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Fiscal Accountability
from Building Blocks to Success Title III Program Administration Policies and Procedures Manual 17-25
Activity Account Numbers
Whenever possible, regular university business procedures are used to document accountability for Title III regulations. Separate account numbers have been assigned by the Controller’s Office to identify the Title III grant activities. These numbers always begin with 205 and are followed by ten other digits and a five-digit object code. New account numbers are assigned yearly for each activity.
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All expenditures (i.e. requisitions, purchase orders, personnel action forms, travel authorizations) submitted to the Title III Office for payment must show the designated activity number and be signed by the budget officer. These requests are checked for programmatic and financial accuracy. The financial check includes a review for availability of funds. If all is accurate, the request is initialed by the Title III Director and submitted for further university required processing.
Activity Expenses
Requests for payment of activity expenses can be processed by the Title III Director when all required documentation and signatures are submitted; however, expenditures were approved by the U. S. Department of Education and cannot be changed without the approval of that agency. Items not specifically identified, such as additional equipment, personnel, or travel (no matter how much money is left over as a result of cost savings) cannot be approved by the Title III Director.
Activity budgets were carefully prepared to support the narrative of the activity, and no changes or substitutions can be made without prior approval of the Title III Director, and in some cases the U. S. Department of Education (DOE). Approval from the DOE is a lengthy process and is discouraged.
Requests for expenditure of funds for approved items are processed within 72 hours after being received in the Title III Office. When a request is received in the Title III Office, it is
stamped with the date and time of receipt. It is then checked for programmatic and financial accuracy. If all is correct and funds are available, the request is submitted with further processing in accord with university policies and procedures. If the request is inaccurate programmatically or financially, the inaccuracies are noted to the requester so that corrections, if possible, can be made. If a Budget Amendment Request is needed to rectify the problem (by transferring available funds into the appropriate category), Title III staff works closely with the requester to complete the transfer form.
Equipment: Defined Requirements
The Office of State Accounting has determined that equipment is defined as those purchases which have a cost of $5,000 or more, a life of one (1) year or more, and a separate identity of their own. Ex: the car not the motor.
While $5,000 is the threshold for the equipment classification, this in no way precludes that the agency head is responsible and accountable for those items with a lesser cost, such as a printer at $450, a computer at $1,800, or sets of items like tools or dishes.
To assure accountability for these lesser items, this agency has classed them as non-capitalized equipment and the Property Control Section of Finance maintains a separate accountability just for these.
(See Procurement User’s Manual 2017 online www.uapb.edu under Purchasing and Procurement)
Property Management
General grant regulations for Title III require that all equipment be properly accounted for by the Title III Director. To comply with this regulation, activity directors will complete an Inventory Form listing all equipment purchased by Title III. This inventory list should be submitted when an item is received. Remember it is very important that:
An inventory list of Title III purchased equipment should be sent to the Title III Office upon receipt of the equipment by the requester. The inventory list must be up-to-date and include all equipment that has been purchased for an activity by Title III.
In addition to the Inventory List, which will be kept on file in the Title III Office, all equipment must bear a decal for the university inventory as well as a decal for Title III inventory. The Title III decal will clearly identify the equipment as being purchased with federal funds. A physical inventory of Title III equipment will be made at a minimum every other year and reconciled with the university’s property management records.
No property purchased with Title III funds may be sold or disposed of except through the office of the Title III Director and consistent with federal regulations.
Money received from the sale of such property must be disposed of consistent with federal guidelines. Any loss, damage, or theft of property must be investigated and fully documented in a report to the Title III Director. Thefts must be documented with a police report. Adequate security and maintenance procedures must be implemented for the equipment.
When Title III purchased equipment is no longer needed for its original purpose (activity), or is not repairable, the Office of Title III should be notified by providing the decal number(s) and other descriptive information for the equipment. A copy of the moving request form should be sent to Title III.
SUPPLANTING - SUPPLEMENTAL REQUIREMENTS
Title III grant funds may not support any service, program, or position that was supported by university resources prior to awarding of the Title III grant.
The following procedures will insure that Title III funds are used to supplement not supplant institutional funds:
1. University Funded Positions
• University continues to fund the position.
• No Title III funds are used.
2.
• Position is university’s contribution to Title III Program.
Title III Funded Positions Requirements
• Personnel paid by the University cannot be moved to
Title III funding for performing the same duties that were university funded.
• Salaries paid by Title III are governed by the same pay rate as the university and cannot be inflated.