Chapter 4: Business & Administration04:10:02 Grant Administration
Related Policies and Guidelines
TBR Guideline G-030 Contracts
NeSCC Policy 04:10:01 Grant Development
NeSCC Policy 05:02:02 Grant Project Personnel
Northeast State periodically applies for and receives grants to initiate, expand, and enhance education, workforce development, and student support programs that align with strategic priorities of the College and the Tennessee Board of Regents. Grants should be viewed as contracts and administered accordingly. Grant funds are designated for specific activities to be performed within a specific timeline for the purpose of achieving specific objectives.
The purpose of this policy is to establish a uniform and coordinated approach to grant administration at Northeast State Community College, and to ensure that all externally-funded projects are managed in accordance with State of Tennessee, Tennessee Board of Regents, NeSCC, and funding agency policies and regulations.
This policy establishes the processes to be followed by Northeast State Community College employees or contractors in the administration of externally-funded projects. It applies to all grants awarded to the College or to the Northeast State Community College Foundation by any external funding source. The Grant Development Office is responsible for developing and distributing procedures to support this policy.
The term “Project Director” is used throughout this policy to refer to the individual that is responsible for administering a grant-funded project. This person might also be known as a “Principle Investigator,” “Grant Coordinator,” or other title, depending on the funding source or their position within the College’s organizational structure.
Role of the Grant Development Office
The Grant Development Office provides centralized oversight and support for administration of all externally-funded projects.
Post-Award responsibilities of the Grant Development Office include, but are not limited to:
- maintaining a calendar of all internal and external grant reporting and compliance deadlines;
- providing technical assistance to grant project staff on issues related to grant management, compliance, and reporting;
- monitoring implementation of externally-funded projects to ensure timely completion of performance objectives and appropriate expenditure of grant funds; and
- maintaining appropriate files and documentation for all grant-related activities and acting as a central repository for institutional grant records;
Unless otherwise directed by the President, the Grant Development office functions as the designated college liaison with grant funding agencies and organizations and serves as the primary point of contact for all grant-related communications.
Responsibilities of Grant Project Directors and Staff
Grant project directors, their supervisors, and other staff working on externally-funded projects are responsible for implementing those projects in accordance with this policy, funding agency terms and conditions, and other applicable policies and regulations.
Upon notice of award, and prior to project implementation, grant project directors must acknowledge their understanding of these and other responsibilities as delineated on the Grants Management Responsibility Matrix and Conflict of Interest Disclosure Form. The acknowledgement may be submitted electronically, via the College’s grant management software, or via a physical signature on a hard copy form submitted to the Grant Development Office.
Notice of Award & Negotiations
Generally, written notices of grant awards are delivered to the Grant Development Office, at which point the Director of Grant Development and Grant Compliance Officer will initiate project start-up activities, ensuring that award documents are executed and distributed appropriately and that all conditions of the grant award are addressed. In the event that a project director or other College employee receives notice of a grant funding decision, they must inform the Grant Development Office immediately.
If the grant award amount is different than the amount requested in the proposal, or if the funding agency requests changes to the grant budget, Grant Development staff will be responsible for budget negotiations, in consultation with Finance staff as appropriate to ensure that the College’s financial interests are protected.
Regardless of funding source, all financial transactions and administrative processes conducted under the auspices of the College are subject to State of Tennessee, Tennessee Board of Regents, and Northeast State policies and procedures, including hiring of grant-funded personnel, purchasing, and travel. No funding agency terms, conditions, or regulations shall be construed to negate, override, or otherwise offset this obligation.
Project directors are responsible for initiating or approving all grant expenditure requests and ensuring that sufficient funds are available in the grant to cover the expense. The grant fund code must be included on all paperwork associated with grant expenditures. Expenditures must be:
- consistent with the most recently approved grant budget;
- allocable to the project; and
- allowable under federal cost principles, funding agency terms and conditions; and/or State of Tennessee, TBR, and Northeast State policies.
Project directors are responsible for monitoring grant expenditures closely, maintaining up-to-date spreadsheets or similar tool to track grant expenditures and retaining appropriate supporting documentation. Project directors must reconcile their budget records with official Banner accounting records at least monthly.
Cost Sharing or Matching
Any matching funds or cost sharing commitments included in grant proposals must be documented during project implementation, and are subject to audit. It is the responsibility of the project director to maintain adequate documentation of matching funds as the project is carried out.
Time & Effort Reporting (See NeSCC Policy 05:02:02 Grant Project Personnel)
Any employee whose salary (wage) is supported in whole or in part by grant funds shall complete and submit monthly time and effort forms, certifying after-the-fact that the time charged to the grant is consistent with the actual work performed in support of grant objectives.
Any employee whose effort is committed as in-kind contribution for a grant award shall complete and submit monthly time and effort forms, certifying after-the-fact that the time claimed as match for the grant project is consistent with the actual work performed in support of grant objectives.
The Grant Development Office is responsible for coordinating monthly time and effort reporting processes via electronic requests generated through its full life cycle grant management software.
Modifications and Amendments
Grant proposal budgets and work plans are developed based on a set of assumptions. During project implementation, evolving circumstances may necessitate modifications to the budget, such as the transfer of funds between categories, or to the work plan, such as a change in key personnel or objectives. Requirements for budget and/or program modifications may vary by funding agency. In all cases, proposed modifications must be reviewed and approved by the Grant Accountant, the Director of Grant Development, the supervising vice president, and the President before they can be submitted to the funding agency for approval.
At minimum, grant project directors must follow these general steps to initiate a budget or program modification:
- discuss the proposed modification with the Grant Development Office;
- complete the Request for Grant Modification Form and secure the necessary internal approvals;
- coordinate with the Grant Development Office to submit the modification request to the funding agency in accordance with established guidelines, if necessary; and
- provide the Grant Development Office with copies of all submitted modification documents and associated approvals/responses from the funding agency.
Data Collection and Evaluation
Provisions for the collection of data from College systems and databases in support of grant administration and program evaluation should be negotiated and coordinated with the Research, Analytics, and Planning (RAP) Office. The use of data must be consistent with federal and state laws and TBR/College policy.
The project director is responsible for completing and submitting all programmatic progress reports in accordance with funding agency requirements. At minimum, reports should describe progress made toward the accomplishment of project objectives; highlight the project’s strengths; identify obstacles to implementation; and describe strategies to address weaknesses. Some funding agencies provide specific reporting forms, templates, or guidelines to which reports must adhere. Draft grant reports should be submitted to the Grant Development Office for review prior to submission to the funding agency. Final copies of all grant reports must be filed with the Grant Development Office.
The Grant Development Office is responsible for maintaining all official records relating to grants managed on behalf of Northeast State Community College and/or the Northeast State Foundation. In some cases, the Grant Development Office is responsible for submitting official grant reports and correspondence. In the event that these responsibilities are handled by grant project staff, the individual(s) responsible for submission of reports and official correspondence must provide the Grant Development Office with copies of all submitted documents.
Grant Development staff will coordinate with Project Directors during the grant closeout process to ensure that project records are retained in accordance with applicable state, federal, and/or funding agency guidelines.
In the event that College personnel with grant management responsibilities leaves employment with the College for any reason prior to grant closeout, the former employee’s immediate supervisor should coordinate with the Grant Development Office to ensure that all files, documents, and records associated with the administration of the grant project are retained in accordance with applicable state, federal, and/or funding agency requirements.
At minimum, retention of records for grant-funded projects must comply with State of Tennessee records retention regulations, which require administrative and fiscal records associated with grant projects to be retained for five years after grant closeout. These guidelines are generally consistent with requirements for most federal grant programs. The project director must abide by the most stringent regulations applicable to any particular project. If the grant award terms and conditions stipulate a longer retention period, they must be followed.
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|Divisional Review Responsibilities Checklist: Administration and Grant Development|
Revision History: Adopted March 2021