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District Policies

Viewing Policy: BP 3230 Federal Grant Funds


Board Policy 3230: Federal Grant Funds

Original Adopted Date: 10/10/2019 | Last Revised Date: 6/10/2021



The County Superintendent of School recognizes the San Benito County Office of Education’s (SBCOE) responsibility to maintain fiscal integrity and transparency in the use of all funds awarded through federal grants. The SBCOE shall comply with all requirements detailed in any grant agreement with an awarding agency and with the federal Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards specified in 2 CFR 200.0-200.521 and any stricter state laws and district policy.

Any goods or services purchased with federal funds shall be reasonable in cost and necessary for the proper and efficient performance or administration of the program.

The County Superintendent or designee shall ensure that the SBCOE’s financial management systems and procedures provide for the following:  (2 CFR 200.302)

  1. Identification in SBCOE accounts of each federal award received and expended and the federal program under which it was received
  1. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements of 2 CFR 200.328 and 200.329
  2. Records and supporting documentation that adequately identify the source and application of funds for federally funded activities, including information pertaining to federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income, and interest
  3. Effective control over and accountability for all funds, property, and other assets and assurance that all assets are used solely for authorized purposes
  4. Comparison of actual expenditures with budgeted amounts for each federal award
  5. Written procedures to implement provisions governing payments as specified in 2 CFR 200.305
  6. Written procedures for determining the allowability of costs in accordance with 2 CFR 200.400-200.475 and the terms and conditions of the federal grant award

The County Superintendent or designee shall develop and implement appropriate internal control processes to reasonably assure that transactions are properly executed, recorded, and accounted for so that the district can prepare reliable financial statements and federal reports, maintain accountability over assets, and demonstrate compliance with federal laws, regulations, and conditions of the federal award.  (2 CFR 200.61, 200.62, 200.303)

Equipment purchased with federal funds shall be properly inventoried and adequately maintained to safeguard against loss, damage, or theft of the property.

All staff involved in the administration or implementation of programs and activities supported by federal funds shall receive information and training on the allowable use of federal funds, purchasing procedures, and reporting processes commensurate with their duties.

The SBCOE  shall submit financial and performance reports to the awarding agency in accordance with the schedule and indicators required for that federal grant by law and the awarding agency. As required, such reports may include a comparison of actual accomplishments to the objectives of the federal award, the relationship between financial data and performance accomplishments, the reasons that established goals were not met if applicable, cost information to demonstrate cost-effective practices, analysis and explanation of any cost overruns or high unit costs, and other relevant information. The final performance report shall be submitted no later than 120 calendar days after the ending date of the grant.  (2 CFR 200.301, 200.328, 200.329)