CS 3.10.4 Control of Sponsored Research/External Funds The institution maintains financial control over externally funded or sponsored research and programs. Judgment of Compliance Compliant Narrative The College receives external funds but not for sponsored research. External funds received by Amarillo College include awards for grants and contracts. Process Before any externally funded applications are submitted to a funding agency, Amarillo College’s faculty and staff must follow guidelines according to Board policy and internal procedures. The College requires that all applicants for potential grants and contracts must submit conceptual ideas through the Resource Development Clearinghouse. The Grant Development staff is charged with coordinating the centralized submission of any externally funded applications, as shown on the flowchart for grant submission. During review of proposed applications, Amarillo College staff verifies that the College has the ability to meet the grant compliance requirements and an executive summary is prepared and submitted to the President or the President’s Cabinet. An example of this is Amarillo College’s FY 2010 GEAR UP Grant Proposal. If a grant is awarded, then the Offices of Grant Compliance review the grant/contract from the funding agency prior to execution, along with the Vice President of Business Affairs and the President. All externally funded programs are monitored to verify that they are consistent with Amarillo College’s mission statement which is “Amarillo College - enriching the lives of our students and our community.” This mission statement, as identified in Amarillo College’s Strategic Plan, has been the basis for the Grants/Contracts Target list. This list is compiled from the strategies of the Strategic Plan to ensure that the College has additional funds to accomplish its goals. The list is updated and approved annually by the President’s Cabinet. The President must approve all grant and contract proposals prior to submission, which further ensures consistency with Amarillo College’s mission. Controls The Office of Grant Accounting has the authority for and is responsible for ensuring all externally funded programs are accounted for accurately and are consistent with Amarillo College’s policies and procedures. This office also has the responsibility for ensuring that all external funding reports are submitted in a timely manner, per the guidelines for each externally funded program, as reflected in the job descriptions for the grant accounting manager and senior accountant. The Office of Grant Compliance reviews each externally funded report prior to submission to verify accuracy and compliance with the externally funded regulations, goals and objectives, reporting structure, and format. Amarillo College also maintains financial control over externally funded programs by following the procedures outlined in the Grants Management Handbook and the Grants Compliance Training Manual, which has been published by the Amarillo College Office of Grant Development and Compliance, by using the fund accounting concept as outlined in the Accounting Manual. All externally funded programs, such as Federal government grants, State government grants, local and other programs are accounted for as restricted funds. These grants have restrictions on how the money may be expended, which is imposed by the outside agencies. The College also follows the policies for purchasing goods and services as outlined in the College’s Purchasing Manual. Amarillo College also maintains financial control over externally funded programs by following the procedures outlined in the circulars from the following: Office of Management and Budget (OMB) for Cost Principles for Educational Institutions, Cost Principles for State, Local, and Indian Tribal Governments, Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospital and Other Non-Profit Organizations, Cost Principles for Non-Profit Organizations and follows the guidelines set forth in Audits of States, Local Governments, and Non-Profit Organizations. For grants funded by Department of Education, the College also follows the regulations from the Education Department General Administrative Regulations (EDGAR), whose purpose is to “establish uniform administrative requirements for federal grants.” The Grant Compliance Officer ensures that all programmatic and fiscal reports meet grant expectations. Amarillo College follows the procedures for calculating the administration fee and indirect cost as outlined in the Administration Fee/Indirect Cost Policy and Procedures. The administration fee and indirect costs have ranged from $176,397 to $265,525 per year. As a general rule, these funds are used by the College to offset a portion of the overhead costs for managing the grants; however, there are some instances where the administration fee/indirect cost have been used by the Project Manager for other grant purposes, as documented in annual audits. Grant general ledger accounts are reconciled on a monthly basis when all activity has been completed for the accounting period. Each account has been reviewed to verify that the expenditures match the requirements for each grant, and then compared to the expenditures versus revenues reports to make sure they end with a zero balance. Annually, during the financial records audit, the qualifying grant accounts are also subjected to an individual audit by independent auditing firm of Connor, McMillon, Mitchell, and Shennum, PLLC (CMMS) to verify compliance to Federal, State, and local standards. Any findings are reported to the Board; responses to these findings are made by the institution, and then reported in the printed copy of the annual audit. Amarillo College has endeavored to make the necessary changes in procedures and policy to ensure that any findings have been corrected to the best ability of the institution. The percentage increase in total income for each year has been consistently higher than the percentage decrease or increase in grants for each year, which would indicate that Amarillo College has not been dependent on these grant funds for day-to-day operations, as noted in the Percentage Change in Grants Between Years Chart. This would also indicate the appropriate use and management of these grant funds has been a consistent objective of the institution. Amarillo College has not had a Federal audit since the mid 1990’s, and has striven to maintain a level of excellence that would require such an audit irrelevant. Amarillo College does not have any sponsored research funds since the College is primarily a teaching institution and does not solicit any research funds. Management expectations for grants and contracts are assigned to project director, Grant Compliance Officer, and Grant Accountant. Cabinet level supervision includes cabinet officer oversight of a particular grant by the Vice President of Academic Affairs, the Vice President of Student Affairs, the Chief of Planning and Advancement, and the Vice President of Business Affairs. The President has ultimate responsibility for all externally funded programs. Supporting Documentation and Evidence 1) Clearing House: Resource Development Clearinghouse Form Guideline 2) Proposal: Amarillo College’s FY 2010 GEAR UP Grant Proposal 3) Grants Accelerated Developmental Ed Pilot ARRA-SECO Texas Comptroller GEAR UP HEP JET Scholarships Texas Comptroller JET Sonography Texas Comptroller NSF Solar Perkins Basic 2009-2010 Perkins Basic 2010-2011 Perkins State Leadership 2010-2011 Perkins Tech Prep 2009-2010 Perkins Tech Prep 2010-2011 Skills Development Fund – Bell 2011 Skills Development Fund - NWTHS 2009 SSS Health Sciences SSS Moore County Campus SSS STEM Title V Amarillo College Board Minutes Sept 09 Amarillo College Board Minutes Aug 10 Amarillo College Board Minutes Oct 10 Amarillo College Board Minutes Feb 11 4) Targets Amarillo College Strategic Plan Targets for Grants and Major Contracts 2010 Targets for Grants and Major Contracts 2011 5) Plan Funding: Strategic Plan Funding 6) Job Descriptions Job Description for Grant Accounting Manager Job Description for Senior Accountant 3-06 7) Administrative Job Description for Chief of Planning and Advancement (former name of position Chief of Advancement and Development) Job Description for Director of Grants Job Description for Grant Compliance Officer Job Description for Administrative Systems Specialist 8) Grant Management 2010 Accounting Manual Grants Management Handbook Grants Compliance Training Manual 9) Grants: Grant Listing 10) Purchasing: Purchasing Manual 11) Office of Management and Budget (OMB) OMB Circular A-21 OMB Circular A-87 OMB Circular A-110 OMB Circular A-122 OMB Circular A-133 12) EDGAR: Education Department General Administrative Regulations 13) Grants Compliance Officer: Job Description for Grant Compliance Officer 14) Administrative Administration Fee/Indirect Cost Policy and Procedures Administration Fee/Indirect Cost Allowances Administration Fee/Indirect Cost Chart 15) Audits 2011 Audit 2010 Audit 2009 Audit 2008 Audit 2007 Audit 16) Reconciliation: Monthly Grant Reconciliation 17) Change: Percentage Change in Grants Between Years Chart 18) Job Qualifications VP of Academic Affairs VP of Student Affairs 19) President: President’s Responsibilities