The Mathematical Association of America
Manual For Principal Investigators
May 2008
Table of Contents
I
Overview of External Funding
of MAA Programs
II
Proposal Development and
Approval Process
II.A
Concept Development
II.B
Proposal
Development Process
II.C
Budget Guidelines
II.D
Timeline
III
Project Management
III.A
Funded
Project Management
III.B
Grant
Modifications
IV
Grants
Financial Management
IV.A
Budgets
IV.B
Reimbursement of
Expenditures
IV.C
Reimbursements for Salaries
/ Personnel Expenses
IV.D
MAA Financial
Reports
IV.E
Subcontracts
IV.F
Miscellaneous Items
Appendix A: Criteria for Review of New and Existing
Programs Appendix B: Reimbursement Forms Appendix C: Purchasing of Goods and Services in
Excess of $25,000 for Federal GrantsAppendix D: Sole Source Justification Request for
Federal Grants for Purchases Over $25,000
I Overview of External Funding of MAA
Programs
The MAA relies on members and committees to carry out special projects
that are supported by external funding from federal agencies and
private foundations. The project leadership team has the
opportunity to work with the MAA in launching a national program that
can have great impact and serve our community and other stakeholders.
There are fundamental differences in leading an externally supported
project for the MAA and being the principal investigator on a project
residing at a university or college. The PI heading a project
whose funding goes to his/her own institutions may work in relative
isolation fulfilling both personal professional advancement and the
greater goals of the university in promoting research. On the
other hand a PI and co-PIs may be funded for a project that has
implications for the department or whole institution and may be working
with a committee and administrators to further departmental and
institutional goals.
External funding to the MAA supports projects for the benefit of MAA
members and the larger community of stakeholders. The PI is the
project leader but is leading an MAA program. Anyone heading an
MAA program or project, whether funded or not, works within the
governing structure of the MAA. The MAA is not simply a fiscal
agent for an individual, or even a group, effort.
Often the PI of an MAA externally funded project is an MAA member
rather than an MAA staff member. Thus, to ensure smooth operation and
financial and managerial accountability an MAA Director will be a
member of the project leadership team and one of the project?s co-PI?s.
This person will be referred to as the Staff Principal Investigator or
S-PI.
This manual provides information to people wishing to be the Principal
Investigator (PI) or co-Principal Investigator (co-PI) on a grant under
the auspices of the MAA. MAA uses the term PI for anyone, staff or
volunteer, in charge of a grant or a project managed operationally or
fiscally by the MAA. This use of the term PI is consistent with usage
in federal grants and contracts.
Grants and projects under the auspices of the MAA often are initiated
by an MAA committee and have a minimum of one volunteer willing to
organize and coordinate the writing of the grant proposal and the
management of the funded project. This person, the PI, identifies one
or more funding sources for the project with the help of the committee,
other MAA volunteers, and staff.
The MAA Executive Director selects the appropriate staff member to act
as S-PI, who lends support to the PI in the management of the entire
process from initial synopsis to final report. The status of the
proposal and grant are reported quarterly to the Executive Committee of
the MAA.
This Manual provides a description of the internal policies and
procedures necessary for the approval and implementation of a project.
It details the process and necessary interactions with the staff and
committees as well as the timing of these interactions.
These guidelines are not intended to supersede any applicable federal
policies or regulations. Such regulations may change over time and
always supersede this manual.
II Proposal Development and Approval Process
II.A Concept Development
A project, to be funded through the MAA, must pass through several
stages. The first is an appraisal to ensure that the aims and goals of
the project are consistent with the mission, goals, and priorities of
MAA. A prospective PI should first present a brief (1-2 page)
prospectus of his/her project to the appropriate MAA Director along
with a copy of the grant program solicitation. This prospectus should
include the background, rationale, a description of the proposed
project and its activities, and an appropriate budget. The budget
should include the MAA indirect cost rate, which is calculated annually
during the MAA audit review. Please contact the relevant Director for
help in writing this prospectus and to obtain the current indirect cost
rate. See the Financial Procedures Section of this manual for further
information.
If this is an individually initiated project, not one coming from a
committee, the Director will confer with the MAA Secretary to determine
the relevant council/committee to give first approval. The approval
process will vary depending upon the council/committee, its current
agenda, and the needs and deadlines of the proposed project.
Councils/EBUSPPRO/committee/committee-list.aspx can approve a prospectus by email or, if further
in-depth discussion is needed, at their semi-annual meetings.
After approval by the council/committee, the prospectus is submitted to
the Executive Director for distribution to the MAA Secretary, the
relevant Director for the project, and other appropriate personnel. The
Executive Director or designated S-PI will present it to Executive
Committee for review and approval. The Executive Committee can approve
the prospectus by email or, if a more in-depth discussion is necessary,
at a quarterly meeting. A decision may take several weeks depending
upon the amount of discussion the Executive Committee needs to make a
decision.
The prospectus should be submitted to the relevant Director as early as
possible in the grant proposal process to allow for meaningful feedback
and so that the Executive Committee can make a timely decision as to
whether the PI should continue to work on a full proposal. The optimum
lead-time is at least six weeks before the grant agency?s proposal
deadline. The S-PI will try very hard to expedite this process, but the
PI should be aware that without adequate lead time concerns regarding
the prospectus might delay the project until a later grant cycle.
The EC will consider the projects? fit with the mission, scope, and
strategic priorities of the MAA; the fit of the proposal with the
funding agency?s solicitation; and an assessment of the program within
the criteria for review of new and existing programs used to evaluate
all new MAA programs. Once the prospectus is approved by the Executive
Committee, the PI working with the S-PI prepares a full draft proposal
(see next section) in accordance with the granting source's
requirements and submits it to the Executive Director. Optimally, this
should be done at least 4 weeks prior to the funding source's deadline.
The SPI and/or the ED will work with the PI and the Executive Committee
to revise the proposal in time for the application deadline. If the PI
has worked closely with the SPI throughout the proposal development
process, this part of the process will go more smoothly and quickly.
A master file is created and maintained at the MAA headquarters. It
holds all original documents pertaining to the project. Anyone, PI or
MAA staff, who originates or receives any document or correspondence
concerning the grant should send the original to the staff facilitator
for distribution to the master file and all appropriate staff and
volunteers. Documents include the synopsis, original full proposal,
award letters, reports, requests for extensions and additional or
supplemental support, letters responding to these requests, and other
pertinent materials and correspondence. Once approved, receipts for
expenses are also forwarded.
II.B Proposal Development Process
A process to assist the MAA carry out appropriate proposal evaluation
is outlined in the Appendix, Criteria for Review of New and Existing
Programs. Some of the criteria most important for prospective PIs to
consider are offered below:
- Is the program in line with the organizational mission and its stated
priorities?
- Does the program enhance the public perception of the MAA or further
name recognition?
- Is the program meeting the needs of the mathematical community,
general public, or other constituencies that is not being met by others?
A proposal must be approved by the Executive Committee, and the budget
must be specifically approved by the Treasurer, before submission to a
funding agency.
The PI ascertains the granting source requirements and format for a
proposal. The PI should work with the S-PI during the grant proposal
development stage. This collaborative effort will speed the approval
process. The PI should submit the completed full proposal to the S-PI
according to the optimal schedule in the preceding section if at all
possible. A proposal submitted with less time before the deadline may
not be able to clear the final approval/editing process in time. The
PI, staff facilitator, and appropriate MAA staff and volunteers work
together to edit the proposal to assure that it is clear, consistent
with the MAA mission, and all budget items are in accordance with
agency and MAA regulations.
The S-PI distributes copies of a full draft proposal package to the
appropriate officers and staff. The Executive Director or staff
facilitator will make every effort to respond to the PI at least one
week before the funder's deadline. The PI will then have adequate time
to make revisions as required by the Executive Committee.
Items to be included in entire package depend on the specifications in
the program solicitation and usually include:
- Cover letter or sheet
- Abstract
- Narrative
- Budget and budget justification
- Vitae
- Completed subcontracts and accompanying documentation
- Letters of support and/or acceptance from:
o subcontracting organizations
o individuals
o other organizations
- Budget and budget justification including the results of any
competitive bidding process that is required by the funding agency (see
Appendices C and D: Purchasing of Goods and Services, and Sole Source
Justification).
Proposals to NSF must be submitted via FastLane and may also be
prepared in FastLane. PI's and co-PI's who are contributing to the
preparation of the proposal can get a FastLane password from the MAA by
contacting the S-PI or the Finance Department's Grants Accounting
Manager. All forms that must be submitted are found at the FastLane
site accessed via the Internet at www.nsf.gov.
If the proposal includes subcontracts, a letter of agreement from the
subcontracting organization or a full subcontract proposal should be
submitted with the full proposal and the subcontract budget should be a
part of the full budget. The process of getting a letter of agreement
should usually begin at least 4 weeks prior to the deadline. The MAA
Finance Department can create the subcontract, which must be approved
by the PI and Executive Director. Some funding agencies may require
that the subcontract be submitted at the same time as the proposal;
others permit the completion of the subcontract after the grant is
awarded. This depends on the program. If a full subcontract proposal is
to be submitted with the proposal, the timeline for development and
approval by MAA is the same as for the main proposal. NSF requires the
subcontractor to submit the subcontract as a part of the FastLane
submission of the grant proposal.
Reviews and revisions continue until all issues are resolved to the
satisfaction of the Executive Director, Executive Committee, and the
PI.
The PI completes the final documents including all forms and documents
required by the granting agency. Once finalized, the full proposal
package is given to the Executive Director a minimum of 3 days prior to
the deadline. The Executive Director signs the proposal for the
Association or writes a cover letter, and submits the proposal to the
granting source where appropriate. For NSF proposals, it is the PI who
initially enters the proposal into FastLane. At that time, the PI may
allow the Institutional Representative (the Executive Director) the
ability to edit the proposal. Doing so may save time if there are any
mistakes that the Executive Director can correct rather than go back to
the PI. The Executive Director will not make any significant changes to
the proposal or the budget without getting the agreement of the PI. NSF
notifies the Executive Director that the proposal has been submitted
and asks for the Executive Director?s approval. The Executive Director
reviews the proposal on FastLane and officially submits it to NSF for
the MAA.
If the funding agency, prior to awarding the grant, requires
modifications that result in changes to the project activities and/or
budget, the Executive Director and S-PI will work with the PI to
expedite approvals as needed.
The granting agency will determine whether it will award or decline the
funds or require modification to the proposal, and will send
notification by mail or email. Most often, this notification will be
sent to MAA staff; sometimes it is sent to the PI. Whoever receives it
must send the original to the Executive Director for distribution,
tracking, and reporting.
If the budgeted amount of any subcontract/contract for goods or
services is in excess of $25,000 per item and is not part of the
original submission to the federal agency, the PI must submit all
documentation related to the competitive bidding process (see
appendices: Purchasing of Goods and Services, and Sole Source
Justification).
II.C Budget Guidelines
The PI should consult with the relevant Director or S-PI in
construction of the budget. Budget items must conform to the
stipulations of the funding agency and MAA financial operations. All
budgetary items must be documentable expenditures. During the operation
of the grant supported activities, this documentation must be provided
on a timely and regular schedule to the MAA. These considerations may
affect budgetary items to be included in the budget. Fringe benefits
must conform to the employer's. Consultant fees must be explained in
detail, with a daily or hourly rate and the number of days or hours to
be supported. The rate cannot exceed the allowable rate specified by
the funding agency.
Anyone compensated by project funding who is not a staff member must be
paid either through their employer as part of their salary or as a
consultant on the project. In the first case, the compensation
must represent a portion of salary equivalent to the time devoted to
the project. In the second case, compensation must be supported
by a formula included in the proposed budget that shows days to be
devoted to the project and the daily rate of pay. Consultants
must report their days devoted to the project in order to receive
compensation in a timely manner; within a month is desirable, but no
later than 2 months. No reimbursements can be made after a grant has
been closed. For those grants developed with multi-year funding
for PI compensation, the budget may be developed with a reasonable
annual percentage increase. Any addition to compensation in time or
rate over and above the approved budget must be approved by the MAA
Treasurer.
II.D Timeline
DEADLINE
|
ACTION
|
| 10 weeks before deadline |
If proposer is
an individual (not an MAA committee or council) 2--3 page prospectus to
ED or S-PI if identified. ED sends to appropriate MAA Committee |
| 8 weeks before deadline |
2--3 page
prospectus from committee to ED or S-PI. Prospectus submitted to
EC. |
| 6 weeks before deadline |
Formal
approval or disapproval of the prospectus given by ED / S-PI to PI. |
| 4 weeks before deadline |
If prospectus
approved, PI submits first full draft proposal. If needed, begin
process of getting letters of agreement or subcontracts from
subcontractor(s). |
| 2 weeks before deadline |
Edited full draft proposal must be in to ED. |
| 3 days before deadline |
Final version
of full proposal submitted to ED or S-PI. For NSF proposals, the
PI must submit the proposal via FastLane. |
| By deadline |
ED approves
proposal to NSF via FastLane or submits proposal to the funding agency
if it is not NSF. |
III Project Management
III.A Funded Project
Management
Once funded, the project is managed using the following procedures:
1. The Executive Director sends a copy of the award letter to the S-PI,
PI, and the MAA Finance Department.
2. The project is assigned a grant identification number by the Finance
Department.
3. The S-PI and Finance Department sends the PI information and forms
to be used in requesting payment of project expenses. The procedures,
forms, etc. of the Finance Department will have a more detailed
explanation in Section B.
4. The PI begins implementation of the project and, in a timely
fashion, submits all reports as required by the grantor and MAA.
Reports to agencies other than NSF must be given to the Executive
Director for submission and distribution. Reports to NSF are submitted
into FastLane directly by the PI. The PI should print a copy of the
report and send these to the S-PI.
5. The Finance Department, in coordination with the S-PI, reviews
project budgets and expenditures on a monthly basis; in addition, the
reviewed data are sent to external PIs on a quarterly basis.
6. The Treasurer approves all budgets. Any significant changes in
budget distribution or request for supplementary funding for additional
activities must be approved by the Treasurer before submission to the
funding agency.
7. The S-PI will be responsible for and manage all staff support of the
project. He/she oversees the portion of the budget that goes
directly to the MAA. All staff compensation is calculated on
actual hours worked and individual salary rates. Staff time
devoted to a project is reported on weekly time sheets. The S-PI
and Finance Department work together to ensure smooth project
management.
8. The S-PI is a co-PI on the project and represents the Executive
Committee and Board in project oversight. If the volunteer
leaders of the project are no longer active in management, the S-PI
will be able to process unresolved financial obligations, write
required reports, and close out the project.
9. Disputes among project PIs or with the MAA staff should be reported
to the MAA Executive Director or any officer.
III.B Grant Modifications
Any significant changes in activities or scope during the
implementation stage must be approved by the Executive Committee. Any
requests for budget revisions, additional or supplemental support, or
no-cost extensions must be approved by the Treasurer subsequent to the
following:
1. PI ascertains the granting source requirements and format for a
request, writes the request, and submits it to the S-PI for
distribution to the Executive Director and other appropriate staff and
volunteers for review and approval. The Executive Director will
determine if the request should be reviewed by officers. Requests
should be made at least 60 days prior to the granting source's deadline
and can be made in the following areas depending upon the granting
source:
a. Extensions: the PI can request an extension (either funded or
unfunded) of the annual or final deadline if the work is not completed.
It should be noted whether the request is for an extension of payments
or just more time to complete the project activities. Note: the NSF
deadline for requests for all extensions, including automatic
extensions, is 45 days before the termination date.
b. More financial support: the PI can request further financial support
from the granting agency to continue or extend the activities of the
project.
c. Budget revisions: the PI can request major revisions in budget line
items based upon changes made in the activities needed to complete the
project.
2. Once the request is approved by the Executive Committee, the PI
completes the final forms and sends them to the Executive Director for
submission and distribution.
3. The granting agency will either award or decline the requested
modification and should send notification by mail or email. Most often,
it will be sent to MAA staff; sometimes it is sent to the PI. Whoever
receives it sends the original to the Executive Director for
distribution, tracking, and reporting.
IV Grants Financial
Management
IV.A Budgets
Financial expenses originate in three areas: 1) core program expenses
2) internal MAA administration costs and 3) sub-contracts. The PI has
primary oversight of the first area; the MAA has primary oversight of
the last two areas.
The PI of any externally funded project is welcome to contact the S-PI,
the Executive Director, or the MAA Grants Accounting Manager (GAM) for
financial assistance or advice. As soon as notification is received
from the funding agency that the grant has been awarded and the final
budget approved, the MAA Finance Office will assign a grant number to
the project and send the PI appropriate forms, including the Grant
Expense Reporting Form and Grant Personnel Activity Form with Time and
Attendance (see appendix B).
The PI is responsible for and has control over expenditures in each
line item in category (1), core program expenses, and is generally more
familiar with where certain expenditures fit into the grant budget. The
PI will review and approve all grant expenditures in category (1).
However, for many externally-funded projects, there are classes of
expenses which are a routine part of the project (e.g. travel expenses
for a group of workshop or conference participants, all subject to the
same guidelines) that may be pre-approved by the PI through a standing
agreement with the S-PI. Once a PI-approved request for an expenditure
or reimbursement under the grant arrives at the MAA offices, staff
under the direction of the S-PI will add internal MAA accounting codes
to the documentation and forward to the GAM.
Although the PI is responsible for assigning expenses to appropriate
grant budget categories, the GAM will review all expenses submitted
against the grant budget. The GAM ensures:
1) a) The expense is allowable per the funding agency, b) the expense
has been coded to the appropriate budget line item per the approved
budget, and c) the appropriate budget line item has a sufficient
balance to cover the expense.
2) If there are any questions or problems with the expenditures
submitted, the GAM will contact the PI to resolve the matter.
3) If the PI finds more funds have been spent than anticipated in the
budgeted amount for a specific task, the PI may request that funds be
transferred from
another line item provided the proper approval has been obtained from
the
funding agency if prior approval is necessary. Budget transfer requests
should
be made to the S-PI and GAM. The GAM, in coordination with the S-PI,
will amend and update the budget with the approved transfers
prior to the distribution of the next quarterly report.
4) Budget changes/readjustments:
a. The PI may request
the MAA GAM (Grants Accounting Manager) to readjust budget lines within
federal guidelines.
b. To adjust budget line items that require federal
approval, the PI must work with the S-PI to seek that approval prior to
any expenditure being incurred that would exceed the current budget
levels. Any departure from this procedure must be rectified
within 30 days of the submission of the expenditure to the GAM by
request of the GAM.
c. Adjustments to the budget as a result of 4.a or
4.b. will be reflected in the next quarterly report.
d. In the event that an expenditure would exceed
current budget levels and federal approval is not granted for an
adjustment, the MAA will not charge that portion of the expenditure
that exceeds the approved amount to the grant.
IV.B Reimbursement of Expenditures
MAA disburses all grant funds on a reimbursement, direct billing, or
direct payment basis. This means that an expense has to have been
incurred before reimbursement can be requested. Policies for processing
payments of authorized expenses will be developed by the PI, S-PI, and
GAM; all requests for reimbursement must be approved by the PI or S-PI,
according to the expense category as described in section IV.A. and the
agreed-upon payment-processing policy.
Reimbursement to institutions, businesses or other vendors that provide
services under a project may be made upon submission of an itemized
institutional invoice.
All requests for reimbursement or payment of expenses to an individual
are to be submitted on an MAA Grant Expense Reporting Form. This form
has prelisted some of the most often used budget expense items and
account codes. The Form should be filled out completely, signed by the
requestor, and then sent to the S-PI. Proper documentation (original
receipts, invoices, etc.) is needed for all expenses of $25 or more and
must accompany the MAA Grant Expense Reporting Form. Original
receipts/invoices are mandatory when the reimbursement request is for
the total amount of an expense. Copies are only acceptable when the MAA
is reimbursing or paying only a portion of an expense. The Grant
Personnel Activity Form With Time and Attendance must be filled out
completely, signed by the requestor and the PI, then sent to the S-PI
to authorize direct payment to any personnel whether salary, stipend,
subcontract, or honorarium.
For travel, actual expenses are reimbursed but per diem may be used if
budgeted and approved as such by the funding agency. Airplane flights
should always be booked at coach rate and reimbursement requests should
include the passenger receipt ticket showing the airfare, flight class,
and airline carrier. The current government mileage reimbursement is
the current federal rate. Mileage will be paid up to the cost of a
coach class airfare to and from the same destination except under
unusual circumstances with must be pre-approved by the S-PI. Please
note that it is important to have all documentation intact so that
reimbursements are not delayed. Any international travel must be
approved in advance by MAA and (if required) by the funding agency.
IV.C Reimbursements for Salaries / Personnel
Expenses
Anyone compensated by project funding who is not a staff member must be
paid either through their employer as part of their salary or as a
consultant on the project. In the first case, the employer will
bill the MAA for reimbursement. In the second case, compensation
must adhere to the formula included in the project budget, and use the
contracted rate of pay. Consultants must report days worked on
the project in timely manner; within a month is desirable, but no later
than two. No reimbursements can be made after a grant has been closed.
Any addition to compensation in time or rate over and above the
approved budget must be approved by the MAA Treasurer.
The PI is responsible for verifying that each person compensated under
the grant did in fact attend the meeting or did perform the agreed-upon
service. Government auditors expect to have contracts or letters of
agreement for every honorarium/stipend that is paid, even if only for
one day. When payment is requested, all available letters of invitation
or announcements of meetings should be attached to demonstrate that the
honorarium/stipend to each person was agreed upon as part of attending
a meeting or other function, and that it is part of the grant budget.
IV.D MAA Financial Reports
After the Finance Office has received and processed all financial data
to close a quarter, each PI will receive an MAA financial report that
shows the budgeted amount for each budget line item and the actual
expenditures year to date. The PI will also receive a copy of the
general ledger detail that reports all the transactions by budget line
item.
By using these reports, the PI can track the grant budget to see if it
is on schedule and to check that the details in the MAA's records are
correct. If any errors are found the PI should notify the S-PI and GAM
immediately so that they can be corrected.
IV.E Subcontracts
Grant proposals that include subcontracts should have letters of
agreement or contracts with the subcontracting agency. The person who
will direct that subcontract should submit to the S-PI and the PI a
statement of the work to be performed and a budget with a budget
explanation. The MAA staff will then prepare the subcontract agreement
and forward the copies to be signed to the appropriate official of the
subcontracting agency. For some agencies, such as NSF, the subcontract
must be prepared by and submitted by the subcontractor along with the
grant proposal. The subcontract must be reviewed and approved by the
MAA along with the proposal.
The subcontract agent will be reimbursed for expenses upon submission
of appropriate documentation, invoices and/or receipts. Reimbursement
requests for work under a subcontract should be sent directly to the
S-PI. Subcontract agencies must comply with the same grant general
terms and conditions as the MAA.
The MAA must perform periodic monitoring of all subcontractors and
grant sub-recipients. Monitoring procedures appropriate to each project
will be included in the subcontract agreement or memorandum of
understanding, depending on the nature of the project.
IV.F Miscellaneous Items
Occasionally a grant may call for special arrangements such as travel
advances, direct billing, etc. Each of these will be handled on a case
by case basis. Please contact the S-PI directly to discuss these items.
Appendices
Appendix A: Criteria for Review of New and Existing
Programs
As decisions for funding new initiatives and general allocation of
resources are made, MAA uses criteria against which all programs are
measured. There are often competing goals between the need to
operate a profitable program and the need to bring to the community
valuable programs that do not have profit potential or may be a
financial liability. Analyzing programs against a pre-determined
set of financial and non-financial criteria assists the MAA in ensuring
its valuable resources go to those programs that can benefit the MAA
and its mission the most. This is not an attempt to be specific about
fund-raising methodologies or objectives. Rather, it offers a
structure to assist in ensuring that the most worthy programs rise to
the top after applying criteria that allow for objective analysis.
Many criteria are considered as the basis for analyzing the financial
and programmatic strength of any new or existing initiative. The
MAA includes the following in its decision process for the development
of new programs and the continuation of existing programs.
- Is the program in line with the organizational mission and its stated
priorities?
- Does the program enhance the public perception of the MAA or further
name recognition?
- Does the program meet the needs of the mathematical community,
general public, or other constituencies that is not being met by others?
- Does the program require additional infrastructure which may not have
residual use?
- Is the program being considered for its fund-raising
capabilities? If so, how much net income can it generate over the
long-term, is matching or in-kind funding required, does the program
take advantage of excess capacity which offers a cost-saving advantage?
- Does this program leverage funding for other programs, is this a new
type of program which will increase the diversity of funding, can
indirect rates be charged against the program?
- Is the program sustainable after initial funding?
- Is this program unique (does it enhance the MAA mission and
recognition)? Is there a significant impact on the community, on
revenue?
Appendix B: Reimbursement Forms
MAA Grant Expense Reimbursement Form
MAA Grant Personnel Activity FormAppendix C: Purchasing of Goods and
Services in Excess of $25,000 for Federal Grants
Policies
1. All item purchases or subcontracts which are not
included in the grant proposal, and are in excess of $25,000, must be
competitively bid. See attached Sole Source Justification Request
for those items for which it is impossible or impractical for
competitive bidding. Cost analysis will be performed on each
submission to determine reasonableness, allocability and allowability.
2. The competitive bidding process must be completed
in advance of any such expenditure being incurred.
3. The results of the competitive bidding process
including any RFP’s or other supporting documentation are to be
submitted to the MAA and made available to the federal funding agency
as requested.
4. Any procurement of goods and services subject to
bid may not be awarded to any person(s) who participated in drafting
the specifications and/or RFP for those goods or services.
Procedures
• Sufficient documentation must be submitted by the
PI to enable the MAA to ensure that all federal procurement policies
are met including:
- The most economical and practical goods and/or
services are being solicited;
- The goods and/or services being solicited are
necessary for the successful completion of the program;
- A clear and accurate description of the technical
requirements for the goods and/or services is being provided.
• Every effort should be made to get the lowest cost
for all purchases without sacrificing utility. The procuring
agent should keep in mind that the MAA is exempt from DC sales tax for
purchases which would normally be subject to sales tax
• The Treasurer and Executive Director may approve a
sole source justification for goods and services as a substitute for
competitive bidding, where competitive bidding is impractical or
impossible (see Sole Source Justification).
• Budgeted items falling within the scope of this
policy, and for which a sole source justification is not being sought,
must be accompanied by three written quotes obtained from
businesses/persons who normally provide such goods or services.
• If the quotes were solicited based on an RFP, that
document should also be submitted.
• The competitive pricing process is initiated by the
PI in conjunction with the S-PI. The PI may also submit an
accompanying memo addressing the programmatic and financial strengths
and weaknesses of the respondents, and his/her resulting
preferences. Once the request is reviewed, decided and approved
by the Treasurer and Executive Director or their designees, all related
documentation becomes a permanent part of the grant record and will
become part of the budget submittal to the funding agency as
appropriate.
• Transactions between the MAA and outside
contractors should be arms length transactions with no favoritism
towards parties having any financial interest in the transaction.
Any actual or perceived relationship between any of the parties
involved must be disclosed.
• Contracts in excess of $25,000 awarded as a result
of the procurement process must contain language which allow for
remedies, including termination, in instances where thee contractor
violates or breaches the contract terms.
Appendix D: Sole Source Justification
Request for Federal Grants for Purchases Over $25,000
To: MAA Treasurer and Executive Director
From: ___________________, authorized individuals
are the PI and S-PI
Date: ___________________, must be submitted prior
to any related expense being incurred
Re: Sole Source Justification on Contract for
____________________
This executed document becomes a permanent part of the grant record and
will be forwarded to the granting agency if so warranted.
This memo is to support the request for a sole source contract for the
purpose of ________________. This request for a sole source
justification is in accordance with the purchasing policies and
procedures of MAA. The exercise of this option is fully within
the purview of the Treasurer and Executive Director and is only to be
used when other options are impractical or impossible.
A sole source justification cannot be used to supersede federal
regulations that govern programs that are funded exclusively through
government funding. The applicable regulations concerning the
expenditures in those programs will govern in the event of a
discrepancy existing between the policies of the MAA and those of the
granting agency.
The justification of this work being contracted using sole source,
non-competitive bidding is as follows:
The person completing the sole source justification should list the
reasons for undertaking a sole source contract including any of those
listed below, or any other reasons that may pertain to this
instance. Be as specific as possible regarding the situation at
hand, using as many reasons as are applicable.
Examples of justifications for pursuing a sole source contract:
• The work to be undertaken is a continuation of work
begun previously, which was competitively bid;
• The contractor being called upon to perform the
work has expertise that cannot be substituted or easily replaced in the
market place;
• The contractor being called upon to perform the
work has familiarity with the work of the MAA to the extent that
purchasing these services from any other contractor would not be cost
effective;
• The contractor being called upon to perform the
work is offering their services at a price substantially below what
which would be expected on the market;
Signed: ________________________________________
Date:____________________
Treasurer
Signed: ________________________________________
Date:____________________
Executive Director