Monthly Reporting and Invoicing

Allowability and Composition of Costs
Cost allowability for grant reimbursement is described extensively in the Office of Management and Budget's "Cost Principles for State & Local Government" (Circular A-87), dated August 29, 1997. Copies of this OMB Circular are available on diskette from the RPO office.

The application of guidelines in the OMB-A87 Circular is based on the premise that federally-funded programs like the Rouge Project should be administered through sound management practices. It is each community's responsibility to ensure that grant funds are being expended and accounted for in a manner consistent with the underlying agreements and Rouge Project objectives.

Cost allowable under a grant program must meet the following general criteria:

Be necessary, reasonable, and allocable for proper and efficient administration of the grant project.
Be authorized or not prohibited under State or local laws or regulations.
Conform to any limitations or exclusions set forth in Federal laws, or other governing limitations as to types or amounts of cost items.
Be consistent with policies, regulations, and procedures that apply uniformly to both federally assisted and other activities of Wayne County government.
Be accorded consistent treatment through application of generally accepted accounting principles appropriate to the circumstances.
Not be allocable to or included as a cost of any other federally financed program in either the current or prior period.
Be net of all applicable credits whose receipts reduce expense items allocable to grants as direct or indirect costs (purchase discounts, rebates or allowances, sale of publications, etc.).

The chart below depicts a schematic of typical community watershed project costs:

Some notes on cost composition:

In general, Direct Costs can be identified with a specific project objective.
In general, Indirect Costs are incurred for a common or joint purpose and are not easily assignable to a specific project objective.
Direct vs. Indirect Costs – No set rule in determining direct or indirect for each project cost component; set each initially and remain consistent throughout project.
Departmental Indirect Costs – All departmental indirect costs, including the various levels of supervision, are eligible for allocation to the project provided they meet the conditions set in OMB Circular A-87, Attachment B.
Fixed Fee Costs – Limited to 15% of labor and overhead costs.
Project Income – Documentation developed through the use of grant funds are generally distributed free of charge to the public. Provisions are available to secure income from large distributions. Communities are asked to discuss this situation with their Project Coordinator if applicable.

This Guide’s Attachment 1 provides a table for community use that details the allowability of various potential project costs as detailed in OMB A-87. Section references are also included in the table for locating additional detail on specific cost items in OMB A-87. Please contact the Rouge Program Office for assistance in determining grant reimbursement eligibility for project costs not highlighted in the table.

Cost Matching or Sharing
Each community watershed project is subject to a specified local cost matching percentage as stated in the corresponding project legal document. Matching or cost sharing applications are detailed in 40 CFR 31.24. Highlights of this section are detailed below:

	Item	Key Requirements	40 CFR 31 Reference
Key Item	Basic Rule: Cost & Contributions Acceptable	Requirements satisfied by either: allowable costs incurred by the community value of third party in-kind contributions during the project’s duration.	24(a)
	Exceptions to Allowable Matching Costs	Exceptions to allowable matching costs are as follows: costs borne by other grants general revenue sharing funds costs counted to other Federal cost matching requirements costs financed by project income services or property financed by income earned by contractors.	24(b)(1-5)
	Standards for Third Party In-Kind Contributions	Standards for third party in-kind contributions are as follows: costs would be allowable if submitted under grant-reimbursable procedures valued according to specifications in sections 24(c) through 24(g).	24(b)(7) 24(c) - 24(g)
Key Item	Records for Local Matching Costs	Local matching costs must be verifiable from community records.	24(b)(6)

Monitoring and Reporting Project Performance
Each community is responsible for managing the day-to-day operations of grant supported activities. Activities must be monitored to assure compliance with applicable Federal requirements and the objectives of the project as set forth in the proposal approved by the Rouge Program Office.

Communities are to prepare and submit a monthly progress report to accompany each grant invoice. Communities are also asked to submit a monthly progress report even if no project invoice is submitted for a given month. The purpose of the status report is to detail activities and expenditures of the project on a monthly basis. Issues and problems identified in the report are to be resolved as soon as possible between the community, RPO, and Wayne County representatives.

Monthly Request for Reimbursement of Grant Funds & Progress Form

Attachment 2 of this Guide provides an example format for the community monthly Request for Reimbursement of Grant Funds and Progress Report required for submittal. The form may be copied and filled out, or may be obtained on diskette from the RPO for the community’s use. Alternate formats will be accepted by the RPO, but must contain at least the items listed in the example monthly progress form.

Example of Completed Request for Reimbursement of Grant Funds & Progress Report

Attachment 3 shows a completed monthly Request for Reimbursement of Grant Funds and Progress Report with the level of detail required for a typical project. Each community’s project may differ from the example shown depending on the size and requirements of the particular project.

Community Project Schedules

An important component of the Community Watershed Project Monthly Progress Report is the reporting of updated schedule dates for project tasks. Care must be taken in setting realistic dates for project milestones as stated in the project legal document. The project must be focused on achieving progress towards meeting these milestone dates.

The Rouge Program Office currently maintains a Program Master Schedule for meeting overall program objectives. Each community’s project is inserted into this Master Schedule and is monitored for compliance in meeting identified milestones. The community has the responsibility of carefully reporting project schedule performance on a monthly basis.

If adjustments are needed to the approved project schedule, communities are asked to submit new schedule dates to the Project Coordinator as stated in the project legal agreement. Approval of schedule extensions are generally easier to secure if submitted as early as possible after slippage in the project schedule is identified.

Project Invoicing and Financial Reporting
On the Request for Reimbursement of Grant Funds and Progress Report, the community should note any supporting documentation attached to the monthly report that provides backup for the project costs summarized in the "Project Cost Component" section. Examples of supporting documentation that could be included with the monthly progress report and invoice are listed below:

	Item	Documentation Type	Notes
Key Item	Direct Labor Costs	Time sheets Payroll register Canceled checks Labor distribution report	Identify hours worked on community project. Show obligation to pay employees working on project. Verify employee received and cashed payroll check. Shows total hours and wages of all employees that worked on project, as well as other work.
	Overhead Costs	Overhead Rate Audited Financial Statements Account Listing Fringe Benefit Costs	Document showing federally approved overhead rate. For most recent fiscal year, in lieu of an approved overhead rate. Indicating accounts treated as direct and those included in overhead. Documents substantiating fringe costs, including contracts, invoices, and time sheets.
	Other Direct Costs	Outside Professional Services Contracts Invoices Purchase Orders Receiving Reports Expense Reports	As needed to support monthly expenditures. Show individual names, total hours, and hourly pay rate. Include receipts for other direct purchases. Mileage rates must be standard.
Key Item	Fixed Fees	Limit: 15% of (labor+overhead)	No fixed fees are allowed on other direct costs for consultant contracts.

Attachment 4 provides a listing of submittal requirements required for monthly processing and payment.

Minority/Women Business Enterprises Summary
The community must submit a "Minority/Women Business Enterprises Summary" project cost update quarterly, as shown in Attachment 5. As stated previously in this Guide, the minimum MBE/WBE requirement of the grant is 8 percent of project costs. If a community is unable to achieve this required level of MBE/WBE participation, the RPO will request supporting documentation detailing the community’s good faith efforts to meet this requirement.

Attachment 6 is an example of a completed MBE/WBE Summary form showing proper placement of project budgets and actual costs.

Monthly Dates for Project Documentation & Reimbursement

A typical timetable for submitting monthly project invoice and status is shown below:

	Date	Action	Notes
Key Item	20th of Month	All prior month progress reports, invoices, and required supporting documentation due to the RPO. Any documentation not received by the close of business on the 20th will not be included in current monthly process.	Send to: Razik Alsaigh Rouge Program Office 220 Bagley, Suite 920 Detroit, MI 48226
	22nd of Month	RPO reviews submittals, prepares, and submits grant reimbursement memos to Wayne County - Watershed Management Division.	Any questions regarding submitted documents will be submitted in writing to communities within 21 days of receipt.
	23rd of Month	WCWMD reviews memos and routes to required Wayne County Departments for processing.	-
Key Item	By the 10th of Following Month	Wayne County Budget & Management performs review process and issues checks to communities.	-
	10th of Following Month	Grant drawdown transmitted to EPA.	-
	13th of Following Month	EPA transfers federal share dollars to Wayne County.	-

Communities should issue checks to subcontractors promptly upon receiving grant funding checks from Wayne County. Interest income from grant funds should be avoided through effective project administration. Refer to Attachment 1 and the OMB A-87 Circular for additional information.

Frequently Asked Questions (FAQ’s)

Can a community representative’s attendance at Rouge River Project meetings be listed for project costs?

Yes, as long as time spent at project meetings can be verified through supporting documentation (time sheets, etc.).

Can community equipment working on a project be listed for project costs?

Yes, with proper application as a direct or indirect cost throughout the project.

Other FAQ’s will be added as comments are received.

Please address all comments and suggestions about the contents of this Web page to rougeweb@co.wayne.mi.us.

The Rouge River National Wet Weather Demonstration Project is funded, in part, by the United States Environmental Protection Agency (EPA) Grants #XP995743-01, -02, -03, -04, -05, -06, -08 and C-264000-01.