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C. Grant Management
1. The Administering Department shall manage awards in accordance with 2 CFR
200, Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards, applicable State laws and/or regulations, and
corresponding contractual agreements. FMS Grant Accounting shall provide
assistance and serve as a resource for clarification of any questions regarding 2
CFR 200.
2. If the grant has subrecipients:
a. The Administering Department, with assistance and support from FMS
Grant Accounting, shall perform a risk assessment for each subrecipient
before passing along awarded funds, in accordance with 2 Code of
Federal Regulations (“CFR”) §200.331, “Requirements for pass-
through entities,” and formulate a risk mitigation plan based on
identified risk factors.
b. The Administering Department, with assistance and support from FMS
Grant Accounting, shall perform subrecipient monitoring in accordance
with §200.330, “Subrecipient and Contractor Determinations,” and
§200.331, “Requirements for Pass-Through Entities,” and document
such monitoring.
3. The Administering Department shall monitoring contractors to ensure
compliance with all contract provisions.
4. All grant-related procurement activities must be conducted in accordance with
all applicable City policies and State and federal laws and regulations (e.g.,
Davis-Bacon Act).
a. If a capital asset is purchased or created with grant funds, FMS Grant
Accounting and FMS Capital Assets should be notified.
b. For federal grants, no local purchasing preference can be given.
c. For federal grants, cost plus a percentage of cost and percentage of
construction cost methods are prohibited.
d. The City is responsible for full compliance with the procurement
regulations contained in 2 CFR 200 (200.317-200.326).
e. Vendors shall be checked against the list of debarred/suspended vendors
on SAM.gov prior to awarding any contract and annually thereafter, at
a minimum.
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