INSTITUTIONAL AID-TITLE III PROGRAMS

Title III Program Policies and Procedures

These policies and procedures have been developed to facilitate the implementation of activities funded by the Institutional Aid/Title III Program. They are to be used in monitoring and evaluating program activities and controlling related expenditures. Additionally, they should serve as a resource for Activity Coordinators.

Compliance with these guidelines and regulations will assure that Jackson State University's Title III Program grant is administered in accordance with the Education Department General Administrative Regulations (EDGAR), and other Federal directives.

A manual containing these and more in depth presentations of Title III Program Policies and Procedures may be downloaded at the end of this page or from the Download page on this website. These policies and procedures will be updated periodically as changes in regulations are made by the United States Department of Education and Jackson State University.

FISCAL MANAGEMENT

The Division of Business and Finance is responsible for maintaining accounting records on a consistent basis and in accordance with accounting principles acceptable to the United States Department Education. All requisitions are submitted to the Office of Grants and Contracts before they are submitted to other fiscal offices. The Title III Office accesses program accounts through the Financial Record System (FRS) which provides balances for each activity account.

The Title III Director has the fiscal responsibility of monitoring actual expenditures and comparing them with the budget plan, monitoring cash flow, recommending action to obligate funds, and approving all expenditures before they are submitted to the Division of Business and Finance for payment.

MAINTENANCE OF FINANCIAL RECORDS

Activity directors and coordinators should establish and maintain spreadsheets of activity account transactions. They should review activity accounts to determine any changes in their assigned budgets; determine whether departmental transfers have been posted; make sure that purchases have been properly charged (expenditures by budget line should equal the amount given on the system); and compare account balances with those maintained on office spreadsheets

PERSONNEL

For all Title III positions, there must be a search process to ensure that the hiring of persons supported by Federal funds is in compliance with all applicable Federal regulations and is within the framework of the Title III plan of operation and the Title III budget. Documentation for personnel management is essential and should be maintained. Personnel are to be hired in a nondiscriminatory manner according to the provisions stated in Jackson State University's Faculty Handbook and the Staff Handbook. The Title III Office requires the University's "Applicant Worksheet" to document that employees were hired in adherence to this requirement. More specific and detailed procedures are provided in the Title III Policy and Procedure Manual.

REPORTS OF TIME AND EFFORT OF EMPLOYEES

The United States Department of Education requires documentation of time spent working on Title III activities by all persons wholly or partially paid with Title III funds. Employees should, therefore, complete the monthly Personnel Activity Report and submit it to the Grant Director on the last day of the month which service was rendered. The Personnel Activity Report must be signed by the employee, his/her immediate supervisor, and the Title III Activity Director.

RULES FOR THE EMPLOYMENT OF GRADUATE STUDENT WORKERS

Only graduate students may be paid to work in the Title III grant. Foreign students in F-1 status may work without prior approval from the U.S. Immigration and Naturalization Service (INS) provided they are enrolled in a full course of study and provided their employment will not displace a U.S. resident [8CFR 214.2(f)(9)(I)]. Students who are selected must be approved by the Office of Financial Aid. Financial Aid approval should occur before employment commences. The maximum number of hours a student may work per week is 20. If a student is employed in more than one of the Title III projects, the supervisor of each project must collaborate to insure that the student does not work hours for which he or she will not be paid. Foreign students in F-1 status are required by law to work only 20 hours per week while school is in session. The maximum rates of pay have been provided to Activity Coordinators who must document the actual hours worked by graduate student workers.

FACULTY COMPENSATION FOR WORK PERFORMED

Federal regulations described in CFR 74 Appendix D, Principles for Determining Costs Applicable to Research and Development Under Grants and Contracts with Education Institutions, limit the amounts that may be paid for work performed in the grant. The regulations also prohibit payments for intrauniversity consulting.

SALARY RATES FOR ACADEMIC YEAR

Charges for work performed in this grant by a faculty member during the academic year must be based on the faculty member's regular compensation for the continuous period, which under the practice of the institution concerned, constitutes the basis for the salary. Charges for work performed during all or any portion of such period is allowable at the base salary rate. In no event will the charge, irrespective of the basis of computation, exceed the proportionate share of the base salary for that period. Any extra compensation above the base salary for work in the grant during the academic year is unallowable. This principle applies to all members of the faculty at the institution.

INTRAUNIVERSITY CONSULTING

Since intrauniversity consulting is assumed to be undertaken as a university obligation requiring no compensation in addition to full-time base salary, the principle described above also applies to those individuals who function as consultants or otherwise contribute to a research agreement conducted by another faculty member of the same institution. However, in unusual cases where consultation is across departmental lines or involves a separate or remote operation and the work performed by the consultant is in addition to his regular departmental load, any charges for such work representing extra compensation above the base salary are allowable provided such consulting arrangement is specifically provided for in the approved application or approved in writing by the United States Department of Education. Charges for work performed by faculty members on Government research during the summer months or other periods not included in the base salary period will be determined for each faculty member at a monthly rate not to exceed what is applicable under the base salary. This is limited, however, to charges made in accordance with the paragraph above.

REPORTS OF RELEASED TIME OF UNIVERSITY EMPLOYEES

The University is required to document the released-time efforts of employees. To avoid supplanting University funds, the University must continue to pay for the work from which an employee is released, and the University must document the funds paid. The Title III Program Director must maintain a "Released Time" report containing information about both released-time employees and persons replacing them. Faculty and staff who are released from their regular duties to work on Title III projects are subject to the salary limitations described in "Faculty Compensation for Work Performed."

TRAVEL

Travel with Title III funds is allowable only for travel expenses identified in the approved grant application. All changes in approved travel must be justified. Travel requests not identified in the approved application, requires written approval by the United States Department of Education.

APPROVAL TO TRAVEL

Title III personnel who will travel with grant funds must complete travel itineraries and have them approved two weeks prior to the actual travel. On travel itineraries, include the total destination cost of the trip (Air fare, taxi fare, registration fees, meals, mileage, car rental, and lodging). Additionally, the purpose of the trip must be indicated. The trip's purpose must coincide with the goals and objectives of the activity as stated in the grant application or activity modification. Travel arrangements must be made through the approved travel agency.

TRAVEL BY PUBLIC CARRIER

Employees who travel by airline or other public carriers are required to have all travel arrangements (transportation, lodging, and rental cars) handled by the state contracted travel agent. The travel agent will send the traveler an itinerary form which will include airline, hotel, and rental vehicle confirmations. A copy of this itinerary form must be attached to the expense voucher for reimbursement. Please note that the travel agent's itinerary is different from the itinerary approval to travel described under the heading "Approval to Travel". Both itineraries are required for reimbursement. Allowable travel expenses include meals, lodging, registration fees, and other expenses that might require approval before such expenditures are incurred. More information is provided in the Title III Policy and Procedure Manual.

Travel Advances are not given to employee by the University. They are only available to students

REIMBURSEMENT FOR APPROVED TRAVEL

After travel has been taken, prepare a Voucher for Travel Reimbursement form of Expenses for Official Travel. To the voucher, attach the approved itinerary, airline ticket receipt (if reimbursement is sought), the airline travel itinerary, receipts for taxi fares, hotel accommodations, fees, and other reimbursable expenses. Secure the appropriate signature and submit the package to the Title III Program Director.

RESTRICTIONS ON TRAVEL

Expenditures for travel may not exceed 125 percent of the amount allotted for such travel by the United States Department of Education. The difference in cost between first-class air accommodations and less than first-class air accommodations are unallowable.

REPORTS ON TRAVEL WITH TITLE III FUNDS

Persons whose travel expenses are paid by the Title III grant are required to complete a "Report on Travel with Title III Funds". A copy of the report is included in the Title III Policy and Procedure Manual.

EQUIPMENT

According to regulations, equipment is tangible non expendable personal property including exempt property charged directly to the award having a useful life of more than one year and an acquisition cost of $5000 or more per unit. Education Department General Administrative Regulations (EDGAR). By University definition, however, equipment begins at a cost of $500. Additionally, the University has other restrictions that require inventory controls that must be followed.

ACQUISITION OF EQUIPMENT AND OTHER FACILITIES

The cost of permanent equipment or other facilities is allowable where such purchases are approved by the sponsoring agency concerned or provided for by the terms of the research agreement.

GENERAL PURPOSE EQUIPMENT

Approval must be obtained to acquire with Government funds any general purpose permanent equipment, i.e., any items which are usable for activities of the institution other than research, such as office equipment and furnishings, air conditioning, reproduction or printing equipment, motor vehicles, etc., or any automatic data processing equipment.

RESEARCH EQUIPMENT

Approval must be obtained to acquire with Government funds any items of permanent research equipment costing $1000 or more.

LIMITATIONS ON PURCHASE OF EQUIPMENT

Only items listed in the final approved plan of operation should be purchased without further approval from the United States Department of Education . Some changes can be authorized by the Title III Program Director, without Department of Education approval. To order equipment included in the approved final plan, complete a Requisition for Purchase form according to the instructions listed under procurement.

EQUIPMENT MANAGEMENT REQUIREMENTS

Procedures for managing equipment (including replacement equipment) until transfer, replacement, or disposition, shall meet minimum requirements. Refer to the Title III Policy and Procedure Manual for those requirements.

MOVING EQUIPMENT

Equipment is approved for use in the assigned Title III Program activity only and should be moved only if the activity is being moved to different quarters. The Title III Program Director must maintain information on the location and use of all equipment purchased with Title III funds. Each year, the Title III Office will request an inventory of equipment. The equipment must be available for inspection by the Director, by external evaluators, and by site visitors from the United States Department of Education.

All requests to move equipment should be made to the Department of Inventory. Please use the forms designated by that department which include but may not be limited to, the Request to Transfer Equipment Form and a Work Order.

IDENTIFICATION OF EQUIPMENT PURCHASED WITH TITLE III FUNDS

All equipment purchased with Title III funds must be identified with an identification strip which contains the grant number under which the equipment was purchased. Equipment strips are available in the Office of Procurement and Inventory.

SUPPLIES

"Supplies" mean all tangible personal property other than equipment. Grantees should purchase supplies from Title III funds only in amounts reasonably expected to be required for the performance of grant activities. Supplies should be procured on a timely basis to reflect use of supplies during the period of grant support. Although there is no requirement for accountability for supplies similar to that for equipment, the grantee is expected to maintain records that support the purchase, receipt, and proper charging of supplies in accordance with good management practices.

Activity directors are not allowed to establish "super card" accounts to make purchases with Title III funds.

CONSULTANTS

Before contacting a consultant, review the information contained in "Suggestions for Using Consultants Effectively". It is provided in the appendix of the Title III Policy and Procedure Manual.

Approval to use consultants other than those identified in the application for Title III funds must be procured. To use such a consultant, complete the "Contract for Consultant Services" form. Consultant tasks must be performed in accord with the objectives stated in the approved grant.

While the activity's department or division might have developed and uses a consultant form unique to its area, the T itle III Office requires the University's Contract for Consultant Services form.

USE OF UNIVERSITY PERSONNEL AS CONSULTANTS

Information on use of University personnel as consultants is provided under the heading, "Faculty Compensation for Work Performed"..

More specific and detailed procedures for travel, other expenses, and standards for documenting the use of consultants are provided in the T itle III Policy and Procedure Manual.

WORKSHOP EVALUATION

Title III participants should evaluate the effectiveness of workshops sponsored through the grant. Each workshop participant should be asked to complete an evaluation form. A summary of the evaluation should be sent to the Title III Program Director. A suggested evaluation is provided in the Title III Policy and Procedure Manual. Activity directors may, however, construct evaluation forms that relate more directly or address the objectives to be achieved by the workshop.

PROGRAMMATIC CHANGES AND BUDGET REVISIONS

Some budget and programmatic revisions require approval by the United States Department of Education. Some revisions can be made without prior approval. Programmatic and Budget Revisions that Require Prior Approval

1. Adding a new budget category that is not included in the approved budget or adding new line items to existing categories of the budget

2. Purchasing equipment that is not included in the approved budget

3. Revising project objectives or the activity's scope

4. Changing key personnel

5. Adding domestic travel that is not in the approved budget

6. ALL FOREIGN TRAVEL REQUIRES APPROVAL

REQUESTS TO REDIRECT THE USE OF FUNDS

Requests made to the United States Department of Education to redirect the use of funds should follow these guidelines:

1. The budget item to be reduced must be identified and the reduction fully justified.

2. Budget items to be increased must be identified along with the amount of the increase and the amount originally approved. The increase must be fully justified.

3. Revisions that involve the purchase of equipment must include the brand name, model description and number, and cost of each item. Purchases should be more economical than rental and lease-purchase agreements. Requests must include a cost analysis and comparison of the alternatives.

4. The letter of request must be signed by the Title III Program Director and the designated official of the Institution. A request without these signatures will not be processed.

5. The request (in triplicate) must be received at least 30 days prior to the expected implementation date.

BUDGET REVISIONS

Budget revisions that require transfer of funds among budget lines should be prepared on a Departmental Transfer Form. Departmental transfers should accompany requisitions which are for expenditures from budget lines where revisions have been made. Budget revisions should be made in accordance with the "Programmatic Changes and Budget Revisions" explained in the Title III Policy and Procedure Manual.

DEPARTMENTAL TRANSFERS

Activity directors should avoid making excessive departmental transfers. Transfers cannot be made to establish a new budget line or to increase an existing one in anticipation of increased expenditures. Only 10% of the budget may be transferred between budget line items. Transfers to lines not included in the approved grant application, require United States Department of Education approval. When Department of Education approval is requested, be prepared to wait six to eight weeks for a response. It has 45 business days from the date a request is received to respond. Only transfers that will impact achievement of the approved objectives will be approved. Departmental transfers must be made for the amount of the attached requisition only. Please note that the approved budget balance required on the transfer form is the balance after any previous transfers.

ENTERTAINMENT EXPENSES

Federal funds cannot be used for reimbursement of expenses for entertaining. Any costs incurred for amusement, social activities, and any items relating thereto, such as meals, lodging, rentals, transportation, and gratuities, are not allowable.

PROCUREMENT POLICIES

In order to obtain the goods and services needed to carry out activity objectives, follow the University's policies and procedures. Any deviation might result in delays in acquiring what is needed. When the items are on competitively bid state contracts, the commodities must be purchased from the contracted supplier at the specified prices unless there is some special exemption. Under this arrangement, orders less than $1,500 do not require bids.

More specific and detailed procedures are provided in the Title III Policy and Procedure Manual.

COMPUTER PURCHASES

In adherence to the University's centralization of microcomputer hardware and software, activity directors should consult the Division of Information Management's Office of Information Technology to discuss proposed computer acquisitions. A homogeneous computing environment is a long-range goal of the University.

MONITORING BY THE TITLE III OFFICE

The Title III Office maintains records of activity expenditures, and reviews each requisition to determine account balances before they are submitted to other University offices. Each activity director or coordinator is required to maintain individual records, of expenditures using the initiating copy of the requisition as documentation.

RECORD KEEPING AND RETENTION

The United States Department of Education requires the University to keep records that provide an accounting of all funds under the grant, how the grant funds were used, the total cost of the project, and other records to facilitate an effective audit. The University must keep records that show compliance with program requirements and records that show significant project experiences and results. These records must be retained for three years after the final financial report has been submitted for the activity for which the funds were granted.

The Secretary of Education, Inspector General of the United States, or any of their authorized representatives have the right of access to any books, documents, papers, or other records of the grantee which are pertinent to the grant, in order to make audit, examination, excerpts, and transcripts. The right of access is not limited to the required retention period but lasts as long as the records are retained.

REPORTING PROGRESS IN ACHIEVING TITLE III OBJECTIVES

Internal evaluations are required by the United States Department of Education. Jackson State University also conducts external evaluations for its Title III grants. Each program, function, or activity is reviewed to assure that adequate progress is being made toward achieving the grants' goals. Internal evaluations will be carried out through quarterly monitoring reports, through annual progress reports, and through Title III activity reviews. External evaluations will be bi-yearly. External evaluators will determine progress in achieving the objectives in the approved application; the effectiveness of individual activities in meeting the purposes of the program, and the effect of projects and activities on the persons being served by the projects.

INTERNAL EVALUATION

Quarterly Reports of Progress . In order to provide systematic documentation of the achievement of objectives for each activity of the grant, activity directors are required to complete a report of progress in achieving grant objectives. The reports are to be placed on the forms provided by the Title III Office. They will be due each quarter according to the schedule that follows. A copy of the form is provided in the appendix of the Title III Policy and Procedure Manual.

Quarter	Period	Due Date
First	October-December	End of the First Week of January
Second	January-March	End of the First Week of April
Third	April-June	End of the First Week of July
Fourth	July-September	End of the First Week of October

Annual Performance Report . In addition to the quarterly report, each activity director will submit an evaluation of the extent to which objectives have been met during the grant year. Because this report is submitted in adherence to requests by the United States Department of Education, its content and submission date might vary. This report will be announced and disseminated by the Title III Program Director.

EXTERNAL EVALUATION

Both Title III Program grants and their individual grant activities are evaluated by a team of independent external evaluators. The evaluation team conducts both formative and summative evaluations. Evaluators look at all aspects of grant activities, including a comparison of actual accomplishments to the goals established for the period, documentation, and project expenditures, as well as effect of the project on strengthening the University.

OBLIGATION OF FUNDS DURING THE GRANT PERIOD

The University may use grant funds only for obligations it makes during the grant period. All requisitions should be submitted in ample time for the obligation to be made within the grant period.