PAP.11.2.080 Maintenance and Compliance

(a) All terms, conditions, and requirements of the grants and between the Tribe and the funding agencies or contractors shall be strictly complied with.

(b) Executive Director is responsible for:

(1) Oversight of all externally funded awards and programs;

(2) Monitor grant compliance and assist directors as needed;

(3) Ensure good stewardship and compliance with the §200 CFR Subpart A - F to avoid fraud, waste, and abuse of Federal funds; and

(4) Work with the Compliance, Accounting Department, and the Program Director to ensure all expiring grants are closed out timely and all grant files and records are retained and archived for audit purposes.

(c) Program Director is responsible for:

(1) Ensuring good stewardship and compliance with the §200 CFR Subpart A - F to carry out the goals and objectives of the award;

(2) Read and understand all grants;

(3) Maintain award documents, grant summary, and provide updates and copies of all correspondence and modifications to the award or budget to the Compliance Department on an ongoing basis until the grant is closed;

(4) Review detailed general ledger transactions and budget to actual report no less than once per month to ensure expenditures are recorded correctly and are in compliance with the award; and

(5) Document matching requirements for funding agency reporting purposes.

(d) Chief Financial Officer (or designee) is responsible for:

(1) Grant monitoring for compliance, reporting for audit purposes, and informs directors, management, and the Tribal Governing Board of any discrepancies;

(2) Processing all drawdowns for payments from the funding agencies as requested by the Compliance Department;

(3) Maintain grant/drawdown summaries; and

(4) Ensure all financial information provided to the Tribe and funding agencies accurately reflect audited numbers.

(e) Compliance department is responsible for:

(1) Designating a Compliance Manager specifically tasked with the daily responsibility of monitoring grant compliance;

(2) The Compliance Manager is the person primarily responsible for overseeing and managing grant compliance issues within the Tribe;

(3) Assisting Program Directors and Accounting Departments as needed;

(4) Ensuring all grants are read and understood;

(5) Ensuring all terms, conditions, and requirements of the grants between the Tribe and the funding agencies or contractors will be strictly complied with;

(6) Document matching requirements for funding agency reporting purposes; and

(7) Responsible for preparation and submission of financial reports to the funding agencies.

(f) If the Tribe has grants with matching requirements, levels of effort, and/or earmarking limitations, the Program Director, Compliance Manager, and Financial Analyst, shall monitor activities to ensure that requirements and limitations are met, and amounts claimed or used for matching were determined in accordance with applicable laws and regulations.