Section... (Page in printed manual shown in parenthesis) Introduction (1) | Organization (2) | Financial Management System Standards (3) | Financial Reporting (4) | Computer System (5) | Property Management (6) | Budgets (7) | Cash Management (8) | Grants and Contracts (9) | Non-Federal Audits (10) | Cash Depositories (11) | Cash Receipts (12) | Procurement Standards (13) | Purchasing Procedures (14) | Voucher System (15) | Cash Disbursements (16) | Payroll (17) | Indirect Cost (18) | Consultant and Contract Service (19) | Travel (20) | Contribution and Donations (21) | Non-Federal Share or Matching (22) | Federal Grant and Subgrant - Related Income (23) | Taxes (24) | Telephone (25) | Bonding and Insurance (26) | Petty Cash (27) | Borrowing (28) | Loans (29) | Retention and Access Requirements for Records (30) | Committees and Board Expenses (31) | Closeout of Grants or Programs (32) | Bank Reconciliations (33) | Occupancy (34)
Other topics of interest (listed alphabetically)... Advance-payment Purchase Requirements | Allowable Costs | Annual Property Inventory Required | Backup/Recovery Required, Computer | Board/Committee Expense Reimbursements | Budgetary Control | Cash/Checks, Handling of | Cash Donations, Handling | Competitive Procurement Standards | Computer/Software Purchases | Consultants (Use of) Requirements | Contract Provisions, Required | Cost-sharing/Matching Requirements | Excess Property Disposition | In-Kind Contributions, Handling | Insurance, Agency | Insurance, Automobile Liability | Insurance, General Liability | Interest/Investment Income Requirements | Internal Reporting Requirements | Loans to Employees Prohibited | Long Distance Telephone Calling | Minority-owned Vendors Utilization | New-Employee Hire-in Requirements | Payables (Bill Payments) Issued Twice Monthly | Personal Telephone Calls Restricted Petty Cash Disbursements Limit/Requirements | Program Income Requirements | Records, Access to | Records Requirements | Records Retention | Renting and Leasing | Requisition Requirements | Restricted Funds | Sales/Use Taxes, AACS Exempt from | Source Docementation Required | Time Sheet Submission Requirements | Travel-expense Advances | Travel Expenses, Reimbursable | Travel Claims, In-Area | Travel Claims, Out-of-Area | Travel Voucher Requirements | Vendor Statement/Receipt Required
This Financial Procedures Manual was prepared by the Financial Administrator in consultation with members of the Administrative Staff, Program Directors, Auditors, and Others. The Manual has been approved by the Executive Director and is effective October 1, 1993.
The Executive Director is the only person authorized to amend, modify or terminate any of the policies or procedures contained in the manual. Accordingly, any violations of the procedures should be reported to the Executive Director.
Operational Backdrop/Agency Legal Status
Audubon Area Community Services, Inc. (AACS) is a private non-profit agency chartered October 15, 1973, upon the submission of Articles of Incorporation to the office of the Kentucky Secretary of State. The Agency formally commenced operations on March 1, 1975 as successor to and the consolidation of two parent agencies operating from April and August, 1966 in Henderson and Owensboro, respectively. Audubon Area Community Services, Inc. is a community action agency created under the Economic Opportunity Act of 1964 (Public Law 88-452) and authorized under the Kentucky Revised Statutes (K.R.S.) 273.410 et sequens, as revised under amendments by the 1982 General Assembly, entitled "Community Action Agencies."
The 1980 General Assembly amended Chapter 65 of the K.R.S. and specifically defined the agency as a "special district" of the Commonwealth of Kentucky. Thus, the AACS, as the term " special district" implies is a unique, limited purpose unit of government created for and involved with its special aspect of public service. As a special district, the AACS is fully accountable to the local Fiscal Courts and the general public to whom it must make an annual report of its budget, services, service area, executive officers, and members of its governing Board of Directors.
Audubon Area Community Services, Inc. is also the recipient of federal grants either directly or indirectly from various Federal departments and agencies. Accordingly, AACS is subject to statutory and regulatory requirements applicable to these grants. OMB Circular A-122 "Cost Principles for Nonprofit Organizations," and other principles issued by Federal granting agencies, such as the Department of Health and Human Services (HHS) 45 CFR 74 Appendix E, "Principles for Determining Cost Applicable to Research and Development Under Grants and Contracts with Hospitals," establish principles and standards for determining costs applicable to grants, contracts, and other agreements. In addition, Federal grants are subject to the provisions of OMB Circular A-110, "Uniform Administrative Requirements for Grants and Cooperative Agreements with Institutions of Higher Education, Hospitals and Other Nonprofit Organizations," and other administrative requirements issued by Federal granting agencies, such as the Department of Health and Human Services (HHS) 45 CFR 74, "Administration of Grants."
The AACS Board of Directors is the agency's overall governing authority. It is fundamentally a policy-making and oversight body. The Board defines policy and practice within the agency. Executing the Board's policy and plans is the function of the staff, under guidance and direction of the Executive Director. The Agency has several advisory groups affiliated with its sponsored programs. In some cases, these are mandated in federal legislation. In others, the agency determined they were needed. Each of these councils is advisory to the Board and/or staff, except for the Head Start Policy Council which functions with the Board in overseeing the governance and operation of the Head Start program. It's specific responsibilities, perogatives, and authority are set forth in federal regulations, "Head Start Transmittal Notice 70.2," which defines designated Head Start operational roles for parents, administrators, and the Board.
The Agency shall meet the following standards for all of its programs.
A. Financial reporting -- Accurate, current, and complete disclosure of the financial results of each project or program shall be made in accordance with the financial reporting requirements of the grant or subgrant.
B. Accounting records -- Records which identify adequately the source and application of funds for grant or subgrant supported activities shall be maintained. These records shall contain information pertaining to grant or subgrant awards, authorizations, obligations, unobligated balance, assets, outlays and income.
C. Internal Control -- Effective control and accountability shall be maintained for all grant or subgrant cash, real and personal property covered by Code of Federal Regulations Part 74 - Administration of Grants, Subpart O - Property or OMB circular A-110, "Grants and Agreements with Institutions of Higher Education, Hospitals and Other Nonprofit Organizations - Uniform Administrative requirements," Attachment N - Property Management Standards.
D. Budgetary Control -- The actual and budgeted amounts for each grant or subgrant shall be compared. If appropriate or specifically required, the Agency shall relate financial information to performance or productivity data, including the production of unit cost information. If unit cost data are required, estimates based on available documentation will be used whenever possible.
E. Advance Payments -- Agency procedures shall be established to minimize the time elapsing between the advance of Federal grant or subgrant funds and their disbursement. When advances are made by letter-of-credit method, the Agency shall make drawdowns as close as possible to the time of making disbursements. The Agency when advancing cash to subgrantees shall conform substantially to the same standard of timing and amount as apply to advances by Federal agencies to grantees, including requirements for timely reporting of cash disbursements and balances.
F. Allowable costs -- Agency procedures shall be established for determining the reasonableness, allowability, and allocability of cost in accordance with the applicable cost principles contained in OMB Circular A-122, "Cost Principals for Nonprofit Organizations."
G. Source documentation -- Accounting records shall be supported by source documentation such as cancelled checks, paid bills, payrolls, contract, and subgrant award documents, etc.
H. Non-Federal Audits -- The agency shall comply with the requirements concerning Non-Federal Audits in OMB Circular A-133, "Audits of Institutions of Higher Education and Other Nonprofit Institutions," including any amendments to those requirements published in the Federal Register by OMB.
I. Audit resolution -- The Agency shall follow a systematic method to assure timely and appropriate resolution of audit findings and recommendations in accordance with the requirements of OMB Circular A-133, " Audits of Institutions of Higher Education and Other Nonprofit Institutions."
A. Internal Reporting --The Agency's Accounting records are maintained on an automated computer system and fund accounting software which provides on-line financial information to the Executive Director, Associate Director, Financial Administrator and Program Directors. In addition, financial reports are distributed to each Program Director for their review. These reports show a comparison of Budget with actual expenditures for the period-to-date and year-to-date totals. A consolidated financial report is submitted to Board of Directors at each meeting. This report shows the total month-to-date and year-to-date expenditures and revenues for each program. Responsibility for preparing and reviewing financial reports are as follows:
B. Reporting to Funding Sources -- The Agency has a variety of funding sources, each unique, and requiring a variety of reporting formats and reporting dates. To assure that all reports are timely submitted, the following procedures will be followed:
The Agency's accounting system is maintained on an computer system using fund accounting software. In addition, the Agency has personal computers which are used for specific purposes within programs or departments. The following procedures apply to all computers and computer systems within the Agency:
A. The Executive Director must approve all purchases of computers and software. This procedure is to be followed to prevent duplication and to assure that all computer equipment and software are compatible with the Agency's goal of a total integrated system.
B. The Financial Administrator is responsible for overseeing the Agency's data processing activity related to the automated cpmputer system and related accounting systems. The following procedures apply:
C. Program Directors are responsible for overseeing the personal computers within their respective programs. At a minimum the following procedures will be followed:
AACS definition of "Property" -- for the purposes of the agency's inventory Control and Record System, the following standard shall be employed:
Real Property. Real property means real-estate, including land, land improvements, structures (buildings) and appurtenances (attachments, built-in accessories, et cetera) thereto, excluding moveable equipment and machines.
All real property shall be properly secured by deed and maintained on a current inventory of Agency Real Property.
Personal Property. Personal property means agency property of any kind except real property. It may be tangible, that is, having a physical existence - or it may be intangible, that is, without physical properties, and include such things as copyrights, trademarks, patents, inventions, or any other form of "intellectual property" created by staff or contractors while in the paid employ of the agency.
Agency personal property is not usually maintained on a formal inventory, but such property still belongs to the agency and may not be converted to personal use or ownership.
Employee personal items located in their offices or other agency premises are individual private property. These should be labeled by the respective owners so as to prevent later questions arising as to the true ownership of those items.
Non-expendable Personal Property. Non-expendable personal property means at a minimum tangible personal (agency) property having an acquisition cost of $5,000 or more per unit and an expected useful life of one year or more or an acquisition cost of less than $5,000 but an expected useful life of five years or more. The latter would include items such as desks, credenzas, chairs (office furniture only, not folding chairs, children's chairs, and so forth), file cabinets, fax machines, desk calculators and other minor equipment.
Individual agency programs should use more restrictive definitions than that above as may be required by their respective grantor/contracting agencies. For example, some state contracts define non-expendable property as having an acquisition of $100 or more with a useful life of more than one year. Individual program directors must advise the agency property officer when a more restrictive than usual standard/definition of property is required by their respective grantor or contracting agency.
All non-expendable personal property - all agency/grantor property which meets the above definitions - must be maintained on the/an agency Inventory of Agency Non-expendable Property.
Some programs, Head Start, for example, may opt to maintain classroom/center-based/local-operations property on a separate inventory. This is permissible so long as the inventory is monitored/verified regularly - at least annually - and properly recorded, with a copy of each local site inventory provided to the agency property officer for review, filing and audit.
All agency non-expendable personal property must be inventoried at least annually and a copy of the inventory provided to the executive director and respective program director for review and approval. The Head Start inventory will be coordinated by the property officer through the Head Start Director and performed in conjunction with his/her designee(s) responsible for Head Start's respective classroom/center-based/local-operations property inventory - normally scheduled during April to early May annually. The property officer shall print out and distribute to the respective Head Start inventory designees the currently-recorded property cataloged in his/her records and provide that printout for each local office/center to the respective designees by April 1 each year.
No items on the inventory of Agency Non-expendable Property may be moved from one location to another without first notifying the agency property officer of its planned relocation. All appropriate paperwork must then be submitted to the property officer so that the inventory can be updated.
Expendable Personal Property. Expendable personal property refers to all tangible (physical) property of the agency other than that which is required to be listed on the inventory of non-expendable property. It includes anything and everything purchased by the agency - other than services, license fees, and such. All expendable personal property of the agency is available for agency use only and may not in any event or extent be converted for private use.
Excess Property. Excess property means any real or personal property of the agency which is determined by the executive director to be no longer required for agency needs or no longer useful for agency purposes. Upon the executive director's sole direction and approval, the property officer - or other designee, specifically the GRITS Transit Manager, Head Start Director, or other senior program director so designated by the executive director - shall be authorized to dispose of such excess property in accordance with all applicable rules, regulations, contract requirements, and/or applicable law. No one else - and no other procedure - is approved for the final disposition of agency property deemed "excess," "junk," or otherwise unusable/un-useful to the agency.
AACS's property management system for nonexpendable personal property includes the following procedural requirements:
A. Property records shall be maintained accurately and shall include:
B. Property owned by Federal Government must be marked to indicate Federal ownership.
A budget will be prepared for each program operated by the Agency at least annually. Development of the program budget will require the cooperation and active involvement of the Executive Director, the Financial Administrator and the Program Director. The following procedures will be followed:
A. Authorization - AACS programs are funded primarily by federal and state grants which are awarded annually. Therefore, formal notification of permission to proceed with planning will be issued by the funding agency, together with a projected program funding level. This may be in the form of a letter of understanding or some similar document.
B. Budget Preparation - The Program Director is primarily responsible for the preparation of the program budget and grant proposal. Consequently, the program budget and grant proposals will be prepared by the Program Director in consultation with members of the program staff and other designated persons.
C. Financial Review - All budgets will be submitted to the Financial Administrator for review prior to being submitted to the funding agency. The Financial Administrator will as a minimum do the following:
D. Administrative Review - All budgets must be submitted to the Executive Director for review and approval before they can be included in funding applications.
E. Board Approval - The Executive Director will at appropriate times submit proposals to the Board of Directors for consideration and approval. Proposals will include both budgets and work programs.
F. Budget Amendments - All changes, or requested changes to budgets, must be submitted to Executive Director for approval.
G. Recordkeeping - The Financial Administrator will insure that budgets which have been properly approved by funding source are on file for all grants and contracts.
The standard for effective cash management which is discussed in
45 CFR 74.61 (e) states that procedures must be established to minimize the time elapsing between the advance of grant or subgrant funds and their disbursement by the recipient. Advancing cash to subgrantees must conform substantially to the same standards of timing and amount as apply to advances received by the Agency, including requirements for timely reporting of cash disbursements and cash balances. The Agency's cash management procedures are as follows:
A. The Financial Administrator is responsible for monitoring and requesting funds for all federal sponsored programs. The following procedures will be followed.
The Board of Directors shall approve all grants, contracts, proposals, amendments or other program related matters, and unless the Chairman of the Board is directly specified by the respective grantor/contractor, the Executive Director is the authorized official to sign grant requests, contracts, grants, amendments, or other related documents. In the absence of the Executive Director, the Associate Director has the authority.
All grants and contracts and amendments awarded to the Agency for operations of programs will be processed in accordance with following procedures:
A. All grants and contracts and amendments will immediately upon receipt be forwarded to the Executive Director, the Executive Director will review the grant, contract, or amendment and if acceptable will distribute copies to the Program Director and Financial Administrator.
B. The Financial Administrator will review the grant, contract or amendment thereto and will report any possible errors or observations to the Executive Director. If the award is acceptable the Financial Administrator will do the following:
C. The Program Director will review the grant, contract or amendment thereto and report any possible errors or observations to the Executive Director. If the award is acceptable, the following procedures will be followed:
The Agency shall have an annual audit made in accordance with OMB Circular A-133, "Audits of Institutions of Higher Education and Other Nonprofit Institutions." The audit will be for the fiscal year ended February 28, the Agency's adopted fiscal year. The cognizant federal agency for monitoring audits and ensuring the resolution of audit findings is the U. S. Department of Health and Human Services, the Federal Agency that provides Audubon Area community Services, Inc. with the most funds.
The following procedures will be followed by the Agency for all non-federal audits:
A. A letter of engagement between the organization and the auditor shall be prepared which contains an understanding of the work that needs to be performed to satisfy the Agency's OMB Circular A-133 requirements for an audit. The letter shall provide an understanding of the terms, nature, and limitations of the engagements. The letter shall include the reporting objectives and responsibilities assumed by the auditors. Agency responsibilities such as the requirements for a client representation letter will also be included.
B. The Financial Administrator is responsible for scheduling the audit fieldwork, providing records and financial information, coordinating with program directors and accounting personnel for any needed information, and answering all questions related to the financial audit.
C. The Program Director in coordination with the Financial Administrator is responsible for providing information and answering all questions in connection with the audit that are related to compliance with laws and regulations as it relates to his or her program.
D. The Executive Director in coordination with the Program Director and Financial Administrator is responsible for the resolution of any audit findings or questioned costs.
The following sets forth the Agency's policy and procedures regarding the use of banks and other institutions as depositories of funds:
A. Depositories will be selected on a competitive basis and will be reviewed periodically as deemed necessary by the Executive Director.
B. The Board of Directors periodically authorizes all bank accounts and check signers.
C. AACS will maintain separate bank accounts for each of its programs to assure that funds are used only for their intended purpose.
The Agency has the following procedures to assure that all cash receipts are deposited promptly and recorded accurately as to account, amount, and period.
A. Incoming Mail - The Agency has a post office box and mail is picked-up each day by the Executive Secretary or a member of the Administrative Staff. The mail is sorted and routed to the various programs and departments. All mail for finance department is opened by the Clerical Assistant and stamped with the current date and forwarded to the Financial Administrator for review and distribution.
B. Recording - The Purchasing and Receivables Manager will receive all cash, checks, and other forms of legal tender received by the Agency and will perform the following procedures.
OMB Circular A-110 prescribes the procurement standards when using Federal funds. The following requirements are to be followed when purchasing goods and services for AACS programs and functions.
A. Positive efforts shall be made to utilize small business and minority owned business as sources of supplies and services. Such efforts should allow these sources the maximum feasible opportunity to compete for contracts utilizing Federal funds.
B. The "cost-plus-a-percentage-of-cost" method of contracting shall not be used.
C. Contract shall be made only with responsible contractors who possess the potential ability to perform successfully under the terms and conditions of a proposed procurement. Consideration shall be given to such matters as contractor integrity, record of past performance, financial and technical resources or accessibility to other necessary resources.
D. Competitive Procurement will be in accordance with the following:
E. The Agency shall include the following provisions in all contracts. These provisions shall also be applied to subcontracts.
The program directors are primarily responsible for compliance with the Agency's Procurement Standards and any other specific grant on contract requirements. The Executive Director, Financial Administrator and the Purchasing and Receiving Manger will provide consultation regarding the Agency's procurement standards and are responsible for monitoring compliance with these standards.
For the procurement of equipment, merchandise or services not requiring advance payments, the following documents and procedures will be used for all Agency purchases, except for items listed in the appendixes.
A. Requisitions -- A "requisition for goods and services" (requisition) must be completed for all purchases. The requisition consists of a white and yellow copy and is the primary document used by Agency employees for the requisition of goods and services. Due to the number of programs and the number of center locations it is not practical to use purchase orders; consequently, purchase orders will be used only when required by the vendor.The following procedures apply to requisitions:
B. Receiving -- The requisition document will be used to document that the goods and services have been received. The following procedures will be used:
C. Review -- After the goods or services have been received, the requisition along with original invoice should be forwarded to the Purchasing and Receivables Manager. The Purchasing and Receivables Manager will attach a purchase order, if required, to the requisition and invoice and forward them to the Payable Manager for payment. Purchase order copies will be distributed or filed as follows:
Purchases requiring payment in advance will follow the same procedures as other purchases, except for the following:
A. The white copy of the requisition along with the vendor order form will be forwarded to the Purchasing and Receivables Manager.
B. The yellow copy of the requisition will be retained by the Central Office until the goods or services have been received. The Central Office will then sign and date the appropriate blocks on the requisition to indicate that the goods or services have been received and forward the requisition to the Purchasing and Receivables Manager.
The Purchasing and Receivables Manager will follow the same procedures as other purchases, except for the following:
A. The Purchasing and Receivables Manager will make a photocopy of the white copy of the requisition and attach it to the original (white) requisition and vendor order form and forward them to the Payables Manager for payment.
B. The Payables Manager will prepare either a manual check or a computer check in accordance with the Agency's cash disbursement procedures. The check number will be recorded on the photocopy of the white copy of the requisition by the Payables Manager and returned to the Purchasing and Receivables Manager.
C. The Purchasing and Receivables Manager will maintain a file of the photocopy of the white requisition by program by month until such time the yellow copy of the requisition is received. Once the yellow copy is received the photocopy will be destroyed and the yellow copy will be stapled to the copy of the check and supporting documents in the regular invoice file.
D. The yellow copy of the requisition should be forwarded to the Purchasing and Receivables Manager within ninety (90) days. The Purchasing and Receivables Manager will periodically review the outstanding requisition and will notify the Program Directors of any requisitions that are ninety (90) days old or older.
The Agency uses a voucher system for the payment of assistance in the area of utilities, meals, food, transportation, lodging, etc. for families and individuals in the Agency's service area. The voucher system requires a voucher to be prepared for every payment. To voucher a payment it is necessary to make out a voucher form giving the facts about the amount to be paid. Vouchers are prepared and signed only by duly authorized persons in the Agency. Furthermore, a check is written only when a duly authorized and signed voucher is presented.
In addition to the voucher, the Agency will maintain a voucher register by county. Each voucher will be numbered consecutively for control purposes and entered into the voucher register in numerical order. Two columns are provided in the voucher register C one for the number of the check and one for the date of payment. In addition, the voucher register will contain columns such as vendor, client, amount and type of assistance, etc.
The payment of vouchers will be in accordance with the Agency's regular cash disbursement procedures. The Financial Administrator is responsible for designating which programs will use the voucher system for assistance type payments.
The Payables Manager is responsible for the preparation of checks for the payment of all invoices and related payables for goods and services. The process of check preparation which is primarily computer generated involves the recording of expenses to the various programs and funds operated by the Agency. The following procedures shall be followed.
A. Vendor statements, Blue Cross statements, telephone bills, contracts, leases, etc. along with completed requisitions and purchase orders when required should be forwarded to the Payables Manager. The Payables Manager will date everything as it is received and will prepare bills for payment as follows:
B. The Payables Manager or designated fiscal staff will verify that all bills are properly supported by documentation, properly approved, and properly coded by the Program Directors or designated persons. Bills not properly supported in accordance with the above will be sent back to the Program Directors. Bills properly supported will be entered into the computer for payment.
C. Bills are entered into the computer by the Payables Manager or fiscal staff from coding sheets if multiple accounts are involved or from the requisition if only a few accounts are involved.
Computer checks are written twice a month on or near the 10th and 25th of each month. Checks are printed by the computer and this process involves the posting of the expenses to the various programs and accounts. Consequently, various edits will be performed prior to the printing of the checks and the posting of the expenses. In addition to the checks, the following reports will be printed and filed:
A. Precheck Audit Report -- Filed in Payables office in a blue folder.
B. Check Register/Bank Cash Requirements/Recap of Check Register -- Filed in the blue Payables Check Register Book.
C. Final Posted Transactions -- Filed in Accounts Payable folder.
D. Edit List -- After the Executive Director and Financial Administrator have reviewed it, file in the Final Edit List file kept in the Payables Office.
Check Signing -- The following procedures apply to all check signing:
A. Check signers are authorized by the Board of Director periodically as deemed necessary by the Executive Director.
B. Check Signers will be independent of:
C. Signing blank checks is forbidden.
D. The facsimile signature plate for the check signing machine will be controlled by the Financial Administrator who will authorize its use.
E. Blank check stock will be locked in the Finance Department's computer room to prevent unauthorized use.
F. Custody of checks after signature and before mailing will be controlled by the Financial Administrator who will supervise the mailing.
G. The vendor's invoice, requisition if required, purchase order if required, and coding sheet if required are stapled to the copy of the check and filed in check number order in the regular paid invoice file.
The Agency's "Personnel Policy & Procedures Manual" contains the procedures and authority for all employee actions. These policies provide that the Executive Director is the authorized person for executing and signing personnel actions. The following procedures apply to all personnel actions:
A. The Personnel/Orientation Manager is responsible for conducting new employee orientation. As part of the orientation the Personnel/Orientation manager obtains the following which are kept in the employee's personnel file:
B. For new employees a "Letter of Appointment Information Sheet" signed by the Executive Director accompanied by a "Employee Payroll Information" document will be sent to the Personnel/Orientation Manager and Property Office. The Personnel/Orientation Manager and Property Officer will do the following:
C. The Payroll Manager will use information contained in the "Letter of Appointment Information Sheet" and "Employee Payroll Information" sheet to set-up employee information in the computer's payroll master file. A file will be maintained in alphabetic order of all personnel actions by the Payroll Manager.
D. Program Directors or Supervisors upon receipt of "Letter of Appointment Information" will notify employee of appointment.
The following personnel actions will be handled in the same manner:
The Agency's employees will be paid on a biweekly basis ending on Friday. Payroll checks are issued on the second Friday following the end of the biweekly payroll period. The following shall apply to the Agency's payroll procedures:
A. Time Sheets -- time and attendance reports, showing hours worked, signed by the supervisor and properly dated are required by all Agency's employees. The following procedures apply to time sheets:
B. Payroll Checks and Register -- During the processing of payroll checks and the various payroll registers, edits will be made prior to running payroll checks to assure that no errors have been made. The procedures for payroll checks are as follows:
The Agency has had an approved Indirect Cost Rate Agreement since 1984, which is annually negotiated. The following procedures will be followed relative to indirect costs.
A. Indirect Cost Proposal -- Within six months after the close of the fiscal year the Agency shall submit a new indirect cost proposal covering the new fiscal year to the cognizant federal agency. The following procedures will be followed:
B. Indirect Costs -- The Indirect Cost Rate Agreement identifies the salaries and expenses which are to be treated as indirect cost. These expenses (administrative costs) will be accounted for in a separate fund. In lieu of charging administrative cost direct to the various programs the following procedures will be followed:
The Agency shall use formal contracts for all projects for contracts involving professional or technical contracts. The Executive Director must approve all professional and technical service contract or in the absences of the Executive Director, the Associate Director. Contracts exceeding $1,000 in the aggregate must use the "long form" and contracts for $1,000 or less can use the "short form." An example of these contracts can be found in the Financial Procedures Manual.
A. Selection -- The following will be considered before contracting for professional or technical service:
B. Payment -- Consultant services will be paid as the work is performed, or at some later date as may be specified in the contract.
The Agency shall use formal lease documents which state the amount of rent and other conditions relating to the lease. The Program Director shall negotiate for use of facilities; however, all leases will be approved and signed by the Executive Director or in the absence of Executive Director, the Associated Director.
A. Selection -- The following factors will be considered before entering into a lease:
B. Payment -- Lease payments generally will be made monthly and will be paid in advance. Leases which require more than a one month advance should be avoided, whenever possible.
Employees and other individuals representing the Agency are entitled to reimbursement for travel expense incurred during the course of trips made on official business for the Agency. Reimbursement will be in accordance with rates listed in the official Standardized Federal Government Travel Regulations.
A. In-Area Travel - Travel which is within the Kentucky Counties of Daviess, Hancock, Henderson, McLean, Ohio, Union and Webster and the additional Pennyrile Area Counties for Head Start employees is classified as local or in-area travel.
B. Out-of-Area Travel -- Travel which is outside the Agency's service area is classified as out-of-area travel. The Agency's service area include the Kentucky Counties of Daviess, Hancock, Henderson, McLean, Ohio, Union, and Webster, and for Head Start employees, the counties located in the Pennyrile Area.
The Payables Manager will periodically review the travel advance file for old outstanding travel advances and report any to the Executive Director.
The Agency will accept all contributions or donations which can be used effectively in the operation of the Agency or its programs. These contributions or donations may be in cash or in-kind.
A. Cash Donations -- The Executive Director, Associate Director and Program Directors are authorized to accept cash donation on behalf of the Agency or its programs. The following procedures shall be followed for all cash donations:
B.In-Kind Contributions -- In-kind contributions usually fall into the following categories: (a) Donated Services; (b) Supplies; (c) Loaned equipment or space; or (d) Donated equipment, building or land. The following procedures shall be followed for all in-kind donations.
The Agency has Federal sponsored program which requires cost sharing and matching. In general cost sharing and matching represent that portion of project or program costs not borne by the Federal Government. Cost sharing or matching may consist of:
A. Charges incurred by the Agency as project costs.
B. Project costs financed with cash contributed or donated to the Agency by other non-federal public agencies and institutions, private organization, or individuals.
C. Project costs represented by services and real and personal property, or use thereof, donated by other Non-federal public agencies and institutions, private organizations or individuals.
All contributions, both cash and inkind, shall be accepted as part of the Agency's cost sharing and matching when such contributions meet all of the following criteria:
A. Are verifiable by the Agency's records.
B. Are not included as contributions for any other federally-assisted program.
C. Are necessary and reasonable for proper and efficient accomplishment of project objectives.
D. Are types of charges that would be allowable under the applicable cost principles.
E. Are not paid by the Federal Government under another assistance Agreement (unless the Agreement is authorized by Federal law to be used for cost sharing or matching).
F. Are provided for in the approved budget when required by the Federal Agency.
In-kind services will be valued in accordance with procedures on contribution and donations. In addition, the accounting for cost sharing and matching will be in accordance with procedures on contributions and donations.
Program Directors are responsible for cost sharing and matching requirements for their respective programs. Accordingly, cost sharing and matching requirements will be reviewed by program directors during the budgeting process and also as part of their review of cost and cost reports.
The Financial Administrator will review cost sharing and matching as part of the budgeting, reporting, and close-out process for Agency's programs.
Grant and subgrant - related income refers to: (1) interest and other investment income earned on grant funds, and (2) program income.
Except where exempted by Federal Statute, the Agency shall remit to Federal sponsoring agency any interest or other investment income earned on grant funds. The following procedures shall apply to interest and investment income.
A. The Financial Administrator in consultation with the Program Director will develop a chart of accounts which will provide for separate accounts for recording interest and investment income earned on the grant program.
B. Unless the Agency receives other remittance instructions from the sponsoring federal agency, the Financial Administrator through the Agency's disbursement procedures shall remit the amount due by check to the sponsoring Federal Agency.
C. Interest earned on grant funds will be reported by the Financial Administrator on the SF-272 or PMS-272, line 13.a of the Federal Transaction Report.
Program income generally means gross income earned by the Agency from activities, part or all of the cost of which is either borne as a direct cost by a grant or counted as a direct cost towards meeting a cost-sharing or matching requirement of a grant.
A. Examples of Program Income:
B. General program income will be retained by the Agency and, unless the grant permits alternate procedures, the income will be used for allowable costs of the project or program. If there is a cost-sharing or matching requirement, costs borne by the income may not count toward satisfying that requirement. Therefore, the maximum percentage of Federal participation is applied to the net amount determined by deducting the income from total allowable costs and third-party in-kind contributions. The income shall be used for current costs unless the granting agency authorizes deferral to a later period.
The following procedures shall be used by the agency when program income is generated by a federal sponsored project or program:
A. The Program Director is responsible for anticipating program income and negotiating with responsible Federal officials during the funding or refunding stage of the grant a method for the use of program income which would benefit both the project and the Agency.
B. The Financial Administrator in consultation with the Program Director will develop a chart of accounts which will provide for separate accounts for recording program income on the grant program.
C. Program income will be reported on the SF-272 in accordance with the SF-272 specific instructions by the Financial Administrator.
Income Taxes--The Agency is exempt from income taxes under Internal Revenue Code Section 501 (c)(3). However, the Agency may be subject to income tax if it has income from operation of a business enterprise not related to the purpose for which it received its exemption.
Sales and Use Taxes -- The Agency is exempt from Kentucky Sales and Use tax on property used for its exempt purpose.
State and County Property Taxes--The Agency is exempt from tangible and intangible property taxes on property used for its exempt purpose.
Federal Unemployment Taxes--The Agency is exempt from federal unemployment taxes as a result of it being exempt under Internal Revenue Code Section 501 (c)(3).
The Agency is responsible for the following federal, state, county and city taxes:
Federal Withholding Tax--The Agency will withhold federal income taxes from employees wages based on Form W-4 (Withholding Allowance Certificate) and applicable withholding tables. Taxes withheld will be deposited in an authorized institution or Federal Reserve Bank within three days after they have been withheld.
Social Security Taxes (FICA)--The Agency will withhold FICA taxes from employees wages based on applicable rates prescribed by the Internal Revenue Service. FICA taxes withheld will be matched by the Agency and deposited in an authorized institution or Federal Reserve Bank within three days after they were withheld.
State Income Taxes--The Agency will withhold state income taxes from employees wages based on withholding allowance certificates and applicable withholding tables. Taxes withheld will be remitted to the states based on their requirements.
City and County Taxes--The Agency will withhold city and county taxes from employees wages based on applicable rates prescribed by the city or county governments. Taxes withheld will be remitted to the city or county governments based on their requirements.
State Unemployment Taxes--The Agency is responsible for unemployment taxes which are based on employee earnings multiplied by an assigned rate. Unemployment taxes will be paid quarterly to the appropriate state unemployment commission.
The Payroll Manager is responsible for
preparing all payroll tax reports for the Agency. The Payroll
Manager is also responsible for preparing all checks for payment
of payroll taxes.
The Financial Administrator will review
all payroll tax reports. In addition, the Executive Director
is authorized to approve and sign payroll reports or in the absence
of the Executive Director, the Associate Director.
The Agency's telephones have been installed
based on need and for the benefit of its programs. Each telephone
is assigned to a particular program and should be used only to
conduct business related to that program. Program Directors are
responsible for their telephones and should annually review their
needs. The following procedures relate to Agency's telephones:
A. Security codes have been installed
to assure that programs are properly charged and to ensure that
programs are not charged for unauthorized calls. These security
codes are confidential.
B. Collect calls are prohibited except
for calls from known staff members.
C. Personal Calls -- Because personal
calls may tie up the lines and delay important business matters,
personal calls should be limited to cases of real need or emergency.
D. Long Distance -- The following procedures
should be followed for all long distance calls:
E. Telephone Bills -- Program Directors
are responsible for their telephone bills. The following procedures
will be used for monthly telephone bills:
The Agency will maintain adequate insurance
to attempt to protect itself against possible claims or damages
resulting from fire and theft, property damage, personal injury,
and liability.
A. Insurance Policies--The Personnel/Orientation
Manager and Property Officer will maintain an insurance file which
contains all of the insurance policies maintained by the Agency.
B. Adequacy of Insurance--Annually the
Executive Director and Personnel/Orientation Manager and Property
Officer will review the adequacy of coverage before renewal.
C. Types of Insurance--The Agency will
maintain insurance coverage in the following general areas, subject
to budgetary limitations and other considerations:
D. Private Insurance--In addition to
the insurance carried by the Agency, each employee who uses his
or her personal car for any purpose related to his or her position
with the agency must have liability insurance coverage as required
by Kentucky Statute.
Program Directors are authorized to establish
petty cash funds as they deem necessary; however, the following
procedures will be followed:
A. A petty cash fund cannot exceed $400.00.
B. Responsibility for each fund will
be assigned to only one person.
C. Petty Cash fund will be maintained
on an imprest basis.
D. Disbursements cannot exceed $100.00
for any item or purpose.
E. Disbursements must be supported by:
F. Loans to employees and cashing accommodation
checks are prohibited.
G. Reimbursements to petty cash funds
should be as follows:
H. Program Directors are responsible
for the petty cash funds and should conduct or designate someone
to conduct surprise counts of their petty cash funds at least
twice a year.
I. The Financial Administrator or designee
is also authorized to conduct surprise counts of petty cash funds
and report any problems to the Executive Director.
The Agency in order to operate must at
various times borrow monies from outside sources. The following
procedures will be used for financing arrangements and the incurrence
of other liabilities (including lease transactions):
A. All borrowing must have the prior
approval of the Board of Directors.
B. The Executive Director or Chairman
of the Board of Directors are the only persons authorized to sign
loan documents.
C. The Financial Administrator is responsible
for all debt records and for reviewing compliance with debt covenants
periodically.
D. Interest incurred on any borrowing
cannot be charged to programs sponsored by Federal Funds, accordingly,
the Executive Director will designated the unrestricted program
fund to be charged.
Restricted funds such as Federal and
state grants, endowment, and donor restricted funds cannot be
used for purposes other than the purpose for which they were designated.
Consequently, restricted funds cannot be loaned to other funds
or other programs within the fund. It is the combined responsibility
of the Executive Director, Financial Administrator and program
directors to monitor restricted funds to assure that violations
do not occur.
Unrestricted funds represent resources
over which the Board of Directors has discretionary control and
are used to carry out operation of the Agency in accordance with
its bylaws. The following procedures are to be followed:
A. Loans from unrestricted funds to other
funds or programs must have the approval of the Executive Director.
B. Loans from unrestricted funds to other
funds or programs will be recorded as interprogram receivables
and payables. These accounts will be reconciled monthly by the
Purchasing and Receivables Manager.
C. Employee loans are prohibited.
Each program or department is responsible
for their own records and files. The following applies to all
financial and programmatic records, supporting documents, statistical
records and other records, which are:
A. Required to be maintained by the terms
of a grant or contract.
B. Required to be maintained by the Internal
Revenue Code or other Federal regulations.
C. Required to be maintained by the Commonwealth
of Kentucky Statutes or other Kentucky regulations.
The following retention periods will
be used by the Agency:
A. Records shall be retained 5 years
from the date of the Agency's fiscal year end which ends on the
last day of February, except as follows:
3. The retention period for equipment
records, where the equipment was purchased in whole or in part
with Federal funds, will be 3 years and the retention period will
begin on the date of the equipment's disposition, replacement,
or transfer at the direction of the awarding party.
Copies made by microfilming, photocopying,
or similar methods may be substituted for the original records.
Access to the Agency's records will be
as follows:
A. Access to any Federal sponsored programs
will be as follows:
B. Access by the Internal Revenue service
and the Commonwealth of Kentucky regulators will be in accordance
with the applicable laws and regulations.
C. Access to all non-federal grants will
be in accordance with contract or grant terms.
D. Access by the general public will
be in accordance with Chapter 65 and 424 of the Kentucky Revised
Statutes.
The Executive Director in coordination
with the Financial Administrator will designate and coordinate
the storage of all Agency records.
The Executive Director in coordination
with the Financial Administrator and, if appropriate, Program
Director will direct and provide access to any Agency records.
The Agency's By-Laws provide that the
Directors of the Agency (Corporation) shall serve as such without
compensation, except that the Board may authorize reimbursement
of reasonable expenses incurred by the Directors in performance
of their duties. The Agency also has several advisory groups
affiliated with its sponsored programs. These advisory groups
including the Head Start Policy Council also serve without compensation
and for all intents and purposes are treated the same as Directors.
Travel expenses incurred by Directors and Advisory groups will
be reimbursed in accordance with the Agency's travel procedures.
Each grant or program shall be closed
out as promptly as is feasible after expiration or termination.
In closing out grants or programs, the following procedures shall
be observed:
A. Request for payment should be filed
for any allowable reimbursable costs not covered by previous payments.
B. The Agency shall immediately refund
or otherwise dispose of, in accordance with instruction from grantor,
any unobligated balance of cash advanced.
C. The Agency shall submit, within 90
days of the date of expiration or termination, all financial,
performance, and other reports required by the terms of the grant.
D. The Agency shall make a settlement
for any upward or downward adjustment of the Federal share of
costs, to the extent called for by the terms of the grant.
Closeout will require the combined effort
of the Program Director and the Financial Administrator. Reports
should be prepared and approved in accordance with the Agency's
financial reporting requirements.
The bank accounts of the Agency will
be reconciled promptly after the end of each month. The following
procedures will be used:
A. The Clerical Assistant is the person
designated to prepare all bank reconciliations.
B. The Clerical Assistant receives all
bank statements (with canceled checks, debit and credit advices,
etc.) unopened from the bank.
C. The Clerical Assistant's procedures
for all bank accounts include the following with respect to disbursements.
D. The Financial Administrator will supervise
and review completed reconciliations.
The Agency's procedures for occupancy costs are as follows:"
A. If the agency owns a facility used for any program, the Agency will charge only depreciation or use allowance based upon the purchase price of the building.
B. If the Agency rents facilities used for a program, documentation will be obtained to show that charges are reasonable.
C. If the Agency is using occupancy costs as Non-Federal share, values will be calculated as follows:
D. All contracts or agreements will be legally sound and will be in the best interest of the agency.
E. If the renovations are included under the grant, such renovations will qualify as renovation and not construction and will be charged in accordance with the cost principles and, if appropriate, ACF guidance.
TELEPHONE:
BONDING AND INSURANCE:
PETTY CASH:
BORROWING:
LOANS:
RETENTION AND ACCESS REQUIREMENTS FOR
RECORDS:
COMMITTEES AND BOARD EXPENSES:
CLOSEOUT OF GRANTS OR PROGRAMS:
BANK RECONCILIATION:
OCCUPANCY:
Return to...
AACS IntraNet Links
AACS World Wide Web Pages
Last updated on June 30, 2005 ||