Grand Island Public Schools
123 South Webb Road
Grand Island, NE 68802
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Their Opportunity.

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4312 - Internal Controls For Federal and State Awards


The Grand Island Public Schools (the District) will develop and maintain internal control procedures as required by law and in accordance with sound fiscal monitoring practices that will ensure appropriate oversight of state and federal funds. The following internal control procedures will be utilized for all federal  grants:

Management requirements:  The District will manage equipment (including replacement equipment), whether acquired in whole or in part under a federal award, until the District disposes of such equipment.  The District will, as a minimum, meet the following requirements:

     1)         Maintain property records of the equipment (including equipment description,                           serial number or other identification number, source of funding, acquisition date,
                 and the like);
     2)         Maintain a physical inventory procedure, with an inventory occurring at a minimum                   of every two years;
     3)         Implement a Control System procedure;
     4)         Continue to develop and implement adequate maintenance procedures for the
                 equipment;
     5)         Continue to develop and implement sales procedures for the equipment; and
     6)         Continue to develop and implement disposition procedure for the equipment.
Legal Reference: 2 C.F.R. §§ 200.313 & 200.33.

Procurement:  The District will use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the requirement standards imposed by law, including:

     1)       A procedure for micro-purchases (Under $10,000);
     2)       A procedure for small purchases (between $10,000 to $250,000);
     3)       A procedure for sealed bids;
     4)       A procedure for competitive proposals; and
     5)       A procedure for noncompetitive bids.
Legal Reference: 2 C.F.R. §§ 200.317 through 200.326.
4440 PURCHASING AUTHORITY 

Record Retention:  Financial records, supporting documents, statistical records, and all other related records pertinent to a federal award will be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the federal awarding agency or pass-through entity in the case of a sub-recipient. 

For all other records, the District will retain such records for the length of time as required by law.

Legal Reference: 2 C.F.R. § 200.333.
5523 DATA OR RECORDS RETENTION 

Suspension and Debarment:  The District will not contract with any entity or individual who has been debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities.  Before entering into a contract regarding a federal award, the District will verify that a vendor has not been debarred, suspended or otherwise excluded, and the District will maintain a copy of said verification.

Legal Reference: 2 C.F.R. § 200.213.
4305 SUSPENSION AND DEBARMENT 

Financial Management:  The District will maintain financial management systems to account for the federal funds, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award. These records will be sufficient to permit the District to prepare 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 Federal award. The financial management system will provide for the following: 

     1)    Identifying all of the federal awards received and expended and the federal programs
            under which they were received;
     2)    Ensuring that accurate, current, and complete disclosure of the financial results of
            each federal award or program are maintained in accordance with reporting
            requirements;
     3)    Identifying adequately the source and application of funds for federally-funded
            activities;
     4)    Ensuring effective controls over and accountability for all funds, property, and other
            assets;
     5)    Comparing actual expenditures with budget amounts for each federal award;
     6)    Ensuring payments of federal funds are made in accordance with applicable law,
            including 2 CFR § 200.305; and
     7)    Determining the allowability of costs in accordance with applicable law and the
            conditions of the federal award.
Legal Reference: 2 C.F.R. § 200.302.
4310 STATE AND FEDERAL FUNDING
4311 ESSA AND FEDERAL PROGRAMS 

Program Income:  The District will consult with the federal awarding agency and refer to the applicable law and federal program terms and conditions to determine how to account for, deduct and otherwise handle income from federal programs.
Legal Reference: 2 C.F.R. § 200.307. 

Cost Sharing or Matching:  For all federal awards, any shared costs or matching funds and all contributions, including cash and third party in-kind contributions, must be accepted as part of the District's cost sharing or matching, when such contributions meet all of the following criteria: 

     1)         Are verifiable from the District's records;
     2)         Are not included as contributions for any other Federal award;
     3)         Are necessary and reasonable for accomplishment of project or program                                   objectives;
     4)         Are allowable under the applicable Cost Principles requirements;
     5)         Are not paid by the Federal Government under another Federal award, except                        where the federal statute authorizing a program specifically provides that Federal
                funds made available for such program can be applied to matching or cost sharing
                requirements of other Federal programs;
     6)        Are provided for in the approved budget when required by the federal awarding
                agency; and
     7)        Conform to other provisions of the law or terms and conditions of the federal
                 award, as applicable.
Legal Reference: 2 C.F.R. § 200.306. 

Compensation:  Compensation for personal services includes all remuneration for services of employees rendered during the period of performance under the federal award, including, but not limited to wages, salaries, and fringe benefits. Costs of compensation may be allowable under federal law and the federal grant to the extent that they satisfy the following requirements: 

     1)         Is reasonable for the services rendered; and
     2)         Conforms to the established written expectations of the District, as applied
                 consistently to both Federal and non-Federal activities.

If the District intends to charge compensation to federal awards, such charges will be based on records that accurately reflect the work performed, and will:
     1)         Be supported by a system of internal control which provides reasonable assurance
                 that the charges are accurate, allowable, and properly allocated;
     2)         Be incorporated into the official records of the District;
     3)         Reasonably reflect the total activity for which the employee is compensated by the
                 District, not exceeding 100% of compensated activities;
     4)         Encompass both federally-assisted and all other activities compensated by the
                 District on an integrated basis, but may include the use of subsidiary records as
                 defined in the District’s written procedures;
     5)         Comply with the established accounting policies and practices of the District; and
     6)         Differentiate and account for the distribution of the employee's salary or wages                         among specific activities or cost objectives if the employee works on more than
                 one Federal award; a Federal award and non-Federal award; an indirect cost
                 activity and a direct cost activity; two or more indirect activities which are allocated
                 using different allocation bases; or an unallowable activity and a direct or indirect
                 cost activity.

Budget estimates will generally not be used to support charges to Federal awards but may be used for interim accounting purposes.
Legal Reference: 2 C.F.R. §§ 200.430 & 200.431.

Unexpected or Extraordinary Circumstances:  For all federal awards, if the District does not currently have in place a sufficient policy that addresses extraordinary circumstances, such as those caused by COVID-19, the District may amend or create a policy at a later date in order to put emergency contingencies in place for federal and non-federal similarly situated employees. If the conditions exist for charges to be made to the federal grant, then charges may also be made to any non-federal sources that are used by the District in order to meet a matching requirement. The District will take other steps to comply with federal award requirements in the event of unexpected or extraordinary circumstances.
RESOLUTION OF THE BOARD OF EDUCATION OF HALL COUNTY SCHOOL DISTRICT 40-0002, A/K/A GRAND ISLAND PUBLIC SCHOOL DISTRICT REGARDING COVID-19 (ALSO KNOWN AS THE CORONAVIRUS) GLOBAL PANDEMIC AND EPIDEMIC SICKNESS – March 13, 2020

Legal Reference:  2 C.F.R. §§ 200, et seq.

Policy Adopted: 10.14.2021

 

.pdf Version

Media Inquiries
Mitchell Roush , Marketing & Communications
308-385-5900 ex. 201127
Grand Island Public Schools
123 South Webb Road
Grand Island, NE 68802
Your Legacy.
Their Opportunity.

Enhancing opportunities by seeking and securing resources for projects, scholarships and programs.

Access digital copies of our district flyers.

Improving school-to-home communication by distribute school flyers directly to families digitally.

4312 - Internal Controls For Federal and State Awards


The Grand Island Public Schools (the District) will develop and maintain internal control procedures as required by law and in accordance with sound fiscal monitoring practices that will ensure appropriate oversight of state and federal funds. The following internal control procedures will be utilized for all federal  grants:

Management requirements:  The District will manage equipment (including replacement equipment), whether acquired in whole or in part under a federal award, until the District disposes of such equipment.  The District will, as a minimum, meet the following requirements:

     1)         Maintain property records of the equipment (including equipment description,                           serial number or other identification number, source of funding, acquisition date,
                 and the like);
     2)         Maintain a physical inventory procedure, with an inventory occurring at a minimum                   of every two years;
     3)         Implement a Control System procedure;
     4)         Continue to develop and implement adequate maintenance procedures for the
                 equipment;
     5)         Continue to develop and implement sales procedures for the equipment; and
     6)         Continue to develop and implement disposition procedure for the equipment.
Legal Reference: 2 C.F.R. §§ 200.313 & 200.33.

Procurement:  The District will use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the requirement standards imposed by law, including:

     1)       A procedure for micro-purchases (Under $10,000);
     2)       A procedure for small purchases (between $10,000 to $250,000);
     3)       A procedure for sealed bids;
     4)       A procedure for competitive proposals; and
     5)       A procedure for noncompetitive bids.
Legal Reference: 2 C.F.R. §§ 200.317 through 200.326.
4440 PURCHASING AUTHORITY 

Record Retention:  Financial records, supporting documents, statistical records, and all other related records pertinent to a federal award will be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the federal awarding agency or pass-through entity in the case of a sub-recipient. 

For all other records, the District will retain such records for the length of time as required by law.

Legal Reference: 2 C.F.R. § 200.333.
5523 DATA OR RECORDS RETENTION 

Suspension and Debarment:  The District will not contract with any entity or individual who has been debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities.  Before entering into a contract regarding a federal award, the District will verify that a vendor has not been debarred, suspended or otherwise excluded, and the District will maintain a copy of said verification.

Legal Reference: 2 C.F.R. § 200.213.
4305 SUSPENSION AND DEBARMENT 

Financial Management:  The District will maintain financial management systems to account for the federal funds, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award. These records will be sufficient to permit the District to prepare 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 Federal award. The financial management system will provide for the following: 

     1)    Identifying all of the federal awards received and expended and the federal programs
            under which they were received;
     2)    Ensuring that accurate, current, and complete disclosure of the financial results of
            each federal award or program are maintained in accordance with reporting
            requirements;
     3)    Identifying adequately the source and application of funds for federally-funded
            activities;
     4)    Ensuring effective controls over and accountability for all funds, property, and other
            assets;
     5)    Comparing actual expenditures with budget amounts for each federal award;
     6)    Ensuring payments of federal funds are made in accordance with applicable law,
            including 2 CFR § 200.305; and
     7)    Determining the allowability of costs in accordance with applicable law and the
            conditions of the federal award.
Legal Reference: 2 C.F.R. § 200.302.
4310 STATE AND FEDERAL FUNDING
4311 ESSA AND FEDERAL PROGRAMS 

Program Income:  The District will consult with the federal awarding agency and refer to the applicable law and federal program terms and conditions to determine how to account for, deduct and otherwise handle income from federal programs.
Legal Reference: 2 C.F.R. § 200.307. 

Cost Sharing or Matching:  For all federal awards, any shared costs or matching funds and all contributions, including cash and third party in-kind contributions, must be accepted as part of the District's cost sharing or matching, when such contributions meet all of the following criteria: 

     1)         Are verifiable from the District's records;
     2)         Are not included as contributions for any other Federal award;
     3)         Are necessary and reasonable for accomplishment of project or program                                   objectives;
     4)         Are allowable under the applicable Cost Principles requirements;
     5)         Are not paid by the Federal Government under another Federal award, except                        where the federal statute authorizing a program specifically provides that Federal
                funds made available for such program can be applied to matching or cost sharing
                requirements of other Federal programs;
     6)        Are provided for in the approved budget when required by the federal awarding
                agency; and
     7)        Conform to other provisions of the law or terms and conditions of the federal
                 award, as applicable.
Legal Reference: 2 C.F.R. § 200.306. 

Compensation:  Compensation for personal services includes all remuneration for services of employees rendered during the period of performance under the federal award, including, but not limited to wages, salaries, and fringe benefits. Costs of compensation may be allowable under federal law and the federal grant to the extent that they satisfy the following requirements: 

     1)         Is reasonable for the services rendered; and
     2)         Conforms to the established written expectations of the District, as applied
                 consistently to both Federal and non-Federal activities.

If the District intends to charge compensation to federal awards, such charges will be based on records that accurately reflect the work performed, and will:
     1)         Be supported by a system of internal control which provides reasonable assurance
                 that the charges are accurate, allowable, and properly allocated;
     2)         Be incorporated into the official records of the District;
     3)         Reasonably reflect the total activity for which the employee is compensated by the
                 District, not exceeding 100% of compensated activities;
     4)         Encompass both federally-assisted and all other activities compensated by the
                 District on an integrated basis, but may include the use of subsidiary records as
                 defined in the District’s written procedures;
     5)         Comply with the established accounting policies and practices of the District; and
     6)         Differentiate and account for the distribution of the employee's salary or wages                         among specific activities or cost objectives if the employee works on more than
                 one Federal award; a Federal award and non-Federal award; an indirect cost
                 activity and a direct cost activity; two or more indirect activities which are allocated
                 using different allocation bases; or an unallowable activity and a direct or indirect
                 cost activity.

Budget estimates will generally not be used to support charges to Federal awards but may be used for interim accounting purposes.
Legal Reference: 2 C.F.R. §§ 200.430 & 200.431.

Unexpected or Extraordinary Circumstances:  For all federal awards, if the District does not currently have in place a sufficient policy that addresses extraordinary circumstances, such as those caused by COVID-19, the District may amend or create a policy at a later date in order to put emergency contingencies in place for federal and non-federal similarly situated employees. If the conditions exist for charges to be made to the federal grant, then charges may also be made to any non-federal sources that are used by the District in order to meet a matching requirement. The District will take other steps to comply with federal award requirements in the event of unexpected or extraordinary circumstances.
RESOLUTION OF THE BOARD OF EDUCATION OF HALL COUNTY SCHOOL DISTRICT 40-0002, A/K/A GRAND ISLAND PUBLIC SCHOOL DISTRICT REGARDING COVID-19 (ALSO KNOWN AS THE CORONAVIRUS) GLOBAL PANDEMIC AND EPIDEMIC SICKNESS – March 13, 2020

Legal Reference:  2 C.F.R. §§ 200, et seq.

Policy Adopted: 10.14.2021

 

.pdf Version

Media Inquiries
Mitchell Roush , Marketing & Communications
308-385-5900 ex. 201127
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