Policies & Procedures

LATAG Policies and ProceduresThis manual details LATAG's goal to make certain that the cleanup of Libby Amphibole (LA) contamination (which resulted from W. R. Grace mine and exportation sites) is comprehensive, complete and timely elimination of the LA threat to human health and the environment. The manual is divided into three sections which can be accessed by the table of contents on the top right.

 

Libby Area Technical Assistance Group, Inc.

Administrative Policy and Procedures Manual

Section II Financial Affairs

Series A: Internal Controls

Organizational Policy

  1.  Budget

    1. At the beginning of the grant fiscal year, the Board shall review the current Grant project period total operating budget.  This review shall ensure LATAG funding is used primarily for the intended purpose (interpretation and communication of site related technical data to the affected community).  The review additionally will serve to ensure administrative expense (such as record keeping and accounting activities) comprise no greater than 20% of the Grant total budgeted project period outlay; and that LATAG's matching share (in-kind contributions) comprise no less than 20% of the Grant total budgeted project period outlay. Expenditure of Federal share funded levels of work beyond that approved and budgeted under current Grant terms, shall not be undertaken until suitable amendment to Grant period total funding has been authorized by the Federal Government (EPA), embracing the identified variance to the projected total Grant program outlay.  Expenditures outside approved Grant period total budget constraints shall be approved by the Board prior to expenditure per the foregoing.  Changes to approved elements within approved Grant period total budget constraints (transfers, leveling, etc.) may be accomplished by the Finance Committee without resolution of the Board and observing Grant cost share policy.

  2. Bank Statements

    1. Bank Statements will be reconciled by the LATAG Treasurer, or his/her designee, who will in turn, compile a treasurer’s report that will be distributed to the Finance committee for review and copies made available to all Board Members at the regular monthly meeting.

  3. Deposits

    1. All deposits will be made by the LATAG Treasurer or her/his designee.

  4. Check Disbursements

    1. The LATAG Chair, Vice Chair, Secretary and Treasurer are the only individuals authorized to sign checks on behalf of the organization. Two (2) signatures are required on any check of $500 or more.

  5. Non-Budgeted Expenditures

    1. Any expenditure that is not a part of an approved budget must be approved by the Executive Officers prior to issuance of a check.

Series B: Financial Reports

  1.  Reports Preparation

    1. Financial reports will be prepared for any month that expenditures exceed $500 or if less than $500 a month, on a quarterly basis by the Treasurer or his/her designee. Once approved, the Treasurer will notify the Board Members, and file a reimbursement request with necessary attachments for outstanding federal share reimbursement.

  2. Federal Tax Reporting

    1. LATAG’s fiscal year will run from January through December each year. The Treasurer or his/her designee is responsible for preparing the federal reports and submitting them to the Finance Committee for approval prior to filing.

  3. Audit

    1. The Treasurer or his/her designee will arrange for a financial audit to be performed yearly, in accordance with requirements of generally accepted auditing standards and requirements of the EPA grant. Results of the audit will be presented to the Board.

Series C: Purchasing

  1.  Organizational Policy

    1. It is the policy of the LATAG Board of directors to contract goods and services on behalf of the organization without favoritism and to seek maximum value for every dollar expended.  All procurements will be made providing economy, consistency and compliance with Federal and State Regulations in purchasing, with appropriate flow-down of ineligible activities and certification requirements ( i.e. Partisan Political Activity, Conducting disputes with EPA, Generation of New Primary Data, Serving as an Expert Witness, Lobbying & Litigation, Drug-Free, Debarment & Suspension, SBE/MBE/WBC compliance).  Additionally, all LATAG procurements shall be compliant with procedures and practices defined in Superfund Technical Assistance Grant (TAG) Handbook: Procurement - Using TAG Funds, EPA 540-K-93-005, publication 9230.1-09C (most current revision) which in part requires the following:

  2. Competitive Procurements

    1. For procurements valued $1,000 or less, determine only that the price is reasonable.  No oral or written solicitations of bids are necessary.
    2. For procurements valued at more than $1,000 but less than $25,000 solicit quotes from two (2) or more qualified sources, providing documentation of this in files.
    3. For procurements valued at least $25,000 but not more than $50,000 solicit written bids from three or more sources.  After receiving bids, evaluate them, decide on the winning bid, and inform all bidders of the decision.
    4. For procurements valued at over $50,000 procurement rules outlined in CFR Part 33 must be followed.

  3. Noncompetitive Procurements

    1. Noncompetitive procurement is allowed when there is only one qualified candidate, or if solicitation effort yields only one bidder.
    2. EPA Grant award Officer prior written approval is required before awarding a noncompetitive contract or using this method to procure goods worth over $1,000.
    3. Before awarding any contract valued over $1,000, inform the EPA project officer of the proposed contract and provide EPA with the opportunity to review the selection process the contract.
    4. Achieve EPA Grant Small Business Enterprises (SBE's) procurement placement objectives, and Minority-Owned Business Enterprises (MBE's) and Women-Owned Business Enterprises (WBE's) "fair share" goals negotiated with EPA by the Montana Department of Environmental Quality.

  4. Payment

    1. Procurements will be made on a reimbursable basis.  Purchaser should obtain approval and verification that funding is allocated for such purchases and that the item is provided for under the approved budget. Purchaser must submit a receipt to the Treasurer or his/her designee. All Federal Share receipts/billings are subject to EPA review/approval and will have appropriate reimbursement made within 30 days of LATAG's receipt of expense reimbursement from the EPA.  Receipts/billings against non-federal share budget allocations (in-kind matching contribution) will be paid within a regular 30-day payment cycle upon receipt.

Series D: Planning

Organizational Policy

  1.  Renewing the Three-Year Grant

    1. If the technical assistance project extends beyond the first budget period and funds are remaining, and the Board of Directors desires to continue, a continuation application for the budget period will be prepared and submitted.
    2. If the LATAG Board wants to request additional funding after having spent the full $50,000 in federal funds, a continuation application will be prepared and submitted.  A waiver to obtain additional funds described in (2) below will also be prepared and submitted.

  2. Waiver of Grant $50,000 Limitation

    1. The Board of directors shall monitor/track the complexity of Libby Superfund Site-related issues for need of additional technical advisory assistance, determine if it believes funds are needed over and above the current grant federal share $50,000 ceiling and apply for a waiver from this limit as circumstances warrant for the EPA to approve such a waiver, to receive $50,000 in additional TAG funds.  Such a request must be approved by the EPA's Regional Office with Grant funding suitably amended before any expenditure against federal share in excess $50,000 (current funding) will be allowed.
    2. After receiving $50,000 in additional funds, the LATAG Board feels that more funding is necessary in order to continue its effective participation in Libby Superfund Site cleanup activity decisions; it may request deviation from the $100,000 total per site limitation.  Such a request must be approved first by EPA's Regional Office and then by the EPA's Headquarters Grants Division with Grant funding suitably amended before any expenditure against federal share $100,000 (prior revised) funding will be allowed.

Libby Area Technical Assistance Group, Inc.
Administrative Policy and Procedures Manual

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