File:  DAC* - Federal Fiscal Compliance

NOTE: Colorado school districts that receive federal funds are required by federal law to adopt a policy on this subject and the law contains some specific direction as to the content or language. This sample policy contains the content/language that CASB believes best meets the intent of the law. However, the district should consult with its own legal counsel to determine appropriate language that meets local circumstances and needs.

Federal funds received by the district shall be administered in accordance with this policy and applicable federal law, including but not limited to the federal Uniform Grant Guidance. The Board designates the [insert title of administrator, e.g., superintendent, business manager, federal programs coordinator] as the district contact for all federal programs and funding.

The superintendent or designee may develop and implement accompanying regulations to assist in the proper administration of federal funds and implementation of this policy, including but not limited to cash management procedures and allowability of costs.

Subrecipient monitoring

If the district awards subgrants, the district shall monitor grant subrecipients to ensure compliance with applicable law and Board policy.

Time and effort reporting

District employees paid with federal funds shall document the time they expend in work performed in support of each federal program and/or such program's cost objective(s), in accordance with applicable federal law. Time and effort reporting requirements do not apply to contracted individuals.

Recordkeeping

The district shall maintain proper federal fiscal records in accordance with Board policy and applicable law. Such records shall be retrievable and available for programmatic or financial audit.

(Adoption date)

LEGAL REFS.: 2 C.F.R. Part 200 (Uniform Grant Guidance)

34 C.F.R. Parts 75, 76 (EDGAR - Education Department General Administrative Regulations)

CROSS REFS.: BCB, School Board Member Conflict of Interest

DJB*, Federal Procurement

EHB, Records Retention

GBEA, Staff Ethics/Conflict of Interest

COLORADO SAMPLE POLICY 2017