NWESD 189 Federal Grant Program Manager/Director

Summary of Common Federal Requirements/Assurances Form

Fiscal Use Only:	Date Received: Date Reviewed:	By Fiscal Staff: By Fiscal Staff:
Please return completed form in to Fiscal within ten (10) days from receiving notice of the grant award.
SECTION I: General Information
Federal Grant Name:
Federal Grantor Agency:	Indirect Cost Rate %:
CFDA # (XX.XXX):	iGrant ID #:	Award $:
NWESD 189 Program # (PPSS):	Funding Period:	thru
Assigned to NWESD 189 Program Manager:
Is grant passed thru a state agency (such as OSPI) rather than received directly from the federal granting agency?	Yes No
If Yes, State Agency Name:	and State Grant #
SECTION II: Types of Compliance Requirements per OMB Circular A-133 Compliance Supplement
The grant program manager/director is responsible for ensuring his/her grant meets all federal requirements and maintaining the related documentation. The following list is intended to aid the program manager/director in determining requirements, but should not be considered an all inclusive list. Additional information regarding grant requirements is available on the Intranet at https://intranet.nwesd.org/Departments/Fiscal/Grants.
Activities Allowed or Unallowed
Do you understand you are responsible for knowing and assuring compliance related to:	Yes	No
1.	The types of activities allowed by the grant?
2.	The types of activities prohibited by the grant?
3.	Obtaining approval from the grantor for any changes to the scope of the project?
Allowable Costs/Cost Principles (OMB Circular A-87 and EDGAR 80.22)
Do you understand you are responsible for knowing and assuring compliance related to:	Yes	No
1.	The “Basic Guidelines” for determining whether a cost is allowable under federal awards? (see OMB Circular A-87, Attachment A, Section C)
2.	The documentation requirements necessary to substantiate all costs charged to the program?
3.	The allowability or unallowability of certain items/costs pursuant to OMB Circular A-87 Attachment B’s Selected Items of Cost?
4.	Documenting any NWESD 189 staff salaries and benefits charged to the grant/program with Time and Effort records (example provided on the Intranet) to ensure appropriate charges?
5.	Any terms, conditions, limitations or exclusions specific to this federal award?
6.	Assuring grant expenditures are consistent with policies, regulations and procedures that apply uniformly to both federal awards and other NWESD 189 programs?
7.	Assuring grant expenditures are not included as a cost within any other NWESD 189 programs? (e.g., each cost may only be assigned to one program)
8.	Assuring grant costs are reasonable and prudent? (e.g. meets market prices, considered ordinary and necessary)
Cash Management
Yes	No
Will grants funds be received in advance of expenditures (draw downs)?
If No (indicating grant funds will be requested as reimbursements after expenditures have been made), this section is not applicable.
If Yes, do you understand you are responsible for:
1.	Minimizing the time elapsing between the advance and expense?
2.	Returning to the federal grantor interest income on any advanced amount in excess of $100? (The Fiscal Department will assist you determine any amount that may need to be remitted)
3.	Monitoring any grant funds passed through to other entities as sub-recipients, to ensure they conform to the same draw down standards?
4.	Maintaining appropriate documentation?
Davis-Bacon Act
Yes	No
Will there be any construction projects (construction, alteration or repair - including painting and decorating - of public buildings or public works) costing more than $2,000?
If No, this section is not applicable.
If Yes, do you understand you are responsible for:
1.	Including a clause in any construction contract requiring the contractor/subcontractor(s) to comply with the requirements of the Davis-Bacon Act and applicable regulations?
2.	Assuring the contractor/subcontractor(s) pay prevailing wages as defined by the Davis Bacon Act? (which may differ from Washington State prevailing wage requirements)
3.	Requiring the contractor/subcontractor(s) to submit weekly certified payroll statements which you review and maintain for prevailing wage compliance and documentation?
Eligibility
Yes	No
Will individuals, groups of individuals and sub-recipients need to meet certain criteria (for example, qualify as low-income) to participate in the program?
If No, this section is not applicable. If Yes, briefly describe the criteria
If Yes, do you understand you are responsible for:
1.	Assuring the individuals, groups of individuals and sub-recipients that participate in the grant program meet all criteria established in the grant?
2.	Maintaining verifiable documentation to confirm the selected individuals, groups of individuals and sub-recipients met the eligibility requirements?
Equipment and Real Property Management (EDGAR CFR 80.32 & 80.31)
Yes	No
1.	Will any piece of equipment costing $5,000 or more be purchased with grant funds?
If No, this portion of the section is not applicable.
If Yes, do you understand you are responsible for:
a.	Assuring any equipment is used in the program for which it was acquired, or when appropriate, other programs supported with federal funds?
b.	Assuring any equipment may not be used in competition with private companies to earn program income?
c.	Assuring any equipment is inventoried and noted as purchased with federal funds?
d.	Assuring that any equipment no longer needed for the grant program with a fair market value greater than $5,000, is sold with the federal grantor having a right to a proportionate (percentage) amount of the current fair market value?
e.	Determining and documenting a compelling reason for any purchase of major equipment near the end of the grant award related to the purpose of the grant?
2.	Will any real property be purchased with grant funds?
If No, this portion of the section is not applicable.
If Yes, work with the Asst. Superintendent of Finance and Compliance to determine any requirements.
Matching, Level of Effort, Earmarking (EDGAR CFR 80.24)
Yes	No
Does the grant require matching? If Yes, what is the matching requirement?
Does the grant require level of effort? If Yes, what is the level of effort requirement?
Does the grant require earmarking? If Yes, what is the earmarking requirement?
If No to ALL three questions, this section is not applicable.
If Yes to ANY of the three questions, do you understand you are responsible for:
1.	Identifying and monitoring compliance with grant requirements?
2.	Maintaining appropriate documentation to verify compliance with these requirements that validate source, value, and compliance with allowable costs/cost principles?
3.	Assuring these requirements are not met with costs borne by or used as match for another federal grant?
4.	Assuring the match provided is consistent with description in the approved grant award?
5.	Understanding and complying with the requirements of certain types of match, including but not limited to, third party in-kind and donated time?
Period of Availability of Federal Funds
1.	Do you understand you are responsible for:	Yes	No
a.	Assuring that all charges to the grant are “obligated” (as defined by EDGAR CFR 75.707 & 76.707) within the funding period and paid within ninety (90) days after the end of the funding period?
b.	Securing specific authorization of any pre-award costs by the federal grantor?
2.	Is the grant a federal award received via a State agency and the funding determined by the State on the basis of a formula?
If Yes, do you understand the date the application was submitted to the State in the “substantially approval” form is likely the date that obligations may begin?
Procurement and Suspension and Debarment
Do you understand you are responsible for:
1.	Assuring all purchases comply with the federal competitive procurement requirements outlined by NWESD 189 Policy 6220 and described with various federal funding scenarios on the NWESD 189 Intranet?
2.	Assuring compliance with Suspension and Debarment requirements for any federally funded transaction (or series of payments to the same vendor) expected to exceed $25,000 (NWESD 189 typically collects a certification or adds a clause to the contract with the vendor)?
Program Income
Yes	No
Does the grant allow the generation of program income (income generated by the expenditure of grant funds)?
If No, this section is not applicable.
If Yes, do you understand you are responsible for:
1.	Determining whether the grant specifically allows the program income to be added to the grant budget or deducted from outlays or used to meet matching requirements (unless specifically allowed, the program income must be used to reduce the federal funds committed to the project)?
2.	Assuring program income is correctly identified, recorded and used in accordance with grant requirements?
Real Property Acquisition/Relocation Assistance	Yes	No
Does the grant provide for real property acquisition?
If No, this section is not applicable.
If Yes, please work with the Assistant Superintendent of Finance and Compliance to ensure compliance.
Reporting
Does the grant have requirements for:	Yes	No
1.	Financial reports?
2.	Performance reports?
3.	Special Reports?
If Yes, for any of the above, have you identified the reports and their deadlines?
If No, meet with Assistant Superintendent of Finance and Compliance, as reports are commonly expected.
Sub-recipient Monitoring
Yes	No
Does the grant allow sub-awards to sub-recipients?
If No, this section is not applicable.
If Yes, will sub-awards be made?
If No, this section is not applicable.
If Yes, do you understand you are responsible for:
1.	Providing sub-recipient(s), prior to award, written federal information? (CFDA title and #, award name, name of federal agency and compliance requirements)
2.	Monitoring any sub-recipient(s) use of the federal funds for compliance with grant requirements, including documentation for audit purposes?
3.	Ensuring any sub-recipient expending $500,000 or more in federal funds during its fiscal year has an audit report meeting federal requirements issued within nine (9) months after the end of its fiscal year?
4.	Working with the Assistant Superintendent of Finance and Compliance if the sub-recipient received a federal audit finding to ensure a management decision is issued within six (6) months after NWESD 189’s receipt of the report?
Special Tests and Provisions
I understand special tests and provisions are unique to each federal program and I must review the grant contract or agreement and referenced laws and regulations to identify the requirements that I must comply with.
Grant Program Manager’s Signature	Date
I understand the receipt of federal funds is a responsibility that requires diligent stewardship. Accountability for the use of the funds is an ongoing activity that lasts the entire life of the award. Therefore, it is imperative I understand all of the grant requirements. If there are any requirements that I do not understand, I will meet with the Assistant Superintendent of Finance and Compliance to assure my understanding and knowledge. I also understand, to support me in my compliance efforts, Fiscal Department staff may review and offer advice in regard to the records for any of the above requirements at any time. I further understand that to increase my comfort level, I may request Fiscal Department review the records related to my grant
Grant Program Manager’s Signature	Date
Fiscal Use Only:	Date Reviewed:	By Asst Supt:
Original to Fiscal Copy retained by Grant Program Manager