• POLICY 721-P - Uniform Grant Guidance Procedure Federal Awards Administration Overview

    Purpose – This manual has been prepared to document the policies and procedures for the administration of federal awards of Cambridge-Isanti Schools (the “District”) and general business procedures. The Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles and Audit Requirements [34 CFR Part 80, 2 CFR Part 213 and Part 6 of the Office of Management and Budget (OMB) UGG - Uniform Grant Guidance Compliance Supplement] require all sub-recipients of federal funds to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Written policies and procedures are part of the necessary internal controls and are required as a precondition to receiving federal funds. These policies and procedures are intended to be sufficiently comprehensive to adequately meet such requirements. However, in no case are these policies and procedures intended to supersede or limit federal or state laws or regulations, or the provisions of individual grant agreements.

    Hierarchy of Authority – In the event that conflicting guidance on the administration of Federal awards is available, the District has deemed Federal guidance to be most authoritative, followed by guidance from the Minnesota Department of Education (“MDE”), and finally other State or local agencies.

    Revisions – Guidance provided by the Federal government through the OMB UGG - Uniform Grant Guidance Compliance Supplement and guidance provided by MDE through the Minnesota Uniform Financial Accounting and Reporting Standards Manual are expected to be updated each year. Such updates are considered by the District as they become available and policies and procedures will be revised accordingly.

    The Superintendent, Director of Finance and Operations and Designees are authorized and required to establish and document operating procedures to ensure compliance with the provisions of federal and state regulations and the provisions of grant agreements. Such procedures are documented herein, and will be reviewed and updated as necessary, but not less than once every three years.

    Training – District accounting and finance personnel, and Program Administrators of Federal awards will be provided the necessary training through various mechanisms, such as: (1) reviewing IDEAS reports, accompanying aid payments (2) consulting with the District’s auditors as needed for clarification, (3) participating in various training opportunities, such as those offered by MDE and appropriate professional organizations, (4) reviewing legislative updates from multiple sources, (5) membership and participation in meetings of the Minnesota Association of School Business Officials (MASBO), (6) coordination and collaboration with individuals performing similar job functions at local Districts or Districts within the Rum River Special Education Cooperative (7) conducting internal meetings with District Office staff in order to share information and ideas.

    Compliance Failures – Compliances failures, whether noted internally by management or through the external audit process, will be addressed immediately by reviewing the reason for the failure with responsible personnel and devising an improved process to encourage compliance in the future.



    General Accounting and Financial Management

    It is the policy of Cambridge-Isanti Schools (the “District”) to comply with all statutory, regulatory, and contractual requirements in the conduct of and accounting for its financial operations. The official books of record for the District will be maintained subject to the following provisions: Board Policies: The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:

    ● 406 Public and Private Personnel
    ● 412 Expense Reimbursement
    ● 701 Establishment and Adoption of a School District Budget
    ● 701.1 Modification of School District Budget
    ● 701.2 Purchasing
    ● 702 Accounting
    ● 703 Annual Audit
    ● 721 Uniform Grant Guidance Policy Regarding Federal Revenue Sources

    Procedures: The following procedures will be applied, to the extent that they do not conflict with or contradict the Board policies listed above:

    1. The District will account for its operations in accordance with the Generally Accepted Accounting Principles (GAAP) applicable to local units of government.
    2. The District will comply with all applicable circulars issued by the Office of Management and Budget (OMB), including, but not limited to:
      1. OMB Circular A-87 – Cost Principles for States, Local and Indian Tribal Governments
      2. OMB UGG - Uniform Grant Guidance – Audits of States, Local Governments, and Non-Profit Organizations (the Single Audit Act)
    3. The District will comply with all contractual requirements detailed in its duly executed grant agreements with awarding agencies.
    4. The Board of Education will contract annually with an independent CPA firm for the purposes of conducting the District’s external financial audit. To the extent that the District has expended federal awards, the District will have a single audit performed in accordance with OMB UGG - Uniform Grant Guidance.
    5. To ensure continuing compliance with all applicable accounting requirements, the Board of Education may, at its discretion, contract with a CPA firm to provide internal auditing and/or consulting services.
    6. All school district financial and pupil accounting audits are required to be submitted according to timelines established under Minnesota Statutes, section 123B.77.
    7. The Director of Finance and Operations shall be responsible for the maintenance of all accounting and financial records (including journals, timesheets, bank statements, audit reports, and similar documents).
    8. Such records shall be retained as required by contractual or regulatory requirements as described in the section of this manual titled “Records Retention”.

    Purchasing and Procurement

    It is the policy of Cambridge-Isanti Schools (the “District”) to ensure that all disbursements of District funds are properly reviewed and authorized, and consistent with sound financial management principles. In order to meet these objectives, all disbursements of District funds shall be subject to the following provisions:

    Procedures: The following procedures will be applied, to the extent that they do not conflict with or contradict with any Board policies:

    1. Substantial state and federal requirements exist pertaining to standards of conduct and conflict of interest. It is the intent of the District for all employees, officers, or agents to conduct all activities associated with procurements in compliance with the highest ethical standards, including the avoidance of any real or perceived conflict of interest. It is also the intent of the District to impose appropriate sanctions or disciplinary actions, including but not limited to termination and/or prosecution, for any employees or officers who violate any of these requirements.
    2. The District avoids the acquisition of unnecessary or duplicative items. Additionally, the District considers consolidating or breaking out procurements to obtain a more economical purchase. And, where appropriate, the District makes an analysis of leases versus purchase alternatives, and other appropriate analyses to determine the most economical approach.
    3. To foster greater economy and efficiency, the District enters into state and local intergovernmental agreements where appropriate for procurement or use of common or shared goods and services. This includes cooperative purchasing agreements where practical and beneficial. Depending on the purchase requested, the district may purchase it from a cooperative or inter-local agreement if the price is competitive and the goods or service are needed in a timely manner. The Director of Finance and Operations will make this determination.
    4. The District awards contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. The District considers such matters as contractor integrity and business ethics, compliance with public policy, ability to complete the project on time and in accordance with specifications, record of past performance, and the contractor’s financial and technical resources.
    5. The District will award a contract to a contractor who has the appropriate experience, expertise, qualifications, and any required certifications, necessary to perform the work. Contractors should also have the financial resources to sustain the project while the initial work is being completed and during each service period until he or she submits invoices for payment to the District as work is completed. Contractors should have the proper equipment or the capability to subcontract for the proper equipment necessary to complete the contracted work.
    6. Debarment and Suspension: The District will not subcontract with or award subgrants to any person or company who is debarred or suspended from receiving federal funds. The appropriate Program Administrator is required to check for excluded parties at the System for Award Management (SAM) website before any procurement transaction paid with federal funds. This list is located at: http://www.sam.gov/.
    7. All procurement transactions paid with federal funds are conducted in a manner providing full and open competition. In an environment of full and open competition, no proposer or bidder has a competitive advantage over another. All potential proposers and bidders must be provided the same information and have the same opportunity to submit a bid or proposal. Providing a competitive advantage to one or more potential proposers or bidders over another can open up the potential for disputes and lawsuits that can be costly and can significantly delay the completion of projects.
    8. In order to ensure objective contractor performance and eliminate unfair competitive advantage, contractors that develop or draft specifications, requirements, statements of work, or invitations for bids or requests for proposals (RFPs) are excluded from competing for such procurements. The District does not engage in the following situations that may restrict full and open competition, including but not limited to:
      1. Placing unreasonable requirements on firms in order for them to qualify to do business;
      2. Requiring unnecessary experience and excessive bonding;
      3. Noncompetitive pricing practices between firms or between affiliated companies;
      4. Noncompetitive contracts to consultants that are on retainer contracts;
      5. Organizational conflicts of interest;
      6. Specifying only a “brand name” product instead of allowing “an equal” product to be offered and describing the performance or other relevant requirements of the procurement; and
      7. Any arbitrary action in the procurement process.
      8. The District conducts federal procurements in a manner that prohibits the use of statutorily or administratively imposed state or local geographical preferences in the evaluation of bids or proposals, except in those cases where applicable federal statutes expressly mandate or encourage geographic preference.
    9. All solicitations will incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured. Such description will not, in competitive procurements, contain features which unduly restrict competition. The description will include a statement of the qualitative nature of the material, product or service to be procured and, when necessary, will set forth those minimum essential characteristics and standards to which it must conform if it is to satisfy its intended use. Detailed product specifications will be avoided if at all possible.
    10. The District will make independent estimates of the goods or services being procured before receiving bids or proposals to get an estimate of how much the goods and services are valued in the current market. To accomplish this, after bids and proposals are received, but before awarding a contract, the District conducts either a price analysis or a cost analysis, depending on the type of contract, in connection with every procurement with federal funds in excess of $100,000.
    11. The District takes all necessary affirmative steps to assure that minority businesses and women’s business enterprises, and labor surplus area firms are used when possible. To accomplish this, the District uses the following required affirmative steps:
      1. Placing qualified small and minority businesses and women’s business enterprises on solicitation lists
      2. Assuring that small and minority business, and women’s business enterprises are solicited whenever they are potential sources
      3. Dividing total requirements, when economically feasible, into smaller tasks or quantities to permit maximum participation by small and minority businesses, and women’s business enterprises
      4. Establishing delivery schedules, where the requirement permits, which encourage participation by small and minority businesses, and women’s business enterprises
      5. Using the services and assistance, as appropriate, of such organizations as the Small Business Administration and the Minority Business Development Agency of the Department of Commerce, and
      6. Requiring the prime contractor, if subcontracts are to be let, to take the affirmative steps listed above.
    12. Federal methods provide for procurement by the following methods:
      1. Micro-purchase means a purchase of supplies or services, the aggregate amount of which does not exceed $3,500.
        1. Micro-purchases made by the District will be made without soliciting competitive quotes if the price is considered to be reasonable.
        2. To the extent practicable, the District will distribute micro-purchases equitably among qualified suppliers.
      2. Small purchases mean a purchase of supplies or services between $3,500 and $99,999.
        1. The District will obtain price or rate quotes from two or more qualified sources.
        2. The District will consider MN Cooperative Purchasing Venture (CPV) contracts before purchasing through another source. No additional quotes will be solicited if making a purchase from this site.
      3. Sealed bids (minimum of 2) are required for purchases that exceed $100,000.
        1. If needed, the District will advertise for proposals. A firm, fixed-price contract will be awarded to the responsible bidder whose bid conforms to all the material terms and conditions of the invitation for bids that is the lowest in price.
      4. Competitive proposals are generally used when conditions are not appropriate for the use of sealed bids. One or more bidders submit either a fixed price or cost-reimbursement type contract.
        1. If needed, the District will advertise for proposals and using a written method for conducting technical evaluations of the proposals, award a contract to the responsible firm whose proposal is most advantageous to the program, with consideration given to price and other factors.
      5. Noncompetitive proposals are used when only one source is solicited.
        1. The District will use noncompetitive proposals when the needed item is available from only a single source, an emergency will not permit a delay resulting from competitive solicitation, the MDE authorizes noncompetitive proposals in response to a written request from Cambridge-Isanti Schools, or after solicitation of a number of source, competition is determined inadequate.
    13. Purchasing Methods
      1. Purchase Orders (POs) are used to pay invoices for goods or services and purchase supplies, materials, and equipment when Procurement Cards are not accepted. All involved parties will follow the steps below to make a purchase using a Purchase Order:
        1. An employee will make a request to attend a workshop or to purchase supplies, materials, and/or equipment using the appropriate form.
        2. When the Administrative Assistant receives an invoice that requires payment or a completed request form from an employee, he/she will create a requisition and electronically upload the invoice or other backup documentation in SMART Finance.
        3. Through SMART Finance, the Administrative Assistant will electronically route the requisition to the appropriate Building or Program Administrator and the Director of Finance and Operations for approval.
        4. The Building or Program Administrator and Director of Finance and Operations will ensure the availability of funds and accuracy of coding before approving the requisition.
        5. Once approved, the Administrative Assistant will electronically transfer the requisition to a Purchase Order in SMART Finance.
        6. The Administrative Assistant will send the Purchase Order with the invoice and/or signed appropriate form, and/or any relevant documents via email or inter-office mail, to the appropriate District Finance Specialist for payment.
        7. The Finance Specialist will process the Purchase Order and have a check issued and sent to the vendor.
        8. Checks will be processed in a weekly check run, unless a note on the Purchase Order indicates the request for a manual check to be cut sooner.
        9. Checks will be issued within 45 days of receipt of invoice.
      2. Procurement Card (P-card) are held by certain staff of Cambridge-Isanti Schools that are responsible for purchasing. Only the appropriate Building or Program Administrator can authorize the distribution of a P-card to a staff member. All P-card holders will follow the policies and procedures as outlined in the Purchasing Card Program Cardholder Manual. All involved parties will follow the steps below to make a purchase using a P-card:
        1. The Administrative Assistant will receive the appropriate request form from an employee.
        2. The Administrative Assistant will route the form to the appropriate Administrator for signature/approval.
        3. Once the request has been approved, the appropriate P-card owner will make the purchase with his/her P-card.
        4. The Administrative Assistant will file the itemized receipt/invoice and appropriate form, and keep a copy for the P-card statement.
        5. If the item is shipped, the Administrative Assistant will distribute it to the appropriate person and retain a copy of the packing slip.
        6. The Administrative Assistant will reconcile the P-card statement monthly.
        7. The Administrative Assistant will route the monthly P-card statement to the appropriate Administrator for their signature.
        8. The appropriate Building or Program Administrator will sign the P-card statements for his/her Administrative Assistant.
        9. The Director of Teaching and Learning, Director of Student Support Services, Director of Finance and Operations or the Superintendent will sign the P-card for the Building or Program Administrators.
        10. The Superintendent will sign the P-card for the Director of Teaching and Learning, Director of Student Support Services and Director of Finance and Operations.
        11. The signed P-card statement, with itemized receipts/invoices attached, to the Education Services Center for processing and payment of P-card.
      3. Employee Reimbursements
        Purchases via P-card and Purchase Orders are the preferred methods for purchasing. However, there may be times an employee needs to make a purchase using their own funds, and be reimbursed through the District. All employees making a purchase using their own funds will follow the steps below to be reimbursed:
        1. The employee making the purchase will receive prior approval from the appropriate Building or Program Administrator and will fill out the appropriate request form.
        2. Once approved, the employee will make the purchase and give the Administrative Assistant the itemized receipt, along with the completed Request for Mileage/Expense Reimbursement Form, and other appropriate request form, if applicable.
        3. The appropriate Building or Program Administrator will sign the Request for Mileage/Expense Reimbursement Form and appropriate request form, if not done so already.
        4. The Administrative Assistant will check the Request for Mileage/Expense Reimbursement Form and itemized receipt(s) for accuracy.
        5. The Administrative Assistant will route the form with attached itemized receipts to the Education Services Center for reimbursement through payroll.
        6. The Administrative Assistant will file a copy of the itemized receipt, Request for Mileage/Expense Reimbursement, and appropriate request form, if applicable.
    14. Purchasing Check-in Procedure
      1. Once a purchase is made and the item(s) is delivered, the Administrative Assistant will ensure all items are received as ordered, keep the packing slip, and mark it received with the date on it before distributing the item(s) to the appropriate person.
      2. The Administrative Assistant will also tag and inventory any sensitive items and/or equipment and follow the Property Management Procedures when applicable. Books, DVDs, and other supplies that are not consumables will be labeled and put on the Materials Inventory Log, which will be maintained by the Administrative Assistant.
    15. Document Retention
      The following documents will be retained for a period of 5 years and may be used during the annual audit and the MDE fiscal audit:
      1. Purchase Orders with attached invoices
      2. P-card statements with attached itemized receipts
      3. Reimbursement Forms with attached itemized receipts (if applicable)
      4. Appropriate request forms
      5. Contracts for goods or services
      6. Time and effort documentation
      7. Federal draws with attached backup documentation
      8. Packing slips
      9. Cancelled checks

    Cash Receipts

    In order to safeguard the funds of Cambridge-Isanti Schools (the “District”), cash receipts will be deposited promptly and intact according to the following policies:

    Board Policies: The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:

    ● 201 Legal Status of the School Board
    ● 511 Student Fundraising
    ● 706 Acceptance of Gifts

    Procedures: The following procedures will be applied, to the extent that they do not conflict with or contradict Board policies:

    1. Cash receipts will be recorded approximately 1-3 times per week based on the amount of collections.
    2. Cash that is initially received by a teacher or advisor is collected is totaled and given to the Building Administrative Assistant along with a receipt of the amount and the purpose of the funds. The Building Administrative Assistant verifies the total, prepares a recap form which lists the money received, the account codes the receipt should be applied to and any other pertinent information/description needed on the deposit. Check stubs and any supporting documents are attached.
    3. The recap form and supporting documentation are then sent to the Finance Specialist at the Education Services Center. The Finance Specialist I recounts the money and verifies the supporting documentation. The Finance Specialist I then prepares a receipt which is given to the Finance Specialist II. The Finance Specialist II prepares a deposit slip and takes the deposit to the bank.
    4. The Finance Specialist will input the receipt information into the financial software.
    5. Receipts are compared to the actual bank deposits and general ledger postings during the monthly account reconciliation process.

    Time and Effort

    The following provisions apply to the payment of Cambridge-Isanti Schools’ (the “District”) employees and recording of time and effort (as required) in accordance with Federal Cost Principles.

    Procedures: The following procedures will be applied, to the extent that they do not conflict with or contradict with any Board policies:
    1. Hourly employees shall have an electronic or paper timesheet for each pay period, with the following information:
    a. The total number of hours actually worked each day
    b. The use of any holiday, personal, vacation, sick, or other approved time off with pay
    c. The total number of hours to be paid
    d. An allocation of those hours to each program or department for which work was performed, when necessary
    e. The dated signature or electronic approval of the employee and his/her supervisor
    2. The allocation of hours between programs or departments should be based exclusively on the actual hours worked, and not be based on available budgets, or predetermined allocation schedules.
    3. In the event that an after-the-fact correction is necessary to an employee’s timesheet due to errors in the allocation of time worked, such corrections must be submitted to the Payroll Specialist and approved in writing by both the employee and his/her supervisor.
    4. The Program Administrator will determine the time and effort documentation required by all staff charged to a Federal grant. If the employee’s time is expensed based on budgetary data, an adjustment shall be made to reconcile the general ledger to the documentation.
    a. An employee who works on a single cost objective (a single function or a single grant or a single activity) will complete a semi-annual certification. The certification will be prepared by the Administrative Assistant at the site where the employee works. Either the employee or a supervisor with first-hand knowledge of the work performed by the employee will sign and date the semi-annual certification.
    i. A semi-annual certification must:
    1. Be executed after the work has been completed;
    2. State that the employee worked solely on activities related to a particular cost objective;
    3. Name the employee and the employee’s position
    4. Identify the single cost objective;
    5. Be signed by the employee or a supervisor with first-hand knowledge of the work performed; and
    6. Be dated.
    ii. Backup documentation for the semi-annual certification will be a schedule, calendar, or job description.
    iii. If an employee works on a short-term cost objective whose end date does not coincide with the normal January/July collection dates for semi-annual certification (e.g. a supplemental contract for summer school programs), the employee’s supervisor will complete and sign the document. The employee is required to provide a schedule or calendar for the time worked.
    b. Employees working on multiple cost objectives (works on more than one Federal award, a Federal award and a non-Federal award, an indirect cost activity and a direct cost activity, two or more indirect activities that are allocated using different location bases, or an unallowable activity and a direct or indirect cost activity) and who have an unpredictable schedule must complete Personnel Activity Reports (PAR) indicating the amount of time spent on each cost objective for the period covered by the PAR. The PAR must:
    i. Be signed by the employee; and
    ii. Be dated after the fact (when the work has been completed).
    iii. Be executed after the work has been completed;
    iv. Account for the total activity for which the employee is compensated, including part-time schedules or overtime (total activity means all of the time an employee works, not just the amount of time worked on a Federal program) as well as any holiday, sick, and vacation time utilized;
    v. Name the employee and the employee’s position;
    vi. Identify all cost objectives including federal program name and Finance codes being worked upon;
    vii. Specify the reporting period; be prepared at least monthly and coincide with one or more pay periods;
    c. Employees working on multiple cost objectives (works on more than one Federal award, a Federal award and a non-Federal award, an indirect cost activity and a direct cost activity, two or more indirect activities that are allocated using different location bases, or an unallowable activity and a direct or indirect cost activity) and who have a predetermined schedule/substitute system approved by MDE will complete a semi-annual certification.
    i. The certification will be prepared by the Program Administrator for which the employee works.
    ii. Either the employee or a supervisor with first-hand knowledge of the work performed by the employee will sign and date the semi-annual certification.
    iii. The employee will provide to his/her supervisor, a schedule that documents what they are doing. The employee’s schedule must specify the work activity or cost objective for each segment of time during the day. It must account for the total hours for which the employee is compensated and be certified at least semi-annually.
    iv. Schedule revisions must be documented and certified and significant deviations from the schedule must be documented through the use of a PAR. A 5% cumulative deviation in the schedule of the employee will be considered a significant deviation from an employee’s established schedule that would warrant an individual reverting to a PAR for the remainder of the fiscal year.
    1. Examples of deviations may include:
    a. Special education teacher substituting in regular education.
    b. Teacher providing professional development during a regular scheduled teaching day that is not related to a cost objective such as curriculum development for regular education.
    c. Special education teacher traveling with the basketball team for a day as head coach.
    2. Examples of a change in schedule that is not a schedule change may include:
    a. A special education teacher has a substitute to complete special education due process paperwork.
    b. A special education teacher participating in an IEP meeting rather than in the classroom teaching.
    c. The schedule is the time that school is in session with face-to-face contact with students, e.g. snow day is not an interruption in the schedule.

    Bank Reconciliation

    The following procedures will apply to Cambridge-Isanti Schools (the “District”) reconciliation of bank accounts:

    Board Policies: The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:
    There are no existing Board policies over the reconciliation of bank accounts.

    Procedures: The following procedures will be applied, to the extent that they do not conflict with or contradict Board policies:
    1. Bank reconciliations will be performed monthly for each bank account.
    2. Bank reconciliations will be completed on a timely basis.
    3. Bank reconciliations for the demand deposit accounts and sweep accounts are completed by the Finance Specialist.
    4. The Finance Specialist posts all cancelled checks in the financial accounting software on a monthly basis and runs a report of outstanding checks for each bank account.
    5. Interbank transfers, ACH receipts, and EFT payments recorded through general journal entry will be verified as part of the bank reconciliation process.
    6. Bank reconciliations are reviewed and approved by the Director of Finance and Operations.

    Journal Entries and Non-routine Transactions

    Cambridge-Isanti Schools (the “District”) will occasionally need to record a general journal entry or other non-routine transaction. Such transactions may relate to Federal awards. The following policies and procedures apply to all general journal entries:

    Board Policies: The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:
    There are no existing Board policies over journal entries and non-routine transactions.

    Procedures: The following procedures will also be applied, to the extent that they do not conflict with or contradict Board policies:
    1. General journal entries will be an allowable transaction type for recording: corrections and adjustments, accruals and reversing entries, inter-fund activity, interbank activity, EFT payments, ACH transfers, etc., to the extent that the entries can be reasonably supported.
    2. All general journal entries will be filed with adequate supporting documentation.
    3. Each general journal entry will be electronically signed/initialed by the preparer.
    4. All entries will be reviewed and approved by an independent administrator, which will also be signed/initialed as evidence of the control.
    5. The ability to post general journal entries in the accounting system will be limited to specific employees.

    Investments

    In order to maximize profits, Cambridge-Isanti Schools (the “District”) can invest funds.

    Board Policies: The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:
    ● 705 Investment of School Funds

    Procedures: The following procedures will also be applied, to the extent that they do not conflict with or contradict Board policies:
    1. Authorization for acquisition and disposition of investments is vested with the District Board of Education.
    2. The District may engage an investment advisor to review cash flow projections and recommend appropriate investment placements.
    3. The Board of Education has formally adopted an investment policy #705 that limits the school District’s allowable investments and addresses the specific types of risk to which the school District may be exposed. The Director of Finance and Operations is charged with the responsibility of determining that investments are of the character and type permitted by legal requirements and that the income earned is dispersed for authorized purposes.
    4. Director of Finance and Operations’ approval is required before any money is deposited into any investment accounts.

    Safekeeping:
    1. All persons having access to securities are authorized by the Board of Education.
    2. All securities are held in the name of the District.

    For Record keeping, detailed records are maintained including the following information:
    1. Date of acquisition, identification, purchase amount or cost
    2. Physical location of item
    3. Interest/dividend/income rates and accrual/receipt dates
    4. Ownership by fund
    5. Detail records are periodically reconciled to the general ledger control accounts and to safekeeping statements by the Director of Finance and Operations.
    6. Investment income is recorded on a timely basis. Investment earnings are credited to the fund “owning” the investment. Any adjustments of investment accounts are approved by the Director of Finance and Operations.
    7. Calculations of fair value and investment income are periodically reviewed for accuracy by the Director of Finance and Operations.
    8. Access to computerized investment records is limited to those with a logical need for access.

    Capital Assets

    The following provisions will govern Cambridge-Isanti Schools’ (the “District”) purchasing, accounting, and inventory of capital assets:

    Board Policies: The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:
    ● 201 Legal Status of the School Board
    ● 706 Acceptance of Gifts
    ● 802 Disposition of Obsolete Equipment and Material
    ● 902 Community Use of School Facilities and Equipment

    Procedures: The following procedures will also be applied, to the extent that they do not conflict with or contradict Board policies:
    1. A capital asset is defined by the District as an individual item with a useful life in excess of 1 year and an individual cost of more than $5,000.
    2. Procurement of capital assets will be governed Minnesota Statute and local purchasing procedures.
    3. Donated capital assets will be accepted only with authorization by the school board and recorded within fixed assets at estimated fair value at the date of donation.
    4. Purchases of capital assets will be recorded as capital outlay expenditures in the governmental fund financial statements. All capital assets will be depreciated using the straight-line method over estimated useful lives.
    5. Capital asset purchases financed through bonds payable will be recorded in accordance with the Minnesota Uniform Financial Accounting and Reporting Standards.
    6. Capital assets with useful lives (i.e., excluding land and construction in progress) will be depreciated using a consistent and systematic approach allowable under GAAP.
    7. Construction or other capital projects in progress at year-end will be reported as “construction in progress” until the related asset is placed into service. No depreciation expense will be incurred on such assets. Outstanding construction commitments at year-end will be disclosed in the District’s audited financial statements.
    8. If the District determines that depreciation expense cannot be reasonably allocated by function, it will be deemed allowable to report all or a portion of depreciation expense as “Depreciation – unallocated” in the government-wide statement of activities, to the extent that this approach remains allowable under GAAP.
    9. To the extent that capital assets are purchased with Federal funds, such items will be flagged as in the financial accounting records in order to ensure the appropriate use of proceeds on sale (if applicable) in accordance with Federal guidelines.
    10. To the extent that the District has purchased capital assets with Federal funds, an inventory of these items and reconciliation to the accounting records will be performed no less than once every two years. If it is not feasible to inventory all the District’s capital assets this frequently, the Federally-funded assets may be inventoried only in order to meet the requirements of the OMB UGG - Uniform Grant Guidance Compliance Supplement.
    11. Other policies and procedures related to compliance with the provisions of the OMB UGG - Uniform Grant Guidance compliance supplement are included within this manual in the section titled “Equipment and Real Property Management”.

    Long-term Debt

    The following provisions will govern Cambridge-Isanti Schools’ (the “District”) issuance of long-term debt (including, but not limited to: bonds and notes payable, capital assets, installment purchase agreements, State Aid Anticipation Notes, compensated absences and severance agreements/early retirement incentives):

    Board Policies: The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:
    ● 201 Legal Status of the School Board

    Procedures: The following procedures will be applied, to the extent that they do not conflict with or contradict Board policies:
    1. The issuance of long-term debt will be subject to approval by the Board of Education and the Minnesota Department of Education..
    2. The issuance of long-term debt will be recorded as an “other financial source” in the governmental fund financial statements, along with any premium or discount thereon. Costs of issuance will be reported in the governmental fund financial statements as a component of debt service expenditures.
    3. In the full-accrual government-wide statements, long-term debt and any related discounts, premiums, or deferred gain/loss on refunding, will be reported as a liability. Bond issuance costs will be expensed when incurred and reported as a component of interest expense in the government-wide statement of activities.
    4. Short-term debt (such as State Aid Anticipation Notes) with an initial maturity of less than one-year will be recorded as a liability in the governmental fund financial statements, along with accrued interest payable thereon.
    5. Compensated absences payable will be recorded in the government-wide statements for earned but unused sick and vacation time, as provided for in bargaining agreements and/or personnel policies. Such accruals will be based on estimated liabilities from analyses completed by an independent actuarial firm conducted at least every other year.
    6. Severance agreements/early retirement incentives will also be recorded liabilities in the government-wide statements. Current obligations will be posted in both the fiscal year of retirement and the year following retirement.

    Grant Administration

    Board Policies: The following policies for Cambridge-Isanti Schools (the “District”) have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:
    ● 721 Uniform Grant Guidance Policy Regarding Federal Revenue Sources

    Procedures: The following procedures will be applied, to the extent that they do not conflict with or contradict Board policies:
    1. Grant Development, Application, and Approval
    a. Legislative Approval – The point at which legislative approval is required is determined by the requirements of the grant program. If the grant must be submitted by “an individual authorized by the legislative body”, then the Board of Education approval is required prior to submitting the application. If such legislative approval is not specifically required by the written terms of the grant, then the Superintendent or designee may, at his or her discretion, approve grant applications.
    b. Matching Funds – Grants that require cash local matches must be coordinated through the writer of the grant and Director of Finance and Operations. At a minimum, funds must be identified within the existing budget to provide the match, or a budget amendment will be required. Depending on the nature of the grant, there may also be some policy implications that will bear discussion. (For example, will the grant establish a level of service that cannot be sustained once the grant funds are depleted?) In all cases involving matching funds, the grant applicant should contact the building or department administrator to determine the strategy for securing matching funds. Refer to the section within this manual titled “Matching, Level of Effort, and Earmarking” for additional information on compliance with the provisions of the OMB UGG - Uniform Grant Guidance Compliance Supplement.
    c. Grant Budgets – Most grants require the submission of an expenditure budget. The Director of Finance and Operations should review this portion of the grant request prior to submission. Frequently, a technical review will discover inconsistencies in the calculations, cost centers that might have been overlooked, or identify reimbursable expenses of which program staff may not be aware—particularly in the area of indirect costs.
    2. Grant Program Implementation
    a. Notification and Acceptance of an Award – Official notification of a grant award is typically sent by a funding agency to the Program Administrator and/or other official designated in the original grant proposal. However, the authorization to actually spend grant funds is derived from the Board of Education through the approval of a grant budget. Such notification should also be directed to the Education Services Center. Adoption of the grant budget as a component of the District-wide operating budget is deemed to be sufficient approval.
    b. Establishment of Accounts – The department that obtained the grant will provide the Director of Finance with information needed to establish revenue and expense accounts for the project. Ordinarily, this information will include a copy of a summary of the project and a copy of the full project budget.
    c. Purchasing Guidelines – All other District purchasing guidelines apply to the expenditure of grant funds. The use of grant funds does not exempt any purchase from normal purchasing requirements. All typical paperwork and bidding requirements apply. All normal staff approvals apply. When in doubt, the Program Administrator should contact the Director of Finance and Operations or Director of Finance for further assistance.
    3. Financial and Budgetary Compliance
    a. Monitoring Grant Funds – Departments may use some internal mechanism (such as a spreadsheet) to monitor grant revenues, expenditures and budgetary compliance. The Director of Finance maintains all this information in financial software system as well; this is considered to be the District’s “official” accounting system by the granting agencies. Program Administrators are strongly encouraged to use financial software reports provided by the District for their grant tracking. If any “off-system” accounting records are maintained, it is the responsibility of the Program Administrator to ensure that the program’s internal records agree to the District’s accounting system.
    b. Fiscal Years – Occasionally, the fiscal year for the granting agency will not coincide with the District’s fiscal year. This may require adjustments to the District’s internal budget accounts and interim financial reports as well as special handling during fiscal year-end close. It is the responsibility of the Program Administrator to bring such discrepancies to the attention of the Director of Finance and Operations at the time the grant accounts are established.
    4. Grant Budgets
    a. The terms of each specific grant will dictate whether any budget transfers between budgeted line items will be permitted. In no case will the Program Administrator be authorized to exceed the total budget authority provided by the grant.
    b. If grant funds have not been totally expended by fiscal year-end, it is the responsibility of the Program Administrator to notify the Director of Finance and Operations to determine whether budget funds need to be carried forward to the new fiscal year, and to confirm the amounts of such carry-forwards. Carry-forwards of grant funds will be subjected to maximum allowable amounts/percentages based on the grant award agreement and/or the OMB UGG - Uniform Grant Guidance Compliance Supplement.
    5. Capital Assets
    a. The District is responsible for maintaining an inventory of assets purchased with grant monies. The District is accountable for them and must make them physically available for inspection during any audit.
    b. The Director of Finance and Operations must be notified immediately of any sale of these assets.
    c. Customarily, the proceeds of the sale can only be used on the grant program that purchased them. (Refer to the specific regulations governing the original grant).
    d. The Director of Finance and Operations will coordinate this grant requirement. All transactions that involve the acquisition or disposal of grant funded fixed assets must be immediately brought to the attention of the Director of Finance and Operations.
    e. Refer to the sections of this manual titled “Capital Assets” and “Equipment and Real Property Management” for additional information. [OMB Circular A-110; 34 CFR Sec. 74.34]
    6. Record Keeping
    a. Audit Workpapers – The District’s external auditors audit all grants at the end of each fiscal year.
    b. The Director of Finance and Operations will prepare the required audit work-papers. Program Administrator may be asked to assist in this process, if necessary.
    c. Record Keeping Requirements – Grant record keeping requirements may vary substantially from one granting agency to another. Consequently, a clear understanding of these grant requirements at the beginning of the grant process is vital. The Director of Finance and Operations will maintain copies of all grant draw requests, and approved grant agreements (including budgets). The Program Administrator should maintain all other records.
    d. Refer to this section of this manual titled “Records Retention” for additional information.
    7. Other Guidelines – Specific information on policies and procedures related to compliance with the provisions of the OMB UGG - Uniform Grant Guidance Compliance Supplement have been addressed later in this manual and should be considered along with the information in this section.

    Year-end Closing and Reporting

    The following provisions will govern the year-end close-out process of Cambridge-Isanti Schools (the “District”) for purposes of external financial reporting:
    1. In accordance with the Minnesota statutes, the District’s fiscal year end for external reporting purposes will be June 30.
    2. Accruals will be recorded as needed to ensure that revenues and expenditures are reported in the appropriate accounting period:
    a. Accounts Payable Disbursements – Invoices for goods or services received during the previous fiscal year will be recorded as expense/accounts payable as of June 30. Such determinations will be made by the District’s Finance Specialists and reviewed for accuracy and completeness by the Director of Finance and Operations.
    b. Payroll-related Accruals – Costs of hourly personnel paid after June 30 for services performed during the previous year will be recorded as expenditures/salaries payable at June 30. The amount will be based on hours worked during the fiscal year multiplied by the employee’s hourly rate.
    i. Salaried teachers and other employees working during the academic year only may elect to receive their annual salary over 12 months ended August 31 of each year or to receive a final payment of remaining salary on the last workday in June. In the latter, all salary payments will have been made prior to June 30 and no additional accrual is necessary. In the former, the difference between the total salary and the amount paid through June 30 will be recorded as expense/salaries payable at June 30 since the period of service is complete at that time. Additional consideration will be made for FICA taxes, retirement, health insurance, and related employee benefits.
    ii. Health insurance and other benefits for employees working on an academic year only will be accrued for the months of July and August and recorded as expenditures/benefits payable at June 30.
    iii. Payroll accruals will be prepared and documented by the Payroll Specialist and reviewed by the Director of Finance and Operations.
    c. Prepaids – Payments made prior to year-end that cover goods or services to be received in a future period will be recorded as prepaid items as of June 30. The District may elect to not record prepaid items in governmental funds in accordance with GASB Codification 1600.127 Other Expenditure Recognition Alternatives.
    d. Inventory – If deemed material, a physical inventory of supplies and materials will be performed after the completion of the academic school year, but no later than June 30. Amounts will be valued at actual cost and provided to the Director of Finance for review and adjustment in the general ledger.
    e. Receivables – General – Cash received after year-end for which a good or service was provided during the previous fiscal year will be recorded as revenue/accounts receivable. All such adjustments will be supported by appropriate documentation, such as remittance advices or dated sub-ledgers.
    f. Receivables – Grant – After all year-end expense accruals have been recorded, an entry will be recorded for the difference between grant expenditures and related grant receipts as of June 30 as revenue/grants receivable. Grant receivables will only be recorded to the extent that sufficient amounts remain in the grant award. Expenditures that will not be reimbursed through grant awards due to lack of available funding will be transferred to a non-grant cost center.
    g. Receivables – State Aid – State Aid is provided to Minnesota School Districts in installments with 90% of the aid entitlement paid in the current fiscal year, and 10% paid out in the subsequent fiscal year. Therefore, subsequent year receipts are intended to finance the previous fiscal year, such amounts will be recorded as revenue/receivable at June 30.
    3. The preparation of the year-end financial statements in accordance with GAAP will be outsourced to the independent external auditors. The draft financial statements provided by the auditors will be reviewed in detail by the Director of Finance and Operations and the Director of Finance with any audit-proposed journal entries, to ensure that the audited financial statements agree to the District’s books and records. Refer to the policy on “Audits” within this manual for further information on audit requirements and related School policies.
    4. To the extent that the District is required to have a single audit completed in accordance with OMB UGG - Uniform Grant Guidance, the District will accumulate the information necessary to prepare a schedule of expenditures of federal awards (SEFA or the “schedule”) in accordance with Federal and State requirements. This schedule will be characterized as follows:
    a. The schedule will include all federal financial assistance, including: grants, contracts, property, loans, loan guarantees, interest subsidies, cooperative agreements, insurance, or direct appropriations. Amounts will be reported whether received directly from the Federal government or through a pass-through agency (given that the District is determined to be a sub-recipient and not a vendor).
    b. Non-cash assistance (such as food commodities) will be described as such in the schedule or in the notes to the schedule.
    c. The schedule will be prepared on the same basis of accounting as the related financial statements.
    d. Federal grants received through the Minnesota Department of Education will agree to, or reconcile with, the SERVS payment summary, as applicable.
    e. Federal awards will be grouped based on Federal awarding agency. Each Federal award with current expenditures will be listed along with its CFDA number, pass-through grantor name (if applicable) and award/pass-through grantor number (if applicable). Such information will agree to the award documentation.
    f. If the CFDA number of a Federal award cannot be reasonably determined, it shall be reported in the schedule using the two-digit prefix for the related Federal agency, followed by “UNKNOWN”.
    g. To the extent that amounts are passed-through to sub-recipients, a schedule of federal awards provided to sub-recipients, including all necessary information to meet the requirements of the Minnesota Department of Education, will be prepared.
    h. In addition to current year expenditures, the schedule will list approved award/grant amount, accrued/deferred revenue at the beginning of the year, current year cash received, current year actual expenditures, and accrued/deferred revenue at the end of the year. If expenditures were incurred relative to this award in the prior year(s), this amount should be disclosed as memorandum-only.
    i. Any adjustments to prior year awards, expenditures, and balances (including transfers between grants) will be disclosed in the footnotes to the schedule.
    j. Accrued/deferred revenue in the schedule shall agree to the amounts recorded as receivable/deferrals in the related financial statements.
    k. To the extent that a separate line item is included in the financial statements for Federal revenue, this amount shall agree to expenditures in the schedule. Any reconciling items will be disclosed in the footnotes to the schedule.
    l. The footnotes to the schedule will disclose the significant accounting policies used in preparing the schedule.

    Chart of Accounts

    Cambridge-Isanti Schools (the “District”) will maintain its chart of accounts in accordance with the requirements of the Minnesota Uniform Financial Accounting and Reporting Standards Manual.

    Board Policies: The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:
    ● 702 Accounting

    Procedures: The following procedures will be applied, to the extent that they do not conflict with or contradict the Board policies:
    1. Each account will be assigned a 17-digit number, as follows, consistent with the Uniform Financial Accounting and Reporting Standards (UFARS):

    Fund Organization Program Course Finance Source/Object
    XX XXX XXX XXX XXX XXX
    *Numbers assigned to each category above will be based on the specific requirements of the District.

    2. Additional differentiation of revenue and/or expenditures may be accomplished through the use of cross walked codes in order to meet the needs of district decision makers.
    3. As applicable, Federal awards revenue and expenditures will be assigned certain program, course and/or finance codes.
    4. The chart of accounts will facilitate the preparation of the UFARS data and will agree to the audited financial statements.
    5. A complete chart of accounts for GASB 34 adjustments will not be maintained formally within the District’s accounting system. Such adjustments are made once per year, for external financial reporting only, and therefore will be determined through use of separate spreadsheets, and integrated into the audit by the District’s independent auditors. The Director of Finance and Operations will review all such adjustments for accuracy prior to the issuance of the audited financial statements.

    Annual Audit

    Every Minnesota public school must have a financial statement audit completed each year by a certified public accounting firm. Cambridge-Isanti Schools (the “District”) will comply with this each year.

    Board Policies: The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:
    ● 201 Legal Status of the School Board
    ● 702 Accounting
    ● 703 Annual Audit

    Procedures: The following procedures will be applied, to the extent that they do not conflict with or contradict the Board policies listed above:
    1. The District will have a financial statement audit completed annually as of its fiscal year ended June 30.
    2. The audit will be completed in accordance with Government Auditing Standards.
    3. An adequate written agreement (the “engagement letter”) will be signed by the District and its independent auditors. It will contain information on: period to be audited, support to be provided, reporting requirements, contractual information, and a statement that the engagement is intended to meet governmental oversight agencies’ requirements (Minnesota Uniform Financial Accounting and Reporting Standards Manual, OMB UGG - Uniform Grant Guidance, GAAS and GAS).
    4. The Director of Finance and Operations shall be responsible for overseeing the process of preparing for the annual audit. In order to minimize errors in this process, all audit schedules and work-papers should be reviewed by an individual other than the preparer.
    5. To the extent that expenditures of federal awards equal or exceed $500,000, the District will also have a single audit completed in accordance with OMB UGG - Uniform Grant Guidance. Refer to the section of this manual titled “Year-end Closing and Reporting” for information on the schedule of expenditures of federal awards.
    6. Detailed financial data will be submitted to the Minnesota Department of Education as required by statute. Unaudited data must be submitted electronically no later than September 15th, and detailed audited date must be submitted electronically no later than November 30th. The final audit will be submitted to the Minnesota Department of Education on or before December 31st each year by the District’s independent auditors.
    7. If a single audit is conducted, the data collection form and reporting package will be submitted electronically to the Federal Audit Clearinghouse as a joint effort between the District and its independent auditors.
    8. The Director of Finance and Operations will submit written corrective action to any findings identified in the audit process as either part of the single audit report or as a separate letter to the Minnesota Department of Education.

    Budgets and Budgetary Compliance

    Cambridge-Isanti Schools (the “District”) uses budgets and budgetary accounting in order to fulfill its requirements from the Minnesota Department of Education and as an internal management tool for monitoring expenditures and identifying abnormalities. Policies and procedures regarding the budgetary process are as follows:

    Board Policies: The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:
    ● 201 Legal Status of the School Board
    ● 701 Establishment and Adoption of School District Budget
    ● 701.1 Modification of School District Budget
    ● 702 Accounting
    ● 703 Audit

    Procedures: The following procedures will also be applied, to the extent that they do not conflict with or contradict the Board policies listed above:
    1. An operating budget will be prepared for the general fund and each special revenue fund consistent with GAAP and the uniform chart of accounts (see previous section titled “Chart of Accounts”).
    2. The minimum level of legal control will be determined based on the specification of the Minnesota Uniform Financial and Accounting Standards Manual.
    3. The budget will be formally adopted by the Board of Education prior to the commencement of the fiscal year.
    4. The adopted budget will include:
    a. Updated revenue and expenditure estimates for the current fiscal year and estimated revenue and expenditures for the ensuing fiscal year.
    b. The amount of surplus or deficit that has accumulated from prior fiscal year, along with an estimate of the amount of surplus or deficit expected in the current fiscal year.
    c. Other data relating to fiscal conditions that the Superintendent and Director of Finance and Operations deem to be useful.
    5. The budget will be amended by the Board of Education, as necessary, throughout the fiscal year. No budget amendments will be allowable after year-end.
    6. In no instance will the total estimated expenditures, including an accrued deficit, exceed the total revenues, including available unappropriated surplus.
    7. Expenditures in excess of budget at the legal level of compliance will be disclosed in the annual audit.
    8. The original budget, final amended budget, actual expenditures, and excess of expenditures over budget will be included for the general fund and each major special revenue fund in the annual audit.
    9. Each Federal grant will have an award budget, which will be incorporated into the District-wide operating budget.
    10. Management will review budget vs. actual data on a periodic basis with the Board of Education in order to identify inconsistencies. Such data will be incorporated into the recommended budget for adoption and include both revenues and expenditures.

    Additional Federal Awards Compliance Requirements

    A substantial amount of the Federal awards received by the Cambridge-Isanti Schools are passed-through the Minnesota Department of Education. In addition to the requirements of the OMB UGG - Uniform Grant Guidance compliance supplement, which are applicable to all Federal grants (refer to next section of this manual for specific on each compliance requirement); the Minnesota Department of Education has issued its own set of guidance on compliance with Federal awards. Management will consider both the OMB UGG - Uniform Grant Guidance Compliance Supplement and the Minnesota Department of Education Uniform Financial Reporting and Accounting Standards Manual in identifying applicable compliance requirements.
    Board Policies.

    The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:
    ● 721 Uniform Grant Guidance Policy Regarding Federal Revenue Sources

    OMB UGG - Uniform Grant Guidance Compliance Supplement General Information

    Source of Information – Each year the Federal government (Office of Management and Budget) issues a comprehensive document on the compliance requirements each grant recipient is obligated to follow in general terms, along with program-specific guidance on various grant awards. There are 14 compliance requirements identified, each of which is considered individually in this manual.

    The following pages document the policies and procedures of the District related to compliance with such procedures, as applicable. In each year that the District is subject to a single audit, applicable compliance requirements are expected to be tested in detail by the District’s independent auditors.

    Objectives – The objectives of most compliance requirements are generic in nature. While the criteria for each program may vary, the main objective of the compliance requirement is relatively consistent across all programs. As such, the policies and procedures of the District have been based on the generic sense of the compliance requirement. For selected compliance requirements, this manual addresses the specific regulations applicable to individual grants. This is not intended to imply that a program is not subject to such policies if it is not specifically mentioned here. It is the intention of the District that all Federal awards are subject to the following policies and procedures.

    Controls over Compliance – In addition to creating policies and procedures over compliance with provisions of Federal awards, the District has implemented internal controls over such compliance, generally in the form of administrative oversight and/or independent review and approval. In order to document these control activities, all independent reviews and signed/initialed and dated.

    Documentation – The District will maintain adequate documentation to support both the compliance with applicable requirements as well as internal controls over such compliance. This documentation will be provided to the District’s independent auditors and/or pass-through grantor agencies, as requested, during the single audit and program audits.

    OMB UGG - Uniform Grant Guidance Compliance Supplement Activities Allowed/Unallowed and Allowable Costs/Cost Principles

    Source of Governing Requirements – The requirements for activities allowed or unallowed are contained in program legislation, Federal awarding agency regulations, and the terms and conditions of the award.

    The requirements for allowable costs/cost principles are contained in the A-102 Common Rule (§.22), OMB Circular A-110 (2 CFR section 215.27), program legislation, Federal awarding agency regulations, and the terms and conditions or the award.

    In order to ensure compliance with these requirements, Cambridge-Isanti Schools (the “District”) has implemented the following policies and procedures:
    1. All grant expenditures will be in compliance with OMB Circular A-87, “ Cost Principles for State, Local, and Indian Tribal Governments ”, State law, District policy, and the provisions of the grant award agreement will also be considered in determining allowability. Grant funds will only be used for expenditures that considered reasonable and necessary for the administration of the program.
    2. Grant expenditures will be approved by Program Administrators or designee initially through the purchase order or purchase card procurement process. This will be evidenced by procedures described in the section of this manual titled “Purchasing and Procurement”.
    3. Payroll costs will be documented in accordance with OMB Circular A-87 as described in the section of this manual titled “Payroll and Timekeeping”.
    4. An indirect cost rate will only be charged to the grant to the extent that it was specifically approved through the grant budget/agreement. When allowable, indirect costs will be charged based on the Cost Allocation Plan of the District and using the rate approved by the Minnesota Department of Education.

    OMB UGG - Uniform Grant Guidance Compliance Supplement Cash Management

    Source of Governing Requirements – The requirements for cash management are contained in the A-102 Common Rule (§.21), OMB Circular A-110 (2 CFR section 215.22), program legislation, Federal awarding agency regulations, and the terms and conditions or the award.

    In order to ensure compliance with these requirements, Cambridge-Isanti Schools (the “District”) has implemented the following procedures:
    1. Substantially all of the District’s grants are awarded on a reimbursement basis. As such, program costs will be expended and disbursed prior to requesting reimbursement from the grantor agency.
    2. Cash draws will be initiated by the Director of Finance and Operations or Director of Finance who will determine the appropriate draw amount. Documentation of how this amount was determined will be retained and signed/dated.
    3. The physical draw of cash will be processed through the Minnesota State Educational Record View and Submission (SERVS) system or through the means prescribed by the grant agreement for other awards by the Director of Finance and Operations.
    4. Supporting documentation from SERVS or a copy of the cash draw paperwork will be filed along with the approved paperwork described above and retained for audit purposes.

    OMB UGG - Uniform Grant Guidance Compliance Supplement Davis-Bacon Act

    Source of Governing Requirements – The requirements for Davis-Bacon are contained in 40 USC 3141-3144, 3146, and 3147; 29 CFR part 29; the A-102 Common Rule (§.36(i)(5)); OMB Circular A-110 (2 CFR part 215, Appendix A, Contract Provisions); program legislation; Federal awarding agency regulations; and the terms and conditions of the award.

    This requirement has not historically been applicable to any of the Federal grants of Cambridge-Isanti Schools (the “District”). Program Administrators are aware of existence of such compliance requirements and will monitor grant agreements for any change in applicability. Formal policies and procedures will be developed, as needed, to meet changes in circumstances.

    OMB UGG - Uniform Grant Guidance Compliance Supplement Eligibility

    Source of Governing Requirements – The requirements for eligibility are contained in program legislation, Federal awarding agency regulations, and the terms and conditions of the award.

    Board Policies. The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:
    ● 721 Uniform Grant Guidance Policy Regarding Federal Revenue Sources

    Procedures. The following procedures will also be applied, to the extent that they do not conflict with or contradict the Board policies listed above:
    1. Federal grants will only benefit those individuals and/or groups of participants that are deemed to be eligible.
    2. Sufficient documentation to support determinations of eligibility will be retained and made available to school administration, auditors, and pass-through or grantor agencies, upon request.

    OMB UGG - Uniform Grant Guidance Compliance Supplement Equipment and Real Property Management

    Source of Governing Requirements – The requirements for equipment are contained in the A-102
    Common Rule (§ .32), OMB Circular A-110 (2 CFR section 215.34), (34 CRF section 74.34), program legislation, Federal awarding agency regulations, and the terms and conditions of the award.

    In order to ensure compliance with these requirements, Cambridge-Isanti Schools (the “District”) has implemented the following policies and procedures:

    Board Policies. The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:
    ● 201 Legal Status of the School Board
    ● 721 Uniform Grant Guidance Policy Regarding Federal Revenue Sources
    ● 802 Disposition of Obsolete Equipment and Material

    Procedures. The following procedures will also be applied, to the extent that they do not conflict with or contradict the Board policies listed above:
    1. All equipment will be used in the program for which it was acquired or, when appropriate, other Federal programs.
    2. When required, purchases of equipment will be pre-approved by the grantor or pass-through agency. The Program Administrator will be responsible for ensuring that equipment purchases have been previously approved, if required, and will retain evidence of this approval.
    3. Equipment records (inventory) will be maintained and an appropriate system shall be used to safeguard equipment, as described in the section of this manual titled “Capital Assets”. Equipment should be assigned to a program and physical location on the inventory. If such equipment is moved, it will be noted on the inventory.
    4. When equipment with a current per unit fair market value of $2,500 or more is no longer needed for a Federal program, it may be retained or sold with the Federal agency having a right to a proportionate amount of the current fair market value. Proper sales procedures shall be used that provide for competition to the extent practicable and result in the highest possible return.
    5. If the District no longer has a use for the equipment or it no longer has a residual value, the District may request, and follow, disposition instructions from the USED Secretary.
    6. The purchase of equipment and materials for special education are for the sole purpose of meeting instructional and related service needs of eligible students as documented within their IEP’s.
    7. All equipment/supplies purchased with state and federal funds must comply with the regulations set forth in the Education Department General Administrative Regulations (EDGAR) IDEA 34 CFR 80.32 (d)(1)-(2), IDEA 34 CFR 80.20 (b)(3).
    8. For each piece of equipment and sensitive item purchased with federal funds, the following information will be maintained in an electronic document:
    a. Serial number or other identification number;
    b. Source of funding for the property;
    c. Title holder;
    d. Acquisition date and cost of the property;
    e. Percentage of federal participation in the project costs for the federal
    f. award under which the property was acquired
    g. Location, use and condition of the property; and
    h. Disposition data including date of disposal and sale price of the property.
    9. Updating the Inventory
    a. In the event that a piece of technology equipment or sensitive item is sold, lost or stolen, or cannot be repaired, the Technology department employee(s) should notify the Finance Specialist who will document the necessary equipment disposition information on the appropriate physical inventory record.
    b. Program Administrators or their Administrative Assistants are to notify the Finance Specialist with document disposition information for all other equipment that is sold, lost or stolen, or cannot be repaired, at the time the disposition occurs
    10. Disposition
    a. When original or replacement equipment acquired under a Federal award is no longer needed for the original project or for other activities currently or previously supported by a Federal award, disposition of the equipment will be made as follows:
    i. Items of equipment with a current fair market value of $2,500 or less will be retained, sold, recycled or otherwise disposed of.
    ii. For items with a fair market value of over $2,500, Cambridge-Isanti Schools will follow the procedures spelled out in 2 C.F.R. 200.313(2)(e)(2-4)

    OMB UGG - Uniform Grant Guidance Compliance Supplement Matching, Level of Effort and Earmarking

    Source of Governing Requirements – The requirements for matching are contained in the A-102 Common Rule (§.24), OMB Circular A-110 (2 CFR section 215.23), program legislation, Federal awarding agency regulations, and the terms and conditions of the award. The requirements for level of effort and earmarking are contained in program legislation, Federal awarding agency regulations, and the terms and conditions of the award.

    Board Policies. The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:

    ● 721 Uniform Grant Guidance Policy Regarding Federal Revenue Sources

    Procedures. The following procedures will also be applied, to the extent that they do not conflict with or contradict the Board policies listed above:

    Cambridge-Isanti Schools (the “District”) define “matching”, “level of effort”, and “earmarking” consistent with the definitions of the OMB UGG - Uniform Grant Guidance Compliance Supplement:
    1. Matching or cost sharing includes requirements to provide contributions (usually non-Federal) or a specified amount or percentage of match Federal awards. Matching may be in the form of allowable costs incurred or in-kind contributions (including third-party in-kind contributions).
    2. Level of effort includes requirements for (a) a specified level of service to be provided from period to period, (b) a specified level of expenditures from non-Federal or Federal sources for specified activities to be maintained from period to period, and (c) Federal funds to supplement and not supplant non-Federal funding of services.
    3. Earmarking includes requirements that specify the minimum and/or maximum amount of percentage of the program’s funding that must/may be used for specified activities, including funds provided to sub-recipients. Earmarking may also be specified in relation to the types of participants covered.
    4. In order to ensure compliance with these requirements, the District has implemented the following procedures:
    a. Compliance with matching, level of effort, and earmarking requirements will be the responsibility of the Program Administrator.
    b. Adequate documentation will be maintained to support compliance with matching, level of effort, and earmarking requirements. Such information will be made available to school administration, auditors,and pass-through or grantor agencies, as requested.
    c. Maintenance of effort for grants through the Minnesota Department of Education will be determined at the State level.

    OMB UGG - Uniform Grant Guidance Compliance Supplement Period of Availability

    Source of Governing Requirements – The requirements for period of availability of Federal funds are contained in the A-102 Common Rule (§.23), OMB Circular A-110 (2 CFR sections 215.28 and 215.71), program legislation, Federal awarding agency regulations, and the terms and conditions of the award.

    In order to ensure compliance with these requirements, Cambridge-Isanti Schools (the “District”) has implemented the following policies and procedures:
    1. Costs will be charged to an award only if the obligation was incurred during the funding period (unless pre-approved by the Federal awarding agency or pass-through grantor agency).
    2. All obligations will be liquidated not later than 90 days after the end of the funding period (or as specified by program legislation).
    3. Compliance with period of availability requirements will initially be assigned to the individual approving the allowability of the expense/payment. This will be subject to review and approval in the central office as part of the payment processing.
    4. No more than 15 percent of the District’s annual Title I allocation will be carried over to the subsequent year. In situations where the remaining unspent award exceeds this percentage, a waiver can be formally requested from the Minnesota Department of Education. A waiver can be granted once every three years unless waived by the U. S. Department of Education (USED).

    OMB UGG - Uniform Grant Guidance Compliance Supplement Procurement, Suspension and Debarment

    Source of Governing Requirements – The requirements for procurement are contained in the A-102 Common Rule (§.36); OMB Circular A-110 (2 CFR sections 215.40 through 215.48), program legislation, Federal awarding agency regulations, and the terms and conditions of the award.

    The requirements for suspension and debarment are contained OMB guidance in 2 CFR part 180, which implements Executive Orders 12549 and 12689, Debarment and Suspension; Federal agency regulations in 2 CFR implementing the OMB guidance; the A-102 Common Rule (§.36); OMB Circular A-110 (2 CFR section 215.13); program legislation; Federal awarding agency regulations; and the terms and conditions of the award.

    In order to ensure compliance with these requirements, Cambridge-Isanti Schools (the “District”) has implemented the following procedures:
    1. Purchasing and procurement related to Federal grants will be subject to the general policies and procedures of the District (described in the section of this manual titled “Purchasing and Procurement”).
    2. Contract files will document the significant history of the procurement, including the rationale for the method of procurement, selection of the contract type, contractor selection or rejection, and the basis of contract price.
    3. The Program Administrator will be responsible for determining whether the District is entering into a transaction that may be subject to suspension or debarment procedures and executing appropriate oversight and control activities at that time.

    OMB UGG - Uniform Grant Guidance Compliance Supplement Program Income

    Source of Governing Requirements – The requirements for program income are found in the A-102 Common Rule (§.21 (payment) and §.25 (program income)); OMB Circular A-110 (2 CFR section 215.2 (program income definition), 2 CFR section 215.22 (payment), and 2 CFR section 215.24 (program income)), program legislation, Federal awarding agency regulations, and the terms and conditions of the award.

    In order to ensure compliance with these requirements, Cambridge-Isanti Schools (the “District”) has implemented the following procedures:
    1. Program income will include (but will not be limited to): income from fees for services performed, the use or rental of real or personal property acquired with grant funds, the sale of commodities or items fabricated under a grant agreement, and payments of principal and interest on loans made with grant funds. It will not include interest on grant funds unless otherwise provided in the Federal awarding agency regulations or terms and conditions of the award.
    2. The District will allow program income to be used in one of three methods:
    a. Deducted from outlays
    b. Added to the project budget
    c. Used to meet matching requirements
    d. Absent specific guidance in the Federal awarding agency regulations or the terms and conditions of the award, program income shall be deducted from program outlays.
    3. Program income, when applicable, will be accounted for as a revenue source in the same program code as the Federal grant. See additional information on the uniform chart of accounts in the section of this manual titled “Chart of Accounts”.

    OMB UGG - Uniform Grant Guidance Compliance Supplement Real Property Relocation and Acquisition

    Source of Governing Requirements – Government-wide requirements for real property acquisition and relocation assistance are contained in Department of Transportation‘s single government-wide rule at 49 CFR part 24, Uniform Relocation Assistance and Real Property Acquisition Regulations for Federal and Federally-Assisted Programs.

    This requirement has not historically been applicable to any of the Federal grants of Cambridge-Isanti Schools. Program Administrators are aware of existence of such compliance requirements and will monitor grant agreements for any change in applicability. Formal policies and procedures will be developed, as needed, to meet changes in circumstances.

    OMB UGG - Uniform Grant Guidance Compliance Supplement Reporting

    Source of Governing Requirements – Reporting requirements are contained in the following documents: A-102 Common Rule – Financial reporting, §.41, Performance reporting, §.40(b), OMB Circular A-110 – Financial reporting, 2 CFR section 215, Performance reporting, 2 CFR section 215.51, program legislation, ARRA (and the previously listed OMB documents and future additional OMB guidance documents that may be issued), the Transparency Act, implementing requirements in 2 CFR part 170 and the FAR, and previously listed OMB guidance documents, Federal awarding agency regulations, and the terms and conditions of the award.

    In order to ensure compliance with these requirements, the District has implemented the following procedures:
    1. Reports will be submitted in the required frequency and within the required deadlines. For Federal grants through the Minnesota Department of Education, a final expenditure report can be filed when the total expenditures equal all approved funds.
    2. Reports will be completed using the standard forms (as applicable) and method of delivery (i.e., e-mail, grantor website, postal service, etc.).
    3. Regardless of the method of report delivery, a copy of the submitted report will be retained along with any documentation necessary to support the data in the report. The report will evidence the date of submission in order to document compliance with timeliness requirements.
    4. Financial reports will always be prepared based on the general ledger using the required basis of accounting (i.e., cash or accrual). In cases where financial data is tracked outside of the general accounting system (such as in spreadsheets or paper ledgers), this information will be reconciled to the general ledger prior to report submission.
    5. Any report with financial-related data will either be prepared or reviewed by the Director of Finance and Operations.
    6. Copies of submitted reports with preparer and, if applicable, reviewer signatures and data will be filed with supporting documentation and any follow-up correspondence from the grantor or pass-through agency. Copies of all such reports will be made available to school administration, auditors, and pass-through or grantor agencies, as requested.

    OMB UGG - Uniform Grant Guidance Compliance Supplement Sub-recipient Monitoring

    Source of Governing Requirements – The requirements for sub-recipient monitoring are contained in 31USC 7502(f)(2)(B) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), OMB UGG - Uniform Grant Guidance (§.225, §.310(d)(5), §.400(d)), A-102 Common Rule (§.37 and §.40(a)), and OMB Circular A-110 (2 CFR section 215.51(a)), program legislation, 2 CFR parts 25 and 170, and 48 CFR parts 4, 42, and 52 Federal awarding agency regulations, and the terms and conditions of the award.

    This requirement has not historically been applicable to any of the Federal grants of the Cambridge-Isanti Schools. Program Administrators are aware of existence of such compliance requirements and will monitor grant agreements for any change in applicability. Formal policies and procedures will be developed, as needed, to meet changes in circumstances.

    OMB UGG - Uniform Grant Guidance Compliance Supplement Special Tests and Provisions

    Source of Governing Requirements – The laws, regulations, and the provisions of contract or grant agreements pertaining to the program Board Policies.

    The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:

    ● 612.1 Development of Parental Involvement Policies for Title I Program

    Procedures.

    The following procedures will also be applied, to the extent that they do not conflict with or contradict the Board policies listed above:
    In order to ensure compliance with these requirements, the District has implemented the following policies and procedures:
    1. The Superintendent or Director of Finance and Operations will be assigned the responsibility for identifying financial-related compliance requirements for special tests and provisions, determining approved methods for compliance, and retaining any necessary documentation. Program-related compliance requirements will be the responsibility of the Program Administrator of the grant.
    2. In any given fiscal year that the District’s Title I award, will include set-aside amounts for parent involvement activities, homeless outreach, and non-public school services. The District will use separate general ledger account(s) to track the expenditure of such funds.
    3. Teachers and instructional paraprofessionals will meet the definition of “highly qualified”.
    a. Documentation to support highly qualified status will be retained in the employee’s personnel file and made available to auditors or grantor agencies upon request.
    b. The Director of Teaching and Learning and the Federal Programs Coordinator will be responsible for ensuring that all teachers and instructional paraprofessionals in Title I classrooms meet this standard and have adequate documentation on file.

    Conflict of Interest

    Transactions for Cambridge-Isanti Schools (the “District”) involved in Federal awards are subject to all conflict of interest policies, as applicable.

    Board Policies. The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:

    ● 210 Conflict of Interest - School Board Members
    ● 306 Administrator Code of Ethics
    ● 421 Gifts to Employees and School Board Members
    ● 721 Uniform Grant Guidance Policy Regarding Federal Revenue Sources
    ● 902 Community Use of School Facilities
    ● 403 Discipline, Suspension, and Dismissal of School District Employees

    Procedures. The following procedures will be applied, to the extent that they do not conflict with or contradict the Board policies listed above. Any officer or employee of the District who is directly and/or indirectly involved in the following acquisition-related activities must adhere to the ethics and conflicts of interest principles of the District:
    • Acquiring goods, services and utilities
    • Developing requests for proposals
    • Evaluating bids or proposals
    • Awarding a contract
    • Selecting the final vendor
    • Drafting and entering into a contract
    • Evaluating performance under a contract
    • Authorizing payments under a contract
    1. General Principles
    a. No employee, officer or agent of the District will participate in the selection, award or administration of a contract supported by a Federal award if he or she has a real or apparent conflict of interest. Such a conflict of interest would arise when the employee, officer or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract.
    b. Board members will disclose any conflict of interest (whether in fact or in appearance). When a member of the Board determines that the possibility of a personal interest conflict exists, he/she should, prior to the matter being considered, disclose his/her interest in a public meeting (which will be noted in the official meeting minutes). The individual shall abstain from discussing or voting on this matter.
    c. Any related party transactions will be disclosed as part of the annual audit.
    d. Board members and District employees will neither solicit nor accept gratuities, favors, or anything of monetary value from current or potential vendors of the District or other interested parties if such items are valued in excess nominal value.
    e. District employees are prohibited from using District equipment, materials, and supplies for personal benefit.
    2. Disciplinary Action for Violations
    a. When an employee believes the potential for a conflict of interest exists, it is the employee’s duty to avoid the situation. If an employee or District administrator determines that a conflict of interest exists, the matter will be assigned to another employee who does not have a conflict of interest.
    b. If a conflict of interest occurs, the Director of Administrative Services and Human Resources will conduct an investigation and determine appropriate disciplinary action.
    c. The District will report, in writing to MDE, any violations of the conflict of interest standard, and fraud, bribery or gratuity violations that potentially affect a Federal award.

    Records Retention

    Cambridge-Isanti Schools (the “District”) has developed various policies and procedures regarding the retention of financial and other grant-related records. Transactions involved Federal awards are subject to all such policies, as applicable.

    Board Policies. The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:
    ● 406 Public and Private Personnel Data
    ● 515 Protection and Privacy of Student Records

    Procedures. The following procedures will also be applied, to the extent that they do not conflict with or contradict the Board policies listed above:
    1. Record retention procedures will follow the record retention schedule published by the State of Minnesota Department of Administration.

    Information Technology

    Cambridge-Isanti Schools (the “District”) identifies the efficiencies and risks that come with the increased reliance on information technology. As such, policies have been adopted to govern the use of information technology:

    Board Policies. The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:
    ● 406 Public and Private Personnel Data
    ● 515 Protection and Privacy of Student Records
    ● 524 Internet Acceptable Use and Safety Policy

    Procedures. The following procedures will also be applied, to the extent that they do not conflict with or contradict the Board policies listed above:
    1. Staff passwords must be changed as needed, or as otherwise specified by Board policy.
    2. The District’s network data is backed up daily at an off-site location.

    Supplies

    Cambridge-Isanti Schools (the “District”) utilizes various supplies in its operations. The following policies and procedures will govern the purchase, use, and recording of such items:

    Board Policies. The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:
    ● There are no existing Board policies over supplies

    Additional Policies and Procedures. The following policies and procedures will also be applied, to the extent that they do not conflict with or contradict the Board policies listed above:
    1. Purchase – The purchase of supplies will be subject to the same purchasing and procurement requirements as general District expenditures. Refer to the “Purchasing and Procurement” section of this manual.
    2. Accounting – Supplies will be recorded as expenditures when purchased. Once per year, in conjunction with the annual audit, department heads will inventory food service supplies, bus parts and fuel tanks. Refer to the section of this manual titled “Year-end Closing and Reporting” for additional information.
    a. Certain supplies on-hand at year-end (such as office supplies) will be deemed immaterial and not inventoried or recorded in the year-end financial statements.
    3. Controls – It will be the responsibility of the Building and Program Administrators to determine the appropriate access to supplies and materials.

    Copyrights

    All employees, administrators, and students of Cambridge-Isanti Schools (the “District”) are subject to the provisions of the Copyright Act of 1976. As such, Cambridge-Isanti Schools’ Board of Education has adopted the following guidelines. These policies are deemed to be applicable to printed materials, internet materials, computer software, audio-visual materials, and sheet music.

    Board Policies. The following policies have been separately reviewed and approved by the Board of Education, and are incorporated here by reference:
    ● 409 Employee Publications, Instructional Materials, Inventions and Creations
    ● 524 Internet Acceptable Use and Safety Policy.

    The following procedures will be applied, to the extent that they do not conflict with or contradict the Board policies listed above and is deemed applicable to all transactions, including those with Federal funds:
    1. Unlawful copies of copyrighted materials will not be produced using District-owned equipment, nor will such materials be distributed.
    2. Teachers and Administrators are responsible for the determination of whether photocopies are legal. The District will not be responsible for any fees imposed on its employees or administrators for misuse of copyrighted materials, nor will legal representation be provided in the event of wrongdoing.
    3. Copyright guidelines are communicated to staff through the employee handbook and policy manual and to students through instruction. Media specialists are to be consulted for final interpretation of copyright and fair use exemptions.

    Training and Sanctions

    TRAINING:
    Cambridge-Isanti Schools will provide training to all staff involved in these procedures through activities such as:
    ● Orientation of new staff
    ● Distribution of federal laws, regulations and guidance
    ● Distribution of Cambridge-Isanti Schools policies and procedures
    ● Distribution of Cambridge-Isanti Public Schools Employee Handbook
    ● Developing templates, checklists and other guidance documents as appropriate
    ● Internal training sessions
    ● Routine staff meetings
    ● Informal technical assistance.

    The Building or Program Administrator will confer with District staff as necessary to ensure that these procedures are followed. These meetings may occur either on an individual basis or in a group setting.

    Board Policies - The following board policies have training implications:
    ● 201 Legal Status of the School Board
    ● 210 Conflict of Interest - School Board Members
    ● 406 Public and Private Personnel Data
    ● 421 Gifts to Employees and School Board Members
    ● 515 Protection and Privacy of Pupil Records
    ● 524 Internet Acceptable Use and Safety Policy
    ● 701 Establishment and Adoption of School District Budget
    ● 701.1 Modification of School District Budget
    ● 702 Accounting
    ● 703 Annual Audit
    ● 721 Uniform Grant Guidance Policy Regarding Federal Revenue Sources
    ● 802 Disposition of Obsolete Equipment and Material
    ● 902 Community Use of School Facilities

    EMPLOYEE ACCOUNTABILITY AND SANCTIONS:
    Failure to follow the provisions of these procedures will subject the individuals responsible for the violation(s) to administrative and/or disciplinary actions in accordance with District disciplinary procedures and the judgment of management. Sanctions may include verbal warnings, written warnings, suspension and/or dismissal.

     

    Updated: 6/22/2017, 2018

     

Policy Manual