2. Securing and Documenting Match and In-kind Support
Gregory Winn, Sr. Grants Advisor, OGM
Susan Meche, Meche Consulting

3. Session Objectives Gain knowledge of match requirements at
basic and more advanced levels
Gather and retain proper match documentation
for accountability and audit review
Document = Webster’s defines a document as an original or official paper relied on as the basis, proof, or support of something
Allowable = permissible by accounting standards, government laws, agency regulations, federal circulars
Allocable = to apportion for a specific purpose or to particular project
Reasonable = not extreme or excessive; marked by impartiality and honesty; free from self-interest, prejudice, or favoritism
Types of match: cash or in-kind (consisting of something other than money, such as goods or commodities
Learn about types and examples of match and
how to address complex requirements
Corporation Grantee Financial Accountability Seminar July 2007

4. Allowability of Project Costs
To be allowable under a grant, costs must:
Be reasonable and allocable for the performance of the award
Conform to grant award limitations or cost principles
Be consistent with policies and procedures that apply to both federally-financed and other activities of the organization
Be given consistent treatment
Be in accordance with Generally Accepted Accounting Principles (GAAP)
Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program
Be adequately documented
Cost sharing = To be allowable under an award, costs must not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period.
Cost sharing = Salaries and wages of employees used in meeting cost sharing or matching requirements on awards must be supported in the same manner as salaries and wages claimed for reimbursement from awarding agencies
Cost share/match = this ratio depends on the grant requirements
The value of the donated services may be used to meet cost sharing or matching requirements under conditions described in Sec.__.23 of Circular A-110.
You may not include the value of direct community service performed by volunteers, but you may include the value of services contributed by volunteers to your organizations for organizational functions such as accounting, audit, and training of staff and AmeriCorps programs.
OMB Circulars – see handout
Corporation Grantee Financial Accountability Seminar July 2007

5. Grantee Share or Match
Cash and in-kind contributions are accepted as part of the grantee’s cost sharing or matching when contributions meet all of the following criteria:
Are verifiable from the grantee's records
Are necessary and reasonable for proper and efficient accomplishment of project or program objectives
Are allowable under the applicable OMB cost principles
Are not paid by the Federal Government under another award, except where authorized by Federal statute to be used for cost sharing or matching
Are provided for in the approved budget
Conform to other grant provisions or OMB Circulars
Cost sharing = To be allowable under an award, costs must not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period.
Cost sharing = Salaries and wages of employees used in meeting cost sharing or matching requirements on awards must be supported in the same manner as salaries and wages claimed for reimbursement from awarding agencies
Cost share/match = this ratio depends on the grant requirements
The value of the donated services may be used to meet cost sharing or matching requirements under conditions described in Sec.__.23 of Circular A-110.
You may not include the value of direct community service performed by volunteers, but you may include the value of services contributed by volunteers to your organizations for organizational functions such as accounting, audit, and training of staff and AmeriCorps programs.
Question: How would you estimate
and record the value of PSAs? (See FAQ Sheet)
Corporation Grantee Financial Accountability Seminar July 2007

6. Talking Technical: Definitions to Know
Project
Costs
Total allowable expenditures incurred to operate the program and accomplish its objectives
Portion of total expenditures paid for with Federal funds (CNCS)
Portion of total expenditures not paid for with Federal funds (CNCS)
– Key Point – grantee share is recorded and documented the same as CNCS funding
Federal
Share
Cost sharing = To be allowable under an award, costs must not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period.
Cost sharing = Salaries and wages of employees used in meeting cost sharing or matching requirements on awards must be supported in the same manner as salaries and wages claimed for reimbursement from awarding agencies
Cost share/match = this ratio depends on the grant requirements
The value of the donated services may be used to meet cost sharing or matching requirements under conditions described in Sec.__.23 of Circular A-110.
You may not include the value of direct community service performed by volunteers, but you may include the value of services contributed by volunteers to your organizations for organizational functions such as accounting, audit, and training of staff and AmeriCorps programs.
Grantee
Share
Corporation Grantee Financial Accountability Seminar July 2007

7. Corporation Grantee Financial Accountability Seminar July 2007
More Technical Talk
Gross income earned by the grantee that is directly generated by a supported activity or earned as a result of the award Key Point: There are three ways to address the use of program income – [see FAQ sheet]
Value of non-cash contributions provided by non-Federal third parties
May be in the form of real property, equipment, supplies, services, and other expendable property
Program
Income
Program Income = deleted from 2005 AmeriCorps provisions, see regulations
Program Income = Program income includes, but is not limited to: (1) income from fees for services performed, (2) the use or rental of real or personal property acquired with grant funds, (3) the sale of commodities or items fabricated under a grant agreement, and (4) from payments of principal and interest on loans made with grant funds. §  states & local
Program income also include (5) license fees and royalties on patents and copyrights §  non-profits
Interest earned on advances of Federal funds is not program income.
Deduction. Ordinarily program income shall be deducted from total allowable costs to determine the net allowable costs. Program income shall be used for current costs unless the Federal agency authorizes otherwise. Program income which the grantee did not anticipate at the time of the award shall be used to reduce the Federal agency and grantee contributions rather than to increase the funds committed to the project
Addition. When authorized, program income may be added to the funds committed to the grant agreement by the Federal agency and the grantee.
Grantee has no obligation to CNCS regarding program income earned after the end of the project
§ 2543 (non-profits) = provides definition of in-kind contributions
§ 2541 ( states & local) Third party in-kind contributions. The term third party in-kind contributions means property or services which benefit a federally assisted project or program and which are contributed by non-Federal third parties without charge to the grantee, or a cost-type contractor under the grant agreement.
In-Kind
Contributions
Corporation Grantee Financial Accountability Seminar July 2007

8. Where Can You Find Match?
Cash:
Donations
Non-federal income
Local governments
State appropriations
Foundation grants or corporate contributions
In-Kind Contributions:
Value of donated services
and/or donated goods
Unfunded Indirect Costs:
The portion of indirect
costs not allowed by CNCS
in Federal Share
Where will you find your match? Sources?
Mimi = example of unique sources where CA Commission finds match
Cash from
Donations
Non-federal Income
State Appropriations
In-Kind Contributions
Value of donated labor
Value of donated space
Value of donated vehicles
Value of donated training for members/staff
Unfunded Indirect Cost Rate
If a grantee’s approved indirect cost rate is greater than the 5% allowed by the AmeriCorps program, the unfunded difference can be counted toward the grantee’s matching obligation.
Allowable 10% Indirect
10% of the sum of the federally-funded direct costs plus the grantee-funded direct costs may be claimed as grantee administrative cost without any documentation.
Government-wide, with few rare exceptions,
Grantees cannot use other Federal funds as match
Corporation Grantee Financial Accountability Seminar July 2007

9. Exception: Volunteer Match
Do not count as match -
The value of direct community services performed by volunteers
Do count as match -
Services that contribute to organizational functions
Count services such as accounting, training of staff or members that are elements of the grantee’s cost allocation plan
DO NOT = 2005 Provisions, Section IV, Para. K.1. = Exception for Donated Professional Service. Because the purpose of this grant is to enable and stimulate volunteer community service, the grantee may not include the value of direct community service performed by volunteers.
YES, YOU CAN COUNT = the value of volunteer services contributed to the organization for organizational functions such as accounting, audit work, training of staff and AmeriCorps Programs.
§ and = Rates for volunteer services shall be consistent with those paid for similar work in the recipient's organization. In those instances in which the required skills are not found in the recipient organization, rates shall be consistent with those paid for similar work in the labor market in which the recipient competes for the kind of services involved. Regardless, include paid fringe benefits that are reasonable, allowable, and allocable
§ and = In-kind contributions from third parties = Volunteer services shall be documented and, to the extent feasible, supported by the same methods used by the recipient for its own employees.
Corporation Grantee Financial Accountability Seminar July 2007

10. How to Record In-Kind Contributions
Maintain adequate documentation to support amounts claimed as match
Maintain same documentation for both CNCS Federal share and for grantee’s share
Documentation must meet same standards as other expenditures
Record donation and valuation of item in detail
Enter into the general ledger as income and expenditure
Failure to enter match contributions into general ledger requires a formal explanatory policy and separate spread sheet accountability of receipt and use
Recording in-kind:
Documentation = obtain and retain the same type of documentation for in-kind as you would for direct costs
Record donation = record the value of the donation in you G/L as income (credit) and as an expense (debit)
Corporation Grantee Financial Accountability Seminar July 2007

11. Corporation Grantee Financial Accountability Seminar July 2007
Why Record In-Kind in General Ledger?
Statement of Financial Accounting Standards
(SFAS #116) sets the standard:
Contributed services are recognized in financial statements if services received:
Create or enhance non-financial assets
Requires specialized skills provided by individuals possessing those skills
Would need to be purchased if not provided by donation
Statement of Financial Accounting Standards (SFAS) No. 116 = Effective 1/1/1995 (Jan. to Dec.) of 7/1/1995 (July to June); Some of the new requirements:
All contributions received are recorded a revenue upon receipt
More explicit definitions of the types of contributed services which should be recorded, and prohibition from recording other types:
The services create or enhance nonfinancial assets or,
The services require specialized skills, are provided by persons possessing those skills, and would typically have to be purchased if volunteers were not available
Corporation Grantee Financial Accountability Seminar July 2007

12. Recording In-Kind Contributions
Enter into the general ledger as income and expenditure:
Example:
Local paint store donates a professional paint sprayer with a fair market value of $550.00
Recording in-kind:
Documentation = obtain and retain the same type of documentation for in-kind as you would for direct costs
Record donation = record the value of the donation in you G/L as income (credit) and as an expense (debit)
$ – 7250 In-Kind Expenses Account (debit)
$ – 5250 In-Kind Income Account (credit)
Corporation Grantee Financial Accountability Seminar July 2007

13. Defining Source Documentation:
Benefits: Supports a value, cost, or performance criteria relative to the grant
Physical information:
Hard copy
Soft copy: CD, flash drive, server, microfilm
Source:
Internal source
External source
NB: Federal Funds and match are maintained and documented the
same way with the exception of in-kind match contributions
Corporation Grantee Financial Accountability Seminar July 2007

14. Why Retain Documentation?
To track incoming information
To review information
To provide historical evidence
To provide evidence of accomplishments
To prepare for an audit
How do you maintain documentation? Internal controls and security for your financial system (see handout)
Corporation Grantee Financial Accountability Seminar July 2007

15. Retaining Source Documentation
Retain all financial records:
3 years from date of submission of final Financial Status Report
Final report submitted by Commission or Parent of National Direct
3 years from final audit resolution when there is an on-going audit
Example 1:
Grant Ends 7/31/2009
90 days to submit Final FSR = 10/31/2009
3 years = 10/31/2012
Example 2:
Grant Ends 7/31/2009
90 days = 10/31/2009
3 years = 10/31/2012
Audit started = 4/1/2012
Final audit resolution = 9/30/2013
3 years = 8/31/2016
Documentation retention
Written policy
Who is authorized to store or dispose
Off-site storage
When is it sent to storage or disposed of
Mimi = example of why retaining records is important
Corporation Grantee Financial Accountability Seminar July 2007

16. Documentation Examples
Salary
Benefits
Travel
Supplies
Contract &
Consultant
Training
This is a summary of what is to come.
See slide.
Evaluation
Volunteer or
Member Costs
Admin
Corporation Grantee Financial Accountability Seminar July 2007

17. Identifying Documentation
Salary
Signed timesheets with supervisory approval
Quarterly payroll returns (941)
Payroll register
Personnel file with salary/wage information
Employment contract
Cancelled checks/Direct deposit schedule
This is a common audit finding and site visit issue – timesheets documenting salary paid
A-21 = educational institutions
A-87 = state, local and indian tribal governments
A-122 = non-profits
Corporation Grantee Financial Accountability Seminar July 2007

18. Time & Activity Reporting Summary
All salaries and wages charged to grants must be supported by signed time & attendance records, i.e., timesheets
Exceptions:
State, Local and Indian Tribal governments must comply with requirements of OMB A-87
Educational Institutions must comply with requirements of OMB A-21
{See Handout for specifics depending on Grantee Type i.e. State, Local and Indian Tribal Governments, Educational Institutions and Non-Profit Organizations}
Non-profits, state, local, and Indian tribal governments must have timesheets
Educational institutions must comply with educational requirements
Corporation Grantee Financial Accountability Seminar July 2007

19. Identifying Documentation
Benefits
Insurance policy
Paid invoices and receipts
Cost allocation plan
Benefits = Fringe Benefits
Benefits are allowances and services provided by employers to their employees as compensation, in addition to regular salaries and wages.
Fringe Benefits include:
Costs of leave – annual leave, sick leave, holidays, court leave, military leave, and other similar leave
Employee insurance – employer contributions or expenses for social security; employee life, health
Pension plan costs
Unemployment benefit plans
Worker’s compensation insurance
Severance pay
Except as provided elsewhere, costs of fringe benefits are allowable to the extent that benefits are reasonable and required by law, governmental unit employee agreement, or an established policy of the government unit.
OMB A-122, Para. 8; A-87, Para. 8; A-21, Para. 10
Fringe benefits are allowable, provided such costs are absorbed by all organization activities in proportion to the relative amount of time or effort actually devoted
Corporation Grantee Financial Accountability Seminar July 2007

20. Identifying Documentation
Travel
Authorization/reimbursement request NB: You must have written policies and procedures on hand on how to authorize and reimburse travel
Paid invoices and receipts
Per diem rates (applicable for area)
Mileage calculation
Reconciliation of advances to payments
Travel = for transportation, lodging, subsistence, and related items while on official business for organization, government, institution (OMB travel same for all)
Methods = costs may be charged on an actual cost basis, on a per diem or mileage basis in lieu of actual costs incurred, or on a combination of the two, provided the method used is applied to an entire trip and not to selected days of the trip, and results in charges consistent with those normally allowed in the organization’s non-federally sponsored activities
Costs shall be considered reasonable and allowable only to the extent such costs do not exceed charges normally allowed by the non-profit organization in its regular operations as the result of the organization’s written travel policy
Written policy = in the absence of the organization’s written policy, the organization shall use federal government travel allowances as established by GSA:
First Class airfare = generally unallowable; organization must justify and document these conditions on a case-by-case basis in order for the use of first-class airfare to be allowable
OMB A-122, Attachment B, Para. 51; A-87, Para. 43; A-21, Para. 53
Travel costs must not exceed charges normally allowed by the organization in its regular operations based on the organization’s written travel policy
Corporation Grantee Financial Accountability Seminar July 2007

21. Identifying Documentation
Supplies
Purchase orders
Packing slips
Paid receipts and invoices
Donated Supplies, i.e., in-kind
Travel = for transportation, lodging, subsistence, and related items while on official business for organization, government, institution (OMB travel same for all)
Methods = costs may be charged on an actual cost basis, on a per diem or mileage basis in lieu of actual costs incurred, or on a combination of the two, provided the method used is applied to an entire trip and not to selected days of the trip, and results in charges consistent with those normally allowed in the organization’s non-federally sponsored activities
Costs shall be considered reasonable and allowable only to the extent such costs do not exceed charges normally allowed by the non-profit organization in its regular operations as the result of the organization’s written travel policy
Written policy = in the absence of the organization’s written policy, the organization shall use federal government travel allowances as established by GSA:
First Class airfare = generally unallowable; organization must justify and document these conditions on a case-by-case basis in order for the use of first-class airfare to be allowable
OMB A-122, Attachment B, Para. 51; A-87, Para. 43; A-21, Para. 53
Corporation Grantee Financial Accountability Seminar July 2007

22. Identifying Documentation
Contract &
Consultant
Purchase orders
Signed agreements
Paid invoices and receipts
Maximum Allowed by CNCS for Consultant fee is $540 per day. In charging contract services it is important to differentiate among days of prep time, number of days of activity, travel and per diem where applicable.
Travel = for transportation, lodging, subsistence, and related items while on official business for organization, government, institution (OMB travel same for all)
Methods = costs may be charged on an actual cost basis, on a per diem or mileage basis in lieu of actual costs incurred, or on a combination of the two, provided the method used is applied to an entire trip and not to selected days of the trip, and results in charges consistent with those normally allowed in the organization’s non-federally sponsored activities
Costs shall be considered reasonable and allowable only to the extent such costs do not exceed charges normally allowed by the non-profit organization in its regular operations as the result of the organization’s written travel policy
Written policy = in the absence of the organization’s written policy, the organization shall use federal government travel allowances as established by GSA:
First Class airfare = generally unallowable; organization must justify and document these conditions on a case-by-case basis in order for the use of first-class airfare to be allowable
OMB A-122, Attachment B, Para. 51; A-87, Para. 43; A-21, Para. 53
Corporation Grantee Financial Accountability Seminar July 2007

23. Identifying Documentation
Training
Agenda
Course description, cost
Sign-in sheet
Consultant/Trainer agreement
Paid invoices and receipts
While the cost of the training, itself, is usually allowable, one cannot include the value of the time given by the attendees to participate.
Participant support costs. Participant support costs are direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with meetings, conferences, symposia, or training projects. These costs are allowable with the prior approval of the awarding agency. OMB A-122, para. 33
Meetings and conferences. Costs of meetings and conferences, the primary purpose of which is the dissemination of technical information, are allowable. This includes costs of meals, transportation, rental of facilities, speakers' fees, and other items incidental to such meetings or conferences OMB A-122, para. 29
Staff development (accounting) = Costs of preparation and maintenance of a program of instruction including but not limited to on-the-job, classroom, and apprenticeship training, designed to increase the vocational effectiveness of employees, including training materials, textbooks, salaries or wages of trainees are allowable. OMB A-122, para. 49
OMB A-122, Attachment B, Para. 49; A-87, Para. 42; A-21, Para. 51
Corporation Grantee Financial Accountability Seminar July 2007

24. Identifying Documentation
Evaluation
Purchase orders
Signed agreement/contract
Paid invoices and receipts
Final copy of the evaluation report
Participant support costs. Participant support costs are direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with meetings, conferences, symposia, or training projects. These costs are allowable with the prior approval of the awarding agency. OMB A-122, para. 33
Meetings and conferences. Costs of meetings and conferences, the primary purpose of which is the dissemination of technical information, are allowable. This includes costs of meals, transportation, rental of facilities, speakers' fees, and other items incidental to such meetings or conferences OMB A-122, para. 29
Staff development (accounting) = Costs of preparation and maintenance of a program of instruction including but not limited to on-the-job, classroom, and apprenticeship training, designed to increase the vocational effectiveness of employees, including training materials, textbooks, salaries or wages of trainees are allowable. OMB A-122, para. 49
OMB A-122, Attachment B, Para. 49; A-87, Para. 42; A-21, Para. 51
Corporation Grantee Financial Accountability Seminar July 2007

25. Identifying Documentation
Volunteer Costs*
Meal receipts
Uniforms invoices and receipts
Insurance invoices and receipts
Recognition invoices and receipts
Travel invoices and receipts
Physical Examinations invoices and receipts
* Senior Corps only
Participant support costs. Participant support costs are direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with meetings, conferences, symposia, or training projects. These costs are allowable with the prior approval of the awarding agency. OMB A-122, para. 33
Meetings and conferences. Costs of meetings and conferences, the primary purpose of which is the dissemination of technical information, are allowable. This includes costs of meals, transportation, rental of facilities, speakers' fees, and other items incidental to such meetings or conferences OMB A-122, para. 29
Staff development (accounting) = Costs of preparation and maintenance of a program of instruction including but not limited to on-the-job, classroom, and apprenticeship training, designed to increase the vocational effectiveness of employees, including training materials, textbooks, salaries or wages of trainees are allowable. OMB A-122, para. 49
OMB A-122, Attachment B, Para. 49; A-87, Para. 42; A-21, Para. 51
Corporation Grantee Financial Accountability Seminar July 2007

26. Identifying Documentation
Member Match
Member eligibility
Signed member contract
Member timesheets signed by both member and supervisor
Documented pay system
Signed mid-year and final member evaluations
Were donations received with restrictions on their use, or on the time of their allowable use? Can grantee use cash contribution for a prior period retroactively of member cost or not? Were contributions received timely and used during the course of the award, or only at the end of it?
Participant support costs. Participant support costs are direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with meetings, conferences, symposia, or training projects. These costs are allowable with the prior approval of the awarding agency. OMB A-122, para. 33
Meetings and conferences. Costs of meetings and conferences, the primary purpose of which is the dissemination of technical information, are allowable. This includes costs of meals, transportation, rental of facilities, speakers' fees, and other items incidental to such meetings or conferences OMB A-122, para. 29
Staff development (accounting) = Costs of preparation and maintenance of a program of instruction including but not limited to on-the-job, classroom, and apprenticeship training, designed to increase the vocational effectiveness of employees, including training materials, textbooks, salaries or wages of trainees are allowable. OMB A-122, para. 49
OMB A-122, Attachment B, Para. 49; A-87, Para. 42; A-21, Para. 51
Corporation Grantee Financial Accountability Seminar July 2007

27. More Technical Talk: Match Requirements
Minimum matching amount the law requires a grantee to provide
Minimum matching amount established by CNCS regulations that may be higher than the statutory requirement
Amount of match grantee provides based on budget, budget narrative, and program narrative contained in grant application; may be greater than statutory or regulatory required match
Statutory
Regulatory
Budgeted
Corporation Grantee Financial Accountability Seminar July 2007

28. Sustainability for AmeriCorps and Service Learning: The Ultimate Goal
New
Program/Project
Mature
Program/Project
Grantee
Share
CNCS
Share
Grantee
Share
CNCS
Share
Corporation Grantee Financial Accountability Seminar July 2007

29. Valuing In-Kind Donations
Use Fair Market Price
Consider what it would cost to obtain similar good or service
Value of donation should be placed by the donor
Review donation letter or form to ensure the value is reasonable and compare with other estimates or bases for value
IRS Definition of Fair market value = Fair market value (FMV) is the price that property would sell for on the open market. It is the price that would be agreed on between a willing buyer and a willing seller, with neither being required to act, and both having reasonable knowledge of the relevant facts. If you put a restriction on the use of property you donate, the FMV must reflect that restriction.
Pub Determining the Value of donate property
Pub. 526 – Charitable Contribution
Mimi = example of how CA Commission has obtained values of in-kind
Corporation Grantee Financial Accountability Seminar July 2007

30. Documenting In-Kind Contributions
Document in-kind contributions to show:
What service or goods were obtained
Why transaction is allowable for
grant purposes
The value of the contribution
How it is traced back to source documentation
In-kind contributions – non cash contributions for goods or services, e.g., staff costs, rent, supplies,
Value = the donor must provide the value of the contribution, not your organization
IRS publication 561 = Determining the value of donated property
Fair market value
Real estate
Inventory
Stocks and bonds
If audited, a grantee may be required to obtain full supporting documentation from all donors if not available during the audit.
Corporation Grantee Financial Accountability Seminar July 2007

31. Documenting In-Kind Contributions
Document the basis for determining value of personal services, material equipment, building, and land
Obtain written acknowledgement of the contribution including:
Name and signature of donor
Date and Location of donation
Detailed description of item/service
Estimated value of contribution, how value was determined, who made the determination
Was the contribution obtained with Federal funds
See slide – self explanatory.
*** Keep a copy of the receipt in your files ***
Corporation Grantee Financial Accountability Seminar July 2007

32. Sample 1: In-Kind Contribution Form
See slide – self explanatory.
Corporation Grantee Financial Accountability Seminar July 2007

33. Sample 2: In-Kind Contribution Form
See slide – self explanatory.
Corporation Grantee Financial Accountability Seminar July 2007

34. Common Audit Findings Related to Cash & In-Kind Match
Establish a written policy
Training all staff: program and financial staff on match and in-kind documentation
Retain records as required
See Handout
Corporation Grantee Financial Accountability Seminar July 2007

35. Summing it up: In a Nutshell
Source Documentation:
Familiarize all staff with cash and in-kind match documentation requirements
Ensure supporting documentation relates directly to approved program funded by the CNCS grant
Establish documentation for expenditure requirements to ensure costs are: reasonable, necessary, allocable, allowable, and adhere to grant guidelines
Maintain proper records and establish a written record retention policy
Establish a written policy
Training all staff: program and financial staff on match and in-kind documentation
Retain records as required
Corporation Grantee Financial Accountability Seminar July 2007

36. Electronic copies of this material can be found at The Resource Center
Search for Financial Accountability Seminar