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    Federal Cash and Financial Management 

    File: 6101

    The district’s financial management system and records will be sufficient for preparing required reports and for tracing expenditures to a level that establishes funds have been used according to federal statutes, regulations, and the terms and conditions of the federal award. This is in addition to maintaining a system of funds and accounts in accordance with the state law and the accounting manual.

    The district’s financial management system will:

    • Identify all federal awards received and expended, including specific information pertaining to the award: federal program name; CFDA title and number; identification number and year; and name of federal and any pass-through agency.
    • Provide for accurate, current, and complete disclosure of the results of each federal award in accordance with reporting requirements.
    • Include records and supporting documentation that identify the source and application of funds for federally funded activities, including authorizations, obligations, unobligated balances, expenditures, assets, income and interest.
    • Enable the district to maintain effective internal controls to ensure accountability and proper safeguarding and use of all funds, property and other assets (for example, adequate segregation of duties).
    • Provide a comparison of expenditures with budget amounts for each federal award.

    In order for the district to comply with federal regulations for grant recipients, the superintendent will implement written procedures for 1) cash management; and 2) determining the allowability of costs in accordance with federal award terms and conditions.

    Bonded Employees and Officers
    Each officer, official, and employee of the district who is assigned the responsibility of receiving and dispensing school funds shall be bonded for not less than $5,000 under a blanket fidelity bond. The cost of the bond shall be paid by the district.

    Conflict of Interest
    No employee, officer, or agent may participate in the selection, award, or administration of a contract supported by Federal funds if he or she has a real or apparent conflict of interest. Such a conflict of interest would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract.

    No employee, officer, or agent of the district may solicit or accept gratuities, favors, or anything of monetary value from federal contractors or parties to subcontracts. Unsolicitied items of nominal value are excluded.

    Procurement
    When federal funds are used for procurement of goods (furniture, supplies, equipment, and textbooks):

    • Purchases of $10,000 or less do not require quotes. However, the district must consider price to be reasonable and, to the extent practical, distribute purchases equitably among suppliers.
    • Purchases between $10,000 and $75,000 must be procured using price or rate quotations from three or more qualified sources.
    • Purchases of $75,000 or more must be publicly solicited using sealed bids.

    When federal funds are used for procurement of services:

    • Purchases of $10,000 or less do not require quotes. However, the district must consider price to be reasonable and, to the extent practical, distribute purchases equitably among suppliers.
    • Purchases between $10,000 and $250,000 must be procured using price or rate quotations from a reasonable number of qualified sources.
    • Purchases of $250,000 or more must be publicly solicited using sealed bids.

    Procurement by noncompetitive proposals may only be used when one of the following applies:

    • The item is only available from a single source;
    • The public emergency for the requirement will not permit a delay resulting from competitive solicitation;
    • The awarding agency (e.g., OSPI) authorizes a noncompetitive proposal in response to a written request from the district; or
    • After solicitation of a number of sources, competition is determined inadequate.

    The district must maintain documentation supporting the applicable circumstance for noncompetitive proposals.

    Suspension and Debarment
    Before entering into federally funded vendor contracts for goods and services that equal or exceed $25,000 and any subcontract award, the district will ensure the vendor is not suspended or debarred from participating in federal assistance programs.

    Adopted:
    09/01/19

    LEGAL REFS.:
    RCW 28A.59.080
    RCW 28A.59.180
    Code of Federal Regulations (CFR), Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Sections 200.302 and 200.305, and Procurement 200.317.326 
    Cash Management Improvement Act of 1990

    Instruction (2000)

    Students (3000)

    Community Relations (4000)

    Personnel (5000)

    Management (6000)