False. The fact that an expenditure is both necessary and not explicitly prohibited by law and program regulations is only part of the criteria that must be met for it to be considered an allowable CDBG expense. In addition, the expenditure must: • Have been authorized by the grantee (through an approved budget or other mechanism). • Be reasonable. • Have been treated by the subrecipient in a manner consistent with its normal procedures for computing costs. • Be allocable to an approved-CDBG cost objective. • Be net of all applicable credits.
False. If the “False” box is checked, each person participating in the entity will be required to fill out a Subscription Agreement.
False. A subrecipient must do a cost or price analysis and maintain documentation of the procurement process for every procurement. However, the level of complexity of the analysis and detail of the documentation should vary by the size of the procurement and the extent of competitiveness in the process. Therefore, the purchase of desktop stationary supplies will require that the subrecipient maintain a very modest level of documentation of how comparative prices were analyzed (through catalogs and/or price quotes). A sole source procurement, on the other hand, will require much more extensive documentation to justify the noncompetitive process and to demonstrate that the price incurred was fair.
False. The purpose of accounting records is to provide information not only on cash but also on all the assets and liabilities of an organization, including property, receivables, payables, and other obligations.
False. The standard for “small purchases” is that the procurement is for services, supplies, or property does not exceed $100,000 in the aggregate. Therefore, for example, it is not allowable to break up arbitrarily a $150,000 procurement of weatherization materials into three $50,000 purchases just to be able to use the less complicated “small purchase” procedures. The purchase of such materials should be handled through a sealed bid method of procurement, with the larger purchase volume entailed in this approach likely to result in lower per unit prices.
False. The pertinent regulations for non-profit subrecipients (24 CFR 570.502(a)(8) and (b)(3)(vi)) require that, regardless of dollar value, equipment acquired with CDBG funds and no longer needed by the subrecipient for CDBG activities must be transferred to the grantee or retained by the subrecipient only after compensating the grantee.
False. One of the primary purposes of a subrecipient’s cash management system is to minimize the time between receipt of CDBG funds and their disbursement; therefore, if the subrecipient’s system is working efficiently, there shouldn’t be any interest income generated on cash advances. In fact, 24 CFR 570.500(a)(2) makes explicit that the definition of program income does not include interest earned on the investment of the initial proceeds of a grant advance, including funds advanced from a grantee to a subrecipient, and any such funds must be promptly remitted to the U.S. Treasury. Moreover, 570.500(b) makes it clear that cash balances held in a revolving fund must be held in an interest-bearing account and that any interest earned on funds held in such an account will be considered to be interest income generated on a cash advance and must be remitted to the Treasury at least annually.
False. Both sets of requirements must be satisfied. Therefore, the competitive procurement procedures adopted by the subrecipient also must be designed to facilitate and encourage local businesses to compete for the proposed work.
False. 15. A patient or individual can report a suspected privacy or security breach to the following entities: