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.
Funding agencies may suspend (in whole or in part), terminate funding for or impose special conditions on a grantee for the following reasons:
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.
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.
The possibility of supplanting will be the subject of careful application review, possible pre-award review, post-award monitoring and audit of any finding.
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.
Sources: DCCCD Development Office; U.S. Department of Justice.