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The mission of Eastfield College is to provide excellence in teaching and learning.

Compliance

Forgiveness is really expensive and may come with legal repercussions when it comes to contractual breaches in regulated grant funding. If any planned action causes the least hesitation or a question, check.

Reasons for Suspension or Termination of Funding

Funding agencies may suspend (in whole or in part), terminate funding for or impose special conditions on a grantee for the following reasons:

  1. Failure to substantially comply with the requirements or statutory objectives of the program guidelines issued thereunder, or other provisions of Federal law.
  2. Failure to make satisfactory progress toward the goals or objectives approved in the application.
  3. Failure to adhere to grant agreement requirements or special conditions.
  4. Proposal of substantial plan changes to the extent that, if originally submitted, would have resulted in the application not being selected for funding.
  5. Failure to submit performance reports.
  6. Filing of a false certification in the application.
  7. For any other good cause.

Don’t lobby. Don’t politic. Don’t entertain. Don’t support religious groups.

All of these things are forbidden with federal and state funds. That includes using staff time for any of these activities. Support letters for legislation cannot come from project staff.

What is Supplanting?

Grant funds must supplement and not supplant. A grant recipient may not use Federal grant funds to defray any costs that the recipient already is obligated to pay. External funds cannot be used to pay for ongoing activities already budgeted or for the usual activities assigned to a position. Supplanting is illegal.

Examples:

  • Grant funds cannot be used to pay the salary of an English instructor for a regularly scheduled course. However, grant funds may be used, if authorized in the funded proposal, to provide new specialized English classes for high-risk populations.
  • Funds currently allocated to purchase office equipment may not be reallocated to other purposes nor refunded, should a grant be made. Non-federal funds for such equipment must remain available for and devoted to that purpose, with grant funds serving as a supplement to those non-federal funds.

The possibility of supplanting will be the subject of careful application review, possible pre-award review, post-award monitoring and audit of any finding.

Hiring and Supervising Grant Funded Personnel

If individuals already on staff have been included in the grant proposal with a portion or all of their salary assigned to the project, an Employment Authorization Form will need to be completed to show percentages.

When a key personnel position in the grant proposal vacated or no longer available, the agency must usually be notified of the change (such as to the project director). A substitution or new hire for the vacant key personnel position must have prior approval from the funding agency. This also must occur immediately to avoid delays.

Staff members who are full-time (100%) on a grant or whose salary is paid in part by external funds are required to keep time and effort documentation. Time and effort documentation should be handled on an appropriate schedule in line with grant regulations. Please see the Operational Memorandum #4310 for College policies and procedures regarding reporting time and effort.

POLICIES AND REGULATORY COMPLIANCE REFERENCES

Eastfield College Operational Memoranda #4306 – Audit Readiness for Grants

Eastfield College Operational Memoranda #4310 – Time and Effort Reporting of All Personnel for Sponsored Programs

Dallas County Community College District Chart of Accounts

Education Department General Administrative Regulations (now Uniform Grant Guidance)

TRIO Talent Search Program Regulations

TRIO Student Support Services Program Regulations

TRIO Upward Bound Program Regulations

Carl D. Perkins Act

Title III – Strengthening Institutions Program Regulations

Office of Management and Budget (OMB) Part 215 (now Uniform Grant Guidance)

Office of Management and Budget (OMB) Part 225/287 (now Uniform Grant Guidance)

Texas Workforce Commission Financial Manual for Grants and Contracts

Sources: DCCCD Development Office; U.S. Department of Justice.