Draw Schedule. An Authorized Officer of the Subrecipient may submit a proposed draw schedule to OBO. Subrecipients should work to minimize the time between the transfer of funds and the expenditure of such funds. o Timing of draw schedule: ▪ Subrecipients should ensure the draw schedule is limited to the minimum amount needed for the time frame requested. The draw schedule must align as closely as possible with the actual expenditure of funds. ▪ Except in emergency cases, no more than one draw per month will be allowed. ▪ Subrecipients may not draw funds on the end date of a U.S. Treasury reporting period. ▪ If a Subrecipient determines that circumstances necessitate a change to the draw schedule, an Authorized Officer of the Subrecipient shall notify OBO in writing of such circumstances and provide a new draw schedule and supporting documentation for review and approval by OBO. • OBO will review proposed draw schedule for compliance with state and federal laws, rules, and policy. If approved, OBO will transfer advance payments based on the draw schedule, pending review and approval of documentation discussed below for each individual draw. • For milestone payments, Low risk subrecipients will attach their certification from the independent third-party engineer along with a request for the specified percentage of funds requested. • Prior to approval of an individual draw, a Subrecipient is to submit to OBO a budget of forecast expenditures and any available detailed documentation for proposed expenditures, including copies of quotes or estimates for service providers, unpaid itemized invoices for proposed purchases, Purchase Orders, executed contracts or subaward agreements, or similar documents indicating upcoming receipt of items or services. For salaries, OBO will consider an Offer Letter as documentation, multiplying the salary by a standard benefit percentage unless the subrecipient is able to provide more detailed information. Subrecipients will also submit proof of competitive bidding and document consideration of small, minority-, women- and US-owned companies, where required. • An advance payment will not be disbursed unless the entire amount proposed is documented as described above. • If proposed expenditures changed after the transfer of advance funds, the Subrecipient must highlight those changes and document in the Subrecipient’s next financial report. • For milestone payments, the certifications from the independent third-party engineers will be all that is required along with the draw request in order to request funds. • Subrecipient will be required to submit Invoices, Purchase Orders, Payroll reports from the payroll system of record, and Bills of Lading to OBO on a quarterly basis for monitoring and eligibility review. If OBO finds that purchases made with advanced payments were non- compliant with the Grant Agreement, a dispute process may be initiated, and OBO may take action including withholding or delaying future payments of funds, recission of the Grant Agreement, modification of funding disbursement methodology, reduction of grant award, and payback of funds to OBO. • The Controlled Advance Grant disbursement is contingent on the continued compliance of the Subrecipient with all its financial and programmatic compliance and reporting duties. Failures or deficiencies in these activities can result in several punitive measures in response, including withholding funds, requiring more frequent reporting, terminating further funding and requesting the return of moneys transferred back to OBO. • If the Subrecipient submits request for Controlled Advance Grant disbursement, and OBO has insufficient funds remaining from the project appropriation, the Subrecipient will obtain or make available and apply other funds necessary to ensure the completion of the project and payment to vendors or subgrantees. Subrecipients may elect to receive funding on a reimbursement basis at their own request. Additionally, subrecipients who, based on a risk assessment, do not maintain written procedures for minimizing time lapse between transfer of funds and distribution and do not have a financial management system that meets standards for fund control and accountability, will be paid on a reimbursement basis. If a Subrecipient does not have the operating capital to operate on a reimbursement basis, the Subrecipient may request a cash advance in accordance with the Working Capital Policy.
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Sources: Grant Agreement, Grant Agreement