The state of Iowa and Office of the Chief Information Officer (OCIO) have provided funding under the Broadband Grants Program – Empower Rural Iowa, Coronavirus State and Local Fiscal Recovery Funds. This Notice of Funding Availability (NOFA) 007 is provided through expenditures from the federal American Rescue Plan Act of 2021. Due to rules put in place under government regulations, there are several compliance checks that companies that received or will receive funding under NOFA 7 will need to be aware of and put in place.
This article is designed to provide a brief summary of some of the required components of grant expenditures. Although not all inclusive, here are some general guidelines to follow to help you maintain compliance and avoid the possibility of being required to return grant funding, or even worse, become debarred from future federal funding.
Generally speaking, any expenditures greater than a cumulative $10,000 with any one vendor should have gone through a competitive bidding process. There may be exceptions allowed in cases where competitive bidding would not have been possible or cost effective; however, this needs to be well documented.
Once vendors are selected, a grantee should have written procedures in place for procurement transactions. These include identification of individuals and their responsibilities each step along the way, including purchase order approvals, approval of goods received, approval of vendor payments, and a best practice of having an independent individual oversee the entire process such as a member of management or a board member. Documentation is always very important, and the expected process needs to indicate when the steps are performed, including evidence of approval with signatures and dates. Best practices would include maintaining adequate safeguards of the documentation such as scanning, which is backed up to an off-site safe location.
Internal payroll and materials costs are allowed to receive grant funding. These also contain cost reasonableness checks and require controls over their activity. If using these activities, a company should maintain strong records on the flow of activity.
Records of adequate communication also are important. Providing work order detail in comparison to budgets and approved vendor contracts is recommended. These should be reviewed by management, the board of directors, or both, with a formal record of this review completed. This should be done regularly whether it is weekly, monthly, or quarterly, depending on the volume of transactions.
The internal control requirements also include an educational component. Individuals involved in the process should be educated on all of the requirements. There are many resources available on the OCIO Broadband website and through the Iowa Communications Alliance for those that are members.
Grantees should review all materials available as part of the grant agreement to be knowledgeable on other details. If you have any questions or need assistance, please reach out to a professional at FORVIS or submit the Contact Us form.