2 CFR 200.302(b)(4) and 2 CFR 200.303), require non-federal entities to maintain financial management and reporting systems that maintain effective control over and accountability for federal funds. This policy is designed to ensure that public resources are spent as intended, within authorized limits, and following sound financial management principles for the resources that are allocated to and entrusted to GBPLD. This policy applies to all employees, officers, and contractors doing business with GBPLD.
Requirements- Financial processes shall be properly documented, measured, and managed to ensure accuracy, financial transparency, strict compliance with generally accepted accounting principles (GAAP), reporting requirements, and continuous improvement.
- To provide reasonable assurance of compliance, GBPLD must validate that:
- Procedures exist to create payment obligations and expenditures.
- Processes are in place that require review of expenditures prior to approval.
- Procedures exist to ensure that appropriation balance, fund balance, and obligation balances are sufficient prior to approval of any purchase order or voucher.
- Written procedures for determining the allowability of costs in accordance with eCFR :: 2 CFR Part 200 Subpart E -- Cost Principles and the terms and conditions of the federal award.
- Expenditures are recorded promptly and accurately in the appropriate accounts. This includes:
- Written procedures for processing and recording obligations and expenditures, and to ensure vendor invoices are paid promptly.
- An expenditure recording system that allows for immediate access to vouchers and rapid determination of available balances.
- Processes over the tracking, recording, and payment of outstanding invoices.
- Compliance with all applicable local, state, and federal laws and regulations for expenditures. This includes:
- Maintenance of records that identify adequately the source and application of funds for state or federally funded activities. Further, these records contain information pertaining to state or federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest, and are supported by source documentation.
- Effective accounting control over expenditures. This includes:
- An expenditure process designed to prevent duplicate payments to vendors.
- Procedures exist to process vendor invoice vouchers accurately, with proper coding, and in agreement with the established terms and conditions.
- An expenditure process that does not allow for personnel performing the recording of expenditures and obligations to have approval authority.
GBPLD officers will provide proactive leadership and ensure their fiscal system is compliant in their respective areas, particularly regarding:
- Fundamental concepts of internal control, especially regarding reliable processes and risk management.
- Sound business case analyses and decision processes, at all levels; and
- Information integrity and high ethical standards.
The Director of Finance will ensure that:
- The resources that have been allocated to GBPLD by funding authorities are effectively and efficiently managed according to fundamental fiduciary responsibilities and associated grant agreements.
- Business decision processes are adequately supported by relevant and reliable financial systems and proactive financial leadership.
- Financial transactions are accurately and efficiently processed.
- Financial, tax, and insurance reporting requirements are satisfied with a high degree of integrity and reliability; and
- GBPLD complies with the relevant laws, regulations, and generally accepted accounting principles (GAAP) related to financial management and accounting.
(3/2024)