18 Miss. Code. R. 8-1.1-4
Overview
In accordance with 2 C.F.R. § 200.302, the Mississippi Department of Human Services (MDHS) requires that Subgrantees and any lower-tier subrecipients have in place, prior to the receipt of funds, a financial management system that will provide:
Accounting Procedures
Separate financial records shall be maintained for each subgrant and lower-tier subrecipients. Separate financial systems ensure record keeping requirements are met and eliminates potential conflicts with the Subgrantees usual record keeping system, which may reflect a different fiscal year, or accounting by function or department rather than by subgrant or work activity. The accounting systems of all Subgrantees must ensure that the agency funds are not commingled with funds from other Federal agencies. Subgrantees must account for each award separately. Funds specifically budgeted and/or received for one subgrant agreement may not be used to support another. Each Subgrantee shall maintain one set of accounting records for the subgrant and shall separately identify the receipts and disbursements for each subgrant or other source of funds.
Each Subgrantee must expend and account for the funds in accordance with state laws and procedures for expending and accounting for the state's own funds. In addition, the financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Subgrant award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Subgrant award. The Subgrantee shall be able to isolate and trace every subgrant dollar from receipt to expenditure and have on file appropriate supporting documentation for each and every transaction. Examples of documentation includes, but is not limited to the following:
All the basic accounting records and documents listed below comprise the framework for a good financial management system. If implemented properly, such a system can provide accurate, current, and complete disclosure of the financial status of each subgrant, work activity, and cost category.
Subgrantees shall develop their accounting system to meet the particular needs of their subgrant. The amounts recorded daily to the individual accounts shall be totaled and posted to the general ledger at least monthly in order for the Subgrantee to complete the monthly Claim Support Form: Cost Reimbursement (MDHS-BA-CS-001). Recording procedures shall be designed to provide information accurately while at the same time serving as an effective control in preventing mistakes and safeguards against unauthorized uses of funds. 2 CFR § 200.302 (a)
Internal Controls
Subgrantees of MDHS shall have in place a financial management process that contains adequate internal controls for the administration of the subgrant program. This system of internal controls may be evaluated during an audit or monitoring review of the Subgrantee.
The following internal accounting control procedures are required of MDHS Subgrantees and lower-tier subrecipients:
Documentation Requirements
The accounting system of each MDHS Subgrantee shall provide the monitors and/or auditors with adequate documentation to support the Subgrantee's financial claims. Source documents are required to support transactions entered into the Subgrantee's record keeping system. The following is a list of the minimum documentation required for selected transaction types:
CATEGORY | DOCUMENTATION |
Grant Revenues | |
Federal, State, and Other Receipts | Identification of the source of funds (i.e., signed subgrant agreement), request for cash and/or request for reimbursement (i.e., Claim Support Form), cash receipts journal, Paymode receipts, validated deposit slips, withdrawals and/or financial reports |
Program Income | Record of service, purpose, amount, and/or deposit slips |
Matching Cash Contributions | Record of source donor, dates, rates, amounts, and/or deposit slips |
Matching Non-Cash Contributions | Record of source donor, dates, rates, amounts, and activities performed including time, date, place, and agenda, certification of cost or market/appraised values, and documentation to verify that expenses reported as in-kind match, and all contributions were in proportion to the benefits received by the subgrant that was matched. Subgrantee's in-kind contributions must be accepted and documented as part of the Subgrantee's cost sharing or matching when such contributions meet the criteria as outlined in 2 C.F.R.§ 200.306(b) (1-5). |
Grant Expenditures | |
Salaries and Fringe Benefits | Personnel files must include a job application or resume, IRS W-4 Form, State Tax withholding form, I-9 Form (if hired after May 1987), E-Verify confirmation, date of hire, current approved salary/wage, pay stubs, approved time sheets and/or activity reports which reflect the actual hours worked and duties performed each pay period. Time distribution/activity sheets are required when the employee's time is charged to more than one (1) subgrant or activity. Fringe benefits documentation must include the detail of the elements that comprise the fringe benefits (i.e. FICA, health insurance, supplemental insurance, etc.). |
Travel | An approved travel voucher showing that all travel expenses were incurred for the benefit of the subgrant; and copies of supporting bills including out-of-state meal receipts, hotel bills, conference registration fee receipts, and/or conference agendas. |
Telephone | Complete telephone bills/invoice and longdistance telephone logs that indicates the person calling and/or the person called, the date and time of the call, the reason and purpose of the call, the number called, and the Subgrantee that benefitted from the telephone call. For Subgrantees with multiple locations, allotment/portion per location is required. |
Equipment/Property | Original vendor invoices, receiving reports, purchase orders, competitive quotes or proof of newspapers advertisements for bids, property records, authorization to purchase equipment, and/or any other documentation necessary for purchasing law conformity. All purchases of equipment/property must be made in accordance with applicable purchasing requirements. |
Commodities (Supplies) | Original vendor invoices, receipts, receiving reports, purchase orders, records of competitive quotes and/or other solicitations issued, proof of required solicitation advertisements, property records, and/or any other procurement related documentation necessary for purchasing compliance of commodities/supplies. All purchases of commodities (supplies) must be made in accordance with applicable procurement regulations. |
Contractual Services | Current contracts that are active and valid during the subgrant agreement term for services charged to the subgrant, evidence of completion of contracts, billings for services (including utility bills), current rental or lease agreements, receipts for postage costs and/or contracts for meter machines, competitive quotes or proof of newspaper advertisement for bids (if applicable), and/or documentation of fair market value. All contracts for services must comply with applicable rules and regulations. |
Subsidies, Loans and Grants | Payments to/for clients: Client attendance records, documentation of services provided, including dates, times, names, and client signatures, and/or documentation to verify units of service provided. Lower-Tier Sub-recipients: Copies of the lower-tier subrecipient agreement, including budget information and the scope of services required, financial and programmatic reports, documentation of payments made to the sub-recipient, evidence of monitoring of lower-tier subrecipients, documentation of compliance with procurement procedures, and required compliance with the MDHS Subgrant Manual. |
Other Direct Cost | Original vendor invoices, receiving reports, purchase orders, competitive quotes or proof of newspaper advertisements for bids (if applicable), and/or documentation of any expenses incurred for the benefit of the subgrant. |
The list above is not all inclusive. Additional documentation may be required if deemed necessary.
Cost Allocation/Indirect Costs
MDHS Subgrantees may hold and administer more than one (1) federal subgrant at a given time and may have different federally approved cost allocation plans and/or indirect cost rate agreements for each subgrant. The Subgrantee shall be responsible for submitting its federally approved cost allocation plan and/or federally approved indirect cost agreement well in advance of an anticipated MDHS subgrant agreement start date. If the Subgrantee's cost allocation plan and/or indirect cost rate agreement is updated during the effective dates of the subgrant, a copy of the updated plan shall be submitted to the MDHS Funding Division that awarded the subgrant as soon as possible, but no later than five (5) business days after federal approval of any cost allocation plan and/or indirect cost rate agreement.
Each Subgrantee shall develop a cost allocation plan and/or an indirect cost rate agreement that covers the Subgrantee's entire operation. Costs included in the plan should only be those that are not easily identifiable with a particular subgrant and/or administrative cost of the Subgrantee, in which shall be equitably distributed to all subgrant programs and/or other sources of funds in proportion to the relative benefits received.
Required documentation for indirect costs includes:
The cost allocation plan and/or indirect cost rate agreement submitted with the subgrant shall be developed in compliance with the requirements contained in the cost principles applicable to each subgrant.
Scrutiny of all vouchers and invoices by Subgrantees and/or by MDHS is necessary to verify that they are only for legitimate cost, eligible under the governing regulations, and authorized in the subgrant agreement. MDHS shall include testing to ensure that costs are properly allocated to the correct subgrant and work activity. The cost allocation plan should be accompanied by a certification of review by MDHS.
Subgrantees that do not have a Federal negotiated indirect cost rate may elect to charge a de minimis rate of up to 15 percent of modified total direct costs. MDHS is authorized to determine the appropriate rate up to this limit. When applying the de minimis rate, costs must be consistently charged as either direct or indirect costs and may not be double charged or inconsistently charged as both.
Reference 2 CFR § 200.414
Types of Costs and Documentation
The following is a listing of selected types of cost and suggested bases for distributing shared costs as direct costs to MDHS subgrants:
Salaries/Fringe Benefits | Number of hours worked for each subgrant/activity |
Auditing | Direct audit hours dollar amount of each subgrant in proportion to the total amount audited |
Office Space Used and Related Costs | Square feet of occupied space (utilities, janitorial service, etc.) |
Local Telephone | Number of telephones |
Fidelity Bond Expense | Employees subject to bond or penalty amounts |
Motor Pool Cost | Number of miles driven and/or days used |
Printing and Reproduction | Direct hours, job basis, pages printed, etc. |
Copy Machine and Related | Number of copies made as documented by a copy log or access code |
Postage Costs | Amount of postage used by each subgrant as documented by log |
Payroll Employees Independent Contractors | Payroll Employees/ Independent Contractors paid, in-whole or in-part from MDHS subgrant shall prepare time sheets indicating the hours worked each pay period. The distribution of payroll charges and/or payments to independent contractors shall be based on the actual time worked for the benefit of the subgr ant/activity |
Lower-Tier Subrecipients
All expenditures that involve agreements between the Subgrantee and a third-party (performing a service related to the program), must be fully disclosed in the cost summaries and budget narrative. If the provisions of a subgrant agreement allow a lower-tier subrecipient to manage and administer subgrant-supported projects, the MDHS Subgrantee must obtain prior written approval from MDHS Funding Division Director before any work is performed by a lower-tier subrecipient and prior to any funds transferred.
MDHS Subgrantee shall have appropriate agreements in place with each lower-tier subrecipient which shall be available for MDHS Funding Division Director review. If authorized, MDHS Subgrantee agreements with lower-tier subrecipient(s) shall contain language binding and requiring any lower-tier sub- recipient agreement to adhere to all provisions of the MDHS Subgrant Manual, applicable Federal and State laws, and all guidelines established by MDHS. The Subgrantee must provide an explanation as to why a lower-tier subrecipient is warranted.
Copies of rental agreements, service agreements, consultant agreements, etc. shall be available to validate the basis of the cost category. In addition, any contractual procurement agreement received in response to solicitation, shall be submitted to MDHS Funding Division Director within thirty (30) days after execution.
Budget Preparation
A budget is a tool used by the Subgrantee to express its planned goals and objectives. It is a management tool to be used in addressing general management functions such as planning, operational performance, and control. The Subgrantee's fiscal staff shall have on file the currently approved subgrant budget including any approved modifications. The required forms and accompanying instructions that shall be used in preparing a budget for MDHS subgrants are:
For any Subgrant Budget to be approved by MDHS, the Subgrantee must present its planned budget in the same format as the MDHS Budget Narrative Form, utilizing the MDHS Budget Summary form and the MDHS Cost Summary Support Sheet.
Budget Activities
Each MDHS subgrant shall be organized and budgeted by activities according to the major functions necessary to accomplish the goals and objectives of the subgrant. This grouping by activities shall be used in preparing the 'Budget Summary' and 'Cost Summary Support Sheet' as well as the Budget Narrative. If the first narrative submission does not contain sufficient information, including that information that is program specific, MDHS Funding Division will request additional documentation.
If any administrative costs (direct or indirect) are included in the subgrant, they shall be budgeted in an Administration activity subject to any limits on the amount of administration that may be charged to the subgrant. Subgrantees shall consult with the MDHS Funding Division to determine what activities are allowable under the subgrant and whether there are limits on the amount of administrative costs that may be charged to the subgrant.
Budget Categories
Subgrantees are required to separate subgrant costs into the below identified and explained categories to capture all associated costs to perform under an MDHS Subgrant. Subgrantees shall be responsible for properly designating their associated costs into the below identified and explained categories pursuant to the requirements and guidance reflected in federal cost principles as codified in 2 C.F.R. §200 and as required of any other federal cost principle as identified codified in the Code of Federal Regulations by the applicable and governing Federal Partner.
Subgrantees shall structure and separate federal funds authorized under MDHS subgrants into the following budget categories as applicable. MDHS will monitor the Subgrantee budget according to the below budget categories for compliance with federal cost principles and requirements contained within the MDHS Subgrant Manual:
Salaries and Wages
This Subgrant budget category includes payments made to officers and employees of a subgrant as compensation for personnel services based on the percentage of time dedicated to the subgrant. The salary budget category shall contain a line item or listing of each position authorized and the salary amount to be paid to each full-time employee and/or hourly rate authorized, and number of hours authorized for each part-time employee charged to the subgrant. The salary line should disclose whether salaries are to be paid from the grant fund or in-kind match. The salary budget category shall be strictly adhered to unless a formal modification of the subgrant is approved. A vacant position may be filled at or below the budgeted rate only and no additional positions may be charged to the subgrant unless approved through the budget modification process.
Salaries included as a part of the budget narrative shall be identified by a clear position/title as well as the appropriate salary for that position. Subgrantees shall also identify, as a percentage, the amount of effort for each position that will be dedicated to performance of the MDHS Subgrant Agreement. Please see the below example for illustrative purposes only:
Position Title | Salary | % Dedicated to MDHS Subgrant | Salary Charged to MDHS Subgrant |
Program Manager | $50,000.00 | 25% | $12,500.00 |
Salary information shall be included as part of Budget Narrative as required above for both the Administrative and Programmatic budget components.
Reference 2 C.F.R. §200.430
Fringe Benefits
This Subgrant budget category includes payments made for the employer's portion of expenses for social security (F.I.C.A. and Medicare), employee health/life/disability insurance premiums, worker's compensation insurance, unemployment insurance, and pension plan costs. The fringe benefits budget category may include compensation paid to employees during periods of authorized absences from the job for vacation leave, sick leave, and/or military leave provided such cost are absorbed by all of the Subgrantee's activity. The fringe benefits budget category must contain a line item or listing of each fringe benefit and the amount authorized on the 'Cost Summary Support Sheet' and in the Budget Narrative. Fringe benefits shall be limited to no more than thirty-nine percent (39%) of salaries, unless justification is submitted in the budget narrative, and approved by MDHS. The amounts withheld from the employee's gross pay (i.e., federal and state taxes, employee health/life/disability insurance premiums) cannot be budgeted or claimed for reimbursement under the subgrant as fringe benefits. Please see the example below for illustrative purposes only. If using the same salary as the previous example of $50,000 with $12,500 dedicated to the MDHS subgrant, calculations would be as follows:
Fringe Benefits | Employer FICA - 7.65% of gross salaries | $956.25 |
Workmen's Compensation - 3% of gross salaries | $375.00 | |
Employer Health Insurance - up to $120 per mo. per employee for 12 mos. x 25% | $360.00 | |
Leave - 3% | $375.00 | |
Total Administration Fringe Benefits | $2,066.25 |
For Subgrantees classified as an Institute of Higher Education (pursuant to 34 C.F.R. § 600.4), tuition may be included as a Fringe sub-category.
Reference 2 C.F.R. §200.431
Fringe Benefits-Lump Sum Payments
A Subgrantee may use grant funding for leave payouts to former employees upon subgrant termination and as part of the subgrant closeout; however, pursuant to 2 C.F.R. § 200.343 and § 200.431, leave payments for each employee are limited to the allocated percentage of each employee within the Subgrant Agreement. Further, leave payments for each former employee are only allowable to former employees identified in the Subgrant Agreement and such payments shall only reflect amounts for leave accrued by each former employee during the Subgrant Agreement period.
Travel
This Subgrant budget category includes payments made for transportation, lodging, and related cost to employees, officers, and volunteers who are in travel status on official business for the purpose of performing proposed services outlined within the subgrant agreement. Travel includes reimbursement for in -state travel, reasonable and project-related costs for conferences, meetings, etc., and staff reimbursement for the use of Subgrantee owned vehicles (vehicles owned by the Subgrantee organization) and privately owned vehicles for project-related functions. The rate of reimbursement per mile will be at the rate approved by the Department of Finance and Administration on the date that travel was performed, as long as the total amount of the subgrant award charged with the expense is not exceeded. (Please see below "DFA Travel Link"). While MDHS will reimburse for mileage, MDHS will not reimburse fuel charges as a travel line item (refer to commodities for reimbursement for fuel as travel) for Subgrantee owned vehicles or privately owned vehicles of employees under this category. Meal costs will be reimbursed based upon the actual cost of each meal; up to the maximum daily meal rate, established by DFA. Receipts for meals reimbursed through subgrants funded by MDHS will be required for auditing purposes. No travel shall be allowed for employees funded through other programs unless approved by MDHS. No reimbursements will be made for the cost of commuting.
Note: MDHS will not reimburse for mileage and fuel for a single project related travel occurrence.
Pursuant to 2 C.F.R. § 200.475, travel costs are expenses incurred by employees who are in travel status on official business. These costs must be consistent with costs normally allowed under the MDHS written travel reimbursement policy as outlined below. These costs may also be subject to the Federal requirements as outlined in 2 C.F.R. § 200.474.
Section § 25-3-41, Mississippi Code Annotated (1972), authorizes the Mississippi Department of Finance and Administration to set guidelines for travel reimbursement of state officials and employees. As these laws and regulations are amended, this policy shall be amended accordingly.
A complete list of all current rules and regulations established by the Mississippi Department of Finance and Administration (DFA) is available at www.dfa.ms.gov. State travel regulations are also contained in the Mississippi Agency Accounting Policies and Procedures Manual (MAAPP), Section 13.
All travel related expenses will be reimbursed at the State rates and pursuant to DFA policies identified above. Should the federal grant exclude certain travel reimbursements and thereby conflict with any DFA travel policy or regulation, then the federal grant exclusion and/or reimbursement requirement shall control. In that instance, Subgrantees must provide written documentation showing that the Subgrantee exercised due diligence to identify the least expensive and most practical method of transportation.
DFA Travel Link
Reference 2 C.F.R. §200.475
Contractual Services
This Subgrant budget category includes payments for services rendered by persons/entities other than employees of the Subgrantee through formal, written, contractual agreements between those persons/entities and the Subgrantee. Examples include, but are not limited to postage, telephone/internet/pager services, utilities, rent, repair or service agreements, service charges, computer software, contract workers that are independent contractors, and/or professional membership fees directly related to MDHS subgrant program operations, as well as, programmatic payments for speakers, trainers, consultants, and other hired professionals.
Rental costs are typically allowable as long as they meet the requirement of 2 C.F.R. § 200.465, grant terms and conditions and other applicable federal regulations. Rental costs are generally associated with a lease agreement. A lease is a contract describing the terms under which one party (tenant) agrees to rent property owned by another party (landlord). Leases fall into two categories:
Rental costs under "less-than-arm's-length" leases are allowable only up to the amount (as explained in paragraph (b) of this section). For this purpose, a less-than-arm's-length lease is one under which one party to the lease agreement is able to control or substantially influence the actions of the other. 2 C.F.R. § 200.465(c).
Depreciation - Depreciation is the method for allocating the cost of fixed assets to periods benefitting from asset use. The non-Federal entity may be compensated for the use of its buildings, capital improvements, equipment, and software projects capitalized in accordance with GAAP, provided that they are used, needed in the non-Federal entity's activities, and properly allocated to Federal awards.
Maintenance - Costs incurred for utilities, insurance, security, necessary maintenance, janitorial services, repair, or upkeep of buildings and equipment (including Federal property unless otherwise provided for) which neither add to the permanent value of the property nor appreciably prolong its intended life, but keep it in an efficient operating condition, are allowable.
Insurance - Costs of insurance required or approved and maintained, pursuant to the Federal award, are allowable.
Pursuant to 2 CFR § 200.465, if the building is owned by the Subgrantee, this would create a "less than arms-length lease" and rent would not be an allowable expense. The only eligible costs associated with the rental space would include depreciation, maintenance, taxes, and insurance as discussed above.
The Subgrantee will be responsible for procuring, administering, and properly maintaining active valid contract agreements with each person/entity identified within the Budget and Budget Narrative.
Reference 2 C.F.R. §200.331, 2 C.F.R. § 200.436, 2 C.F.R. § 200.452, 2 C.F.R. § 200.447
Commodities
This Subgrant budget category includes payments for various consumable supplies, goods, or merchandise of every kind purchased by a Subgrantee or lower tier subrecipient. Budget narrative categories shall include an itemized list for any items purchased in this category. Examples include but are not limited to office supplies, training materials and fuel for vehicles.
Capital Outlay - Equipment
This Subgrant budget category includes payments for machinery, furniture and fixtures which are required to be reported on inventory regardless of cost; or payments as compensation for the use of equipment purchased and owned or leased by the Subgrantee through depreciation or use allowance charges computed in accordance with the cost principles applicable to the Subgrantee. Examples include but are not limited to computers, printers, office furniture, telephone systems, motor vehicles, etc. Additional fees and services (shipping, freight, labor, etc.) must be included in the budget. (Refer to the Property Management chapter of this manual for details.)
Reference 2 C.F.R. § 200.1, 2 C.F.R. §200.313
Capital Outlay - Other
This Subgrant budget category includes payments for land, buildings and/or improvements to land or buildings that materially increase their value or useful life of the building; or payments for compensation for the use of buildings through depreciation or use allowance charges computed in accordance with the cost principles applicable to the Subgrantee.
Please note that pursuant to 2 C.F.R. § 200.439(3), "Capital expenditures for improvements to land, buildings, or equipment which materially increase their value or useful life are unallowable as a direct cost except with the prior written approval of the Federal awarding agency, or pass-through entity. See §200.436, for rules on the allowability of depreciation on buildings, capital improvements, and equipment."
Reference 2 C.F.R. §200.439
Subsidies, Loans, and Grants
Subsidies, Loans, and Grants may be identified as direct program services and/or assistance provided by MDHS approved lower-tier subrecipients to clients or individuals.
Tuition may be paid in this budget category only when paid on behalf of clients served by organizations classified as a "Non-Institute of Higher Education (Non-IHE)." For definition of Non-IHE please reference 34 C.F.R. § 600.4.
Indirect Costs
Indirect Costs may be identified as the actual costs allocated to MDHS subgrants in accordance with an agency-wide cost allocation plan or indirect cost rate agreement that complies with the cost principles applicable to the Subgrantee organization or as approved by the appropriate federal awarding agency.
Reference 2 C.F.R. §200.414
Payments and Cost Reporting
MDHS permits two (2) methods of cost reporting: Cost Reimbursement and Current Needs/Cash Advance.
Cost Reimbursement
For Cost Reimbursement payments, the Subgrantee may submit to the MDHS Subgrant Claims Unit a Cash Advance Claim for an initial payment projecting the Subgrantee's cash needs for only the first sixty (60) days of the subgrant term. Subgrantees must submit this initial payment through an MDHS Cash Advance Claim Support Form.
All payment requests following the initial payment request will be on a Cost Reimbursement basis. Cost Reimbursement claims shall be accompanied by the following required supporting documentation: Subgrantee's General Ledger or Detailed Expenditure Report, Monthly Expenditure Report Form, and any other MDHS required programmatic data supporting funds expended under an approved MDHS subgrant. All subgrant payment requests shall comply with the most current version of the MDHS Subgrant Manual. In order to process Subgrantee claim forms for payment, the Subgrantee must submit a complete and accurate claim form along with the above required supporting documentation or any other supporting documentation required by MDHS.
Subgrantees will receive funds the following month for expenditures incurred the previous month. The Subgrantee shall report the cost incurred for the month and request reimbursement by submitting the Cost Reimbursement Claim Support Form. The form shall be used by Subgrantees to report the "total cumulative cost to date."
The Cost Reimbursement Claim Support Form shall be submitted to the appropriate MDHS submission method (i.e. Email, Smartsheet, Portal) by the tenth (10th) calendar day of the following month. Supporting documentation shall be submitted with each claim form and as required by MDHS. If the 10th falls on the weekend, the form must be submitted on the following Monday. To the extent available, Subgrantees must use funds from program income, rebates, refunds, contract settlements, audit recoveries, and interest earned on such funds before requesting additional payments.
Current Needs/Cash Advance
Depending upon requirements of a federal award and other applicable federal cost principles, MDHS may provide reimbursement to Subgrantees on a Current Needs/Cash Advance basis. Payments on Current Needs/Cash Advance basis may be permitted by MDHS provided that the Subgrantee maintains and/or demonstrates the capacity through established written procedures and financial management systems to meet the requirements of applicable federal cost principles.
Under the Current Needs/ Cash Advance, the Subgrantee shall project its cash needs for the month and submit a Cash Advance Claim Support Form. The Subgrantee shall submit subsequent Current Needs/Cash Advance payment requests projecting the immediate cash needs of the Subgrantee to provide MDHS subgrant related program activities over a reasonable duration. Current Needs/Cash Advance claims shall be accompanied by the following required supporting documentation: the Supplemental Form and any other MDHS required programmatic data supporting funds expended under an approved MDHS Subgrant Agreement.
Current Needs/Cash Advance monthly expenditure reporting shall be submitted monthly and be accompanied by the following required supporting documentation: Subgrantee's General Ledger, Monthly Subgrantee Expenditure Report, and any other MDHS required data supporting funds expended under an approved MDHS Subgrant Agreement. All subgrant payment requests shall comply with the most current version of the MDHS Subgrant Manual. In order to process Subgrantee claim forms for payment, Subgrantee must submit a complete and accurate claim form along with the above required supporting documentation or any other supporting documentation required by MDHS.
Claim forms are required at least thirty (30) calendar days prior to the date that funds will be needed to allow processing time for MDHS, as well as DFA. The Cash Advance Claim Support Form may be adjusted pending availability of funds.
The Claim Support Form and Monthly Subgrantee Expenditure Report shall be submitted to the appropriate MDHS submission method (i.e. electronic mail, Smartsheet, and/or Portal) address by the tenth (10th) calendar day of the following month. Supporting documentation shall be submitted with each claim form and Monthly Expenditure Report as required by MDHS. If the 10th falls on the weekend, the form must be submitted on the following Monday. If due date falls on a State holiday, the report will be issued the following business day. To the extent available, Subgrantees must use funds from program income, rebates, refunds, contract settlements, audit recoveries, and interest earned on such funds before requesting additional payments.
Reference 2 C.F.R. §200.305
Procurement Standards
General
Subgrant activities may be contracted through a third-party. Subgrantees shall follow the same policies and procedures used for procuring services, commodities, and equipment paid for by non-Federal funds. The Subgrantees are responsible for ensuring that each vendor agreement contains the required State and Federal contract provisions, as well as the requirements outlined in the most current version of the MDHS Subgrant Manual.
Compliance with State and Federal Regulations
Subgrantees shall establish and follow their own procurement procedures reflecting applicable State, local, and tribal laws and regulations provided that those procurements procedures conform to applicable Federal procurement requirements as set forth in 45 C.F.R. Part 75, Part 92 and 2 C.F.R. § 200.318 through § 200.327. These requirements apply to purchase for contractual services, commodities, and equipment.
State agencies or entities as an MDHS Subgrantee shall have documented procurement procedures and policies in place at the start of an MDHS Subgrant Agreement that align and reflect compliance with State procurement requirements as outlined in Miss. Code Ann. § 31-7-13 (1972).
All other MDHS Subgrantees classified as "non-federal entities" shall have documented procurement procedures and policies in place at the start of an MDHS Subgrant Agreement that align and reflect compliance with federal procurement requirements as outlined in 2 C.F.R. § 200.318 through § 200.327.
Subgrantees shall administer its procurement operations in a manner promoting open and fair competition in selection of Subgrantee vendors/lower-tier subrecipients that aligns Federal procurements contained in 45 C.F.R. Parts 75 and 92 and 2 C.F.R. §200.
Code of Conduct
There shall be no conflict of interest, real or apparent, in the award or administration of a contract supported by subgrant funds. The Subgrantee shall maintain a written code or standards of conduct, which shall govern the performance of their officers, employees or agents engaged in the award and administration of contracts supported by federal funds for performance of an MDHS administered subgrant agreement. (Refer to 45 C.F.R. Parts 73 and 92, 2 C.F.R. § 200.318, or other applicable Federal law for further specific guidance.) Contractors/Vendors involved with drafting specifications, requirements, statements of work, request for proposal (RFP), or any other solicitation shall be excluded from bidding or submitting a proposal to compete for award for such procurement.
Open and Free Competition
All Subgrantee procurement transactions shall be conducted in a manner that provides maximum open and free competition consistent with 45 C.F.R. Parts 75, 92, and 2 C.F.R. §200 and other applicable Federal and State laws. Procurement procedures shall not restrict or eliminate competition. Interagency agreements are excluded from this provision; however, Subgrantees must obtain a fair market value assessment for products/services utilized through an interagency agreement. Procurement procedures must also affirmatively encourage use of minority businesses, women's business enterprises, and labor surplus area firms. (Refer to 2 C.F.R. § 200.321 for additional guidance.)
Subgrantee Files
Each Subgrantee shall maintain adequate files and documentation to support any purchases made and to detail the procurement process for each purchase. Purchases made by formal bid process or otherwise may be subject to public records request as provided in Section § 25-61-1 et seq. Mississippi Code of 1972, Annotated.
Debarment
To protect the public trust imposed upon MDHS and its involvement with Subgrantees, it is the policy of the agency to conduct business only with responsible persons/Subgrantees. Therefore, MDHS shall verify the suspension/debarment status of any potential Subgrantee, prior to contracting with the Subgrantee and shall maintain written documentation of the verification. In addition, the MDHS Subgrantee shall verify the suspension/debarment status of his/her lower-tier subrecipient(s) prior to contracting with the lower-tier subrecipient and shall maintain written documentation of the verification. When it appears that a Subgrantee's conduct, as determined by MDHS or appropriate Federal and/or State partners, creates a reasonable belief that a particular act or omission has occurred, MDHS shall implement discretionary actions known as debarment and suspension, possibly leading to termination. A Subgrantee and/or a lower-tier subrecipient who is debarred or suspended shall be excluded from Agency financial and nonfinancial assistance and benefits. These are serious actions which shall be used only in the public interest and for the Agency and State of Mississippi's protection and not for purposes of punishment.
Reference 2 C.F.R. 200.214
Debarment Coverage
This policy shall apply to all persons/Subgrantees who are currently participating in transactions under state non-procurement programs. For purposes of these regulations, transactions shall be referred to as covered transactions which may be subdivided into (1) primary covered transactions, (i.e., any non-procurement transactions between MDHS and the Subgrantee, regardless of type,) or (2) lower-tier covered transactions, (i.e., transactions between Subgrantee and another other than a procurement contract for goods or services), regardless of type, under a primary covered transaction.
Effect of Debarment/Suspension Action
Except to the extent prohibited by law, Subgrantees that are debarred or suspended shall be excluded from primary covered transactions and lower-tier covered transactions for the period of their debarment or suspension.
Reference 13 C.F.R. § 400.109
18 Miss. Code. R. 8-1.1-4