HomeMy Public PortalAbout2320.1 - Business and Financial Services - Financial Reporting - Management and Administration of Grants and Other Types of Financial AssistanceOffice of Business and Financial Services
Grants and Other Types of Financial Assistance Section 2320.1
Policies and Procedures Manual Page 1
2320.1: Management and Administration of
Grants and Other Types of Financial
Assistance
Objective:
The purpose of these policies and procedures is to develop, implement and
maintain effective grant oversight and coordination for the City of Orlando,
(the “City”), thereby increasing grant-related revenue, enhancing
compliance, limiting the City’s exposure to grant-related legal liability, and
improving the efficiency, effectiveness, and impact of programs and
services funded through grants and other types of financial assistance.
Authority:
This policy amended by City Council April 22, 2024, Item A-01.
Direction:
The Chief Financial Officer, as an appointed official, serves at the pleasure
of, and receives direction from the Mayor.
Functions:
1. Introduction
City government, as an institution, has multiple partners, including
citizens, taxpayers, businesses, visitors, employees, and other
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governments. As a major economic institution and service provider in
the region, it is important that the City strengthen relationships with its
partners by adopting clear and comprehensive policies and
procedures.
Grants and other types of financial assistance received by the City
support important programs and services the City provides to the
community. These funds allow the City to fund existing services,
introduce new initiatives, advance technological capacity, subsidize
programmatic staffing, and support a variety of activities and
programs, including, but not limited to homeland security, economic
development, social services, public safety, recreation, infrastructure
improvement and maintenance.
Since grants and other types of financial assistance allow the City to
leverage local public funds to extend and enhance the services it
offers to the community, the impact of these funds on the community
is significant. Grants administration and management is an integral,
critical, and important function. Adopting an effective set of policies
and procedures is a key element in maintaining the City’s ability to
manage grants with integrity.
These policies and procedures are intended to encourage prudent
financial stewardship and foster public trust through redundancies
and a rigorous adherence to ethical and professional standards
associated with grant-related activity. Adherence to these policies
and procedures will promote efficiency, enhance transparency and
accountability, and create a strategic approach to funding
opportunities while placing the City in a more competitive position to
secure grant funds.
If specific direction relative to grants cannot be located within this
policy, please refer to the grant directives, and other applicable City
Policies & Procedures.
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2. Grants and Other Types of Financial Assistance covered by this
Policy
A grant is a type of financial assistance (in cash or kind) bestowed by
a government or other organization (called the grantor) for specified
purposes to an eligible recipient (called the grantee). Grants are
conditional upon certain qualifications and are bound by some type of
contractual obligation as to the use, maintenance of specified
standards, or a proportional contribution (cost share or match) by the
grantee or other grantor(s).
In addition to grants, there are other types of financial assistance the
City receives which may not include the term “grant” but are also
covered by this policy. The City considers the term grant to include,
but not be limited to contracts or agreements that fall under the
purview of 2 CFR 200 - Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards, also known
as the Uniform Guidance. This circular incorporates guidance
previously found in OMB Circulars A-87, A-102, and A-133. In
addition, the term grant includes state contracts or agreements
subject to the Florida Single Audit Act, Rules of the Department of
Financial Services.
Donations or charitable contributions are not covered by this policy
and should follow the City’s Policies & Procedures for cash
collections.
Grants and other types of financial assistance that are awarded to the
City are legal contracts and should also follow applicable Policies &
Procedures of the City Attorney’s Office.
The following list and definitions represent several types of grants
and other types of assistance typically received by the City. However,
this list is not comprehensive.
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a. Block Grant – a broad intergovernmental transfer of funds or
other assets by the U.S. federal government to state or local
governments for specific activities determined largely at the
recipient’s discretion. Block grants are distributed according to
legal formulas defining broad functional areas such as housing,
health, income security, education, transportation, etc.
b. Competitive (Discretionary) Grant – an award of financial
assistance in the form of funds or other assets, by the Federal
Government to an eligible grantee, usually made on the basis
of a competitive review process.
c. Continuation of Any Grant Type – a continuation grant provides
additional funding and/or time beyond the initial grant award
budget and/or period.
d. Conditional Grant – a conditional grant involves one grantor
seeking the involvement of others by making their grant
conditional upon the remainder of the cost being funded from
another source.
e. Cooperative Agreement – a type of Federal assistance
awarded by a Federal agency when it anticipates having
substantial involvement with the grantee during the
performance of a funded project.
f. Earmark – refers to a provision in legislation requiring that a
portion of a certain source of revenue be designated for specific
projects, usually at the request of a legislator. Typically, the City
submits requests for projects to state and federal legislators
who seek to obtain funds for those requests, usually to be spent
in the district the legislator represents. Earmarking bypasses
the normal procedure by which revenues are pooled in a
general fund and then allocated among various government
spending programs as opposed to a specific project.
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g. Formula Grant – a grant that a Federal agency is directed by
Congress to make to grantees, for which the amount is
established by a formula based on criteria written into the
legislation and program regulations. This funding is directly
awarded and administered in the Federal agency’s program
offices.
h. Joint Participation Agreement (JPA) – A JPA is an agreement
between an agency, such as the City, and a Federal or State
agency that establishes a joint participation project. A JPA
defines the scope, budget, funding source, responsibilities, and
any legal provision necessary for the project.
i. Local Agency Program (LAP) Agreement – A funding
agreement between the Florida Department of Transportation
(FDOT) and a local agency for use of Federal Highway
Administration (FHWA) funds to develop, design, acquire right-
of-way, and construct transportation facilities, and to reimburse
these governmental agencies for services provided to the
traveling public.
j. Loan – a written agreement between the Federal or State
Government and the City that outlines terms and conditions
associated with a financing transaction. The agreement may
indicate the obligations of each party, reporting requirements,
possible sanctions for lack of borrower performance, and any
restrictions placed on the borrower. Loans other than Federal or
State are not covered by this policy.
k. Loan Guarantee – a program bound by a Federal or State
Government statute to pay part or all of a loan’s principal and
interest to a lender or the holder of a security in the event of
borrower default. Loan Guarantees other than Federal or State
are not covered by this policy.
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l. Pass-Thru of Any Grant Type – a grant originating from one
grantor–generally the federal government–but passed through
another grantor–typically the State of Florida–to the grantee.
m. Reimbursement Program – a grant in which the grantee is
reimbursed for eligible expenditures incurred, as specified in
the terms of the grant agreement.
n. Transportation Regional Incentive Program (TRIP) Agreement
– state or municipal funds available throughout Florida to
provide incentives for local governments and the private sector
to help pay for critically needed projects that benefit regional
travel and commerce.
o. County Grant – a grant made by a County Government.
p. State Grant – a grant made by the State of Florida, which has a
corresponding Catalog of State Financial Assistance (CSFA)
number. Consult the online catalog for covered classes of
financial assistance.
q. Federal Grant – a grant made by the Federal Government,
which has a corresponding Assistance Listing (formerly called
Catalog of Federal Domestic Assistance (CFDA) number).
Consult the online catalog for types of financial and non-
financial assistance.
r. Foundation Grant – a grant made by a philanthropic foundation.
s. Corporate Grant – a grant made by a corporate foundation.
t. Workshare Agreement – proceeds received and expended
under an Equitable Share Agreement. Please also reference
the Orlando Police Department Policy and Procedure, Law
Enforcement/Federal Asset Sharing Trust Funds.
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3. Grants Management System
The Grants Management System is integrated within the City’s
financial system and is used to assist in the tracking and
management of grants applied for and awarded to the City, improve
coordination, enhance oversight and provide reporting of the City’s
grants. It is managed by the Chief Financial Officer, or their designee.
4. Grant Application Process
a. Departmental Assessment – Prior to applying for a grant, a
department should assess its capacity to apply for and manage
the grant in question. City departments, divisions and offices
(“departments”) that seek and utilize grant funds are
responsible for all aspects of applying for and managing grants
including: planning for grant acquisition; preparation and
submission of grant proposals; grant writing; preparing City
Council Agenda items; preparing budget revision requests to
accept grant funds; grant orientation and review; managing
grant programs and projects; preparing and submitting reports
to grantors; managing and monitoring subrecipients whenever
applicable; and properly closing out grant projects as detailed in
this policy and the grant agreement or award letter that
delineates the terms and conditions of the grant.
b. Approval Process – Departments interested in applying for a
grant must first seek approval to apply through submission of
the Grants & Financial Assistance Approval Form which is
routed through the Grants Management System to the OBFS
Grants Unit, Controller, Department Director, Budget Division,
City Attorney’s Office, the department’s authorized signer and
the CFO, or their designee(s). The approval of the Department
Director, or designee, signifies that they approve pursuit of the
grant by the department designated individual hereto known
as the “Grant Coordinator” or “Grant Manager” or “Principal
Investigator” as noted on the Grants & Financial Assistance
Approval Form and that department staff have carefully
reviewed the grantor guidelines
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and adequately disclosed information on the form in
accordance with Directive ACL-D-2320.1 issued by the CFO.
The department’s authorized signers include the Chief
Administrative Officer, for City operating and other departments,
divisions, or offices that report to the CAO; Chief Financial
Officer, for the Office of Business and Financial Services; Chief
of Staff, for Executive Offices; City Attorney, for City Attorney’s
Office; Chief Venues Officer, for Venues; and the Mayor.
Approval of the Grants & Financial Assistance Approval Form
in the Grants Management System signifies that the Grant
Coordinator or Grant Manager is the designated authority to
submit electronic grant applications on behalf of the
Department.
c. Competing Grant Applications – The CAO or designee, in
consultation with the CFO, shall be the final arbiter of which
department shall submit the application when internal
competition for a grant application cannot otherwise be
resolved, or to obtain approval to submit multiple applications to
a grantor.
d. Requesting Letters of Support from Other Governments or
Elected Officials – When requesting a letter of support for a City
grant application from another government agency, local
government, intergovernmental organization, or local, state, or
federal elected or appointed official (excluding Orlando City
Commissioners), the request should be forwarded to the
Director of Intergovernmental Relations for submission to the
appropriate agency or official.
e. City Attorney’s Office Review – Prior to application submission,
the City Attorney’s Office shall conduct a legal review of grant
applications.
f. City Council Approval – When City Council approval is required
for the submission of an application, the Department shall be
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responsible for preparing the agenda item. City Council
approval of an application is required when:
i. Conditions, certifications and assurances contained in the
grant application become binding, or are likely to become
binding if the grantor funds the application;
ii. Funding has been earmarked or set aside through a
similar process such as a local or regional task force,
board or committee recommendation, where the
application process is generally a formality used to enter
into a grant agreement that will ultimately bind the City
upon grantor acceptance;
iii. City Council approval is required by the grantor, City
Code, or City Policies & Procedures at the time of
submission; or
iv. Recommended by the Assistant Controller and approved
by the Department’s Authorized Signatory.
v. The Mayor or chief executive’s signature is required on a
grant application, except in time sensitive cases, as noted
in section g;
g. Mayor’s Signature – In time sensitive cases, to meet a grant
application or grant agreement deadline, where the next City
Council meeting is after the grantor’s deadline, the Mayor has
authority to sign grant applications.
h. Delegation of Authority – To enhance efficiency or address
circumstances that warrant delegation, authority over a specific
grant project or program, grant application, or grant agreement
may be delegated to the Department Director through the
approval of the Grants & Financial Assistance Approval Form in
the Grants Management System. A copy of this policy may be
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provided to a grantor whenever a request is made for a
signature other than those specified in 4(b) of this policy.
i. Federal and State Grants Systems – The Office of Business
and Financial Services has the sole responsibility of managing
and renewing the City of Orlando’s registration with the U.S.
Government’s System for Award Management (SAM) and for
managing user access to federal and state grants systems that
are used by multiple departments to apply for grants.
5. Grant Award Acceptance
a. Departmental Role – Departments carry a significant legal and
ethical responsibility when accepting grant funding and are
responsible for thoroughly reviewing and ensuring it can comply
with the terms and conditions of a grant agreement and other
award documents before accepting an award.
b. City Attorney’s Office Review – All grant agreements or
contracts shall be reviewed by the City Attorney’s Office prior to
City Council consideration.
c. City Council Acceptance – A department that has been
awarded grant funds shall prepare a council agenda item for
City Council to accept the grant and approve the terms and
conditions. Grant agreements are legal contracts and are
subject to all applicable City Policies & Procedures and City
Code, including City Council Approval for all contracts and
agreements (see City’s Policy & Procedure 161.3).
d. Execution of Award – The Mayor, or designee, signs grant
agreements which have been approved by City Council and
delivered for signature by the City Clerk. In time sensitive
cases, where the next City Council meeting is after the
grantor’s deadline, the Mayor has authority to sign grant
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agreements. Ratification of the grant agreement shall be
required by City Council.
e. Award Activation – The department shall forward the executed
grant agreement signed by the City’s authorized signatory and
the grantor to the Citywide Grants Manager who will establish a
grant in the appropriate fund using the Grants Management
system. The department shall prepare a budget amendment to
be scheduled on the next available Budget Review Committee
meeting.
6. Managing Awards
It is the Department’s responsibility to ensure that the project, and/or
activities, and objectives associated with a grant are accomplished
while adhering to and complying with the terms and conditions
prescribed by the grantor. Failure to do so increases the City's
exposure to legal liability and potentially compromises current and
future grant funding.
Violations for mismanaging grant funds can result in a range of
penalties, including suspension of future funds from the grantor,
return of funds associated with the award, including those already
expended, and civil and/or criminal penalties.
Grant requirements should be read and interpreted in conjunction
with all other grant administrative requirements. When there is more
than one consistent grant requirement, the more specific requirement
should govern. When grant requirements are inconsistent, the
following Order of Precedence should be followed unless there is no
built-in waiver of precedence, deference to other requirements or
specified terms and conditions of the award.
a. Order of Precedence
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The order of precedence for grants and other types of financial
assistance is as follows: 1) Federal Statutes 2) Government
Directives (such as Presidential Executive Orders and 2 CFR
200) 3) Administrative Regulations 4) Program Regulations 5)
Award Terms & Conditions 6) City Policies & Procedures.
b. Allowable Costs
Grant Managers are ultimately responsible for adhering to the
requirements and conditions of the approved grant agreement
and ensuring that only allowable and eligible expenditures are
incurred. This means that they are allowable, allocable,
necessary and reasonable and provide a direct benefit to the
grant-funded project.
c. Revenue
i. All departments receiving grant funds should follow the
City’s Policies & Procedures for cash collections. Grant
funds should be managed and maintained as established
in the award letter, grant agreement, contract, special
conditions, or other document generated by the federal
government, state government or granting entity.
ii. Grants and external awards must be reported to the
Controller, or designee, for the purpose of inclusion on
the annual Schedule of Expenditures of Federal Awards
and State Financial Assistance (SEFA) as outlined in
Section L.2, Accounting and Reporting of Grants. Grants
and other types of financial assistance required to be
included (SEFA) are listed in the Assistance Listings
(formerly called Catalog of Federal Domestic Assistance
or CFDA) or the Catalog of State Financial Assistance
(CSFA), both of which can be accessed via the internet.
d. Budget
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i. Modifications to a grant’s budget that alters the grant
amount or moves funds from one budget line item to
another must adhere to City Policies & Procedures for
budget modifications and grantor requirements.
ii. All grant and any related matching fund revenues and
expenditures shall be recorded in the appropriate grant
and the accompanying matching grant in the Grant
Management System. Any revenues or expenditures that
occur in another cost center that are used as a match
shall require a journal entry (JE) to record the revenues or
expenditures in the appropriate matching grant with a
detailed explanation, including original general ledger
date and other relevant information. Grant funds received
shall not be recorded against an expenditure account
unless a previously purchased item was returned.
e. Supplanting
Grant funds awarded to the City may not be used to supplant an
existing expense so that current funds can be diverted to
another use, unless such use of grant funds is explicitly
identified as allowable in writing by the grantor.
f. Procurement
i. All procurement activity associated with federal and state
grant-funded projects shall follow Directive, PUR-D-1301
Federal and State Grant Procurement; and other
applicable City, State, and Federal procurement
guidelines.
ii. Moreover, any department that applies for and utilizes
grant funds is also responsible for supplying the
Procurement Division with any and all additional grant
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requirements with respect to the purchase of those grant-
funded goods and services when completing a
purchasing requisition. These requirements shall include
not only the detailed descriptions, specifications, terms,
and conditions of the goods and services, but also all
other grant mandates and compliance requirements
needed in the procurement process.
iii. Prior to the procurement of any contract, which will be
paid, in part or in whole with state or federal funds, the
City department requesting the procurement will provide
for a review of the proposed procurement to avoid
purchase of unnecessary or duplicative items.
Consideration will be given to consolidating or breaking
out procurements to obtain a more economical purchase.
Where appropriate, an analysis will be made of lease
versus purchase alternatives, and any other appropriate
analysis to determine the most financially beneficial
option.
g. Asset Management
Asset Management ensures requirements for the acquisition,
supervision, safeguard, transfer and disposal of tangible
personal property are met. All property and equipment
(including information technology systems) having a useful life
of more than one year and a per-unit acquisition cost which
equals or exceeds $5,000 acquired or received through grant
funds are tagged and included in the Asset Management
inventory. As required by the grant or upon request of the
grantee department, attractive assets of lesser value may also
be tagged. Refer to the definition of property and equipment
acquired through grants at 2 CFR 200 (Uniform Guidance).
h. Subawards
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A Department may decide that it’s in the City’s interest to
subaward all or part of a grant to one or more eligible
organizations. The Department is responsible for conducting a
risk assessment of any prospective subrecipient to ensure that
the organization has not been debarred or excluded, is eligible
to receive a subaward, and has the financial and operational
capacity to perform the scope of work. A formal subrecipient
agreement shall be prepared by the City Attorney’s office and
approved by City Council. The Grant Manager is responsible for
monitoring the subrecipient’s performance and compliance with
all grant terms. Grant Managers are responsible for ensuring
that all subawards and contracts are only awarded to
responsible contractors and that federal funds are not awarded
to a party listed on the government-wide Excluded Parties List
in the System for Award Management (SAM) and that state
funds are not awarded to a party listed on the State of Florida’s
suspended or debarred list. Grant Managers are responsible for
retaining documentation in the grant file reflecting that vendors
or subrecipients are not suspended or debarred from state or
federal contracting opportunities.
i. Terminating an Award
In the event a grant agreement needs to be terminated after an
award has been made to the City, but before the period of
performance ends, the Department Director from the recipient
department must prepare a letter to the granting entity declining
the award. A draft of the letter must be provided to the Assistant
Controller, who shall route it to the Chief Financial Officer and
the Department’s Authorized Signatory as defined in Section
4(b), Authorized Signature Authority, for approval before the
letter and funding is returned to the granting entity. The letter
should clearly articulate the specific reason(s) the award is
being returned. If a budget has been established in the City’s
financial system, the Department shall also initiate grant
closeout and receive approval to closeout with the City and the
grantor in accordance with Directive, ACL-D-2320.1 issued by
the CFO.
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j. Return of Grant Funds
The Controller, or designee, must be notified in the event that
grant funds need to be returned to the grantor for any reason.
The Department Director from the recipient department must
prepare a letter to the grantor and provide a draft to the
Assistant Controller, for review and routing to the Chief
Financial Officer and the Department’s Authorized Signatory
as defined in Section 4(b), Authorized Signature Authority, for
approval prior to sending the letter and returning the funding
to the grantor. The letter should express the City’s regret in
returning the funding and clearly articulate the specific
reason(s) funding is being returned.
k. Site Visits and Audits
In the event that a grantor, auditor, or inspector requests a site
visit and/or audit, the Grant Manager must notify their
department’s GOC Liaison and the Assistant Controller with the
date and time of the site visit and/or audit. The Assistant
Controller will determine whether attendance by Office of
Business and Financial Services’ Grants Unit is necessary.
7. Grant Oversight and Monitoring
The grant oversight and monitoring process has four components: (1)
Grant Orientation and Review; (2) Accounting and Reporting of
Grants; (3) Expenditure Monitoring; and (4) Submitting Grant Reports
to Grantor.
a. Grant Orientation and Review
The purpose of this policy is to ensure the Grant Manager,
Grants Oversight Committee Liaison, the Department’s Fiscal
Manager, and Grant Accountant are familiar with the terms of
the award, timelines, and grantor due dates at the inception of
the grant period of performance.
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The Grant Manager shall review the project plan, timeline,
key deliverables, allowable expenses, compliance
requirements and due dates outlined in the terms of the
grant agreement with the Department’s Grants Oversight
Committee Liaison, Fiscal Manager, and Grant Accountant
at the inception of the grant period of performance.
b. Accounting and Reporting of Grants
All grants received by the City, either directly, with the City as a
recipient, or indirectly with the City as a sub-recipient, must be
reported to the Controller, or designee, in the Office of Business
and Financial Services. Notification shall be provided when the
grant is awarded, modified, amended, extended, cancelled, or
terminated. In addition, all City property and equipment with a
useful life of at least one year and per-unit acquisition cost,
which equals or exceeds $5,000 and acquired or received
through grants shall be tagged and included in the Asset
Management inventory.
In order to ensure all grants received by the City are reported
on the annual Schedule of Expenditures of Federal Awards and
State Financial Assistance (SEFA) the Controller, or designee,
shall be copied on all agenda items involving grants that are
presented during the year to City Council for action.
The Controller, or designee, shall prepare the Schedule of
Expenditures of Federal Awards and State Financial Assistance
based on information provided by the City departments
receiving grants. Grants and external awards required to be
included on the SEFA are listed in the Assistance Listings or
the Catalog of State Financial Assistance (CSFA), both of
which can be accessed via the internet.
c. Expenditure Monitoring
Requests for advances, reimbursements and revenue draws
shall be submitted according to the terms outlined in the grant
agreement, and shall be monitored monthly and reconciled, at a
minimum on a quarterly basis. The Controller or designee shall
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monitor the department’s grant activities to minimize errors and
discrepancies.
At a minimum, the Department’s Fiscal Manager or equivalent
and Grant Manager shall reconcile grant revenues and
expenditures with the financial accounting system on a
quarterly basis to confirm that charges are allowable and are
accurately posted to the general ledger.
All costs must be allowable to be charged against a grant. This
means that they are allowable, allocable, necessary, and
reasonable and provide a direct benefit to a grant-funded
project or activity. Disallowed charges are generally noted in
the grantor’s guidance.
d. Submitting Reports to the Grantor
Grants awarded to the City may require that progress,
programmatic, financial, and other reports be submitted to the
grantor. Accurate and timely reporting is critical to compliance
and maintaining a good relationship with the grantor. Late or
inaccurate reports may negatively impact current or future
funding.
i. All reporting required by the grantor is the sole
responsibility of the Grant Manager and the department
receiving the grant. Grant Managers must prepare timely
and accurate progress, programmatic, financial, or other
reports as required by grantor. The financial information in
the reports must reconcile to the general ledger and be
supported with sufficient corroborating documentation.
ii. If the report preparer is not the department’s Fiscal
Manager or equivalent, the preparer shall submit all
financial reports to the Fiscal Manager for review and
verification before submitting them to the grantor. If the
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preparer is the department’s Fiscal Manager or
equivalent, all financial reports shall be submitted to the
citywide Grant Accountant before submitting them to the
grantor.
iii. The Grant Manager’s supervisor shall review any
programmatic reports for content and quality and address
any issues with the Grant Manager before they are
submitted to the grantor.
iv. Copies of all reports prepared for submission to the
grantor shall be kept by the department to ensure
compliance as well as uploaded to the Grants
Management System through the Award Task
functionality. These reports need to be available as
required.
v. The Controller, or designee, shall monitor the financial
reports for content and quality and address any issues
with the recipient department.
e. File Management, Access, and Retention
The Controller, or designee, may review the files, activities,
equipment and facilities, as well as interview relevant personnel
and contracted entities, of any City of Orlando project that is
funded with grants awarded to the City.
i. File Management
The department that receives the grant is the keeper of
the required grant documentation; when feasible
electronic files should also be retained on the City’s
financial management system and grant management
system. All department files associated with a grant must
include:
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1. Submittal (e.g., application guidelines and a copy of
the submitted application).
2. Research (e.g., statistical and other information
used in preparation of and support of the grant).
3. Award (e.g., award letter, council agenda item, fully
executed grant agreement, grant amendments,
modifications, extensions, subawards, cancellations
and terminations, evidence grantor considers award
closed, and anything else related to the award).
4. Finance (e.g., comparison of budget to actual,
purchase orders, vendor contracts, invoices, payroll
records, journal entry support, evidence of proper
procurement, bids, quotes, etc.).
5. Eligibility (e.g. beneficiary data and income
certifications).
6. Subrecipient Monitoring (e.g. risk assessment,
monitoring policy and plan, and monitoring report)
7. Reports (e.g., reports to granting entity and
evaluation components, expenditure reports,
performance reports, audit reports, and other
reports as requested or needed).
ii. File Retention
The department that receives the grant must maintain
grant records for at least three years from the date of
submission of the final expenditure report or, for Federal
awards that are renewed quarterly or annually, from the
date of the submission of the quarterly or annual financial
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report, respectively, as reported to the Federal awarding
agency or pass-through entity in the case of a
subrecipient.
1. If any litigation, claim, negotiation, audit, or other
action involving grant records has been started
before expiration of the three-year period, the
records must be retained until completion of the
action and resolution of all issues which arise from
it, or until the end of the regular three-year period,
whichever is later.
2. Grantors may require retention periods in excess of
the City’s policy of three years. Departments must
ensure they comply with retention requirements
specified by each grantor when they exceed the
City’s retention policy.
3. Retention requirements extend to books of original
entry, source documents supporting accounting
transactions, the general ledger, subsidiary ledgers,
personnel and payroll records, invoices and related
documents and records that justify expenditures.
4. Source documents include copies of all awards,
applications, and required recipient financial and
narrative reports. Personnel and payroll records
shall include the time and attendance reports, work
activity reports or equivalent documentation for all
individuals reimbursed under the award.
5. Recipient departments are also obligated to protect
records adequately against loss, theft, fire or other
damage in accordance with statutory provisions of
Chapters 119, Public Records Law and 257, Public
Libraries and State Archives, of the Florida Statutes,
Office of Business and Financial Services
Grants and Other Types of Financial Assistance Section 2320.1
Policies and Procedures Manual Page 22
as outlined in the most current General Records
Schedule.
6. Except for the provisions above, records must be
destroyed in accordance with Chapters 119, Public
Records Law and 257, Public Libraries and State
Archives, of the Florida Statutes. Proof of document
destruction is retained by the City Clerk.
8. Grants Oversight Committee (GOC)
a. Role of Grants Oversight Committee: The Grants Oversight
Committee is a committee comprised of liaisons from each
department, designated divisions, and offices of the City. The
GOC is the mechanism for communication between the
Assistant Controller, citywide Grants Manager and City
departments about grants management and administration.
b. Grants Oversight Committee Liaison: The GOC Liaison is a key
component to the success of the City’s grants management and
administration goals. To facilitate communication, each
Department Director shall select an individual, called the GOC
Liaison, to represent the department on the Grants Oversight
Committee, and to be the department’s point of contact with the
citywide Grants Manager. The Department Director may
designate more than one GOC Liaison. The GOC Liaison shall:
i. Communicate grant related information, including but not
limited from the Assistant Controller, citywide Grants
Manager, GOC meetings and received communications
to all staff with grant responsibilities in their department.
ii. Serves as the conduit for grant-related ideas and
information from the department to the Assistant
Controller, citywide Grants Manager and GOC.
Office of Business and Financial Services
Grants and Other Types of Financial Assistance Section 2320.1
Policies and Procedures Manual Page 23
iii. Have the authority to communicate with department staff,
and obtain necessary approvals and signatures as
required by this policy.
iv. Ensure the applicable grants management and
administration policies are followed within the department.
v. Ensure their department’s grant activity is entered into the
Grants Management System as outlined in this policy.
vi. Participate in GOC meetings and subcommittee meetings
to accomplish committee goals and objectives as needed.
vii. Share ideas and expertise in grant related meetings and
training events as requested.
9. Conflict of Interest
Actual or perceived conflicts of interest can damage the reputation
and credibility of the City. One of the key purposes of this policy is to
eliminate or mitigate the risk either in actual or in appearance of a
conflict of interest or breach of trust by an official or employee of the
City.
a. No official or employee of the City shall have any interest,
financial or otherwise, direct or indirect, or arrangement
concerning prospective employment that will, or may be
reasonably expected to, bias the design, conduct, or reporting,
of a grant-funded project on which they are involved.
b. Any official or employee shall ensure that in the use of project
funds, officials or employees of the City, nongovernmental
recipients, or sub recipients shall avoid any action that might
result in, or create the appearance of:
i. Using their official position for private gain,
Office of Business and Financial Services
Grants and Other Types of Financial Assistance Section 2320.1
Policies and Procedures Manual Page 24
ii. Giving preferential treatment to any person or
organization,
iii. Losing partial or complete independence,
iv. Making an official decision outside official channels, or
v. Adversely affecting public confidence or trust in the grant-
funded program in particular and the City in general.
c. In addition to any other ethics rules or standards of conduct
established by the City, no employee, official or agent of the
City, shall participate in the selection, awarding, or
administration, of a contract supported by federal funds if
participation creates an actual conflict of interest. Such a
conflict would arise when:
i. The employee, official or agent;
ii. Any member of their immediate family;
iii. Their partner; or
iv. An organization which employs, or is about to employ,
any of the above, has a financial or other interest in or a
tangible personal benefit from a firm considered for a
contract or award. Subject to the monetary amounts set
forth in the City’s Ethics Policy, the City’s officers,
employees, or agents (and the City’s subgrantees’
officers, employers or agents) will neither solicit nor
accept gratuities, favors or anything of monetary value
from contractors or parties to subcontracts, potential
contractors, or parties to subagreements.
Office of Business and Financial Services
Grants and Other Types of Financial Assistance Section 2320.1
Policies and Procedures Manual Page 25
d. Organizational Conflicts of Interests in Federally Funded
Procurements: An organizational conflict of interest exists
where there is a relationship between a bidder or other potential
contractor and the City, which is equivalent to that of a parent
company, affiliate, or subsidiary organization. In such cases,
the entity having an organizational conflict of interest with the
City should not be awarded a contract by the City without
guidance and/or approval from the federal awarding agency. At
a minimum, for quotes and formal solicitations, the entity having
an organizational conflict of interest should not have
participated in the preparation of the City’s specifications for the
quote or solicitation and should meet all material requirements
applicable to other eligible respondents.
e. Designated Official to Solicit and Review Disclosures of
Significant Financial Interests from Principal Investigators:
Where a grantor requires disclosures of significant financial
interests, the Citywide Grants Manager shall serve as the
designated official to solicit and review disclosures of significant
financial interest from each Grant Manager (who may be
referred to as the “Principal Investigator” by the grantor). When
required by a grantor, the Citywide Grants Manager shall
require a disclosure of significant financial interests no later
than at the time of application, and at least annually, or as often
as required by the grantor. Each disclosure shall be signed and
dated by the Grant Manager (or “Principal Investigator”) and
shall include a certification statement as required by the
grantor. Where the Citywide Grants Manager reasonably
determines that there is a significant financial interest that could
affect the project, the Citywide Grants Manager will submit the
disclosure(s) to the Chief Administrative Officer to make a
determination whether to forego an application for the grant, to
appoint a different individual to manage the grant, or develop
and implement a management plan to manage the conflict of
interest.
Any violation of these provisions is governed by the City’s
Office of Business and Financial Services
Grants and Other Types of Financial Assistance Section 2320.1
Policies and Procedures Manual Page 26
Ethics Policy.
10. Requests for Support from External Organizations for Grant
Applications
External organizations frequently seek support from the City for grant
applications they intend to submit to a grantor. The letters are treated
differently based on whether any City resources are obligated or
committed.
a. Letters of Support Requests: A letter of support request is
defined as a request from a non-profit organization or
governmental entity for a letter from the City endorsing a grant
application to an external (non-City) grantor in which the City
makes no commitment for financial or in-kind support or
engagement.
Letters of support shall be coordinated by the Department
Director and provided to the Citywide Grants Manager. The
Citywide Grants Manager will work with the City Attorney’s
Office to confirm that the request does not obligate or commit
City resources and shall notify the requesting Department
Director of the outcome. The Citywide Grants Manager will also
confirm there are no competing grant applications or requests
before notifying the requesting Department Director. The CAO
or designee will determine whether a request for a letter of
support should be provided in support of an external
organization that may compete with City’s grant application to
the same grantor. The Department’s Authorized Signatory as
defined in Section 4(b), Authorized Signature Authority, shall
determine whether it is in the City’s best interest to provide a
letter of support. Letters of support should be signed by the
Department’s Authorized Signatory as defined in Section 4(b).
b. Letters of Commitment Requests from External Organizations:
A letter of commitment request is defined as a request from an
external agency for a letter from the City endorsing a grant
application in which the City is a collaborating partner or agrees
Office of Business and Financial Services
Grants and Other Types of Financial Assistance Section 2320.1
Policies and Procedures Manual Page 27
to provide financial or non-financial (in-kind) support.
Since letters of commitment obligate the City to a grant-funded
project, to seek approval for the award proposal, the requesting
Department shall provide the Citywide Grants Manager with a
completed Grants & Financial Assistance Approval Form. The
Citywide Grants Manager will enter it into the Grants
Management System. The City Attorney’s Office shall review all
letters of commitment for external organizations. Approved
Letters of Commitment, only after any approval by City Council,
shall be signed by the Department’s Authorized Signer or the
Mayor or designee.
c. Letters of Collaboration Requests from External Organizations:
A letter of collaboration request is defined as a request from an
external nonprofit organization or governmental entity for a
letter from an individual City employee with expertise in a
particular field. No letter of collaboration will be issued in an
employee’s official capacity or using the employee’s official title
unless it simply restates a position on an issue approved by
City Council. A letter of collaboration request should be
forwarded to the Citywide Grants Manager who will confirm that
the request is for a letter of collaboration and reflects a position
taken by City Council. A letter of collaboration can be signed by
the individual who is undertaking the collaboration, with
approval from the individual’s supervisor.
Forms:
Grants & Financial Assistance Approval Form.
Grant Closeout Form.
Committee Responsibilities:
The Grants Oversight Committee, under the direction of the Assistant
Office of Business and Financial Services
Grants and Other Types of Financial Assistance Section 2320.1
Policies and Procedures Manual Page 28
Controller, is responsible for reviewing these policies on an annual basis
and updating when necessary.
Reference:
Policy adopted by City Council October 15, 2007, Item A11, modified on
May 9, 2011, Item 7-1; amended September 6, 2017, Item A-1; amended
February 7, 2022, Item A-1; amended April 22, 2024, Item A-01.
Date:
This policy effective April 22, 2024.
Grants & Financial Assistance Approval Form
N:\Finance\common\!Financial Reporting\Administration\Forms\Grants
Form created by City of Orlando, OBFS September 3, 2008. Updated January 2020
Application Due Date: Submission Date:
*Grant Coordinator: *Grant Manager:
(Contact for application) (if different from application contact)
Title: Title:
Department: Department:
Extension: Extension:
Department Director:
Grant/Award Title:
Description:
Awarding Agency (Grantor):
If a Federal pass-through, identify Federal source:
CFDA or CSFA #:
CIP or FPN #:
Amount of funding request:
Proposed award period of performance: (mm/dd/yy) to
Funding Type (reimbursement, fixed, or advancement):
Match percentage or
amount:
0 Source of Match
Funding:
N/A
Award Notice/Announcement/Instruction link:
Programmatic Considerations Indicate Response Here
What City departments does the proposed project impact, if any?
What external organizations are you collaborating with, if any?
Will there be any subrecipients? If so, what organizations are
identified in the proposal as subrecipients?
Are all identified subrecipients eligible for federal funding,
according to SAM.gov?
Financial Considerations Indicate Response Here
What is the total anticipated project cost?
If applicable, identify the amount and funding source(s) that support
the remainder of the project or program cost.
Are administrative costs allowed?
Will the grant be used to fund salaries and benefits?
Will the receipt of this grant cause the City to incur additional or
future operating costs?
If program generates revenue, how so and the anticipated amount?
If grant requires continuation of the program beyond the grant
period, how will it be funded?
Legal Considerations Indicate Response Here
Provide a short description of unique contract requirements that the
City Attorney needs to be made aware of, or needs to clarify for
Dept.
Does this application need City Council approval? If so, why?
Procurement Considerations Indicate Response Here
Grants & Financial Assistance Approval Form
N:\Finance\common\!Financial Reporting\Administration\Forms\Grants
Form created by City of Orlando, OBFS September 3, 2008. Updated January 2020
Provide a short description of any special procurement requirements
that need to be disclosed and evaluated at the time of application.
*Successful completion of ALL approvals in Workday signifies authorization to apply for the grant.
Does the receipt of the grant involve the lease or purchase of real
estate? If so, please describe the real estate need?
N:\Finance\common\!Financial Reporting\Administration\Forms\Grants
Form created by City of Orlando, OBFS September 3, 2008. Updated December 9, 2022
GRANT CLOSEOUT FORM
Section 1: to be completed by Submitting Department.
Department/Division: Award Amount: $
Award #: AWD Eligible Expenditures incurred to date: $
Grant Name: Cash received to date: $
Grant #: G Required match: $
If award was not fully spent, please explain why and if
any grant funds were returned.
The complete grant file(s) [paper and electronic] will be labeled GRANT along with the above AWD# and transferred
to the Clerk’s office upon completion of audit to comply with federal grant retention requirements. ☐
Prepared by: Date: -
Print name Grant Manager
Approved by: Date: -
Print name Fiscal Manager or Equivalent
Section 2, Compliance Information: to be completed by the OBFS Grants Team.
1. Financial Information above agrees to City’s financial accounting system.
2. No exceptions noted with Compliance and Internal Control Testing. See Audit Testing Workpaper for further details.
3. All Award Tasks have been completed in the Workday system.
Summary of Exceptions Noted and Resolutions:-
Completed by: Date: -
Print name OBFS Accountant
Approved by: Date: -
Print name Assistant Controller
FORM INSTRUCTIONS
(1) Section 1 is to be completed by Submitting Department after closing with the grantor.
(2) Section 2 is to be completed by the OBFS Grants Team. Checkmarks indicate agreement. Approved form and Audit Testing
Workpaper will be attached to the Award in Workday. Award will be closed and Grant inactivated to prevent further posting.
Significant Financial Interest Disclosure
Applicable to Grant Managers or Principal Inves�gators in US Department of Energy-Funded projects
Grant Manager / Principal Inves�gator _____________________________________________________
Department ___________________________________________________________________________
Grant Applica�on ______________________________________________________________________
Proposal Submited to (name of funding agency) _____________________________________________
Award Proposal Number: ________________________________________________________________
☐ I do not have any significant financial interests to disclose at this �me.
☐ I am disclosing the following significant financial interests.
Significant financial interest means an interest of monetary value in one or more of the following by the
Grant Manager / Principal Investigator (including their spouse, domestic partner and/or dependent children)
that reasonably appears to be related to their responsibilities of managing the grant-funded project.
☐ Financial interest in a public or private en�ty if the value of any renumera�on received in the last 12
months and the current value of any equity interest holdings in the en�ty, when aggregated, exceeds
$5,000. Check all that apply:
☐ Salary or other payment for services (e.g. consul�ng fees, honoraria, paid authorship)
☐ Equity interest (e.g. stocks, stock op�ons or other ownership interests)
☐ Income from intellectual property rights and interests (e.g. patents, copyrights, royal�es)
☐ Reimbursed or sponsored travel, provided that the travel is not reimbursed or sponsored by a
government agency or an ins�tu�on of higher educa�on.
☐ Other significant interests of the inves�gator that possibly could affect or be perceived to affect the
results of the grant-funded project.
☐ Any financial interests received from a foreign en�ty, including a government of another country or
ins�tu�on of higher educa�on based in another country.
Further, I agree:
• To update this disclosure during the period of the award on an annual basis, or as new reportable
significant financial interests are discovered or acquired (within 30 days).
• To cooperate in the development of a plan to resolve any conflicts of interest.
• To comply with any condi�ons or restric�ons imposed by the City of Orlando to manage, reduce, or
eliminate actual or poten�al conflicts of interests or to forfeit the award.
_____________________________ _____________________________________ _______________
Printed Name Signature Date