Written Procedure Requirements for Grant Recipients

Grant recipients are required to have four types of written procedure:

• Payment methods
• Procedures for determining the allowability of costs
• Standards of conduct
• Procedures for procurement transactions

Use our checklist to review your written procedures or download your own copy of our written procedure requirements.

Payment Methods Checklist

• Do you get funds advanced to your or are you on reimbursement?
• Minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity
• Meet the standards for fund control and accountability in financial management system

Procedures for Determining the Allowability of Costs

• Are the costs necessary and reasonable for the performance of the Federal award and be allocable to the award?
• Are the costs limited or excluded by the Federal Cost Principles?
• Are the costs consistent with policies and procedures that are applied uniformly to both federally-financed and other activities of the non-Federal entity.
• Are the costs treated consistently between direct and indirect costs?
• Are the costs included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period?
• Are the costs adequately documented?
• Consistent with the selected items of cost in 2 CFR Part 200?

Standards of Conduct Checklist

• Governs both employees working on Federal awards and administering procurement contracts
• Covers employees, officers, and agents
• Includes members of immediate family, partners, including employers and potential employers
• Can’t solicit or accept gratuities, favors, or items of monetary value
• Non-Federal entities may set standards define what constitutes the nominal value of gift or a non-substantial financial interest

If determined that real or apparent conflict of interest involved:

• Can’t participate in selection, award or administration of contract
• Must include disciplinary actions for violation of standards
• Covers both individuals and organizations
• Recipients must be alert to Organizational conflicts of interest
• Must have method to identify and communicate potential risk

Procedures for Procurement Transactions

Items to include in the Procurement Records:

• Description of Goods and Services
• Clear, accurate description that includes technical requirements
• Don’t unduly restrict competition

Requirements

• Technical requirements in terms of the “functions to be performed”
• What requirements the bidder is expected to fulfill?
• What factors will be used to evaluate the bids Written Procedure Requirements?

Selection basis for contractor

• Cost or Price basis for goods and services
• Cost or price analysis
• Excluded Parties review

If applicable, include:

• Lease vs. buy decision
• Which option is the most economical and practical?

Download your own copy of our written procedures checklist. Share with your colleagues! And check out our editable Grant Management Templates

Ready to Improve Your Grant Management?

How about you? Would you like to be a better grant manager? We have another grant management training seminar coming soon. Click here to get all the details! Hope to see you there! Author: Lucy Morgan CPA, MBA CEO, Compliance Warrior Author of “Decoding Grant Management-The Ultimate Success Guide to the Federal Grant Regulations in 2 CFR Part 200”  The 2nd Edition is now available on Amazon in Paperback and Kindle versions.