Grants Administration Manual Frequently Asked Questions

Effective Date: 07/01/2022

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?

SWCDs are only empowered to do what is found in 103C and more importantly under the powers and duties section. SWCDs do not explicitly have the authority to incur debt. If your SWCD plans to or has obtained a loan or incurred debt, please consult with your county attorney or designated legal counsel, your insurance provider, and your auditor to determine your legal and fiscal authorities and insurance coverage options.

Can BWSR grant funds be used as a loan to land occupiers?

No.  When installing conservation assistance practices, a contract is required between the grant recipient and the landowner.  There may be programs available through other agencies which are designed to loan funds for conservation projects.

Are grantees required to follow Municipal Contracting Law?

Per Minn. Stat. §471.345, grantees that are municipalities as defined in Subd. 1 of this statute must follow the Uniform Municipal Contracting Law. For additional information review the executed Grant Agreement.

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 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 costs. If actual leave costs (not applicable to accrued leave) were used in the billing rate, then pay-out of severance can be handled in one of two ways:

1. If the employee’s work was concentrated on a few grants and grant programs, the payout should be allocated across those grants.

2. 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 cost and included in the billing rate or indirect cost allocation.

Can staff time costs be split between more than one program and, if so, how can grantees meet the time and effort documentation requirements when splitting the cost of the same hour of staff time among more than one program?  For example, charging the salary, benefits, and leave costs to one program and facilities and administration costs to another program.

It may be allowable depending on the approved grant workplan.  Contact your Grants Compliance Specialist or Board Conservationist for further guidance. 

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.

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.

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 often can the billing rates change given staffing changes or wage 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).

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.

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.

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 administration added to the modified base rate under Option 1 is intended to cover facilities and administration costs. The exceptions are costs in excess of normal facilities costs specific to achieving grant funded outcomes. Some examples are vehicle maintenance, cell phone monthly expenses, or computers where the purchase price is below the organization’s capital asset threshold.

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.

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 template (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 template or use the modified base rate (wages, benefits, and leave) to charge their time worked to grants.

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 wages + 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 wages / [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 Wages 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).

For calculating the cost of benefits in a billing rate using Option 2 of the BWSR billing rate template, 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).

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 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.

When calculating billing rates for the next year and there is a rent increase, can the known rent increase amount be included as a facilities cost?

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.

Grantees may receive dividends related to previous payments for health insurance, MCIT insurance premiums, etc... Must these dividends be applied to reduce costs included as a facilities cost 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.

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.

Staff time spent working on administrative tasks such as training, board meetings, staff meetings, planning, time tracking, or general operations are essential to run an office and administer grants. However, it is not practical to charge this time to any one grant. BWSR does allow a proportionate amount of general administrative time to be included as an administration cost added to the billing rate calculations. Nearly all BWSR grants are program or project specific and while they do pay for work that is direct and necessary for administering the grant, they 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. For example, in some smaller organizations, technical staff may also perform administrative functions. In organizations such as larger cities or counties, the general administration hours can only come from administrative staff within the department where work on the grant is being done.