6101P - Federal Cash & Financial Management, Allowable Costs, and Procurements Procedure

Federal Cash & Financial Management

The District may draw federal funds using a reimbursement or advance payment method. 

Reimbursement Payment Method

For reimbursements of federal funds, the District will:

1. Monitor the fiscal activity (payments and reimbursements) under each grant on a continuous basis, and request timely reimbursement only for expenditures that have already been disbursed and comply with all applicable award requirements.
2. Maintain source documentation/accounting records that reconcile to the reimbursement request at a level adequate to establish that funds have not been used in violation of any applicable statutory restrictions or prohibitions.
3. If the District transfers expenditures previously charged to a federal award for which reimbursement has been claimed to a non-federal fund source, the District will calculate the interest earned on the federal funds pursuant to possible submittal - refer to Interest Earned section below.

Advance Payment Method

For advances of federal funds, the District will:

1. Monitor the fiscal activity (drawdowns and payments) under each grant on a continuous basis and maintain source documentation/accounting records at a level adequate to establish that funds have not been used in violation of any applicable statutory restrictions or prohibitions.
2. To the extent available, disburse funds available from program income, rebates, refunds, contract settlements, audit recoveries, and interest earned on such funds before requesting additional cash payments.
3. Plan for cash flow in the grant project during the budget period and review project cash requirements before each drawdown.
4. Draw down only the amount of funds necessary to meet the immediate needs of the program/project (including the proportionate share of any allowable indirect costs), and minimize the time between receiving and disbursing those funds.
5. Pay out federal funds for expenditures that comply with all applicable grant requirements as soon as administratively feasible (a rule of thumb is no more than three business days after receiving the funds).
6. Deposit advance payments into insured accounts whenever possible. Unless conditions listed in CFR Title 2 Part 200 Subpart D §200.305(b)(8) apply, the District will maintain advance payments in interest-bearing accounts.
7. Remit interest earned over $500 annually – refer to Interest Earned section below.

Interest Earned

1. The District will retain interest earned amounts up to $500 per year for administrative expenses.
2. Any additional interest earned on those funds will be remitted annually to the Department of Health and Human Services (HHS) Payment Management System (PMS) through an electronic medium or by check to the HHS Program Support The District will refer to the federal or pass-through agency for pertinent information about the remittance.

Allowable Costs for Federal Programs

The purpose of this procedure is to ensure federal funds are spent only on allowable activities in accordance with CFR Part 200 Subpart E – Cost Principles, other special terms or conditions of the grant award, and/or other applicable state and federal guidelines. In determining allowable costs, the District will use the guiding principles as established in the Regulation 6101.

Two categories of costs may be charged to a Federal award. The first are direct costs, which are costs that directly benefit the activity and are easy to identify. The second are indirect costs, which are costs that either benefit the activity in an indirect manner or directly benefit the activity but the complexity of adequately identifying the costs as such outweighs the benefit of charging them directly.

Costs will meet the requirements of necessary and reasonable when they do not exceed those which would be incurred by a prudent person under the circumstances at the time the decision was made to incur the cost. District employees will use the following questions to determine reasonable and necessary costs:

• Does the District really need this item/service?
• Is the expense targeted to a valid programmatic/administrative need?
• Is this the minimum amount we need to spend to meet our needs?
• Do we have the capacity to use what we are purchasing?
• If we were asked to defend this purchase, would we be able to?
• Did we pay a fair rate?

The District will implement a reasonable method of allocating costs that equates to the relative benefit received by the program for the proportion of the costs charged to the program.

Period of Performance

Federal funds may be obligated on the later of the date funds become available or the submission date of the grant application, either in full form, or “Substantially Approvable Status (SAS)”, depending on the terms of the Federal award.

Federal funds may not be expended subsequent to the end date of the grant except to liquidate allowable obligations that were made on or before that date. All liquidations of prior obligations must be made within 90 days of the grant end-date, or an earlier date established by the granting agency.

The following table indicates the date that expenditure is determined to be obligated:

IF THE OBLIGATION IS FOR	THE OBLIGATION WAS MADE
Acquisition of real or personal property	On the date on which the District makes a binding written commitment to acquire the property
Personal services by an employee of the District	When the services are performed
Personal services by a contractor who is not an employee of the District	On the date on which the District makes a binding written commitment to obtain the services
Performance of work other than personal services	On the date on which the District makes a binding written commitment to obtain the work
Public utility services	When the District receives the services
Travel	When the travel is taken
Rental of real or personal property	When the District uses the property

Direct Costs

Expenditures charged directly to a federal grant award will follow all District regulations and procedures as well as federal requirements applicable to those costs, including, but not limited to; procurement requirements, property standards, travel regulations, and cost criteria established by 2 CFR Part 200, Subsection E, as identified in the Regulation #6101. Additionally, all direct expenditures will be allowable under the terms of the grant award and program regulations. Requirements followed will be the more restrictive of the local, state, or federal regulations associated with a particular type of expenditure.

Staff responsible for reviewing expenditures for allowability will be familiar with the allowable costs of all programs reviewed. Staff responsible for budget and expenditure monitoring will be responsible for ensuring all charges are reviewed by appropriate staff for allowability.

Prior approvals of expenditures, as stated in 2 CFR, Part 200 and the grant award terms, will be obtained prior to the expenditure being obligated. Expenditures will be supported by adequate documentation including all pertinent details that assists in determining the item was allowable.

Indirect Costs

Federal grant awards will include an amount of indirect expenditures that Districts are entitled to for organization wide costs of the grantee that benefit the federal program being administered by the District, unless specifically disallowed by the terms of the grant award.

Indirect rates are negotiated by the District’s cognizant or oversight agency and can be applied to all Federal awards the District receives.

For grants awarded by the Office of Superintendent of Public Instruction (OSPI), indirect rates are calculated annually based on financial information obtained through the F-196. OSPI negotiates the indirect cost rate calculation methodology with the Department of Education every 5 years.

There are two types of federal indirect costs. A restricted rate is used for any federal program that has a “supplement, not supplant” requirement, which means the federal money is used to supplement the amount of money that a District has to spend on a particular program, and is not used “in place of” state/local funds. An unrestricted rate is used for programs that do not have a “supplement, not supplant” requirement.

The District is not required to claim any or the entire indirect amount they are entitled to, but may claim up to the full amount, as long as it is included in the District’s approved budget. The indirect rate may be applied to all allowable direct expenditures that will be claimed under a particular grant award, less some exceptions (e.g., indirect costs will only be applied to the first $25,000 of an individual contract).

No expenditures will be charged through both a direct cost and an indirect cost.

Procurement Using Federal Funds

Effective November 12, 2020, The Uniform Grant Guidance allows non-federal entities who qualify as a low-risk auditee for the most recent audit, or perform an annual internal institutional risk assessment to identify, mitigate and manage financial risks that result in a low-risk assessment, to use a micro purchase threshold of $50,000. However, the more restrictive state threshold of $40,000 must be used for the purchase of goods.

The District chose to annually self-certify by qualifying as a low-risk auditee from our most recent audit.

Small purchases have a purchase threshold of $250,000, however the more restrictive $75,000 state threshold must be used for the purchase of goods, except for books.

The following table outlines procurement requirements when using Federal Funds.

Procurement Method	Goods (includes taxes & shipping)	Services	Instructions
Micro-Purchase	$10,000 or less OR $40,000 if deemed low risk	$10,000 or less OR $50,000 if deemed low risk	No quotes required. Consider price to be reasonable, and, to the extent practical, distribute purchases equitably among suppliers.
Small Purchase Procedures	$10,000 or less OR $40,000 if deemed low risk - $75,000	$10,000 or less OR $50,000 if deemed low risk - $250,000	Obtain/document quotes from a reasonable number of qualified sources (at least three). A non-response from a vendor is also considered a quote invitation.
Sealed Bids / Competitive Bids (Formal)	$75,000 or more	$250,000 or more	Must be publicly solicited using sealed bids. See Regulation #6220P-Purchasing Bids & Contracts.
Non-competitive proposals	Appropriate only when:	Micro purchase Meets sole source criteria; The public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation; The awarding agency (e.g., OSPI) authorizes a noncompetitive proposal in response to a written request from the District, i.e. Safety Net, etc.; or After solicitation of a number of sources, competition is determined inadequate.