The institution maintains financial control over externally funded or sponsored research and programs.

  X   Compliance                     ___Partial Compliance                       ___Non-Compliance

Narrative

St. Petersburg College is in compliance with this comprehensive standard because is maintains appropriate control over externally funded programs.

Policies Governing Expenditures of External Funds

St. Petersburg College encourages its Faculty and staff to seek financial support beyond state appropriated resources.  External funding is obtained from federal, state, local or private sources.

The College has an extensive grant development process.  In identifying a potential grant opportunity the proposer will present the idea through his or her Cabinet member to Cabinet and the President of the College.  A decision will be made by the President to pursue the grant based on a combination of several factors:  centrality to mission, institutional/program strength in the area of the grant, appropriateness to the community college, time and effort vs. size of the grant, timing/workload, number of awards to be made, usefulness in securing other grants and/or achieving other critical institutional needs, prestige, institutional impact, matching requirements, and commitment of institutional resources and manpower over time.  The Cabinet sponsor and President will provide final approval on the grant proposal before submission to the Board of Trustees.  The grant proposal application is then submitted to the College’s Board of Trustees for review and approval.

The College adheres to the following statutes, rules, policies and procedures that govern the expenditures of external funds:

(1)   U.S. OMB, Circulars:  Circular A-21, Cost Principals fro Educational Institutions; Circular A-110, Uniform Administrative Requirements or Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Nonprofit Organizations; Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations.

(2)   Board of Trustees Rule 6Hx23-5.25, Grant Restricted Funding Approval

(3)   Board of Trustees Procedure P6Hx23-5.25, Grant Approval

(4)   Board of Trustees Rule 6Hx23-5.12 and Procedure P6Hx23-5.12, Purchasing

(5)   Accounting Manual for Florida’s Public Community Colleges

(6)   State of Florida Department of Education Green Book (Project Application and Amendment Procedures for Federal and State Programs)

(7)   U.S. Department of Health & Human Services indirect cost Rate Agreement for 07/01/04 – 06/30/07

Applications for external support must be routed for internal approval at several levels within the College during the grants development and submission process.  The relevant program director, campus provost and cabinet member must approve pursuing grant opportunities.  The cabinet member then reviews the grant opportunity with the President’s Cabinet, which approves or disapproves pursuit and submission of the grant.  When grant narratives and budgets are complete the Human Resources Director, Facilities Director, and relevant campus provost and senior vice president review and approve the grant using a grant information summary (GIS) form which is then submitted for Cabinet, Presidential and Board approval.  The President signs all SPC Board of Trustee Memorandums (a formal request for Board action) for grants that are submitted by the College.  The President (in addition to the relevant budget supervisor and provost, Purchasing Director, Associate Vice President of Financial and Business Services and the Vice President of Information Systems, Business Services, Budgets, Planning and Research) signs the Request for Contract forms (a formal request for the College to enter into a contract).  The President also signs the grant application signature pages that are required by grant funding sources.  GIS forms, SPC Board of Trustee Memorandums, Request for Contract forms, and grant application signature pages signed by the President are on file and available for review for each grant submitted.  When the grant is approved and awarded by the granting agency, it is submitted to the Board of Trustees for official acceptance for the College.

When the College is notified that a project has been funded, responsibility for the administration and supervision of the operations of a grant program at the College is shared by the department in which the grant was developed and the Office of Financial and Business Services.  The program director or coordinator of the grant is responsible for maintaining files required to verify compliance with all provisions of the grant including grant goals, objectives, budgets and timelines.  The program director is responsible for all aspects of grants management, including meeting performance goals and fiscal goals.  The Grants Accounting Office, a subset of Financial and Business Services, maintains financial controls over grant funds.  The Associate Vice President of Financial and Business Services has fiscal reporting responsibility and certifies the use of external funds; currently this administrator is a Certified Public Accountant with over 18 years of experience in auditing and financial reporting in accordance with the United States Office of Management and Budget (OMB) guidelines and non-profit organizations.  The Grants Accounting Office establishes, monitors, and reports on externally restricted funds that are used to support College programs and services.  Expenditures for grants and contracts follow the same rules and procedures as all other expenditures in the College, and all personnel are subject to the Board of Trustees rules for all employees.

In addition, the Grants Accounting Office coordinates audit monitoring visits of funding agencies, reviews grant and contract proposals, assists in forecasting, revising, and amending budgets for sponsored programs, provides guidance related to program budget management, monitors grants to assure compliance with polices for expenditures, and assists external auditors with program financial and performance information.  The College’s Board Rules and Procedures, the Post Award Grant Accounting Procedures (with staff), and the Post Award Grant Accounting Procedures (no staff) all provide instructions for how to manage a broad range of finance-related tasks.  The Board of Trustees Rules and Procedures are available for review on the College’s Web site.  All College Faculty and Staff have access to the Financial and Business Services Web site where the Post Award Grant Accounting Procedures may be reviewed.

Institution’s Financial Policies and Procedures for Externally Funded Programs

The Institution’s externally funded programs are accounted for in an appropriate manner consistent with the Institution’s financial policies and procedures. St. Petersburg College has clear policies and procedures for both pre-award and post-award financial management of externally funded grants and contracts.

The Grants Development Office is responsible for a broad range of grant-funding research and grant proposal development activities that are intended to directly support the mission, goals, and strategic priorities of SPC as directed by the President of the College and approved by the SPC Board of Trustees.  The following graph is a “snapshot” of grant award amounts for currently active grants.  This information is generated from the master list of grants and contracts maintained by the grants accounting office.

                       Grants Development Office chart, 11-13-06

The activities of the Office of Grant Development include but are not limited to the following: communication of grant funding opportunities; coordination of grant development activities (internally and externally); preparation of grant-funding proposals; preparation of SPC Cabinet and Board of Trustee documents; grant budget development; program planning; grant records management; development of Grants Development Office policies/procedures; and ongoing support of grants management activities following a funding award.  All of the above identified activities are managed on an ongoing basis throughout the year by the Director of Grants Development under final approval of the President of St. Petersburg College, as stated in the Board of Trustees policies/procedures.

In the post-award phase, the Grants Accounting Office in Financial and Business Services provides guidance for management of a grant or contract.  This guidance includes information on and assistance with authorization of expenditures, cost-sharing, reporting of time and effort, purchasing, travel authorizations, equipment, post-award changes in the project, retroactive cost transfers, and close-out of the grant.  The financial procedures for managing grants and contracts are conducted in accordance with the standards of the particular funding agency and  governed by state laws, and  are in compliance with the requirements of the federal principles and guides (Accounting Manual for Florida’s Public Community Colleges; the State Department of Education Green Book Office of the Comptroller Staff and Responsibilities; U. S. OMB, Circular A-21, Cost Principles for Educational Institutions; U.S. OMB, Circular A-133 Audits of States, Local Governments, and Non-Profit Organizations;  U.S. Office of Management and Budget Circular A-110, Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals, and Other Nonprofit Organizations).

Reporting of Externally Funded Programs

Appropriate reports are filed in a timely manner as required by the external source of funds. St. Petersburg College manages approximately 100 grants/contracts per year.  A Master List of Grants and Contracts awarded is maintained and updated monthly by the grants accounting department. This master list includes the awarding agencies, titles of grants, department numbers, principal investigator, periods of grants, due dates for filing reports and amounts of applicable indirect cost rates.  The following information, prepared by the Grants Development Office reflects the federal earmark, federal other, state, local and private grant and contract funds earned and expended during fiscal years 2002 – 2003 through 2005- 2006.

            Grants Development Office chart on funds earned and expended

Indirect costs are provided by external agencies that award grants and contracts to St. Petersburg College.  Indirect costs are to support the general operations and administration necessary for grants activities.  Depending upon the agency and the type of grant or contract, the indirect cost rate can range from zero (0) to a maximum of a negotiated rate.  The current negotiated Federal indirect cost rate for Facilities and Administrative cost rate is 47% direct salaries and wages.  This rate is valid through June 30, 2007.

Furthermore, reporting requirements are mandated by each grant (Monthly Report; Quarterly Report) and a Final Report is issued when each grant’s funding cycle is complete.  The College has consistently filed all reports required by external sources in a timely manner.

Management’s Control over External Program Funds

St. Petersburg College’s externally funded programs are audited annually by the State of Florida Auditor General’s Office.  The audits are conducted per the requirements of the OMB Circular A-133.  An examination of Federal awards administered by the College is included in the Florida statewide audit of Federal awards.  Full Federal Audit Reports are available on the Florida Auditor General - Financial/Federal Awards (http://www.state.fl.us/audgen/pages/subjects/financial.htm); the reports are not issued separately by College.

In addition to the Florida’s Auditor General’s Office audit, selected agencies visit the College and inspect the records and procedures.  Examples of some agency reviews are listed below:

• U.S. Department of Education, Office of Postsecondary Education conducted an on-site review of the federally funded Project Eagle Online Learning program in July, 2005. This on-site review disclosed no findings.
• Work Net Pinellas, Inc. of Clearwater, FL conducted a Financial and Administrative Monitoring Review on October 10, 2006 for the funding contract from July 1, 2005 to June 30, 2006 of $1,792,500.  This review disclosed no findings or recommendations.
• U.S. Department of Labor, Employment and Training Administration of Atlanta, GA conducted a review in August, 2006 on the SPC Community Based Job Training Grant, Registered Nurse Job Fulfillment Partnership Associate Program.  The purpose of the visit was to determine compliance with federal regulations and to review the programmatic, financial and administrative activities of the grant.  This review disclosed no findings.

References