Download the Federal Grant Administrative Bulletin
Executive Office for Administration and Finance
Glen Shor, Secretary
Effective Date: October 1, 2013
Purpose and Scope
The purpose of this Administrative Bulletin is to provide guidance on the uniform guidelines and procedures that all state agencies shall follow to seek and administer federal grants to comply with state law governing federal grants, M.G.L. c.29, 6B.
The provision of Comptroller Regulation 815 CMR 2.00 governs the receipt and expenditure of grants and subsidies, including federal grants. Under M.G.L. c. 29, s. 6B, “The comptroller, in consultation with the secretary of administration and finance, shall promulgate regulations which shall not be subject to chapter 30A to govern notice requirements for applications for federal grants by a state agency and the receipt and expenditure of federal fund.”
The following terms are defined as follows in this Bulletin.
Federal Grant – Any financial assistance available to a state agency from the United States government for a public purpose to benefit the general public or a segment of the general public. For the purposes of this Bulletin "federal grant" does not mean federal financial assistance provided pursuant to Titles XVIII, XIX or XXI of the Social Security Act or other reimbursements received for state earned benefits expenditures and credited to the General Fund; nor does it mean federal financial assistance from the Temporary Assistance to Needy Families block grant, the Child Care Development Fund block grant, or the Social Service block grant; nor does it mean federal financial assistance from the United States government for direct payments to individuals, or for other purposes as provided in G.L. c. 29, 2E; c.90, 34; c.92; or c.151A, 48. A Federal Grant does not include any grant from a federal agency intermediary, including private non-profits, associations or collaborative those are not United States government federal agencies not part of the CMIA disbursement system.
Funding from third party entities that are not a United States government federal agency are not considered “federal grants” even if the funds that are being offered as a grant may originate from a federal grantor agency. The funding from third party often require matching funds, or an expenditure of operating funds in order to be eligible for “reimbursement” and do not present a federal grant situation. Since the payment of the grant funds are not treated as an obligation and require an operational expense prior to receipt, these type of grants are riskier and do not fall under the federal grant umbrella rules and are considered a state grant under 815 CMR 2.00 and do not fall under M.G.L. c. 29, s. 6B. State agencies should work with their budget analysts at ANF and the CTR Accounting Bureau to determine the authority and funding to accept these types of third party grants.
Application – Documents which a state agency prepares to secure a grant award from a federal grant program in which the agency is not currently participating.
Reapplication or Renewal Application – Documents which a state agency prepares to secure continued participation in a federal grant program for which the original term is expiring.
Multi-Year Grant – Federal grant for which a state agency prepares a single application for funding which the federal grantor agency will distribute over a period of calendar years (any length over 12 months) defined in the application and subsequent award letter.
Formula Grant – Federal funding for which the allocation methodology is strictly determined in federal statute or regulation, and for which a state agency prepares a single application and receives subsequent years' allocations without reapplication.
The following sections set out activities that agencies must undertake in compliance with state law governing federal grants
Notification of Application for a Federal Grant
Any state agency submitting a new grant application or a renewal application to a federal funding agency must notify the Federal Grants Management Office (FGMO) within the Executive Office of Administration and Finance (ANF) and the Office of the State Comptroller (CTR) no later than 30 days after submitting the application to the appropriate federal agency.
Required notice to the FMGO and CTR will be done via a Notice of Application for a Federal Grant form. (The link to the form is found at the bottom of this document.) In order to avoid duplicate submission of this form, agencies will only need to submit the form once to CTR and it will then be shared with ANF. The form should be submitted electronically in Microsoft Word format to the following email address: email@example.com .Do not submit duplicate forms to both agencies. Agencies are not required to include a copy of the actual grant application or renewal application but must be able to provide it upon request. If an agency has any questions about how to fill out this form they should contact the FGMO within ANF. Contact information is provided at the bottom of this document.
The Notice of Application for a Federal Grant will be reviewed for completeness by ANF’s Federal Grants Management Office. The state agency submitting the Notice of Application for a Federal Grant is responsible for clarifying or resolving any matters related to the form.
Grants that are exempt from this notice of application requirement are:
(a) federal grants to institutions of higher education, including research grants;
(b) research grants to individuals, agencies, or institutions, not exceeding fifty thousand dollars annually and not creating new programs or expanding existing programs or commitments of state resources;
(c) any federal grant funds not exceeding five thousand dollars annually; and
(d) federal grants to the state for costs and damages resulting from natural disasters, civil disobedience, or other occurrences for which the Governor has declared a state of emergency.
Request to Establish a Federal Grant Appropriation
No state agency may expend federal grant funds without an appropriation by the General Court, unless otherwise provided by law. Every agency expecting to make expenditures from a federal grant during the ensuing state fiscal year must request a federal grant appropriation account number from ANF for each such grant by sending an email to the ANF Operations Analyst in the ANF Operations Department.
A Request for Appropriation can be done prior to receiving official notification of a federal grant award from the federal funding agency. These Requests for Appropriation are required for all federal grants, including new grants, grants requiring reapplications or renewals, ongoing multi-year grants, and formula grants. ANF will evaluate the Requests for Appropriation submissions and will ensure the number requested is available. The appropriation number to be used will be confirmed with agencies. ANF will include those appropriations in the Governor's budget recommendation for the ensuing fiscal year. If a grant is received after the publication of the Governor’s budget recommendation, agencies will still need to request an appropriation from ANF and also inform the legislature so that they can also include the new federal grant account in the General Appropriations Act (GAA).
Notice of Federal Grant Award
Upon official notification to a state agency from a federal funding agency of approval of a state plan or application for federal funds, the state agency is required to immediately notify the FGMO and the Comptroller through a Notice of Federal Grant Award form, also known as the Federal Grant Set-up form. (The link to the form is found at the bottom of this document.) A state agency may not incur any obligations anticipated to be made against the federal grant award prior to submission and establishment of the federal grant in MMARS to ensure that the documentation supports an actual funding authorization.
The Notice of Federal Grant Award will record, among other things, relevant information such as the amount of the federal grant, its duration, payment schedule and other attendant financial terms and conditions. State agencies are required to also include a copy of the official grant award letter with the Notice of Federal Grant Award form. In order to avoid duplicate submission of these forms, agencies will only need to submit the form once to CTR and then it will be shared with ANF.
The Notice of Federal Grant Award form should be submitted electronically in Microsoft Word format to the following email address: firstname.lastname@example.org . The form must be submitted in Microsoft Word format so that the data can be extracted. All attachments, including the award letter, should be submitted electronically in PDF format. The state agency submitting the Notice of Federal Grant Award form must have the information in the form validated as accurate and complete, and signed by a department head authorized signatory, such as the CFO and retained in the federal grant file. The electronic email submission of the Notice of Federal Grant Award Form and attachments must be submitted by a state agency department head authorized signatory (with DHSA signature authority in MMARS), or the CFO. The CFO must submit or be copied on the email submission as the state agency’s key fiscal representative to ensure that the state agency is incurring obligations in accordance with the terms of the federal grant, and fulfilling other associated obligations in accordance with state finance law.
Do not submit duplicate forms to both agencies. This form is required for new and continuing federal grant awards. Continuing grants include both increases in award amounts as well as extensions granted by a federal funding agency. All inquiries relative to Section I of the Notice of Federal Grant Award form should be addressed to the Office of the Comptroller; and questions relative to Section II of the form should be addressed to the Federal Grants Management Office within ANF.
It is recommended, not required, that the highest official within the appropriate Executive Office, Constitutional office or independent agency also be notified. This may be done through any mechanism internal to the agency.
Multi-Year and Formula Grants
State agencies do not need to submit a Notice of Application for a Federal Grant under this Bulletin for the continuation of funding in the second and subsequent years of an ongoing multi-year grant. However, any time the recipients of formula grants, where an updated multi-year plan or reapplication is submitted to a federal funding agency, the state agency must notify FGMO of the subsequent year funding amounts, to ensure that subsequent years' funding is consistent with information contained in the original notification to the reviewers. State agencies should do this through a new Notice of Application for a Federal Grant and Notice of Federal Grant Award upon receipt of a grant award letter or other official notice of award.
Recipients of formula grants must also provide FGMO with updated descriptions of the program and the federal formulas that determine the Commonwealth's share of funding, as necessary. When a multi-year grant or formula grant is expiring and an agency intends to reapply for it, it must comply with the notice requirements in this Bulletin. Agencies receiving either multi-year grants or formula grants must comply with the annual appropriation request requirements in this Bulletin.
Management of Expenditure and Revenue Accounts
No state agency may expend federal grant funds until the agency has submitted the official notice of award from a federal grantor agency to FGMO and the Comptroller, regardless of the existence of an appropriation for the grant in the General Appropriation Act.
This official notification is usually in the form of a grant award letter approving a state plan, application, or reapplication; confirming multi-year grant funding in a certain amount for a particular year; or allocating a formula grant in a certain amount. This information is necessary to ensure that the records of projected federal receipts and expenditures in the state accounting system are accurate.
State agencies must use sound business practices and comply with applicable federal and state laws and regulations in managing obligations and expenditures undertaken in anticipation of receipt of federal grant funds. If a state agency learns that actual federal grant receipts during the current or ensuing fiscal year may be less than the amounts previously projected, it must immediately take appropriate steps to control spending and provide written notice to ANF and the Comptroller. The notice must include revised projections of federal grant receipts for the current and ensuing fiscal years.
Disbursement of Federal Funds
Once federal grant funds are awarded and established through the grant set up process outlined above, the disbursement of funds is governed by the Office of the Comptroller regulation 815 CMR 2.00, the specific terms of the federal grant award, the Comptroller Policy State Grants and Federal Subgrants, and policies and procedures for the disbursement of funds.
Draw Down of Federal Funds (CMIA)
To assure compliance with the federal Cash Management Improvement Act (CMIA), all draws of federal funds must be processed through the Commonwealth's Automated Central Draw process, under the supervision of the Comptroller. The Comptroller may delegate draw authority directly to a state agency if the Comptroller determines that either federal restrictions or currently available payment mechanisms are inconsistent with efficient use of the Automated Central Draw process.
State agencies are responsible for working with the Comptroller and the Treasurer to ensure that federal funds are received in a timely fashion and in compliance with all federal and state regulations. State agencies must inform the Comptroller of impending changes in processes or in codes that may affect future requests for federal funds.
Quarterly Reporting to the Legislature
The Office of the Comptroller is required to report quarterly to the House and Senate Committees on Ways and Means on the status of federal funds applied for, received and expended. To comply with this mandate, the Comptroller’s Office will gather pertinent information from departments regarding the status of federal funds applied for and compile quarterly expenditure reports via data from the state accounting system (MMARS) regarding the status of federal funds received and expended.
It is each department’s CFO’s responsibility to ensure compliance with this reporting requirement. Departments should take steps to ensure that all applicable funds that have been applied for, including newly announced federal funds, existing grant award requests for increase, and federal funds applied for that were not awarded are submitted to the Office of the Comptroller. Departments are expected to update this information at least quarterly throughout the fiscal year. This information should be maintained in your department files as a reference for any subsequent review by the Office of the Comptroller and the Executive Office for Administration and Finance.
Questions regarding quarterly reporting should be directed to the Director of Federal Grants & Cost Allocation Bureau in the Office of the Comptroller. The form and instructions for submission can be found in the links below:
In order to assist agencies, ANF has provided the required Notice of Federal Grant Application form and the Notice of Federal Grant Award below:
Procedures related to this Bulletin will be circulated to the Agency CFO’s and Budget Directors for distribution.
State agencies should contact the Federal Grants Management Office (FGMO) within the Executive Office for Administration and Finance, if they have questions regarding any of the procedures detailed or forms referenced in this Bulletin.
ANF Secretary Approval and Effective Date
This Administrative Bulletin published by the Executive Office for Administration and Finance shall be effective as of the date specified below:
Glen Shor, Secretary
Effective Date: October 1, 2013