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City of Brockton Grant Policy and Procedure Manual

Background

The City of Brockton recognizes that grants are essential to the City’s operations by bridging gaps in funding needs, offering opportunities for growth, and promoting social and economic wellbeing to build a better future. The Finance Department outlines the following grants policy and requires full compliance from each department unless specifically exempted. Department Heads, as well as Committees, Commissions, and Boards are expected to review this manual to ensure responsible and effective grants management.

This manual contains the internal controls and grant management standards used by the City to ensure that grant funds are lawfully expended. These standards include the uniform administrative requirements, cost principles, and audit requirements for federal awards articulated by 2 C.F.R. §200. As of the current date, the City of Brockton adheres to the most recent Massachusetts grant financial policies and standards, and federal policies, standards, and regulations.

Roles and Responsibilities

Grant Writers

Grant Writing
  • Assists City grant applicants with the application process and proposed grant budget.
  • Organizes and presents prospective opportunities at monthly Grants Committee meetings.
  • Assists with grant reporting when requested.
  • Communicates with federal, state, and private agencies on behalf of the City as appropriate.
  • Works in collaboration with city officials, including the school department and the auditing department.
Grant Management
  • Creates and maintains a list of awarded grants, grant managers, awarded amounts, drawdown information, and current total expenditures for reporting purposes.
  • Completes and submits required documents for grants and earmarks.
  • Exercises financial oversight and administration of funding in conjunction with the Finance Office team.

Department Heads, Committee Chairs, Commissioners, and other grant applicants

  • Attends monthly grant meetings.
  • Notifies Human Resources, Payroll, Auditing, and Finance of grant-funded salaries.
  • Manages the grant budget:
    • Runs flex reports and account inquiries in MUNIS to track expenditures, salaries, stipends, purchase orders, and amendments.
    • Ensures grant spending is allowable and within budget
    • Coordinates deadlines and grant reporting requirements with the grant writers.
    • Prepares for the closing of the grant and final report. Collaborates with the grant writers and Auditing Office to ensure grant closeout is successful.
  • Attends City Council and Finance Committee meetings to accept grants when appropriate.

Budget Director

  • Supervises and directs Grant Writers with the exception of the Brockton Police Department’s Grant Writer. However, the Brockton Police Department’s Grant Writer shall collaborate with the Budget Director as needed.
  • Provides oversight and accounting of city-wide grants in coordination with other departments.
  • Ensures correct salaries are paid out of a grant when applicable.

Assistant City Auditor

  • Manages the creation of funds in MUNIS.
  • Reviews and manages the processing of journal entries.
  • Oversees the management of the accounting for all grant activity on Munis

Compliance, Quality, and Technical Control Administrator

  • Serves as a contact for department heads/grant applicants/facilitators to track grant spending.
  • Responsible for the accounting entries for all grant activity in the City.
  • Ensures reimbursement was filed and received when applicable, assists departments in ensuring draw down deadlines are met for reimbursement grants for the sake of accounting entries made prior to Sept. 30th and the balance sheet for DOR.
  • Runs balance sheet reports for all special revenue accounts on a monthly basis.
  • Works with department heads to ensure grant spending is allowable and within budget.

Applying for and identifying grants

When prospecting grant opportunities, departments should ensure the opportunity is in alignment with the City’s strategic goals and the given department’s mission. Considering grants that align with the vision of the department/commission/board/council is necessary to set the City as a whole up for successful future grant funding and fiscal health.

All departments seeking grants, with the exception of the Brockton Police Department, shall provide advance notice to the Finance Department regarding each grant opportunity. Notice can be provided via email or phone, or it can be presented at monthly grant committee meetings. Notice should be addressed to the grant writers. A department’s interest in a federal grant opportunity should be conveyed to the grants team at least two months in advance of the grant deadline. Interest in a state or private grant opportunity should be expressed at least one month in advance of the grant deadline. There are few exceptions. The Brockton Police Department and the Brockton Fire Department may use different timelines due to their independent application and management of the grant process. These minimums guarantee that the grants team, in collaboration with the grant-seeking department, has sufficient time to put together an application that will have a significant chance of success once it is sent to the grantor agency. Notice should address any significant requirements of a grant opportunity, such as match or cost-share requirements, restrictions on indirect costs, requirements to maintain a program beyond the grant closeout, and other notable demands of the notice of funding opportunity.

All departments with active grants are required to attend the monthly grants meetings organized by the City’s grant writers. As of the date this policy is effective, Grants Committee meetings are held every four weeks, typically the first Monday of every month, from 3pm to 3:30pm in the GAR Room at City Hall. If unable to attend the Mayor’s Grants Committee meetings, any department with active grants must meet at least once per month with the grant writers and auditing department. If preferred, meeting one-to-one is an available option. Attendance records will be kept. These monthly meetings ensure that grant funds are not spent into a deficit and that all requirements of the grant are being met, so as to not jeopardize future critical funding. The monthly meetings also prevent efforts on grant applications from being duplicated and minimize the likelihood that grant opportunities are pursued so close to the deadline. Additionally, departments will be required to meet with the auditing department more frequently toward the end of the fiscal year due to reimbursement concerns and other pressing deadlines.

If the proposed grant project creates an ongoing commitment, it is critical that the responsible department has notified other departments, appointing authorities, and officials before the grant 3 application is submitted, with the exception of the Police and Fire Departments. Examples of ongoing commitments include but are not limited to: annual maintenance of capital assets, the establishment of a new service that needs to be maintained beyond the grant period, or creating new jobs to be funded out of a grant.

If a match is required to submit a grant, please discuss this with the Finance Department prior to submitting the application.

To assist city departments in evaluating grant needs, important considerations for boards, commissions, committees, departments, and officials to make when evaluating a grant opportunity have been outlined below:

  1. Whether the grant is relevant to the mission and needs of the City and the particular board/commission/committee/department/official
  2. Whether the grant has restrictions
  3. Whether the grant may contribute to financial burden on the City and, if so, what is the source of funding for it
  4. Whether the long-term financial impacts of the grant have been accounted for, particularly where there could be significant operations, maintenance, or capital costs associated with the grant
  5. Whether there may be non-financial impacts of the grant such as but not limited to environmental, traffic-related, or land use-related impacts

Administrative costs

All grant applicants within the City must include administrative costs into their grant request when applicable. This policy mandates that grant applicants must utilize a 10% de minimis rate for administrative costs in all grant application budgets. There are exceptions, as indirect cost rate percentages and restrictions vary across federal, state, and private agencies, and when administrative costs do not materially impact the implementation and success of the grant funded program. Administrative costs are not related to the direct provision of program activities. Administrative costs are usually for general operating expenses incurred by the organization. As of April 2, 2025, any applications submitted without an effort to include administrative costs or coordinate not including administrative costs beforehand, will be subject to additional review by the Finance Department and may be required to amend their grant budget. Including administrative costs in grant applications is critical to the future of the City. Indirect costs allow departments the benefit of pursuing more projects they would like to in the future by contributing to the City’s fiscal stability. Every effort to include indirect costs must be made when applicable. The grants team and other Finance Department staff are available to help with administrative costs and any other grants related issues.

Grant acceptance

As of April 2, 2025, the City’s Grant Intake Form must be completed prior to a grant award going before the City Council for approval.

Under Chapter 44 Section 53A of Massachusetts General Law, all grants and donations received by a municipality must be approved by a governing body. Furthermore, a fund account cannot be created without authorization from a government body. Therefore, all grants awarded must go before City Council prior to the creation of a fund account in Munis.

Upon notification of a grant award, no recipient within the City of Brockton shall expend grant funds until a fully executed agreement has been accepted and approved for expenditure by the City Council. Additionally, no grant funds shall be used to supplant an existing expense for the purpose of diverting current funds to another use. The recipient department/committee/board/commission is ultimately responsible for ensuring their expenditures are aligned with the City’s internal tracking via Munis as well as the funding agency’s requirements. The grants team and Auditing Department are available to assist.

Reporting

Reporting and grant management must be coordinated with the Finance Department upon receiving an award. Information regarding reporting should be submitted via the Grant Intake Form to communicate reporting requirements. Departments are welcome and encouraged to do their own grant reporting upon receiving an award, but the grants team out of the Finance Department is willing and able to provide support or take the lead on reporting when appropriate.

Grant set-up

The following is a checklist of what the Auditing Department needs to set up new grants. These documents should be submitted through the Grant Intake Form:

  • Contract form copy signed by mayor with contract routing form
  • Grant agreement (preferred) and/or award letter
    • If no grant agreement is available, then an award letter suffices.
  • Council order
  • Breakdown of budget (if it is not included in grant agreement)

Recurring or existing grants require the same documentation detailed above, in addition to an updated contract or other relevant documentation. Auditing and/or Finance will reach out to the recipient department if more information is needed.

Grant management and accounting

Communications from the funding agency during and after the grant period must be responded to in a timely manner. The Finance Department, particularly the grant writers, must be informed of such communications and any emerging requirements from the funding agency. For example, if a letter is sent by a federal agency regarding an informal audit of past drawdowns from previous fiscal years, the recipient must inform the Finance Department and/or the Auditing Department within 5 business days. If not communicated in a timely manner, this may result in corrective action from the Auditing Department.

External consultants may play a role in grants management, but Munis is the most accurate and up to date resource for grant-managing staff to see what has actually been spent out of a grant account. External consultants may assist departments with grant management, but the work of the consultants MUST be mirrored on Munis. Receiving departments have the responsibility of auditing their work on Munis (i.e. making sure their expenditures and revenue make sense of them based on the work they have done). Grant managing departments are strongly encouraged to use Munis when tracking grant expenditures. The Compliance & Quality Technical Control Administrator is available to provide assistance in grant management. Furthermore, each grant-managing staff member is strongly encouraged to independently track the expenses in each grant account and periodically audit the balances to ensure they match.

If a grant application is denied and a debrief call is available, the applying department is strongly encouraged to attend the debrief call.

Note the date any grant reports, reimbursement requests, or other requirements are due, so the grant award, and the City as an applicant entity, remains in good standing. If your grant is reimbursable, please request reimbursements in a timely manner. Requesting reimbursements on a monthly basis is preferred if allowable to maintain positive cash flow.

Timely reporting on the City’s part is necessary to be able to reapply for future funding. It is critical to submit reports in advance of the deadline so that future grant opportunities are not jeopardized. Your grant contact is a resource to ask questions about the particular grant opportunity; typically, you can find their information on your grant agreement or award letter.

Grant closeout

Grants are to be closed out in accordance with the contractual period stated in the grant documents. If an extension beyond the initially proposed grant closeout date is needed, an extension request must be planned for and filed far in advance of the initial closeout date.

The Auditing Office will close out grant funds in accordance with the closeout period, unless the responsible department has secured an extension and approval has been documented and submitted to the Assistant City Auditor. The responsible department will provide the Auditing Office with timely notification of the grant closeout and if there are any unanticipated issues.

2 CFR 200 mandates that grant records are kept for three years following the grant closeout. The Secretary of the Commonwealth of Massachusetts mandates the three-year period as well for record retention. Not only must the City follow these to comply with record-keeping laws but these records are also necessary for both random selection and annual audits.

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