Prior to making a grant purchase, Grants Accounting must set the grant up in the accounting system and assign a unique cost center number.
Grant purchasing follows the same Procurement Policies and Procedures used for any other CCCC purchases. Procurement actions with federal funds must also conform to regulations as stipulated in 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”), 200.318 to 200.326. For more information on Procurement Policies and Procedures, please see Procurement website.
The PI/PD and their supervising Dean/VP are responsible for understanding and following the applicable purchasing requirements stipulated in the terms and conditions for the grant award(s). The PI/PD, Grant Compliance Analyst, and/or Grant Accountant review costs before charging them to an award to ensure that they are allowable. All grant purchases should be accompanied by a Grant Activity Procurement that documents allowability as well as proper procurement procedures.
The Grants Office or Grants Accounting should be contacted for specific questions concerning grant expenditures in advance of the incurrence of a cost.
Allowable Expenditure Information
For ALL awards:
- The expense must adhere to sponsor-specific policies and award-specific terms and conditions.
- The expense must adhere to CCCC policies regarding the specific cost and item.
- The expense must be adequately documented.
Additionally, all costs charged to a federally sponsored award must be:
- Reasonable. Costs must not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost (i.e., a prudent person would purchase the item at that price).
- Allocable to the specific project – incurred specifically to advance the project funded by the award and assigned to the award in accordance with the relative benefit received by the award.
- Consistent with the way the same costs are treated in like circumstances at CCCC.
- Allowable under applicable federal cost principles, agency-specific policies, award-specific terms and conditions, and CCCC policies.
For grant budget purposes, equipment is any item that costs more than $5K and has a useful life of more than one year. Before purchasing equipment, determine if prior approval from the sponsoring agency is required and follow appropriate procurement procedures. All equipment should be purchased well in advance of the last 90 days of a grant period, with some awards having a specific deadline for equipment purchase.
Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place, requires that a physical inventory be conducted consistent with College policies and procedures and that the property records include:
- Local college tag number to link to record information
- Description of the property
- Serial number or other identification number
- Source of funding for the property (including the FAIN/Award number; CFDA number)
- Who holds title
- Acquisition date
- Cost of the property
- Percentage of Federal participation in the project costs for the Federal award under which the property was acquired
- Use and condition of the property
- Any ultimate disposition data including the date of disposal and sale price of the property
Grant-funded travel must be consistent with College Travel Policies and Procedures. Prior to arranging travel, review allowable travel requirements under the sponsoring agency and the grant terms and conditions.
Consultant or Vendor Agreements
Agreements to secure the services of a consultant or other professional services on a grant-funded project are created for the services described in the proposal narrative and budget. Consultants are independent contractors and not employees of the College. Prior to making the decision to hire a consultant, PI/PDs need to determine whether the individual is considered an employee or a consultant/independent contractor. Contact the Grants Office or Grants Accounting for guidance in determining if a consultant or vendor agreement is necessary and appropriate. Depending on cost, you may have to obtain quotes or use bid procedures for consulting and other professional services. CCCC employees cannot be hired with grant funds to provide professional services outside their regular duties, except in certain specific situations and only if explained in the awarded budget.