliance Support provided for awards received that are serviced by our

department.


Figure 1. Grant & Contract Post-Award Compliance Support Process Map


The process map in Figure 1 is organized into 3 sections:

I. Set-up, Risk Assessment & Initiation

Inclusive of Green Boxes 1-4

- The steps involved and the roles/responsibilities for every award supported through our

office.

II. Monitoring

Inclusive of the Green/White Boxes 5, 6, and 7, as well as the 6 boxes in white/green

below that labeled as “Compliance Review Components”,

- 1-3 Status Reviews are done per grant, depending on the results of the Risk

Assessment. Ongoing post-award support is provided for the PD/PI and FM

throughout the grant funding period.

III. Additional Support Functions-

Inclusive of 10 boxes in gray along the bottom row of the map.

Various types of additional post-award support are provided by Grant Compliance

staff for the PD/PI & FM to assist them in effectively managing the grant, following-

up on grant award requirements, and to mitigate risk of non-compliance.

This section of the Grant Management Handbook details and explains each of the three sections.

I. Set-up, Risk Assessment & Grant Initiation

Set-up of the Grant The Grant Compliance staff member works in collaboration with the PD/PI and FM to complete

necessary documentation before South Texas College’s Business Office staff can establish a fund

for the grant within BANNER. BANNER is an enterprise resource planning software that is used

by South Texas College in many capacities. For fiscal purposes, Banner is used to review budget

activity, track document history, approve or disapprove requisition requests and much more.

Grant Budget Form The Budget Request Form (BO-4200), Figure 2, is a Business Office form. This form requires that

the budget breakdown of categories and amounts be provided accurately and completely for the

account to be properly set-up. The Grant Name, Budget Category Descriptions, STC Account

Codes and Justification for request are required for this form to be complete. Grant Compliance

staff provide assistance to the PD/PI to ensure the form is complete and submitted to the business

office for processing. The BO-4200 requires signatures of the PD/PI, FM, Division Vice President

and Vice President of Finance and Administrative Services. Table 1 provides the grant categories

that are divided within the specific South Texas College BANNER Cost Accounts.


Table 1.

South Texas College Account Pools for Grant Budgets

Note: The following account classifications are the most commonly used. More are available on

the Accounts Payable website at

https://finance.southtexascollege.edu/businessoffice/forms/ap/Account_Classifications.pdf

SALARY

610000

Full-Time

Faculty

Overloads

Part-Time

Faculty

Trainer

Stipends &

Special

Assignment

Stipends - Cell

Phone

Professional/Tec

hnical Support

Classified

Overtime

Student Direct

Wage

Non-Student

Direct Wage

Direct Wage

BENEFITS

620000

Group

Insurance

State & STC

State - SKIP

FICA

Workmen's

Comp

Unemployment

Comp Ins

Retirement

Other

OPERATING

710000

Consumables

Fuels & Lubricants

Promo Items

Chemicals & Gases

Food Purchased

Office Supplies

Computer Supplies

Hardware/Materials/Par

ts/Supplies

Telecom Parts/Supplies

Educational-Testing &

Graduation

Educational-Food

Purchases

Educational-Lab

Parts/Supplies

Educational-Classroom

Parts/Supplies

Subscriptions

Books & Reference

Materials

Membership Dues

Registration Fees

Insurance

Non-Capital

Furn/Equip/Comp/Lapt

ops

Software

Rentals

Contracted / Purchased

Services

Temporary Services

Child Care Services

Advertising Services

Honorariums

Grant Sub-Contracts

Grant Training

Payments

Utilities

Freight Delivery

Postage

Fees & Other Charges

TRAVEL

730000

In-State

Mileage

Car Rental

Incidental

Travel for

Grant Partners

Out-of-State

CAPITAL

740000

Furniture &

Equipment

> $4,999.99

Computer

Equipment

> $4,999.99

Computer

Software >

$4,999.99

Software

License >

$4,999.99

IT Telecom

Computer

Equipment

> $4,999.99

IT Telecom

Computer

Software >

$4,999.99

IT Telecom

Computer

Software >

$4,999.99

SCHOLARS

HIP/TUITI

ON

750000

Tuition

Scholarship

Sponsored

Items

CONST

RUCTI

ON

770000

Construc

tion

https://finance.southtexascollege.edu/businessoffice/forms/ap/Account_Classifications.pdf


Grant Set-up Form The Request to Set-up a New Grant Fund (BO-4201), Figure 3, is a Business Office Form. This

form provides grant and grantor detail so that the Grant Accounting Office can provide adequate

support to the PD/PI and FM of the grant. The form also needs to include the grant name, purpose,

determined PD/PI, FM and VP, along with the dates of the grant period, agency contact

information, funding amount from the agency and if in-kind budget contribution is required. This

form also lists the name of the individual requesting the budget to be set-up on the bottom of the

form, date of the request, and the name of the Financial Manager. This information can be typed

as signatures are not required for the BO-4201.

BANNER Finance Access Request Form The BANNER Finance Access Request Form (BO-7200), Figure 4, is also a Business Office Form.

This form provides access to the Fund Code set up for the grant and depending on what is needed,

requisitioning access and view only access may be considered. Requisitioning access is used for

any support involving the initiation of a requisition through BANNER. Typically, this means that

there is operating, capital, or registration payments approved within the grant agreement. View

only access is used to view the funding activity within BANNER. Typically, this access is provided

to anyone who can support in viewing the activity within the Fund.

This form is required to be signed by the employee needing access, the FM for that Fund, and then

submitted with the BO-4200 and BO-4201 to the Business Office for further processing.

The Financial Manager has grant access to the Fund automatically in BANNER when the Fund is

set up. A PD/PI will need to request access to the fund with the BO-7200, in addition any person

submitting requisitions. This individual is typically a secretary or administrative assistant

designated to assist to gain access to the account to support with budget review and status of

activity within BANNER.


Figure 2. Request for Grant Budget (BO-4200)


Figure 3. Request to Set-up a New Grant Fund (BO-4201)


Figure 4. Banner Finance Access Request Form (BO-7200)


Initiating Grant Funded Project

Grant initiation involves the Department of Resource Development, Management and

Compliance, the Grant Accounting Office, the Project Director/Principal Investigator, and the

Financial Manager who will implement and manage the grant funded project.

Note: Grant Funded Activity may not begin before the South Texas College Board of Trustees

approves of the award or a Grant Initiation Meeting takes place.

Grant Initiation Meeting The Department of Resource Development, Management and Compliance facilitates the Grant

Initiation Meeting. The purpose of a Grant Initiation Meeting is to ensure everyone has a clear

understanding of the grant requirements and to process the forms for fund set-up.

The required attendees for this meeting are the Project Director/Principal Investigator, Financial

Manager, the Grant Compliance staff assigned to the grant and a representative from Grant

Accounting Office.

A Grant Initiation Meeting Checklist (Figure 5) is used by Grant Compliance staff to review

documents, including the grant application or proposal, contract terms and conditions, funding

agency requirements, and other applicable rules and regulations to plan for the Grant Initiation

Meeting. The following items are addressed within the Grant Initiation Meeting, if applicable.

The importance of each item is mentioned within the Grant Initiation Meeting below:

• Compliance Overview/Role (Website and Compliance Review): RDMC webpage

• Project Goals and Objectives

• Internal Owners: PI, FM, and BANNER Access

• Funding Cycle

• Fiscal/Program

• Award Amount

• Budget Breakdown

• In-Kind/Match

• Project Personnel Faculty/Staff (personnel documentation)

• Develop list of project personnel and responsibilities by Department(s)

• Purchasing Requirements/Inventory

• Travel

• Scholarship/Tuition

• Subrecipient(s), if applicable

• Deliverables

• Reporting

• Fiscal Reporting

• Programmatic Reporting

• Data Collection/Evaluation Support Needed from Institutional Effectiveness

• Grant Record Retention (Original documents)


Within the Grant Initiation Meeting, specific documents are discussed and when completed are

routed as a packet along with the award paperwork to be vetted through all necessary signatures.

This packet should have the completed Budget Request Form, Grant Set-up Form and the

BANNER Access Request Form/s, along with the fully executed (if available) Notice of Grant

Award. Then, the packet is submitted to the Grant Accounting Office for review, approval and

further processing.

Upon Grant Accounting completing set-up of the Grant Account in BANNER, per the packet

provided, an email is sent to the PD/PI, FM of the grant and Grant Compliance is copied on the

correspondence. A BANNER Systems Analyst provides access to BANNER for the specified

Fund to the FM automatically and provides grant access to other individuals designated to assist

the FM with access to submit requisitions and/or view status of the funding activities. This may

include the PD/PI and/or an Administrative Assistant, Project Manager, Project Coordinator or

other staff designated by the Project Director and Financial Manager. A separate email will be

sent to the individuals with authorization to access the Fund in BANNER.


Figure 5. Grant Initiation Meeting Checklist


Conducting Risk Assessment for Grants

When a grant is approved by the STC Board of Trustees and it is assigned to a Grant Compliance

staff member, a risk assessment on the grant is conducted.

There are five Risk Factors:

• Poor outcomes on federal or state desk review, audit or site visit ($750,000+)

• Unfamiliar/new personnel as PI or FM on grant

• Lack of prior experience with working with grantor

• Defaulting on time sensitive activity based on length of grant and grant requirements

• Failure to meet or address deliverables

*If the grant has a subawardee, the risk may be rated higher depending on how the 5 risk factors

affects the probability of a factor happening or the impact of the factor.

Figure 6 provides an example of a completed risk assessment. Reading left to right, the table

shows the five risk factors in the first column, and the designated weight for each risk factor is

provided in the next column. To complete the risk assessment, the Grant Compliance staff

members reviews information about the grantee and if applicable, subgrantee(s) to determine the

Probability of Risk. A mitigation score is derived from the weighted impact of a specific risk

factor multiplied by the Probability of Risk.

.


Figure 6. Risk Assessment Sample

Risk Factors Weighted

Impact

Probability

of risk

occurring

Mitigation

Score

Poor outcomes on federal or state desk review, audit or

site visit ($750,000+) (consider to rank higher if there is a

subawardee)

25 3 75

Unfamiliar/new personnel as PI or FM on grant

(consider to rank higher if there is a subawardee) 15 1 15

Lack of prior experience with working with grantor 10 3 30

Defaulting on time sensitive activity based on length of

grant and grant requirements (consider to rank higher if

there is a subawardee)

20 3 60

Failure to meet or address deliverables (consider to rank

higher if there is a subawardee) 30 2 60

100 12 240

Low 1

Medium 2

High 3

Number of Status Reviews 1 2 3

Mitigation Scale 100-166 167-233 234-300

II. Monitoring

Grant Compliance conducts three types of Compliance Reviews: Status Reviews, Close-

Out Status Reviews, and Comprehensive Reviews. One hundred percent of grants

approved by the STC Board of Trustees before May of the current fiscal year will receive

at least one Compliance Review.

Figure 7 provides detail regarding Compliance Status Reviews that are done for grant

awards depending on the level of risk determined based on the Risk Assessment. These

reviews are for compliance monitoring purposes.


a) Status Reviews (100% of Grants)

Once the Risk Assessment has been completed, an annual frequency number of Status

Reviews is assigned to the awarded Grant based on the level of risk determined (Low,

Medium, or High), see Risk Assessment Map, Figure 7.

Figure 7. Risk Assessment Map

All grants will receive at least 1 Status Review. A Status Review consists of information that is

collected from the PD/PI about the status of expenditures, programmatic and fiscal reports,

subrecipient(s), and grant progress on meeting deliverables. If any one of those indicates an issue,

Grant Compliance will communicate directly with the Project Director/Principal Investigator and

FM, as needed to mitigate risk of noncompliance and intervene with added support, as needed.


Status Review Form Email

Figure 8 shows the standard email from Grant Compliance that is sent via Outlook

between 1 and 3 times a year based on Risk Assessment outcome, as show in Figure 6.

Within the Status Review Form Email there is a link for the Status Review Form (Figure

9).

i. The Project Director (PD) or Principal Investigator (PI) are expected to

1. Respond to all applicable questions from the Status Review Form

2. Click ‘submit’ (results will automatically be sent to Grant Compliance

staff)

*Should the PD/PI have any questions, they may contact the Grant

Compliance staff that is assigned to the grant directly or use this email:

[email protected]

Figure 8. Email to PD/PI with Status Review Form

Status Review Form Email

Subject: RDMC Status Review Form

Dear Principal Investigator,

The Department of Resource Development, Management and Compliance (RDMC) asks that you

complete the Grant Status Review Form, for ________________________________ Grant,

_________ Fund Number. This form will help us in providing added, customized support to you

for your grant. This mandatory Status Review Form is due ________________.

The benefits for you, as a Principal Investigator (PI) is:

• A periodic snapshot of grant progress.

• It allows for a secondary and comprehensive assessment of grant activity.

• A platform to request additional support to meet grant goals/objectives/deliverables.

Please take a few minutes to fill out in the following link: _____________________ and click the

“Submit Form” button on the bottom when completed.

If you have any questions about this form, please contact us at [email protected].

Thank you,

Resource Development, Management and Compliance

mailto:[email protected]



ii. Compliance Staff will complete the following:

1) Review the responses from the PD/PIs and Compliance Staff will reply, as

applicable. For example: If a PD/PI responds “Yes” to the question “is

there a Programmatic report due in the next 45 days”, and the Grant

Compliance staff member has not received a draft, a reminder and deadline

will be posted for the PD/PI to submit the report for review.

2) Grant Compliance provides ongoing compliance monitoring to mitigate

risk of non-compliance with grant requirements. When the Status Review

information is received, the information provides an update on

programmatic progress and fiscal management. Even if the PD/PI provides

a positive response to all questions, the Grant Compliance staff member

has reviewed programmatic report deadlines, sent reminders, reviewed the

status of the expenditures, and has been in communication with the PD/PI

throughout the life of the grant about the deliverables for the grant or

contract. If there are any concerns or potential issues, the Grant

Compliance staff member alerts or informs the PD/PI.

3) Grant Compliance maintains documentation of Status Reviews internally

on a Cumulative Results of Status Reviews spreadsheet, which includes the

respondent’s comments with reference to communication between Grant

Compliance and PD/PI, such as emails, phone calls, meeting

agendas/notes, memoranda, etc. The Grant Compliance staff member will

add all Status Review Form review responses received from PDs/PIs to a

Cumulative Results of Status Reviews spreadsheet. The Cumulative Results

of Status Review Spreadsheet allows Grant Compliance staff to review past

reviews to follow-up with the PD/PI to reduce and prevent risk of re-

occurrences of the issue initially documented on the Status Review.


Figure 9. Status Review Form, with all questions expanded

(If the response is to the Purple highlighted question, then additional questions “pop-out”.

Questions with an * are required to be answered.)

Grant Status Review Form

Date - Month and Year*

Principal Investigator (PI) Name*

Grant Name

Grant Fund Number

Required Section: 1. Does your grant include funding for personnel, travel or non-consumable items?

Yes No

If yes, then the following will show resources.

▪Personnel

▪Effort Reporting Selection Process

▪Travel

▪Link to Travel Guidelines

▪Non-consumable Grant Items

▪Inventory Tracking Guidelines

2. Is your project on track in accordance with your grant? Yes No

(Select all areas of concern.)

▪Personnel

▪Travel

▪Processing a Requisition

▪Tuition/Scholarships/Participants

Personnel: (Select all areas that apply.) ▪Filling grant role/s▪Routing commitment forms▪NOEs▪Completing Activity ▪Certification

Form▪Other ________________________

Please explain: _________________________ (required field)

Travel: (Select all areas that apply.) ▪Completing travel authorizations (GSA Rates, tips, split funding, etc.) ▪Submitting travel

voucher (incidentals) ▪Reviewing mileage (supporting documentation) ▪Other

________________________ Please explain: _________________________ (required field)

Processing a Requisition (operating/equipment): (Select all areas that apply.) ▪Accessing Fund▪Allowability ▪Purchase Order▪Invoice Payments

▪Other ________________________



Tuition/Scholarships/Participants: (Select all areas that apply.) ▪Eligibility▪Recruitment ▪Set-Up▪Other _______________________


IV. Is there a Program Report due before _____?

Yes No

3a) Has the program report draft been sent to Grant Compliance?

Yes No

Provide status: ________________________ (required field)

V. Is there a Fiscal Report due before ______?

Yes No

4a) Has the fiscal report been approved and sent to Grant Accounting?

Yes No

Provide status: ________________________ (required field)

4b) Is there a match or in-kind requirement part of the project?

Yes No

4b-1) Has the detailed match or in-kind support documentation been sent to Grant

Accounting?

Yes No

Provide status: ________________________ (required field) Support documentation examples: effort reporting forms, invoices, travel paperwork, etc.

5) Does South Texas College have "Subrecipient" partners in the grant? * Yes No "Subrecipient" is an entity responsible to follow grant terms and conditions, not 3rd party vendors.

5a) Are you receiving accurate and timely data/information necessary from the

subrecipient related to grant activity? *

Yes No

If No, please explain? * (required field)

Comments/Upload Section: Please comment and/or attach any document that will support your responses to this form.

Once submitted, the Status Review Form responses are reviewed by the Grant Compliance staff

member assigned to the grant to prepare additional support that may be needed.


b) Comprehensive Reviews (higher risk grants)

In addition to Status Reviews, completed for 100% of all grants, a Comprehensive

Review is completed for those grants in which the Risk Assessment determine a

score of 3, Red level High Risk (as show in the Risk Assessment Map).

Process and documents used during a Comprehensive Review

Send a Comprehensive Review Email Notification (Figure 10) to the PD/PI

and FM that the grant has been selected for Comprehensive Review. The

Grant Compliance staff member assigned to the grant will initiate the

Comprehensive Compliance Review by reviewing the following systems

and documentation specific to the grant in the period (usually the current

FY in which the review is initiated). The review is completed with

information available to the grant compliance staff member. If information

or documentation is necessary to complete the review and is not available,

the PD/PI may be contacted to supply such information.

Below is a list of systems/documentation that may be accessed to complete

the review (this is not an exhaustive list, as some grants may have other

useful documentation)

i. Fiscal and Program Reports

ii. Grant Fund Account in Banner/Management Tracker

iii. Grant Deliverables as defined in the contract, Agreement, MOU

or Scope of Work

iv. Time & Effort Documentation has been completed or are

scheduled to be completed

v. Inventory Tracking Logs (as submitted in Status Reviews)


Figure 10: Comprehensive Review Email Notification

Comprehensive Review Form Email

Subject: RDMC Comprehensive Review


The Department of Resource Development, Management and Compliance (RDMC) would like to

inform you that your grant has been selected for a Comprehensive Review. At this time, no

information or documentation is needed from you for this review, Grant Compliance should have

access to all records, however if something is needed, we will contact you. Once the

Comprehensive Review has concluded, you will be provided a summary for your records.

If you have any questions, please contact us at [email protected].

Thank you,


a. The following Comprehensive Review form (Figure 11) is be used by Grant

Compliance staff during the review. Each section of the review has been designed

to review specific sections of a grant. For example, the Financial Compliance

Section has triggers for Grant Compliance to enter the Grant Fund account in

Banner to review past Requisitions, Pos, or invoices, review encumbrances,

expenditures to date and available balances by category. Fiscal reports are also

available to gran compliance through internal sharing with Grant Accounting.

b. Monitoring Grants Based on Comprehensive Compliance Review Data

Once the review is completed, Grant Compliance Staff send a copy of the

completed report to the PD/PI with a copy to the FM. In the comments and

Recommendations section of the review is the specific location Grant Compliance

staff would put any issues found. Follow up communication with PD/PI by the

assigned Grant Compliance staff, if it is warranted.



Figure 11: Comprehensive Compliance Review Form

Comprehensive Compliance Review

This Comprehensive Compliance Review includes all detail compiled from the grant within a given timeframe. The intent of this report is to ensure compliance and effective grant management.

Review Term: Month Reviewed:

Principal Investigator Name:

Financial Manager Name:

Grant Division:

Grant Title:

Grant Start Date:

Grant End Date:

Total award amount:

Financial Compliance Are all expenditures allowable under the grant?

Yes No If no, briefly explain steps necessary to mitigate risk:

________________________________________________

________________________________________________

Are grant expenditures listed in budget categories accurate on the management tracker?


________________________________________________

________________________________________________

Have all required financial reports been submitted?

Yes No NA If no, briefly explain steps necessary to mitigate risk:

________________________________________________


________________________________________________

Effort Reporting

If there is a payment linked to personnel expenses, have all necessary personnel reporting paperwork been submitted?

• Notice of Employment

• Responsibilities and Commitment Form

• Personnel Certification

• Personnel Activity Report If no, communication on procedures will be sent to the department. If yes, a copy should be stored in SharePoint.


________________________________________________

________________________________________________

Programmatic Compliance

If there is a payment linked to the purchasing of non-consumables, has a physical inventory document (preferably in a spreadsheet) which includes item name, descriptions, serial numbers, silver/green tag numbers, acquisition cost been submitted? If yes, a copy should be stored in SharePoint.


________________________________________________

________________________________________________

Have all required programmatic reports been submitted? If yes, a copy should be stored in SharePoint.


________________________________________________

________________________________________________

Does the grant appear to be on track with deliverables stated in the contract*? *A deliverable is an activity to meet the scope, objectives and goals of a grant.


________________________________________________

________________________________________________

Does the Principal Investigator/Project Director have a file for retaining grant documents?


________________________________________________

________________________________________________


If no, communication on procedures and requirements will be sent to the department.

Comments and Recommendations:

Low and Medium Risk Grant Monitoring

As stated previously and defined in the Risk Assessment Map, all grants are reviewed, weighted,

scored and determined as low, medium or high risk of non-compliance in one or more of the

Risk Factors. Low and Medium Risk grants receive 1 or 2 status reviews, depending on their

risk level determination, besides Grant Compliance’s standard support provided to all grants, as

shown in Figure 1. Grant Compliance’s standard support is provided from beginning with start-

up and set-up of a grant, to management during the life of a grant, as well as Close-out at end of

life and required grant record retention periods.


c. Close-out status reviews (100% of Grants)

The Grant Compliance staff conducts a close-out status review with the PD/PI of the

grant in accordance with the end date of the funding period of the grant. The PD/PI

receives a Grant Close-out Status Review Email, Figure 12, with a copy to the FM,

notifying them when the Close-out Status Review has been initiated. This email

includes a link to the Close-out Status Review Form, Figure 13.

i. The Project Director/Principal Investigator (PD/PI) will complete the

following:

1) Respond to all applicable questions from the Close-out Status Review

Form sent in the email

2) Once all questions are answered and information filled out, the PD/PI

will click submit and the results will be sent to RDMC.

3) Should the PD/PI have any questions, the compliance staff member

assigned to the grant or the [email protected] email can be

contacted.

ii. Grant Compliance Staff will complete the following:

1) Review responses from the PD/PI and reply accordingly to see if the

grant is ready for close out, depending on the close requirements and

terminology of the grant. Such items may include:

a. All expenditures have posted to the Grant Account in Banner

b. No outstanding encumbrances

c. Time and Effort Documentation completed

d. All Programmatic and Fiscal Reports submitted

e. Contractual deliverables complete (or will be complete)

f. All equipment purchases tracked, tagged and logged

g. Amendments and extensions signed and filed, if applicable

2) All PD/PI responses to Close-out Status Reviews will copied into

SharePoint, as well as RDMC’s response.



Figure 12: Grant Close-out Status Review Email

Grant Close-out Status Review Email


The Department of Resource Development, Management and Compliance (RDMC) asks that

you complete the Grant Close-out Status Review Form, for

________________________________ Grant, _________ Fund Number which is closing out in

approximately _____ days. This form will help us in achieving a smooth close out of your

grant. This mandatory Grant Close-out Status Review Form is due Day, mo/dd/yyyy.

Please take a few minutes to fill out in the following link: Insert Correct Link and click the

“Submit Form” button on the bottom when completed.

If you have any questions about this form, please contact us at [email protected].

Thank you,


https://southtexascollege.formstack.com/forms/fy20_close_out_status_review_november



Figure 13: Close-Out Status Review Form (If the response is to the Purple highlighted question,

then additional questions “pop-out”. Questions with an * are required.)

Close-out Status Review Form

Date - Month and Year*

Principal Investigator (PI) Name*

Grant Name*

Grant Fund Number

Required Section: 1) Does your grant end within the next 90 days? * Yes ____No_____

1a) Did this grant fund non-consumable items? Yes ____No_______

Submit your inventory list of Grant Items.

1b) Did this grant fund personnel? Yes_______ No_______

Submit the names of all grant personnel.

1c) Will there be grant funds remaining at the end of the grant term? Yes__ No____

Approximately how much will be remaining at the end of the grant

term? _______ (required field)

Please explain: _____________________ (required field)

1d) When is the final report due? __________________ (required field)

Note: Per South Texas College procedure, all grant documents are subject to be retained as the

grant requires. Please refer to the Grant Document Retention Process.

Comments/Upload Section: Please comment and/or attach any document that will support your responses to this form.

Once submitted, the Close-out Status Review Form responses are reviewed by the department of

Grant Compliance and compared against documentation available in Banner, Progress & Fiscal

Reports to ensure the information is consistent (if inconsistencies exist, Grant Compliance will

work with the PD/PI, FM, Grant Accounting and potentially other areas who may assist in

resolving the conflict.

https://admin.southtexascollege.edu/grants/files/GDMC-009%20Grant%20Technical%20Assistance%20Form.pdf


Additional Post-Award Support from Grant Compliance

(Green and White boxes below the Compliance Reviews in the Grant & Contract Post-Award

Compliance Support Process Map, Figure 1. These items are accessed and used as support of the

various types of reviews used to monitor grants.

a. Program and Fiscal Reports

Grants usually require reports to be submitted including:

1. Program (the operational status of the Grant) or Fiscal (The

financial health and status of the grant) or both

2. Monthly, Quarterly or Annual reporting

3. Submitted electronically through email or a portal or another

method defined by the grantor

Program reports are submitted as draft to Compliance staff for review before

submission to the grantor. Fiscal report data is compiled by Grant Accounting staff,

sent to the PI and FM for approval with a copy to Grant Compliance staff and

submitted to the grantor by grant accounting in the method requested by the grantor.

b. Banner Financial

Before the latter part of FY-20 Grant Compliance had access to Management

Trackers produced by Grant Accounting. At the latter of FY-20 Grant Compliance

has access to BANNER “view-only” access for Grant fund status and history of the

financial standing of the Grant. Grant Compliance will first review a “summary”

(FGRITD) of the grant budget in Banner, which includes a snapshot of the original

grant budget, how it was broken down by budget category (Salaries, Benefits,

Operation (Materials/Supplies/Indirect), Travel, Tuition/Scholarships and Capital

Equipment), how much has been expended, encumbrances and any remaining

balance.

If any red flags are seen (over expenditure in one or more categories, encumbrances

not attributed to the grant,) the PD/PI and/or FM will be contacted.

o It is highly recommended the FM use their own reconciliation of the grant so

that they can reconcile on a monthly basis (a sample of a method of reconciling

is included in Figure 14, but please free to use any format that works for this

purpose).


Figure 14: Sample of Grant Reconciliation


c. Deliverables

Depending on the Grant and sometimes specified within the contract or agreement,

are the deliverables to meet or complete on your way to completing a contract.

Deliverables can be as quantifiable as:

“Complete training for 200 new jobs towards an Industrial Machinery

certification”

Or as vague as

“Transform face to face curriculum to online format”

In either form, it is critical to the success of a grant to meet and complete

deliverables. If deliverables are written and reported directly the grant, gran

Compliance staff will review them against the requirements of the contract. If the

deliverables are not directly written out stated by grantor, Grant Compliance will

review the progress report (or any data available) to compare against the contract

or grant agreement in which the purpose and objectives of the grant are stated.

d. Time & Effort Documentation

Time and Effort reporting is the way we can measure and track the amount of time

and effort spent using grant funds to work on or complete a grant project. The Time

and Effort Section of the Grant Management Handbook. This section of discusses

different types of Time & Effort reporting, in which scenarios to use what forms

and how to process them for approval and submission.

e. Inventory

Capital Equipment purchased with grant funds must be tracked to now when

it was purchased and what is the current location of the item and what and

what the status is of the equipment. Figure 14 is a sample of what one can

look like (but feel free to make your own.


Figure 15: Sample Grant Inventory

f. Record Retention

Most grants specify within the Terms and Conditions of the grant agreement or

within the grant award itself or in the case of federally funded grants, with the

Code of Federal Regulations (CFR) 200.333, what the grantee’s responsibility is

in terms of required length of time to retain grant documents. If it is not stated

anywhere or not clear, Grant Compliance staff will contact the funding agency or

the grantor, prior to the Grant Initiation Meeting, to find out.

Per Figure 5, Grant Initiation Checklist, the record retention period defined by the

grantor will be discussed. Further information, including a detailed Grant

Retention Process Map, can be found in the Record Retention section of the Grant

Management Handbook.

III. Other Types of Award Support

Other types of award support provided by Grant Compliance not inherent to the primary

process but may occur as needed.

a. Develop Grant Plan

Grant Compliance may assist the PD/PI and the FM break down the all aspects of a grant

from deliverables to reporting to a timeline to include all the necessary components to

complete the deliverable to include: staff, supplies, PR & Marketing, Research and

Analytical Services (RAS), and Institutional Effectiveness & Assessment (IEA).


b. Negotiations

The Department of Resource Development, Management and Compliance provides

technical support and as the primary point of contact for grants, schedules negotiations, as

needed. Entering into negotiations post-award can occur when communication is initiated

by the grantor, the college’s grant compliance officer, or the Principal Investigator (PI) or

Project Director for a grant who sees a need to discuss specific components (deliverables,

budget, timeline, etc.) of a grant prior to the college entering into a contractual agreement

with the funding agency.

c. Amendments

Any change/modification to the budget, scope of work, goals, and/or key personnel

requires prior approval from the Grantor (funding agency). Grant Compliance staff will

work with the PD/PI to facilitate the development of the proposed changes prior to any

revisions being submitted to the Grantor and to ensure Grantor’s provisions and deadlines

are met.

Once the Grantor approves any budget modifications, Grant Compliance will work with

the PD/PI and FM to reflect the changes on the banner system by completing an amendment

to the Request for Grant Budget form, BO-4200 (See Figure 2).

d. Contract/Agreement Review

Grant Compliance assists in the review of subaward contracts, statements of work, and

Memorandums of Understanding as they relate to a Grant to confirm correctness and

compliance with the Grant.

e. Guidance in Grant Management and Compliance

Grant Compliance is available to the PD/PI and FM via email and phone to answer

questions and provide guidance as it applies to the Grant to include: deliverables, specifics

of reporting requirements, PR & Marketing, RAS/IEA, internal and external amendments,

financial reports and compliance with the specifics of the Grant.

f. Customized Trainings

Upon request a PD/PI and/or FM may request customized training in addition to the Annual

Grant Management training provided by Grant Compliance. The PD/PI and/or FM may

request the customized training for their Grant for guidance developing a plan for the Grant,

process and required documentation for staff compensated from the Grant to include Time

and Effort documentation requirements and review of financial information and Inventory.

g. Development of Program Reporting

Most grants require programmatic reports (interim, annual, and/or ad hoc). The Grant

PD/PI is responsible for compiling and submitting programmatic reports. The PD/PI should

submit the report to Grant Compliance for review before submission of the reports for

review and feedback to assist in the development of the report.


h. Development of Fiscal Reporting

Most grants require fiscal reports (interim, annual, and/or ad hoc). Grant Accounting,

Business Office, is responsible for compiling and most often submitting fiscal reports.

Grant Accounting should submit the report to the PD/PI and the FM for approval with a

copy to Grant Compliance for review before the report is submitted to verify all items

reported are correct and request corrective action before submission, if possible.

i. Subrecipient Monitoring

South Texas College is responsible for monitoring the programmatic and financial

activities of its subrecipients in order to ensure compliance with appropriate use of funds,

as well as timely and effective implementation of the subaward by the subrecipient or

subawardee. The Project Director/Principal Investigator of a grant is responsible for

engaging in monitoring subrecipients and works in collaboration with staff in the

Department of Resource Development, Management and Compliance that provide post-

award technical assistance to help ensure deliverables are met and to review and assist in

responding to any deficiencies or problems related to performance reports, financial reports

in Management Tracker, or subaward activity. More on this can be found in the section

entitled Subrecipient Monitoring in the Grant Management Handbook

j. Audit Preparation

Grant Compliance participates in the preparing for Grant related audits, Desk Reviews, and

Site Visits. Grant Compliance assists the PD/PI, FM, and Grant Accounting to verify

documentation for correctness and completeness and assists with corrective action, if

necessary.

Grant & Contract Post-Award Compliance Support · 2020. 8. 14. · Assessment. Ongoing post-award...

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