appendix m3 sample management plan (grant project managed by third-party nonprofit) this document is only a sample. it is important that lo

APPENDIX M3
SAMPLE MANAGEMENT PLAN (Grant Project Managed by Third-Party Nonprofit)
This document is only a sample. It is important that local officials
create a management plan based on how things are actually done
(especially in regards to the financial management) by the local
government; the sample management plan should not simply be copied if
it does not fit the local government’s particular situation.
MONTANA DEPARTMENT OF COMMERCE
COMMUNITY DEVELOPMENT BLOCK GRANT
ECONOMIC DEVELOPMENT PROGRAM
CONTRACT NO. MT-CDBG-ED-xx-xx
(Name of Assisted Business)
In Fiscal Year (xxxx), the (Name of Local Government) received a grant
from the Montana CDBG-ED Program that will be given to (Name of
Assisted Business). New and expanding businesses that receive funds
from the CDBG-ED program promise to provide jobs to low and
moderate-income (LMI) families in the (Name of Local Government). The
(City/Town/County) will enter into a Sub-Recipient Agreement with name
of (name of Local Development Organization) (LDO) for administering
the CDBG-ED Project. This Management Plan is written to assure proper
management of the CDBG-ED project, which includes financial management
of grant funds, compliance with State and federal requirements, and
timely start‑up and completion of project activities.
A.
ADMINISTRATIVE STRUCTURE
1.
LOCAL GOVERNMENT GRANTEE
The (Name of Local Government) is an incorporated (City/Town/County)
with a (Mayor/Council, City Manager/Council or County Commission) form
of government. The following persons will have lead responsibility for
administering the (City/Town/County)’s FY (xxxx) Community Development
Block Grant-Economic Development (CDBG-ED) Project on behalf of the
(City/Town/County) to (Describe Activity Funded) for (Name of Assisted
Business).
a.
(Name, Local Government Elected Official), as the (City/Town/County)’s
chief elected official, will have responsibility for all official
contacts with the Montana Department of Commerce (MDOC). The (Local
Government Elected Official) and (Council or Commissioners) will
have the ultimate authority and responsibility for the
implementation of the (Name of Local Government)’s FY (xxxx)
CDBG-ED project for Economic Development to facilitate an
expansion of (Name of Assisted Business). The (Local Government
Elected Official) will approve and sign administrative documents,
designate the Environmental Certifying Officer and approve all
requests for payment from the CDBG-ED program. The (Council or
Commissioners) will approve all contracts and drawdown requests.
The telephone number for the (Local Government Elected Official)
and (Council or Commissioners) is (406) (xxx-xxxx). (Email
xxxx@xxx)
b.
(Name), (City/Town/County) Attorney, will review any proposed
contractual agreements associated with the CDBG-ED Project, advise
the (Council or Commissioners) regarding the agreements, and
provide any other legal guidance as requested. (Telephone: (406) (xxx-xxxx).)
(Email xxxx@xxx)
c.
(Name), (City/Town/County) Clerk, will be responsible for
maintaining records related to the management of the initial
CDBG-ED project funds for the (Name of Local Government).
(Telephone: (406) (xxx-xxxx).) (Email xxxx@xxx)
d.
(Name), (City/Town/County) (Position (i.e. County Development
Office)), will be the liaison between the (name of Local
Development Organization) (LDO), the (Council or Commission)
members and the (City/Town/County) Attorney. (He/She) will make
appropriate recommendations and route all contract documents,
administrative documents, and drawdowns as necessary. (He/She)
will also be responsible for the Environmental Review process.
(Telephone: (406) (xxx-xxxx).) (Email xxxx@xxx)
2.
(Name of Local Development Organization) (LDO)
To provide general technical assistance, coordination of funding
sources, assurances of compliance with all applicable state and
federal requirements for the CDBG-ED program, the (Name of Local
Government) has designated the (name of Local Development
Organization) (LDO) as its Project Administrator. (Name of Local
Development Organization) (LDO) is a not-for-profit 501(c)(3) Local
Community Development Agency located in (Name of Local Government).
The following (name of Local Development Organization) (LDO) personnel
will be responsible for the project:
a.
(Name), Executive Director, will be responsible for all official
contacts with the (Name of Local Government) on behalf of (name of
Local Development Organization) (LDO), keeping the (name of Local
Development Organization) (LDO) Board of Directors apprised of
project status, and entering agreements on behalf of (name of
Local Development Organization) (LDO). (Telephone: (406) (xxx-xxxx).)
(Email xxxx@xxx)
b.
(Name), Project Manager, will be responsible for overall
coordination of the CDBG-ED Grant awarded to the (Name of Local
Government). (He/She) will establish and maintain complete and
accurate project files, monitor all project activities for
compliance with all applicable requirements, and supervise the
project outreach, intake, application and project selection
process. (Telephone: (406) (xxx-xxxx).) (Email xxxx@xxx)
c.
(Name), Fiscal Officer, will be responsible for the fiscal
management of the project, in coordination with the Project
Manager and in accordance with the (name of Local Development
Organization) (LDO) Fiscal Procedures Manual. (He/she) will assure
compliance with all applicable federal, state and local
requirements, keep all fiscal records and accounts for the (name
of Local Development Organization) (LDO), assure coordination of
all funding sources, review all project expenditures from the
business, process pay requests, draft drawdown requests, and
prepare all project closeout documents. (Telephone: (406) (xxx-xxxx).)
(Email xxxx@xxx)
B.
PROJECT MANAGEMENT
1.
(Name), (City/Town/County), (Position) will:
a.
Complete the environmental review for each project to assure
compliance with National and Montana Environmental Policy Acts
b.
Complete the Statutory Checklist or Consolidated Environmental
Assessment Form, as applicable, and any other applicable
environmental requirements
c.
Prepare any legal notices required to be published for the
environmental review process and conduct any required public
hearings or informational meetings
d.
Prepare a request for release of funds to the MDOC
e.
Assist in the development of a CDBG-ED contract between the (City/Town/County)
and the MDOC
f.
Review, approve, and submit the CDBG-ED drawdown requests, after
preparation by (name of Local Development Organization) (LDO) and
approval by the (Council or Commissioners), to the CDBG-ED
Program, Business Resources Division, Montana Department of
Commerce, and ensure disbursement of funds to the (name of Local
Development Organization) (LDO) for administrative expenses
g.
Review and approve all CDBG-ED closeout documents.
2.
As a sub-grantee, the Project Administrator, (name of Local
Development Organization) (LDO), is responsible for the following
day to day project activities:
a.
Coordinating with the (Name of Local Government) for completion of
the environmental review process required of each CDBG-ED project
considered for funding to assure full compliance with the National
and Montana Environmental Policy Acts and the preparation of any
legal notices required to be published for the environmental
review process and conducting any required public hearings or
informational meetings.
b.
Assisting the (Name of Local Government) and the MDOC in
developing the (Name of Local Government) contract with the MDOC
that will address all requirements related to effective project
start‑up and implementation. This will include preparation of all
management agreements between the (Name of Local Government) and
the Project Administrator.
c.
Establishing and maintaining complete and accurate project files
and preparing all documentation and reports incidental to
administration of the grant
d.
Reviewing all proposed project expenditures or requests for
payment from the business to ensure their propriety and proper
allocation of expenditures to the CDBG-ED budget.
e.
In cooperation with the (Name of Local Government) project manager,
processing quarterly payment requests and preparing drawdown
requests to the MDOC, including the Request for Payment and Status
of Funds Report and the Project Progress Report
f.
Assuring compliance with applicable civil rights requirements
included in the (Name of Local Government)’s adopted equal
opportunity plan and fair housing resolution
g.
Preparing all required performance reports and closeout documents
for submittal to MDOC and assisting the (Name of Local Government)
auditors with the completion of the project's audit requirements
h.
Expending the CDBG-ED funds in a timely fashion in accordance with
the project implementation schedule
i.
Monitoring compliance with the requirements of the grant agreement
including implementation of the project hiring and training plan,
submission of monthly financial statements, and documentation of
benefit to low and moderate-income families
j.
Attending (Council or Commissioners) meetings to provide project
status reports and representing the CDBG-ED project at any other
public meetings as deemed necessary by the (Council or
Commissioners)
k.
Developing a means for assisting the ultimate grant recipient with
fulfilling the hiring and training plan requirements, including
reports to MDOC regarding progress.
C.
FINANCIAL MANAGEMENT
1.
The (Name of Local Government) Clerk will be responsible for:
a. Establishing a CDBG-ED bank account and transferring CDBG-ED funds
from that account to the (Name of Local Government) treasury for
disbursements, based on claims and supporting documents approved by
the Project Manager and (Council or Commissioners). As the
(City/Town/County) uses an interest bearing account for its general
disbursements a separate non-interest bearing account will be used for
CDBG-ED funds. Balances in that account will not exceed $5,000 for a
period of three days. Funds will be transferred to the (name of Local
Development Organization) (LDO) account and the (name of Local
Development Organization) (LDO) will disperse funds for (describe
activity funded).
b. Entering all project transactions into the (City/Town/County)’s
existing accounting system (BARS) and preparing warrants for approved
expenditures.
c. With the assistance of the Project Administrator, preparing the
Request for Payment and Status of Funds Reports to be submitted to
MDOC. All drawdown requests will be signed by two of the three
following persons: (i.e. Mayor, Director of the County Development
Office, President of the City Council).
d. The (i.e. Project Administrator, the County Development Director
and/or City Clerk) will review all proposed expenditures of CDBG-ED
funds and will prepare drawdown requests, which will be signed by the
officials cited above. All disbursements will be made in accordance
with the (City/Town/County) established claim review procedures.
Before submitting the claim to the (City/Town/County) Clerk, the
Project Administrator will attach a certification to each claim
stating that the proposed expenditure is an eligible expense of the
(City/Town/County) CDBG-ED grant and consistent with the project
budget.
e. With the assistance of the Project Administrator, preparing the
final financial report for project closeout.
f. Financial record keeping will conform to the recommendations of the
MDOC/Local Governmental Services Bureau as described in Chapter 4 of
the CDBG Grant Administration Manual. The original financial documents
(claims with all supporting documents attached) will be retained in
the (Name of Local Government) offices.
g. With oversight and approval from (Name of Local Government), (name
of Local Development Organization) (LDO) will administer the project
within the framework of its financial procedures manual. These
procedures are designed to ensure the efficient and effective
administration of federal grants within the constraints of uniform
federal compliance requirements as outlined in OMB Circular A-110 and
further codified in 24 CFR 570-502 (Revised as of April 1, 1997).
h. A separate fund for the project will be set up within the general
ledger accounts at (name of Local Development Organization) (LDO). All
CDBG-ED activities including revenues and administrative expenditures
will be segregated, recorded, and reported in this fund and will be
entitled "(Name of Local Government) CDBG-ED Project Fund".
i. Subsequent draw downs will consist of administrative payments from
the (Name of Local Government) to the (name of Local Development
Organization) (LDO). Administrative payments will consist of
reimbursement for actual time and costs incurred. The (name of Local
Development Organization) (LDO) will prepare the CDBG-ED draw down and
attach a copy of a detailed invoice (example on page M-18). Upon
review and approval, the (Name of Local Government) will forward the
draw down request to the MDOC. The (Name of Local Government) will
reimburse the (name of Local Development Organization) (LDO) for
eligible administrative expenses upon receipt of funds from the MDOC.
j. The CDBG-ED project fund will be audited on a yearly basis in
conjunction with (Name of Local Government)’s audit, and the audit
will be conducted according to OMB Circular A-133.
If (name of Local Development Organization) (LDO) ceases to exist or
an event of default occurs, Program Income relating to the CDBG-ED
Project, including funds on hand and accounts or notes receivable will
revert to the (Name of Local Government).
IN WITNESS WHEREOF, the parties hereto acknowledge that the parties
named within are aware of their responsibilities and execute this
Agreement on the ______ day of _________________, 20__.Project
Administrator:
______________________ ________________
(Name, Title) Date
(name of Local Development Organization)
(Name of City, Town or County):
______________________ _________________
(Name, Title of Elected Official) Date
(Name of Local Government)
Example of a Local Development Organization’s Invoice
(Submitted to the Local Government for
CDBG-ED Administrative Services Payment)
Invoice # XXXXX
PUNXSUTAWNEY ECONOMIC DEVELOPMENT PROJECT
Here-to-Help Staff Project Hours
June-August 2013
Staff Hours Activity Date Performed
===================================
Johnson 4.0 Meet w/ city and engineer 6/8/13
(200 travel miles)
Williams 2.0 Reviewed Contracts 6/20/13
Williams 3.0 Reviewed Files, Prepared progress report 7/24/13
Johnson 4.0 Meet w/ CDBG-ED rep at project site 8/4/13
(200 travel miles)
Williams 2.0 Prepare drawdown #1 and progress report 8/22/13
Total Hours Williams 7.0
Johnson 8.0
Williams 7.0 hours @ $40/hour $280.00
Johnson 8.0 hours @ $60/hour $480.00
Travel to City and Project site (400 mi. @ $.50/mi.) $200.00
Invoice Total: $960.00
See the attached additional documentation substantiating the charges.
Community Development Block Grant Program Economic Development
Application Guidelines
Montana Department of Commerce M3-7 February 2012

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