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1. Compliance with matching, level of effort, and earmarking requirements will be the responsibility of theFinance <br />Director. <br />2. Adequate documentation will be maintained to support compliance with matching, level of effort, and <br />earmarking requirements. Such information will be made available to city administration, auditors, and pass - <br />through or grantor agencies, as requested. <br />3. Maintenance of effort for grants through the State Minnesota will be determined at the State level. <br />Period of Performance <br />Source of Governing Requirements — The requirements for period of performance of Federal funds are contained in <br />the A-102 Common Rule (§ .23), OMB Circular A-133 (2 CFR sections 215.28 and 215.71), program legislation, <br />Federal awarding agency regulations, and the terms and conditions of the award. <br />In order to ensure compliance with these requirements, the city has implemented the following policies and <br />procedures: <br />1. Costs will be charged to an award only if the obligation was incurred during the funding period (unless pre - <br />approved by the Federal awarding agency or pass -through grantor agency). <br />2. All obligations will be liquidated not later than 90 days after the end ofthe funding period (or as specified by <br />program legislation). <br />3. Compliance with period of performance requirements will initially be assigned to the individual approving the <br />allowability of the expense/payment. This will be subject to review and approval by the Finance Department as <br />part of the payment processing. <br />Procurement, Suspension and Debarment <br />Source of Governing Requirements — The requirements for procurement are contained in the A-102 Common Rule (§ <br />.36); OMB Circular A-133 (2 CFR sections 215.40 through 215.48), program legislation, Federal awarding agency <br />regulations, and the terms and conditions of the award. The requirements for suspension and debarment are contained <br />OMB guidance in 2 CFR part 180, which implements Executive Orders 12549 and 12689, Debarment and Suspension; <br />Federal agency regulations in 2 CFR implementing the OMB guidance; the A-102 Common Rule (§.36); OMB <br />Circular A-133 (2 CFR section 215.13); program legislation; Federal awarding agency regulations; and the terms and <br />conditions of the award. <br />In order to ensure compliance with these requirements, the city has implemented the following policies and <br />procedures: <br />1. Purchasing and procurement related to Federal grants will be subject to the general policies and proceduresof <br />the city (described in the section of this manual titled "Purchasing and Procurement"). <br />2. Contract files will document the significant history of the procurement, including the rationale for the method of <br />procurement, selection of the contract type, contractor selection or rejection, and the basis of contract price. <br />3. The Finance Director will be responsible for determining whether the city is entering into a transaction thatmay <br />be subject to suspension or debarment procedures and executing appropriate oversight and control activities at <br />that time. <br />Page 13 <br />