Federal Funds Payment and Cash Management

Version: December 2015

The policy of Lewis & Clark College is to request payments from federal agencies at the time each agency requires financial reporting. The total disbursements for allowable costs for a given reporting period, less any credits, discounts, rebates, refunds, program income, or amounts withheld from payment to contractors to assure satisfactory completion of work, will represent the amount requested as a reimbursement.

• Monthly Reporting: The Department of Education requires monthly reporting. Funds will be requested monthly only if the academic period for the disbursements has begun or will begin within 10 days. Direct Loan funds are requested as needed after the loans are posted for academic periods that have begun or will begin within 10 days. At the beginning of each semester, when Title IV grants have been posted to student accounts and classes have begun, the Controller or CFO may authorize a reimbursement request from the Department of Education prior to the end of the reporting period.
  
  
• Quarterly Reporting: Agencies including the Internal Revenue Service (IRS), the National Endowment for the Humanities (NEH), National Endowment for the Arts (NEA), PHS (Public Health Service) Agencies including the National Institutes of Health (NIH), and the National Science Foundation (NSF) require quarterly reporting, and funds are requested quarterly. Funds may be requested for reimbursement of net expenditures as of year-end, if authorized by the Controller or CFO. When a large equipment purchase is made that is funded by a federal grant, the Controller or CFO may authorize a reimbursement request prior to the end of the reporting period.
  
  
• If at any time the College elects to request funds from a federal agency prior to expending the funds, the following steps are required:
  • Written approval by the Controller or CFO
  • Verification by the Director of Accounting that the expenditure has been vouchered in the AP system and will be disbursed within two days or less.
  • Payment request will be certified by the CFO or Controller.
• Payments to sub-recipients shall conform to the standards of timing and amounts that apply to the payments by the respective agency to its grantees. Sub-recipients will be required to submit invoices with a breakdown by budget category to the PI/Program Director of the primary grant at Lewis & Clark. After the PI/Program Director has reviewed and approved the invoice for payment, it will be submitted to the L&C Business Office. Payment will be made the following Friday as per the Accounts Payable schedule.

Erroneous Payments
Advances or reimbursements made in error will be promptly refunded to the federal agency through www.pay.gov. The Director of Accounting will calculate the interest earned on any excess funds due to an erroneous payment. Interest liability begins accruing on the date the funds were credited to the Lewis & Clark General Fund and is accrued until the date the funds are used for program purposes for that agency, or are returned. Interest calculations must be documented and auditable. Interest earned in excess of $500 per fiscal year will be remitted to the Department of Health and Human Services.

Certifications
Payments from federal agencies for grants and contracts will be requested by the method established by the agency. Several examples are:

• ACM$ for NSF awards
• Division of Payment Management for NIH and IRS awards
• G5 for the Department of Education.

The required certification for payment requests is stated at 2 CFR 200.415(a):
“(a) To assure that expenditures are proper and in accordance with the terms and conditions of the Federal award and approved project budgets, the annual and final fiscal reports or vouchers requesting payment under the agreements must include a certification, signed by an official who is authorized to legally bind the non-Federal entity, which reads as follows: “By signing this report, I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise.”

Therefore, each payment request must be certified, by an officer who is authorized to legally bind Lewis & Clark College per the current Certificate of Incumbency, before the payment request is made.

Cash Management
Based on established federal funds payment policies, and with the exception of Federal Perkins Loan Program funds, Lewis & Clark is not expected to earn interest on federal funds in excess of $500 per year. This determination is based upon the best reasonably available interest-bearing account.

The Lewis & Clark College Federal Perkins Loan Program Fund will be maintained in a low-risk interest-bearing account. Interest or income earned on the Fund balance is retained by the College as part of the Fund. The account name will be “Lewis & Clark College Federal Perkins Loan Account”.