2/25/2016 Page | 1
Gulf Coast Ecosystem Restoration Council
Recipient Internal Control Compliance Document List and Certification
Instructions: The following list must be reviewed, verified and signed by the authorized representative for the organization.
Recipients are advised that the following written documentation should be prepared and maintained by the agency
throughout the life of the grant.
Copies of documents may be requested at any time by the RESTORE Council,
the Government Accountability Office or the Treasury Office of the Inspector General.
Description
Process Area
Grant Management Manual used by the entity to administer Federal grants, or an equivalent document
2
Procedure documents related to the accounting and categorization of Federal grant funding (if not included in Grant
Management Manual). Including:
- Defining, tracking, and reporting Allowable and Unallowable costs
- Defining, tracking, and reporting Direct and Indirect costs
- Process of charging Administrative Costs
- Accounting of Personnel costs
- Chart of accounts used for Allowable, Unallowable, Direct, and Indirect costs
- Compensation and Benefits used by the entity for services rendered during performance under a Federal Grant
Federal Awards
3
Policies and procedure documents related to the security of the internal accounting or financial systems used by the
entity to manage Federal grants (not including Grant Solution or ASAP financial systems). Including:
- User Access
- Safeguards against system destruction
- User Segregation of duties
- External system threats
- Data recovery and business continuity
Information
Technology
4
Policies and procedure documents for the management of Federal Cash used by entity to manage Federal grants (if not
included in Grant Management Manual). Including:
- Process of repaying excess funds related to Federal grants
- Adding program income to Federal award and restricting program income based on the terms and conditions of the award
- Any debts determined to be owed to the Federal Government
- Processes related to cash drawdowns related to Federal grants
Management of
Federal Cash
5
(a) Procedure documents for processes related to the review of internal and external audits performed on the entity.
Including:
- How the entity formally responds to observations identified in the audit.
- Process to periodically perform a self-assessments to evaluate potential risk of the internal control environment of the
entity. (i.e. cross functional reviews)
- Process of creating and monitoring corrective action plans for internal or external audit findings
(b) Copy of most recent organizational risk assessment and associated documentation
Monitoring
6
(a) Organizational chart of all departments involved (i.e., programmatically or financially) with the RESTORE Act
program
(b) Policies and procedures related to the following:
- Code of Conduct and/or Code of Ethics document that the entity issues to staff members
- Policies on Personally Identifiable Information (PII)
- Conflict of Interest relating to Federal grants
- Procedure documents for the staff members to confidentially report suspected violations
- How the entity addresses criminal and fraud violations that occur related to Federal grants
- Periodic review of Federal grant regulations to ensure compliance
- Establishment of a Board of Directors, or similar type of organization, including the level of oversight provided by the
Board
- Training documents used to promote anti-fraud awareness to staff members
- Training documents used to train staff/members and sub-recipients on Federal grants
Policy