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.

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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.