2023 Guide To Grants v2
2023 Guide To Grants v2
GUIDE TO GRANTS
PUBLIC SAFETY OFFICE
SEP. 2023
Guide to Grants 2
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1. Award
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1. Award
• Grant Programs. The Office of the Governor’s Public Safety Office (PSO) is comprised
of several programs that this Guide applies to: Border Security, Child Sex Trafficking,
Crime Stoppers, Justice, Terrorism Preparedness, Victim Services, and the Sexual
Tools
Assault Survivors Task Force. To learn who your grant manager is
for each grant, go to eGrants and
• Primary contact. Each grant has a PSO staff member who is assigned as the grant select the “My.Home” tab for contact
manager. This person is responsible for oversight of your grant project and can help you information.
with your questions and other needs. We recommend that you contact your Grant
Manager directly by clicking on the Grant Managers name in eGrants under the
My.Home tab. This action will automatically create an email in Outlook for your Grant
Manager.
Contact Information
Guide to Grants 4
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1. Award
Getting started
References
1 TAC §3.11, Grant and
Supplemental Award Acceptance
• Announcement. All three grant officials—the authorized official, the financial officer, 1 TAC §3.2503, Obligating Funds
and the project director—will receive an email announcing the award.
2 CFR 200.403, Factors Affecting
• Acceptance. The authorized official must accept the award. Only after acceptance Allowability of Costs
can you begin activities and draw funds or take other actions in eGrants. This action TxGMS, pg 32, Basic
must take place within 45 days of award. We recommend reading all award Considerations
documents prior to accepting the grant; acceptance of the award indicates the
grantee’s acceptance of all award conditions.
Guide to Grants 5
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1. Award
Conditions of funding
References
• Standard conditions. General grant conditions applicable to any award are
included within the Standard Conditions and Responsibilities Memo attached to the 1 TAC §3.2001, Conditions
award and found on the eGrants Summary/Award.Statement tab. of Funding
1 TAC §3.2515, Bonding
• Federal fund-specific conditions. Federal funds often come with additional
conditions that must be passed down to subrecipients. These conditions will also
be attached to the award and found on the eGrants Summary/Award.Statement
tab.
• Special conditions. The PSO may also place special conditions on your grant
award prior to or during the project period beyond those in the Standard
Conditions. They are listed in the statement of grant award and on the eGrants
Conditions.of.Funding tab. These conditions may come with payment hold. See
next slide for various types of payment holds.
• Risk-based conditions. When the PSO finds that a risk exists because a
grantee has not submitted required information or has not complied with any
applicable statute, rule, regulation, guideline, or requirement, we may place a
condition of funding on the grant, which may include a hold on funds.
• Non-profit bonds. Each nonprofit corporation receiving funds must obtain and
have on-file a blanket fidelity bond that indemnifies the PSO against the loss and
theft of the entire amount of grant funds, including match. The cost of the bond is
an eligible grant expense.
Guide to Grants 6
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1. Award
Payment holds
The PSO may temporarily withhold payments if a sub-grantee fails to comply with any
term or condition of an award or when additional project information is needed.
References
Types of holds:
eGrants Financial Management
• Budget line-item (BLI) hold – May be placed on a single budget line item within Guide
a grant when additional information is needed, or certain requirements must be
met, before reimbursement can be made on the line item. Budget line-item holds
are commonly placed pending submission of a Training Approval Review,
Procurement Questionnaire, Environmental Planning and Historical Preservation
Review, Interoperability Standards Statewide Interoperability Coordinator (SWIC)
Review, or an indirect cost rate letter. (Instructions and forms related to these
holds may be found within eGrants.)
• Fund hold (FH) – May be placed on an individual grant award when additional
information is needed, or certain requirements must be met, before ANY
reimbursement can be made under the grant. Fund holds are commonly placed
on a grant for an expired System for Award Management (SAM) registration, an
outdated authorizing resolution, or High-Risk Designation.
• Vendor hold (VH) – Withholds all funds from the PSO to the grantee agency,
regardless of the fund source. Vendor holds are commonly placed on an agency
for delinquent progress reports, delinquent required Financial Status Reports
(FSRs), missing single audits, unresolved monitoring findings, and other serious
infractions as determined by the PSO.
Guide to Grants 7
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1. Award
• PSO General FAQs. A list of commonly asked questions in an easy-to-read question and answer format.
• DOJ Financial Guide. Issued by the Office of Justice Programs, US Department of Justice (DOJ). This guide is applicable to grantees
receiving federal pass-through funds originating from DOJ and offers more in-depth information on common issues in grants and
financial management.
• FEMA Information Bulletins and Policies. The US Department of Homeland Security’s Federal Emergency Management Agency
(FEMA) has issued the Preparedness Grants Manual, numerous information bulletins and policy statements related to common grant
issues. These bulletins and policies are applicable to Border Security and Preparedness Program grantees receiving federal pass-
through funds originating from FEMA.
Guide to Grants 8
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1. Award
The Authorized Official (AO) is usually a county judge, mayor, city manager, chairman of a
non-profit board, head of a state agency, executive director, etc. They are authorized by the
governing body of the organization to:
• apply for, accept, reject, alter, or terminate the grant; and
• certify changes made to applications or grants.
The Financial Official (FO) must be either an employee or board member and should be
the Chief Financial Officer, Auditor, or Treasurer of the Board for the grantee agency. The
employee or board member designated as the FO should have an in-depth understanding of
the grantee’s financial tracking system as well as their obligations related to grant and match
expenditures. They are responsible for:
• maintaining financial records to account for all grant expenditures and funds;
• requesting payments; and
• completing all required financial reporting at least quarterly.
The Project Director (PD) must be an employee of the grantee agency. They are
responsible for:
• the day-to-day operations of the project; and
• required programmatic reporting.
Guide to Grants 9
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1. Award
Guide to Grants 10
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2. Report
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2. Report
• Method. To submit a FSR see the eGrants Financial Management Guide or the FSR
Instructional Video for detailed instructions.
• Delinquent reports. If you do not submit required quarterly FSRs on time, your entire
agency will be placed on vendor hold, meaning that no payments from the Governor’s
Office will be made to your agency until the report is submitted.
Tools
• 10% Rule (May not apply to all HSGP or NSGP programs). In certain budget categories
you may report expenditures in excess of the budgeted amount, as long as you do not To submit an FSR, go to eGrants and
exceed 10% of the OOG award amount – this is called the 10% Rule. Note: This rule does from the My Home tab click on the
not apply to the Equipment or Indirect Cost budget categories; any changes to items in grant record, then choose the Budget
these budget categories must be approved through a budget adjustment prior to requesting tab and click on the Financial Status
reimbursement. Report sub tab.
Due Dates
Quarter FSR Due
Programmatic reporting
• Requirement. Grantees must report their progress in meeting the goals, References
objectives, and measures of their grant. (1 TAC §3.2527) 1 TAC §3.2527, Grantee Reports
2 CFR §200.329, Monitoring and
• Method. Most progress reporting will occur within eGrants on the reporting program performance
Summary/Progress.Reports.General and Summary/Progress.Reports.Federal
2 CFR §200.332, Requirements for
tabs. Grantees with federally funded awards will submit both a General and a
pass-through agencies
Federal Progress Report. Grantees with state-funded awards will submit a
General Progress Report. Some exceptions may apply and will be communicated TxGMS, pg 28, Performance and
in writing. Financial Monitoring and Reporting
• Frequency. The number of reports and the due dates depend on the funding
source for your grant. The reporting tabs in eGrants indicate the type of reports
applicable for each funding source and grant. See the table below for the due
dates by report type. Note also that some grant awards may require more
frequent reporting. *VAWA and SASP grants may have an alternate due date.
Quarterly Jan. 15
Apr. 15
Jul. 15
Oct. 15
Semiannual Jan. 15
Jul. 15
Biannual Mar. 15
Sep. 15
Guide to Grants 13
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2. Report
• State funds. Most awards that come from state sources must have a SAM
registration at the time of application, which must be valid at the time of award.
Note: Crime Stoppers programs do not require SAM registration.
• Guidance. The requirement for SAM is included in the Request for Applications
for each program or funding source.
• Updates. If the grantee updates the SAM registration and receives a new
expiration date on the federal SAM website, they must also submit a grant
adjustment through eGrants to update the SAM expiration date on the grant
record.
Guide to Grants 14
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3. Manage
TOC 15
3. Manage
Financial management
• Exercise controls. The system must enforce effective control over, and
accountability for, all funds, property, and other assets. It must also adequately
safeguard all assets and assure that they are used solely for authorized
purposes.
• Manage budget. The system must provide for comparison of expenditures with
budget amounts for each grant and include written procedures for determining the
allowability of costs.
Guide to Grants 16
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3. Manage
Unallowable costs
The Request for Applications for each grant program may set out additional unallowable
costs; however, there are some costs that are never allowed:
References
• Supplanting or the use of grant • Federally prohibited equipment, including weapons DOJ Grants Financial Guide,3.11
Unallowable Costs
funds to replace any other existing
• Lobbying
federal, state or local funds TxGMS, Appendix 7, Selected
• Fundraising Items of Cost Supplement Chart
• Inherently religious activities such
as prayer, worship, religious • Corporate formation 2 CFR 200, Subpart E, Cost
instruction, or proselytization Principles
• Entertainment
• Promotional gifts Prohibited and Controlled Equipment
• Fines and penalties (BJA)
• Any salary or compensation for an • Credit card fees FEMA Preparedness Grants Manual
elected or appointed city, county, or
state government official • Passport charges
Guide to Grants 17
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3. Manage
Matching contributions
Required match. If the fund source requires matching funds on a grant, the grantee must
ensure that it possesses or can acquire the required matching funds. A third-party (i.e.,
contractor or participating entity/partner) may contribute toward the matching funds
requirement but the applicant bears the responsibility for satisfying the matching funds
References
requirement. 1 TAC §3.73, Matching Funds Policy
2 CFR §200.306, Cost Sharing or
Cash match expenditures. Actual non-OOG cash spent by the grantee on eligible items Matching
included within the approved eGrants budget.
2 CFR §200.436 Depreciation
In-kind contributions. If a program allows for in-kind contributions, the fair market value of
goods and services must be documented and supported by the same methods otherwise TxGMS, pg15, Cost Sharing or
used to support reimbursed costs. In-kind contributions must be donated to the grantee by a Matching
third party (employees and board members of the grantee are not considered third parties).
Volunteer time on grant-related activities may be used as in-kind match, but rates must be
consistent with those paid by the grantee for similar work and may not be provided by paid
employees or board members of the grantee.
Applicable rules and policies. Matching funds are part of the overall total project budget
and are considered grant funds. As a result, all rules and policies that apply to the OOG
award amount also apply to the matching funds. Match contributions may only be used for
eligible, approved budget items that are necessary and reasonable to accomplish project
objectives. These policies apply to both the required match and any voluntary overmatch.
Guide to Grants 18
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3. Manage
Personnel costs
Salary level. Compensation for grant-funded employees must be comparable to that of non-
grant funded employees performing similar work duties. Compensation typically includes
wages or salary as well as employer paid taxes and fringe benefits. Fringe benefits are an
allowable expense. Some common types of fringe benefits include: life, disability, and health References
insurance; unemployment taxes; workers compensation; tuition reimbursement; education
assistance; and retirement plan contributions. 1 TAC §3.75, Personnel
2 CFR § 200.430,
Compensation— Personal
Leave payouts. Grantees may use grant funds to compensate staff members leaving Services
employment with accrued leave (which includes, but is not limited to, annual leave,
compensatory time, and sick leave) in accordance with the grantee's written policy. These DOJ Grants Financial Guide,3.9
payments may only fund leave earned during the current grant period. The proportion of Allowable Costs
grant funds paid for leave cannot exceed the proportion of grant funds used to pay the staff TxGMS, pg 96, Chapter 783
member's salary (if the employee is paid from OOG funds at 50% of full time, then the grant Supplement for State Grant
can only provide 50% of the leave payout). Programs
Severance pay. Grantees may use grant funds to provide severance pay to employees
who, through no fault of their own, were terminated, furloughed, laid off, retired, took early
retirement, etc., and when payments are in accordance with the grantee’s written policy.
Costs of severance pay must be allocated to all projects on which the employee was funded
during the current grant period and must be based on normal severances over a
representative past period. Grantees must seek prior approval from PSO for abnormal or
mass severance pay.
Unallowable cost. The PSO will not pay any portion of the salary of, or any other
compensation for, an elected or appointed city, county, or state government
official (e.g., Sheriff, Constable, Treasurer, etc.).
Guide to Grants 19
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3. Manage
Overtime. Overtime is allowable to the extent that it is included in the approved budget, the grantee
agency has a written overtime policy approved by its governing body, and both grant-paid and non-
grant paid personnel are treated the same with regards to the application of overtime policies. The
approved overtime policy should be part of the grant application. In no case is dual compensation Tools
allowable. That is, an employee of a grantee agency may not receive compensation for hours worked When reporting Overtime
(including paid leave) from his/her agency AND from an award for a single period of time, even expenses for a border security
though such work may benefit both activities. The PSO will only reimburse the grantee for overtime or preparedness grant on an
that does not exceed a total of 16-hours worked (regular plus overtime) during any 24-hour period. FSR you must complete and
Overtime payments issued outside of these guidelines are the responsibility of the subrecipient upload a Personnel Overtime
agency. Summary Form for each
overtime line item. (Under
On-call time. On-call hours for employees should not be included in physical hours worked or as “Forms”)
eligible hours for overtime. Time recorded for on-call hours should be maintained in accordance with
grant time and effort documentation requirements. The maximum hourly rate charged to the grant
cannot exceed 50% of the employee’s regular hourly rate. If the governing board has established a
lower rate, then the lower rate must be used. On-call services for volunteers may be used to meet
match requirements when on-call services are necessary to carry out the mission of the project. The
lowest comparable employee rate must be used to determine the 50% volunteer rate. The budget
line-item description should clearly indicate if the employee or volunteer provides on-call services.
Grantees must have a board-approved on-call policy and provide a copy upon request.
Self-Funded Grantees. For benefits provided by the entity itself (self-insured), the grantee should ensure to maintain on file:
• Descriptions on the types of insurance provided by the grantee (e.g., health, dental, life, disability, retirement, worker’s
compensation, etc.).
• Procedures or methodology followed by the entity for determining self-insured rates (employer and employee portions).
• Policy and procedures on how self-insurance works and how it is tracked in the accounting system.
• A list of insurance benefit policies offered, and rates assigned for employee and employer.
• Report(s) used to determine rates (i.e., Internal and Actuarial Analysis).
• Proof of purchase & payment for Stop Loss Insurance
• Signed minutes (board/committee or other) showing approval of the rates and effective period(s).
Guide to Grants 20
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3. Manage
Less than 100% on a single grant. Any employee who is not working solely on the grant (i.e. works on
more than one grant, a grant and non-grant activity, an indirect cost activity and a direct cost activity, two or
more indirect activities which are allocated using different allocation bases, or an unallowable activity and a Tools
direct or indirect grant activity) must keep time and activity reports recording all hours worked and allocated
Sample time and activity
by funding source (regardless of internal policy, this requirement also applies to exempt employees when
they are less than 100% funded). (See “Grantee Personnel Time and Activity Report Requirements.”) These report
reports should be developed to coincide with each pay period (preferably) or at minimum monthly. Sample employee effort
certification
Overtime grants. Entities receiving grant funds for overtime must maintain time and activity reports
for all time physically worked.
Documentation. All timekeeping records (timesheets, time and activity reports and certifications) must be
signed (manually or electronically) by the employee and a supervisory official having firsthand knowledge
of the work performed, and the documentation must be incorporated into grantee’s official records.
Grantees must have written procedures in place when the agency allows employees and/or supervisors to
sign documents electronically. Salaries and wages of employees used in meeting cost sharing or
matching requirements on Federal awards must be supported in the same manner as salaries and wages
claimed for reimbursement from Federal awards.
Guide to Grants 21
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3. Manage
Guide to Grants 22
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3. Manage
Equipment
Definition. Tangible personal property (including information technology systems) having a
useful life of more than one year and a per-unit cost of $5,000 or more, or less if the grantee References
chooses to capitalize items costing less. 1 TAC §3.2509, Equipment Inventory
Reports
State-Controlled Assets. The following items valued between $500.00 and
$4,999.99 are designated by the Texas Comptroller as controlled assets within the State 1 TAC §3.81, Equipment
Property Accounting guidance and must be maintained within the grantee’s inventory
records: sound systems and other audio equipment; cameras; TVs; video players/recorders; 2 CFR §200.1, Equipment
desktop or laptop computers; data projectors; smartphones, tablets and other handheld 2 CFR §200.439, Equipment
devices; and unmanned aerial vehicle drones. The PSO has also designated mobile and and other capital expenditures
portable radios as a controlled asset.
2 CFR §200.313, Equipment
Use. Equipment must be used by the grantee in the program or project for which it was State Comptroller’s Controlled
acquired as long as needed, whether or not the program or project continues to be Assets List
supported by grant funds. After the program has closed, and when the equipment is no DOJ Grants Financial Guide,3.9
longer needed for the original program or project the agency may need to request disposition Allowable Costs
instructions.
PSO General FAQs
TxGMS, pg 26, Property Standards
Guide to Grants 23
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3. Manage
Inventory. The PSO requires each grantee to maintain written procedures for managing
equipment and maintaining an updated inventory report. Grantees must maintain on file a
current inventory report with property records for all equipment and state-controlled assets
(as defined above), and items capitalized by the grantee, purchased with grant funds during Tools
the grant period. The following elements must be included within the property records:
Equipment Disposition
description of the property; serial number or other ID number; source of funding including the
Request Form
OOG-issued grant number and the Federal/State Award Identification Number (FAIN/SAIN);
who holds title; acquisition date; cost of property; percentage of the property’s cost paid with Equipment Inventory
grant funds; location; use; condition (does not mean ‘new’ or ‘used’; see PSO General FAQ Template
for condition types); and disposition data, including the date of disposal and sale price (or fair
market value if item is not sold).
Physical Inventory. A physical inventory of the property must be taken and the results
reconciled with the property records as least once every two years.
Disposition. When equipment acquired under an award is no longer needed for the original
project or program or for other activities supported by the federal* awarding agency (or for
state funds from the OOG), the grantee may need to request disposition instructions from
the OOG using the Equipment Disposition Request form. Items with a current per unit fair
market value less than $5,000 may be retained, sold, or otherwise disposed of with no
further obligation to the Federal awarding agency or OOG.
*For equipment funded under a state award, when the equipment acquired with state funds is no
longer needed for the original project or for other activities supported by an award from the OOG, the
grantee may need to request disposition instructions.
Guide to Grants 24
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3. Manage
Supplies. The PSO defines supplies as tangible personal property, including general office References
supplies and project supplies, with a per-unit cost of less than $5,000, unless the grantee
1 TAC §3.83, Supplies and
agency chooses to capitalize the item, in which case it would be considered equipment. Direct Operating Expenses
Supplies which are considered state-controlled assets must be listed on the equipment
inventory list. 2 CFR §200.1, Supplies
TxGMS, pg 27, Supplies
Other Direct Operating Expenses. This budget category also includes other direct costs DOJ Grants Financial Guide, 3.9
such as leases for space, rental costs, advertising costs for staff vacancies, utilities, cell Allowable Costs
phones, liability insurance, payroll services, vehicle operating costs (e.g., fuel and
maintenance), intangible property such as software and software licenses, etc.
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3. Manage
Training courses, conferences and meetings. Grantees must maintain records that TxGMS, pg 128, Chapter 783
Supplement for State Grant
properly document attendance at conferences and completion of all grant-funded Programs
training courses. For formal training classes and courses, a certificate of completion
must be retained along with other supporting documentation. For conferences, DOJ Grants Financial Guide,3.9
workshops, symposiums or other meetings where completion certificates are not Allowable Costs
issued, the following are some examples of acceptable documentation: Sign-in
sheets; copies of travel vouchers (listing the purpose of travel/trip) along with the
conference flyer, program or meeting agenda; emailed verification of attendance from
the conference/meeting host; or meeting minutes that include a list of attendees.
Tools
Homeland Security training. Grantees requesting to offer or attend training using
Homeland Security Grant Program (HSGP) or Nonprofit Security Grant Program The Homeland Security Training
(NSGP) funds must receive approval from the PSO and the Texas Training Point of Review Form can be found in
eGrants by going to the eGrants
Contact employed by the Texas Division of Emergency Management to ensure it falls
home page > Updates > Forms
within the FEMA mission to prepare personnel to prevent, protect against, mitigate,
respond to, and recover from acts of terrorism and catastrophic events and the
jurisdictions Emergency Operations Plan. A Homeland Security Training Review Form
must be completed to begin the review process.
Guide to Grants 26
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3. Manage
Indirect costs
Allowability. Some funding sources allow for indirect costs in accordance with applicable state and
federal guidelines. Indirect costs must be approved in the Statement of Grant Award.
References
Approved rates. If the applicant has an approved indirect cost rate from either their federal or state
cognizant agency and wishes to charge indirect costs to the grant, the applicant must identify the 1 TAC §3.85, Indirect Costs
indirect cost rate and provide the Negotiated Indirect Cost Rate Agreement (NICRA), including any 2 CFR §200.414, Indirect
information needed to understand the basis for the rate. (F&A) Costs
De minimis rate. If the applicant does not currently have a federally recognized or state approved DOJ Grants Financial Guide,3.11
indirect cost rate, the PSO may approve indirect costs in an amount not to exceed ten percent of the Indirect Costs
approved modified total direct costs (MTDC). Calculating the MTDC should be performed when TxGMS, pg 36, Indirect Costs
developing the grant budget and prior to submitting each FSR. Equipment, capital expenditures,
charges for patient care, tuition remission, and scholarships and fellowships should be
excluded when calculating MTDC.
Calculating MTDC
Budget item Amount
Personnel costs $
Travel and employee training + $
Supplies and direct operating expenses + $
Rental costs (including space) - $
Participant support costs (stipends or subsistence allowances, travel allowances, and - $
registration fees paid to or on behalf of participants or trainees, but not employees.)
Each subcontract or sub-award OR $25,000 for each, whichever is less + $
Modified total direct costs = $
Guide to Grants 27
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3. Manage
Program income
References
Definition. The PSO defines program income as gross income generated by an
activity supported by a grant. Such activities are most commonly participant fees. 1 TAC §3.87, Program Income
Use of income. Program income may only be used for allowable project costs as
reflected in an approved grant budget. There are three methods for accounting for
program income:
− Addition. Program income is added to the total project costs and must be used
for the purposes and under the conditions of the grant.
− Cost sharing or matching. Program income is used to meet the cost sharing
or matching requirement of grant.
Guide to Grants 28
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3. Manage
References
Nature of adjustments. Adjustments are generally intended to respond to unexpected 1 TAC §3.2501, Grant Officials
events and changes that affect grant projects. Grantees should attempt to anticipate,
1 TAC §3.2513, Grant Adjustments
plan, and budget for costs in their grant application.
Adjustments requested in the last 30 days of a project period will receive special
scrutiny.
Initiating an adjustment. The project director, financial officer, or authorized official may
submit requests for grant adjustments through eGrants. Adjustments are subject to approval Tools
by the PSO, and grantees who expend funds prior to approval do so at their own risk – they To submit a grant adjustment
are not guaranteed for reimbursement. Note: Features are available on the My.Home tab that request, go to eGrants then click on
allow you to update grant officials or the SAM expiration date on multiple grant records in the Budget tab and then the
bulk. ‘Request Adjustment’ sub tab.
Grant officials can update their
individual phone numbers,
addresses, title and position on the
My.Profile tab in egrants. This action
does not require a grant adjustment.
eGrants Video: Make Changes Using
the Grant Adjustment Process
Guide to Grants 29
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3. Manage
Guide to Grants 30
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4. Monitor
TOC 31
4. Monitor
OOG monitoring
Overview. The OOG has oversight responsibility for the grants it awards. Monitoring may
consist of programmatic reviews, financial reviews, technical assistance, or formal audits
commissioned by the PSO or the Office of Compliance and Monitoring (OCM) within the
Office of the Governor. The PSO or OCM may conduct monitoring through an on-site References
review at the grantee’s location or through a desk review. 1 TAC §3.2601, Monitoring
Documentation and inquiries. The PSO or OCM may request grantees to submit 1 TAC §3.2525, Evaluating Project
information needed to conduct a monitoring review. Grantees must maintain and Effectiveness
make available all records relevant to a monitoring review upon request. Inadequate
or incomplete documentation may result in disallowed costs or other remedies for 1 TAC §3.2529, Grant Management
noncompliance. 2 CFR § 200.332,
Follow up. After a monitoring review is complete, the grantee will receive either a Requirements for pass-through
preliminary report or a final report. If a preliminary report is issued, it will outline identified entities
findings along with corrective actions to resolve the findings.
2 CFR §200.339, Remedies for
Response. For programmatic monitoring reviews conducted by the PSO, the grantee noncompliance
must complete any required actions within the timeframe specified in the report. For
financial monitoring reviews conducted by OCM, the grantee must respond to the TxGMS, pg 25, Subgrantee
preliminary report with a management response that addresses the finding(s) included in Monitoring and Management
the report. This management response must be provided to the monitor/auditor within
the timeframe specified in the report. A corrective action plan shall include:
− the titles of the persons responsible for implementing the corrective action plan;
− the corrective action to be taken; and
− the anticipated completion date.
Disagreement. If the grantee believes corrective action is not required, the management
response must provide an explanation of the specific reason(s). The PSO or OCM will
determine whether the response is adequate.
Final report and resolution. The grantee's management response and the approved
corrective action plan will become part of the final report. The grantee shall resolve all
identified findings within the time specified by the PSO or OCM. Failure to respond by the
due date may result in sanctions.
Guide to Grants 32
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4. Monitor
Grantee monitoring
Monitoring and Oversight of Grant Activities. Grantees have their own monitoring References
responsibilities. They must: 1 TAC §3.2601, Monitoring
1 TAC §3.2525, Evaluating Project
• Regularly evaluate their projects, including any contracted services; Effectiveness
• Monitor the day-to-day operations of grant and sub-award supported activities, 1 TAC §3.2529, Grant Management
including those of their contractors and subcontractors per their contract 2 CFR §200.329, Monitoring and
monitoring plan; reporting program performance
Guide to Grants 33
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4. Monitor
Single audits
Requirement.
References
− Grantees that expend $750,000 or more in combined federal grant funding,
during the entity’s fiscal year, or $750,000 or more in combined state grant 1 TAC §3.2603, Audits Not
funding, during the entity’s fiscal year, must submit a Single Audit reporting Performed by PSO or OCM
package. 2 CFR 200, Subpart F-
Audit Requirements
− All other grantees who are not required to have such an audit for any fiscal
years in which the OOG award was made or expended, must certify this fact to TxGMS, pg 40, Audit
the Office of Compliance and Monitoring (OCM). A Certification of Single Audit Requirements
Reporting Requirement Exemption form is available on the eGrants website
and must be submitted within 60 days of the end of the grantee’s fiscal year to
OCM-FMU@gov.texas.gov.
Reporting. Grantees required to perform a Single Audit must submit the required
Single Audit reporting package within 30 calendar days of receiving the Single Audit
report from the independent auditor or 9 months after the end of the audit period,
whichever is earlier. Tools
Certification of Single Audit
- For grantees expending $750,000 or more in federal grant funds: reporting
Reporting Requirement Exemption
documentation must be submitted to the Federal Audit Clearinghouse at Form (select appropriate FY under
http://harvester.census.gov/sac/. Single Audits, Threshold
Certification).
- For grantees expending $750,000 or more in state grant funds: reporting
documentation must be submitted to the Governor’s Office of Compliance and
Monitoring (OCM) at OCM-FMU@gov.texas.gov.
Guide to Grants 34
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4. Monitor
Other audits
Other audits. All other audits performed by auditors independent of the PSO or OCM References
must be maintained at the grantee's administrative offices and be made available
upon request. 1 TAC §3.2603, Audits Not
Performed by PSO or OCM
Audit Confirmation Letters. Requests for confirmation of grant payments from the 2 CFR 200, Subpart F-Audit
OOG (audit confirmation letters) should be sent to the OOG Financial Services Requirements
Division (FSD).
TxGMS, pg 41, Program
Requests via email are preferred and should be submitted to: accounting@gov.texas.gov. Specific Audit
If email is not feasible, requests may be made in writing to the following address:
Adverse findings. Grantees must notify the PSO of any audit results that may adversely
impact grant funds.
Guide to Grants 35
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4. Monitor
Most common types of fraud. Most cases of fraud fall into one of these categories:
References
— Conflict of interest. No one involved with a grant can participate in any
decisions, approvals, disapprovals, recommendations, decisions, or other action DOJ Grants Financial Guide, 3.20
if it concerns or benefits family members, a partner, any organization they serve Grant Fraud, Waste, and Abuse
in an official capacity, or any organization they are considering employment with. 2 CFR §200.113, Mandatory
— Failure to Properly Support the Use of Award Funds. Typical issues involve Disclosures
deliberate redirection of funds in a manner different from the purpose outlined in TxGMS, pg 88 Reporting
the award agreement or failure to adequately account for, track, or support Suspected Fraud and Unlawful
transactions. Conduct
— Theft. This is the most common issue. Keep in mind that people who
embezzle funds can be extremely creative, while often appearing very
trustworthy. These abilities are precisely why they can do so much damage to
an organization and remain undetected for extended periods of time. Poor or
no internal controls provide an opening for theft. A lack of proper separation of
duties is one of the most common weaknesses.
— Criminal or licensing violations. While not as common as other types of fraud,
failing to report a criminal or licensing violation by an employee, officer,
contractor, or anyone with an official relationship with the grantee, is a form of
fraud. Any grantee who becomes aware of such an investigation by a law
enforcement agency or state or federal licensing agency must disclose it
immediately.
Mandatory disclosures. Grantees and applicants must immediately disclose, in writing, to the PSO all violations of
federal or state criminal law involving fraud, bribery, or gratuity violations potentially affecting the grant award. Failure to
make required disclosures can result in grant sanctions including termination of the award.
Guide to Grants 36
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4. Monitor
Reducing risk
Reduce the risk. There are several things that you can do to reduce the risk of
References
fraudulent use of your grant funds: DOJ Grants Financial Guide,3.20
Grant Fraud, Waste, and Abuse
Controls. Examine your operations and internal controls to identify your fraud
vulnerabilities. Maintain a well-designed and regularly tested system of internal
controls.
Education. Implement specific fraud prevention strategies including educating
others about the risks. The more people are aware of the issues, the more they
can help prevent problems or detect them as early as possible.
Documentation. Ensure all financial or other certifications and progress reports
are adequately supported with appropriate documentation and evidence.
Conflicts of Interest. Identify any potential conflict-of-interest issues and disclose
them to the awarding agency for specific guidance and advice.
Fair procurement. Follow a fair and transparent procurement process, especially
when using consultants. Ensure that the rate of pay is reasonable and justifiable,
and that the work product is well-defined and documented.
Guide to Grants 37
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5. Close
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5. Close
Liquidation
Financial reporting. The liquidation date is the final date you can report expenses
that were obligated during the grant period. A required Final FSR is due in eGrants on
or before the grant liquidation date. Failure to submit a Final FSR by the liquidation
date will result in the Governor’s Office holding reimbursement for all grants to your Tools
agency. Note: Equipment, supplies and other tangible items may be received by the
The grant start date, end date and
agency and the vendor paid during the liquidation period, as long as the expense was
liquidation date can be found on
incurred during the period of performance.
the eGrants “Profile-Details” tab or
the header of each tab in eGrants.
Deobligation. Funds not obligated by the end of the grant period and not expended
To submit an FSR, go to eGrants
by the liquidation date will revert to the OOG. and from the My Home tab click on
the grant record, then choose the
Budget tab and click on the Financial
Status Report sub tab.
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5. Close
Guide to Grants 40
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5. Close
Records retention
Core requirement. Grantees must maintain all financial records, supporting References
documents, statistical records, and all other records pertinent to the award for at least 1 TAC §3.2505, Retention
three* years following the closure of the most recent audit report or submission of the of Records
final financial status report if the audit report requirement has been waived. Grantees
2 CFR §200.334, Retention
may retain records in an electronic format. All records are subject to audit or requirements for records
monitoring during the entire retention period.
TxGMS, pg 29 Records
Equipment. Grantees must retain records for equipment, non-expendable personal Retention and Access
property, and real property for a period of three years from the date of the item's
disposition, replacement, or transfer.
Further actions. If any litigation, claim, or audit is started before the expiration of the
three-year records retention period, the grantee must retain the records under review
until the completion of the action and resolution of all issues which arise from it or until
the end of the regular three-year period, whichever is later.
Guide to Grants 41
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