Effective Date: 07/01/2019
Can I use state funds to repair previously installed conservation practices that have been damaged or removed?
If it is within the designed project life expectancy and the damage was done due to an unavoidable act of nature, then the practice is eligible and you should consult with your Board Conservationist. If the project is past its designed life expectancy, the practice is eligible for cost share if brought to current design standards. Consult the grant program policy and your Board Conservationist for more information.
Do I need to issue a 1099 to a landowner who has received financial assistance under a grant?
There are instances where a 1099 is required. , Consult IRS Publication 225 or your accountant for additional information.
How long must conservation practice project files for cancelled projects be retained?
Under Minnesota Statutes §16B.98, the State has the authority to examine records and documents relevant to the grant or transaction for a minimum of six years from the end of a grant agreement, receipt and approval of all final reports, or the required period of time to satisfy all State and program retention requirements, whichever is later.
Can a Soil and Water Conservation District accept a donation?
According to MN Statute §103C.331 Subd. 12(b), a district may accept donations, gifts, grants, or contributions in money, services, materials, or otherwise from the United States, a state agency, or other source to accomplish the authorization in this section. A board may enter into a contract or agreement necessary or appropriate to accomplish the transfer. A board may use or expend money, services, materials, or other things to accomplish an authorized purpose.
Is an SWCD authorized to take out a loan?
No, SWCDs are not able to borrow money. They are only empowered to do what is found in 103C and more importantly under the powers and duties section. If an SWCD enters into a “rent to own situation,” they are not borrowing funds but rather have a contract with some form of payment and, at the end of the contract, they would own the property (i.e. vehicle, building, land).
What activities are eligible as match?
If a cost is allowable to be charged to a grant, it can count as match. In addition, donated services and property may count as match. (See Allowable and Unallowable Costs chapter and relevant policies, RFPs, and FAQs)
How can a grantee value the time National Resources Conservation Service (NRCS) staff contribute as match to a grant?
NRCS staff should value their time using an intergovernmental rate or published NRCS rates.
How can a grantee value the time volunteers contribute as match to a grant?
Rates for volunteer services should be established through local policy. Rates for volunteer time used on projects should correspond to published or established rates applicable to the area. Applicable rates for volunteer time depend on the activity; not the volunteer’s profession. For example, an organization may have a lawyer or engineer helping install plants as part of a raingarden and could only charge a rate for the volunteer work performed as a landscaping and grounds keeping worker, not the customary hourly rate associated with their professions as a lawyer or engineer. For help valuing the time volunteers contribute as match to a grant, see the rates published for Minnesota at the US Bureau of Labor Statistics, http://www.bls.gov/oes/current/oes_mn.htm. For a generic value of volunteer time in Minnesota, see Independent Sector, at http://independentsector.org/volunteer_time.
How can the value of donated property be quantified? For example, if a county donates space to a grantee to house its offices, how can the space be quantified?
Calculate the square footage of the donated space. If the county pays rent on the entire property, use the portion of the total rent ([grantee’s square footage / total square footage] * rent) to calculate an annual value for the donation. If the county owns the building and does not pay rent, you may consider the donation as a portion of a capital asset and value the donation as a portion of the building’s depreciation or calculate a use allowance for the space using an equivalent market rate.
Are unemployment payments allowable costs to a BWSR grant?
Funds reserved for unemployment and not actually paid out are not allowable. Paid unemployment insurance may be classified as a facilities and administrative cost; depending on work assignment, the unemployment payment can be a direct or indirect cost.
How can a grantee account for the payout of severance, vacation and sick leave when an employee leaves employment?
If accrued leave costs are included in the billing rate, severance pay cannot be included in facilities and administrative costs. If actual leave costs were used in the billing rate, then pay-out of severance can be handled in one of two ways:
If the employee’s work was concentrated on a few grants and grant programs, the payout should be allocated across those grants.
If the employee was employed for a long period of time and worked on many grants and grant programs, the payout for vacation and sick leave may be included as a facilities and administration cost and included in the billing rate or indirect cost allocation.
What type of documentation should a fiscal agent obtain from a grant recipient when managing a BWSR grant?
At a minimum, the fiscal agent would need the timeframe of services rendered (must fall within the BWSR grant period), number of hours worked, services provided, and hourly rate and/or amount charged. As fiscal agent, you would want documentation sufficient to provide reasonable assurance the invoice is accurate and appropriate for the services rendered. Services provided, as listed on the invoices, should align with reporting in the various categories within eLINK. If there are variances, please work with your Board Conservationist to make adjustments to the workplan/grant reporting. A fiscal agent could request detailed time tracking information in support of invoices submitted for services rendered but is not obligated to do so when BWSR funds are involved.
When reimbursing other local governments for equipment/materials purchased and charged to BWSR grants, obtaining copies of the supporting invoices is appropriate and a good accounting practice. See the Allowable and Unallowable Costs chapter of the Grants Administration Manual.
How can an SWCD support a local organization to further conservation efforts?
The SWCD could enter into a contract and/or agreement with the local organization to provide a specific quantifiable deliverable which advances soil and water conservation in the county. The SWCD would pay based on deliverables provided supported by an invoice from the local organization. The amount of money paid must be related to the value of the services provided.
If a grantee has an hourly rate included in a workplan that is approved by the Board Conservationist, is the hourly rate subject to review by a Grants Compliance Specialist?
Yes, a workplan is a budgeted amount. Rates and hours included in workplans are for budgeting purposes only. BCs are approving the budgeted amounts for each activity category along with the general types of projects planned in alignment with the approved grant application. GCSs review actual costs associated with the grant.
How can a grantee charge a grant for the cost of administrative time spent on things like training, board meetings, staff meetings, planning, or time tracking (general operations)? These activities are essential to run an office and administer grants but are not practical to assign to any one grant.
BWSR grants pay for work that is “direct and necessary” for a grant, including administering the grant. Recognizing not all administrative time direct and necessary to administer grants can be tracked and charged directly to any one grant, BWSR grants allow a proportionate amount of general administrative time to be included in the facilities and administrative costs added (in the BWSR billing rate template) to a billing rate or indirect cost allocation. Nearly all BWSR grants are program or project specific and are not intended to pay for the entire operations of a grantee.
Why are only administrative employees allowed to include a portion of their general administrative time not charged to grants in the billing rate or indirect cost allocation?
In contrast to administrative staff, the work time of technical employees (including the time they spend administering the grant) are assumed to be documented and assigned directly to the grant. Staff time administering the office (general administrative time) is assumed to be contributed by administrative staff and is assigned to the indirect cost pool. The definition of administrative staff must be consistent with the organization of the grantee.
What costs could be direct charged to grants when using Option 1: How to Calculate Billing Rates Using Modified Base Rate + 10%?
The 10 percent for facilities and administrative added to the modified base rate under Option 1 is intended to cover facilities and administrative costs. The exceptions are costs in excess of normal facilities costs specific to achieving grant funded outcomes.
Does Option 1: How to Calculate Billing Rates Using Modified Base Rate + 10% allow for employer contributions to a health savings account?
Yes, employer contributions to employee benefit packages should be included within the costs for the benefits insurance line.
Is the amount of an employee’s benefits private data under the Minnesota Government Data Practices Act (MGDPA)? Can a grantee include the amount in a billing rate or indirect cost allocation?
The amount of an employee’s benefits is public information. The Data Practices Act classifies “the value and nature of employer paid fringe benefits” as public data (Minnesota Statutes 2015, section 13.43, subdivision 2). Information regarding the use of health or medical benefits, including sick time (13.43, subdivision 2 (a)(8)) and “data pertaining to an employee's dependents” (13.43, subdivision 4), is private information and should be secured. BWSR’s billing rate template includes a field for “Yearly Hours” but does not specify a reason for working or not working the number of hours.
For calculating the cost of benefits in a billing rate using Option 2 of the BWSR billing rate spreadsheet, can health, dental, disability and other benefits be averaged across all employees enrolled?
No. Benefits are specific to each employee (See Determining a Billing Rate chapter).
How can organizations account for part time employees when determining a billing rate?
For part-time permanent employees, enter the hours to be worked by the employee, in terms of a part of a full-time equivalent (FTE), in the Yearly Hours Worked box on the billing rate spreadsheet (i.e. if the employee is employed at ½ FTE, enter 1044 in the Yearly Hours Worked box). For short-term seasonal/intern employees, you have the option to include them on the billing rate spreadsheet or use the modified base rate (salary, benefits, and leave) to charge their time worked to grants.
Why is the number of workable hours for a full-time equivalent employee (FTE) set at 2,088?
The Legislative Coordinating Commission calculates FTEs based on a denominator of 2,088 workable hours in a year. See Minnesota Statutes 2015, section 3.303, subdivision 10.
Should you choose, how can you use the billing rate template to account for overtime?
If the employee is paid overtime, enter the total hours worked by the employee (2088 + overtime hours) in Yearly Hours Based on FTEs and enter the effective hourly rate ([annual salary + overtime pay] / [2088 + overtime hours]) in the Base Rate field. If the employee is not paid overtime, enter the total hours worked by the employee (2088 + overtime hours) in the Yearly Hours field and enter the effective hourly rate (annual salary / [2088 + extra hours]) in the Base Rate field. This is also applicable to salaried or hourly employees.
Should you choose, how can you use the billing rate template to account for compensatory (comp) time?
1. For employees who earn one hour of comp time for every extra hour worked, there is no gain in recording the time off for this calculation. Calculate the billing rates as normal.
2. For employees who earn greater than one hour of comp time for every extra hour worked, the billing rate calculation could be adjusted.
- Enter 2088 + extra hours actually worked in the Yearly Hours Based on FTEs field (B on the template).
- Recalculate the Base Rate (C on the template) by dividing Annual Salary by Yearly Hours Based on FTEs (B). Enter the amount in C, Base Rate.
- Enter leave hours actually taken (regular + sick + holiday + extra comp time hours taken) in “Leave Hours Taken” (E on the template).
How do you calculate the number of leave hours for a billing rate when using actual or accrued leave?
Actual leave can be calculated per employee or averaged across all employees based on the past year. Accrued leave is calculated per employee based upon accrual rates; however, once this method is selected, the organization cannot revert back to actual hours nor can they claim severance in the facilities costs portion of the billing rate. Consult your Grants Compliance Specialist to discuss the best option for your organization. Be sure to retain your calculations each time billing rates are updated.
Is it allowable to include known holiday hours in the actual cost of leave calculation before they have actually been taken?
Yes, holiday hours can be included because they are contractual and/or Board approved.
How often can the billing rate change given staffing changes or salary increases?
Billing rates should be evaluated annually, but may be recalculated more often to reflect changes in costs or employees (See Determining a Billing Rate chapter).
When calculating billing rates for the next year and there is a rent increase, can the known rent increase amount be included in the overhead costs?
Yes, known actual costs for the current year can be included in the current year’s billing rate calculations. For example, if rent is increasing per a signed lease agreement, the expense can be included in the current year’s billing rate calculations.
Does BWSR’s billing rate policy and guidance apply to Clean Water Fund grants or to all grants including NRBG, State Cost Share, etc.?
The BWSR Grants Administration Manual applies to all grants unless specifically exempted through program policy.
SWCDs may receive dividends related to previous payments for health insurance or MCIT insurance premiums. Must these dividends be applied to reduce costs included as overhead in the billing rate calculations?
Dividends received are typically an immaterial amount; therefore, there’s no need to reduce the insurance costs included in the billing rate calculations.
Previous versions of the Grants Administration Manual contained two sections called Purpose and Scope and Terminology that have been combined into one section for the 2017 version, revises existing terminology for clarity and consistency, removes unused terms, and adds new terms.
Added additional FAQs based on grantee feedback and internal review.