Excelsior Practices & Policies:
Records must be maintained to detail the history of procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price.
- Disclosure of Compensated External Professional Activities Form (document hosted at Excelsior’s internal SharePoint site)
- Subrecipient vs Contractor Checklist
- Excelsior’s Subrecipient Monitoring Policy
- Video on Risk Mitigation Strategies for medium to High Risk Subcontracts
Excelsior College utilizes resources to aid in subrecipient monitoring offered by the Federal Demonstration Partnership, an association where universities and the government work together to help colleges and universities administer federally-funded grant and sponsored programs. Should it be determined that a grant project will include one or more subrecipients, the Grants Office and the Fiscal Office will work closely with the external partners to ensure the relationship is set up in accordance with federal regulations and that appropriate monitoring occurs.
- 10% FTE or greater to be charged against a funded project – Template – Time Certification for 10 percent or more effort
- Under 10% FTE to be charged against a funded project – Template -Time Sheet for grant awards effort below 10 percent
Federal Regulatory Information:
The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR 200 (alternately referred to as the Uniform Grants Guidance, or more commonly Uniform Guidance) is a set of requirements for all federally funded grants. Most federal agencies have additional regulations to follow, so it is important to know what applies to your specific program.
A currently updated version of the Code of Federal Regulations (CFR). The e-CFR is an editorial compilation of CFR material and Federal Register amendments and is not an official legal edition of the CFR.
Read the e-CFR
The Council on Financial Assistance Reform (COFAR) offers many resources to help understand the regulations and how to stay in compliance.
View the site
(Video – 1:13:26)
Gil Tran, senior policy analyst with the Executive Office of the President, Office of Management and Budget (OMB) presents on the Uniform Guidance. Please note that this is approximately one hour long.
Watch the Video
Reasoning and Purpose for Uniform Guidance
(Video – 3:32)
Victoria Collin, senior policy analyst with the Executive Office of the President, Office of Management and Budget (OMB) presents on the reasoning and purpose for Uniform Guidance.
Watch the Video
Procurement Standards for Regulatory Compliance Presentation
(Video – 10:32)
Victoria Collin, senior policy analyst with the Executive Office of the President, Office of Management and Budget (OMB) presents on the Procurement Standards essential for regulatory compliance.
Watch the Video
Bard College to Pay $4 Million to Resolve False Claims Act Allegations. Learn more about Bard by reading the article and learn more about the False Claims Act by watching the video below.
If you’re concerned about the use of grant funds, please contact the Grants Office and General Counsel. If you’re concerned about broaches in ethical conduct, please visit the EthicsPoint website for more information on how and who to address.