Page
101
Appendix D: Federal Grant Criteria and Regulations Related to Finding 6
Uniform Guidance 2 Code of Federal Regulations (CFR) Part 200 criteria applicable to all grants in this finding:
2 CFR 200.302(a)
Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR 200.303(a)
The non-Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.403 Factors affecting allowability of costs.
Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
Be adequately documented.
Higher Education Emergency Relief Fund (HEERF)
1. HEERF Student Aid Portion
The HEERF Student Aid Portion grant agreement award notification requires HEERF Student Aid grant funds were to be “liquidated within 15 days of receipt” consistent with 2CFR 200.305. “Grantee must maintain drawn down grant funds in an interest-bearing account, and any interest earned on all Federal grant funds above $500 (all Federal grants together) during an institutions fiscal year must be returned (remitted) to the Federal government.”
2 CFR 200.305(b) states, “For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.”