Section III - Business & Financial Matters


Use of Federal Funding

To state the College's policy for handling federal funds

The U.S. Department of Education released updated Education Department General Administrative Regulations (EDGAR) on December 19, 2014. The Office of Management and Budget (OMB) consolidated several circulars into a uniform set of rules. These changes lead to the newly updated EDGAR which has been incorporated into the Uniform Guidance.

Randolph Community College is the recipient of federal grant funds. Except where otherwise noted in specific grant funding, RCC will use the following policy for the expenditure of federal grant funds.

Cash Management Plan: RCC adheres to a strict cash management plan. For federal funds passing through the state, the North Carolina Office of the State Controller delegates the authority to make disbursements through a disbursing account established by the State Treasurer. The college adheres to the same procedures for federal funds passing through the college’s institutional accounts.

Travel: Individuals who travel on behalf of the college will follow policy as provided in the Randolph Community College Personnel Handbook and Policy Manual, section III G.

Procurement: When procuring items such as equipment, supplies, and/or services using federal funds, individuals will follow the procurement standards of the State of North Carolina as published in the Accounting Procedures Manual. Randolph Community College’s procurement policy follows the standards established by the State. RCC procurement policies can be found in the Randolph Community College Personnel Handbook and Policy Manual, section III F 1-3. As mentioned above, if the grant has more restrictive standards, RCC will always follow the more restrictive policy for federal funds.

Standard of Ethics: All employees of Randolph Community College are expected to adhere to RCC’s code of ethics. This policy can be found in the Randolph Community College Personnel Handbook and Policy Manual, section VI B 16. This policy covers gifts/gratuities, conflict of interest, nepotism, as well as other ethical situations to avoid.

Indirect Cost: RCC has an indirect cost rate. This rate was negotiated with the federal government. If you need additional information on RCC’s indirect cost rate, please contact either the Vice President for Administrative Services or the Director of Financial Services.

Allowability: Allowability for the expenditure of federal grant funds will follow the guidance of individual grants as well as purchasing policies set for by the North Carolina Community College System Office. Specific guidance is found in the Accounting Procedures Manual of the NCCCS. Further guidance is found in the NCCCS State Aid Allocation and Budget Policies document.

Documentation of Personnel Services: Federal regulations (2 CFR 200.430(i)) states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.

Payroll distribution records must:

  • Be incorporated into the official records
  • Reasonably reflect the employee’s total activity
    o Records cannot include time that an employee is not compensated for and cannot be compensated above 100%
  • Encompass both Federally assisted and all other activities compensated on an integrated basis
  • Comply with accounting policies and procedures
  • Support the distribution of salary or wages among specific activities or cost objectives if an employee works on more than one award or activity.
Time and Effort reporting documentation requirements also apply to salaries counted as match under the grant. To be allowable as match, a cost must be allowable as a grant charge. All requirements that apply to the grant funds also apply to matching funds.

In cases of split appointments, where part of a salary is changed to a federal grant and part to another funding source, documentation must be maintained regarding the allocation of the salary. Time worked, level of effort, and dollars charged are not independent of each other; they are linked and methodologies for tracking, reporting, and the internal controls that are in place, need to be part of the documentation associated with personnel charges to your federal grant.


Adopted: 05/18/2017