Seattle College District Procedure

NUMBER: 670

TITLE: SCD GRANTS AND CONTRACTS

INDEX

670.10 — Overview
670.20 — Applications and Proposals
670.30 — Financial Guidelines
670.40 — Approval Process
670.50 — Required Documentation
670.60 — Application/Proposal Submission
670.70 — Receiving Awards and Grants
670.80 — Amendments and Cancellations
670.90 — Closing the Grant/Contract

APPENDICES

670.10   Overview

Contracts are agreements entered into between the District/College(s) and another entity in return for programs or services described in a written agreement. Often, contracts will generate funds or Program Income for general use by the College (refer to the definition of Program Income in APPENDIX A, Definitions).

Grants are monies received in return for programs or services performed over a period defined by the Grantor (refer to the definition of Grantor in APPENDIX A, Definitions). Grantors might be federal, state or local government agencies, private foundations, or other entities external to the District or College. Grant funds are restricted based on the Grantor’s intent and may contain requirements for matching or leveraged funds and/or periodic progress reports. Applications and proposals and financial and performance reports are generally submitted in a format established by the Grantor. If the Grantor has indicated no restrictive purpose, the funds are considered unrestricted for use in general by the District or College.

670.20   Applications and Proposals

ALL applications and proposals must:

1. Follow the specific instructions and format established by the Contractor/Grantor.
2. Support the overall mission and goals of Seattle Colleges.
3. Conform to District policies and procedures (including requirements for consulting impacted College departments and obtaining approval before submission, as described further in District Procedure 670.40), legal and financial considerations, and District/College service capabilities.
4. Include a budget that complies with District Procedure 670.30 described below and in APPENDIX D, Financial Considerations and Summary Guidance, which describes financial guidelines in detail.
5. Satisfy space and facility requirements unless costs for additional space and utilities are included within the funding provided by the Contractor/Grantor (refer also to APPENDIX D, Financial Considerations and Summary Guidance, for space and facility considerations).
6. Include matching funds when required by the Contractor/Grantor. District and/or College matching funds must be available when match or matching contributions are a condition of the contract or grant (refer to the definition of Match or Matching Contributions in APPENDIX A, Definitions, and to the procedure for obtaining approval before submission, as described further in District Procedure 670.50).

670.30   Financial Guidelines

Applications / proposals must comply with these financial guidelines and APPENDIX D, Financial Considerations and Summary Guidance. The application/proposal budget must include costs that are reasonable and allowable within the policies of the District, the Contractor/Grantor, 2 CFR 200 – Uniform Administrative Requirements, Cost Principles, cost principles for federal awards (for Federal grants), and the Washington State Office of Financial Management.

1. The Program Manager / Primary Investigator (PI) (refer to the definition of Program Manager in APPENDIX A, Definitions) must apply the following standards to determine the reasonableness, allowability, and allocability of all costs planned or charged to Federal Grants:
   1. The cost must be allowable as defined by federal regulations and by the terms of the particular award.
   2. The cost must be allocable, that is, the project paying the expense must benefit from it.
   3. The cost must be reasonable, that is, the cost reflects what a prudent person may pay.
   4. Additionally, regulations require consistency in how costs are applied across departments or programs. Costs may not be treated as direct expenses for one program and indirect expenses for another program.
2. When allowable, applications/proposals must include:
   1. Salaries and benefits that are consistent with District salary schedules or appropriate contract-training rates. Benefit costs must correspond to the employee salary; contact the College Business Office for information and rates.
   2. Other expenditure items including but not limited to contract services, goods & services, travel, equipment, and client services (such as tuition, lab fees, childcare, transportation, etc., for students).
   3. Indirect cost recoveries consistent with APPENDIX E, Indirect Costs. Refer also to the definition of Indirect Costs in APPENDIX A.
3. Certain types of expenses are not allowed to be charged to federal grants including:
   1. advertising (only certain types are allowable)
   2. alcoholic beverages
   3. entertainment
   4. fundraising or lobbying costs
   5. fines and penalties
   6. memorabilia or promotional materials
   7. moving costs if employee resigns within 12 months
   8. certain recruitment costs
   9. certain travel costs, e.g., first-class travel
   10. cash donations to other parties
   11. costs in excess of College severance policy
   12. interest payments
   13. memberships in civic, community or social organizations, or dining or country clubs
   14. goods or services for the personal use of employees, including automobiles
4. The Program Manager / PI must initiate a cost transfer when costs charged to a grant are deemed unallowable. The Program Manager / PI must send a request for cost transfers to the Campus Business Office, which reviews and approves the transfer request.

670.40   Approval Process

The Program Manager / PI must work closely with their College Grants Office in seeking contract or grant opportunities and navigating these Procedures. The College’s legal approving authority, the President or their delegated designate(s), must approve all contracts and grant applications/proposals for them to be binding upon the College.

1. Consulting Impacted Departments
   If other college departments are required to provide support to the project, such as registration, financial aid, counseling, advising, cashiering, computing support, etc., the Program Manager/PI must consult these departments prior to submitting the application/proposal. Communicating with other departments about the proposed project/program helps to ensure seamless implementation and operation of the project/program, if awarded.
2. Obtaining Required Signatures
   The application/proposal must be approved by the President or District Chancellor (for District wide grants) before being submitted to the Contractor/Grantor. Before the application/proposal may be submitted to the President or District Chancellor for approval, the application/proposal (and all other required documentation per District Procedure 670.50) must first be approved by the parties listed below using the applicable mechanism described in District Procedure 670.50.
   1. Program Manager / Primary Investigator (PI) and Sponsoring Dean Signature represents:
      • Knowledge and responsibility for the service to be provided, and in the case of federal grants, knowledge of the standards of cost reasonability, allocability, and allowability.
      • Responsibility for compliance with the grant / contract terms and conditions,
      • Responsibility for financial management of the grant or contract, and
      • Responsibility for program/project outcomes and results.
   2. Business Office/Operations Signature represents:
      • Determination that the budget is reasonable with verification that all costs, including indirect costs, are provided in the application/proposal; and
      • Verification that budgeted line items are allowable within the policies of the District, the Contractor/Grantor, and the Washington State Office of Financial Management, as applicable.
   3. Vice President for Instruction or Student Services (signature from sponsoring division only) Signature represents:
      • Determination that this program or service supports the college's mission and/or strategic plan,
      • Approval that this program or service meets all instructional or student services regulations and directives, and
      • Understanding of the financial commitment of the institution.
   4. Vice-President for Administrative Services Signature represents:
      • Knowledge of liability and financial commitments and risks associated with the project/program,
      • Understanding of administrative support to be provided to Program Manager/PI, and
      • Responsibility for invoicing and coordinating all financial transactions with District Office.
   5. College President or District Chancellor for District wide grants Signature represents:
      • Legally binding commitment to provide the program and/or service as described in the grant application or contract.
3. Additional Requirements if contract or grant involves a request to reduce or waive indirect costs or requires matching funds.
   1. Process for Approving Reductions or Waivers of Indirect Costs
      When allowable by the Contractor/Grantor, the application/proposal must include indirect cost recoveries consistent with APPENDIX E, Indirect Costs. If indirect costs requested are less than the amount/percentage allowed by the Contractor/Grantor, the District Chancellor (if the District is the applicant) or the College President (if the an individual college is the applicant) must approve the Request to Waive Indirect Costs (APPENDIX E) in advance.
   2. Process for Approving Matching Funds
      When a condition of the contract or grant, college matching funds must be available. Matching funds must be reasonably stated and have been specifically approved in advance by the District Chancellor, District Vice Chancellor for Finance (if the District is the applicant), or College President (if an individual college is the applicant).

670.50   Required Documentation for the application/proposal to be approved by the President

The President or District Chancellor (for District wide grants) must approve ALL applications/proposals before submission to the Contractor/Grantor. The following documentation is required for the application/proposal to be approved by the President or District Chancellor:

1. Application/proposal and/or summary of funding opportunity;
2. Request to Apply for External Funding (APPENDIX G) signed by the parties described in District Procedure 670.40;
3. Budget summary consistent with APPENDIX D, Financial Considerations and Summary Guidance;
4. Request to Waive or Reduce Indirect Costs (APPENDIX F) if Indirect Costs requested are less than the amount/percentage allowed by the Contractor/Grantor; and
5. At the discretion of the College, Program Manager/PI Agreement (refer to page 3 of APPENDIX I (Sample Contract).

670.60   Application / Proposal Submission
Once the application/proposal is approved by the President, the Program Manager/PI will coordinate the application/proposal submission with the Grants Office. The College Grants Office will maintain a complete record of the submission.

670.70  
Upon receipt of the award letter or contract signed by the Contractor/Grantor, the Program Manager/PI must coordinate with the following College offices:

1. Business Office to Create a Budget Number.
   The Program Manager/PI must provide a copy of the award letter and grant application/proposal to the College Business Office; the award letter is the basis for the College Business Office to create a budget number for the contract or grant. The Indirect Cost rate is associated with the newly created budget number based on APPENDIX E, Indirect Costs, which was included in the grant application and approved in the award.
2. Financial Aid Office to Create a Financial Aid Program Code (FAPC).
   If the contract or grant pays for tuition, fees, parking, or any other charges on behalf of students, the Program Manager/PI must initiate a FAPC request by coordinating with the Financial Aid Office and College Business Office. The Financial Aid Office creates a FAPC form that the College Business Office reviews and transmits to the District Budget Office for approval and activation.

670.80   Amendments and Cancellations
All amendments and/or cancellations of a contract or grant must adhere to the conditions of the agreement. Certain types of amendments (e.g., changes in Program Manager/PI, extensions and/or budget line item(s)) may require pre-approval by the Contractor/Grantor before changes can be made. The Program Manager/PI is responsible for understanding the Contractor’s/Grantor’s requirements and ensuring adherence to those requirements. The Program Manager/PI must coordinate with the following College offices:

1. Grants Office. For changes to the program/project that do not alter or change the fiscal structure of the grant, the Program Manager/PI must consult with the Grants Office before communicating these changes to the Contractor/Grantor.
2. Program Manager/PI must approve contracts, grants, and amendments prior to submitting for further approval as described in District Procedure 670.40. The College Presidents and Chancellor have delegated authority to the Program Manager/PI to accept grant amendments that do not change the fiscal structure of the grant
3. Campus Business Office. For any changes that affect the fiscal structure of the contract or grant (e.g., total contract or grant amount, budget line item(s), end date, indirect cost rate, billing process, or reimbursement base), the Program Manager/PI must coordinate with the College Business Office. The Business office will route any contracts included in amendments for signature approval following Policy 108.

   The Program Manager/PI must also work with the Grants Office to verify that the original requirements of the grant will be met given the budget revision.

670.90   Closing the Grant/Contract
The authority to expend the funds for a grant or contract expires upon completion of the grant or contract, or at the end of the funding period.

1. Within 90 days of the end date of the grant or contract, the Program Manager/PI in conjunction with the Grants Office and College Business Office must review the financial status of the grant or contract to determine if any closing adjustments need to be made.
2. If the grant or contract ends in a deficit (negative) position, a thorough review must be conducted by the Program Manager/PI and the College Business Office to determine the contributing factors. The Business Office will make decisions on what actions will be taken to correct deficits on a case-by-case basis.
3. If the grant or contract ends in a surplus (positive), the surplus will be transferred into the grant/contract reserve account when allowed by the Contractor/Grantor; otherwise the surplus funds will be returned to the Contractor/Grantor. Before surplus funds may be used/spent, the College Business Office must verify the availability of these funds. A department may request to expend any portion of a particular grant or contract surplus by completing a Surplus Usage Request Form (Appendix H).
4. The College Business Office will verify that all accounts receivable, accounts payable, encumbrances, and cash general ledgers are zero before the account may be closed. If not, the College Business office will work with District Accounting to clear the accounting entries.
5. The Program Manager/PI is responsible for submitting any performance reports to the Contractor/Grantor.
6. The College Business Office will officially close out and inactivate the budget number.

Chancellor’s Cabinet – Revision & Adoption History
Adopted: 4/25/2005
Revised: 4/25/2005
Revised: 3/27/2017
Revised: 3/19/2020