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11-21-2019 Special Commission Meeting Agenda City Manager City Commission Ronald J.Wasson ]Enid Weisman,Mayor Marc Narotsky,Vice Mayor City Clerk Denise Landman,Commissioner ;; ]Elllisa L.Horvath,MMC Dr.Linda Marks,Commissioner i Gladys Mezrahi,Commissioner City Attorney Robert Shelley,Commissioner Weiss Scrota Helfman Howard Weinberg,Commissioner e �� Cole&Bierman CITY COMMISSION SPECIAL MEETING AGENDA NOVEMBER 21, 2019 Following 9:00 a.m. Commission Workshop Executive Conference Room Aventura Government Center 19200 West Country Club Drive Aventura, Florida 33180 1. CALL TO ORDER\ROLL CALL 2. RESOLUTIONS: A. A RESOLUTION OF THE CITY COMMISSION OF THE CITY OF AVENTURA, FLORIDA AWARDING AND LETTING A BID/CONTRACT FOR BID NO. 20-10-17- 3, CITY OF AVENTURA MUNICIPAL TRANSIT SERVICES FOR CITY WIDE SHUTTLE SERVICE TO RTW MANAGEMENT FOR THE INDIVIDUAL BID PRICE AS CONTAINED IN EXHIBIT "A" ATTACHED; AUTHORIZING THE CITY MANAGER TO EXECUTE ASSOCIATED CONTRACT;AUTHORIZING THE CITY MANAGER TO TAKE NECESSARY AND EXPEDIENT ACTION TO CARRY OUT THE AIMS OF THIS RESOLUTION; PROVIDING FOR THE APPROPRIATION AND ALLOCATION OF FUNDS FOR SAID BID AWARD; AND PROVIDING FOR AN EFFECTIVE DATE. B. CITY COMMISSION, ACTING IN ITS CAPACITY AS THE CITY COMMISSION AND THE GOVERNING BOARD FOR THE DON SOFFER AVENTURA HIGH SCHOOL: A RESOLUTION OF THE CITY COMMISSION OF THE CITY OF AVENTURA, FLORIDA, ACTING IN ITS CAPACITY AS THE GOVERNING BOARD FOR THE DON SOFFER AVENTURA HIGH SCHOOL, APPROVING THE ATTACHED CHARTER SCHOOLS USA CHARTER SCHOOL PROGRAM (CSP) GRANT POLICIES AND PROCEDURES MANUAL; AUTHORIZING THE EXECUTION OF NECESSARY DOCUMENTS; PROVIDING FOR IMPLEMENTATION; AND PROVIDING FOR AN EFFECTIVE DATE. 3. ADJOURNMENT This meeting is open to the public.In accordance with the Americans with Disabilities Act of 1990,all persons who are disabled and who need special accommodations to participate in this meeting because of that disability should contact the Office of the City Clerk,305-466-8901,not later than two days prior to such proceeding. One or more members of the City of Aventura Advisory Boards may be in attendance and may participate at the meeting. Anyone wishing to appeal any decision made by the Aventura City Commission with respect to any matter considered at such meeting or hearing will need a record of the proceedings and, for such purpose, may need to ensure that a verbatim record of the proceedings is made,which record includes the testimony and evidence upon which the appeal is to be based. Agenda items may be viewed at the Office of the City Clerk, City of Aventura Government Center, 19200 W. Country Club Drive,Aventura,Florida,33180. Anyone wishing to obtain a copy of any agenda item should contact the City Clerk at 305-466-8901. CITY OF AVENTURA PUBLIC WORKS/TRANSPORTATION DEPARTMENT MEMORANDUM TO: City Commission FROM: Ronald J Wasson, City Manage; BY: Joseph S Kroll, Public Works/Transportation Director // p p �, - DATE: November 15, 2019 SUBJECT: Bid No. 20-10-17-3 - City of Aventura Municipal Transit Services November 21, 2019 City Commission Workshop Recommendation: It is recommended that the City Commission adopt the attached Resolution awarding Bid No. 20-10-17-3 City of Aventura Municipal Transit Services to the lowest responsible and responsive bidder; RTW Management for the amount $1,270,000.00 per year. Background: The bidding process was in accordance with the City's Purchasing Ordinance. Bids for this maintenance contract were solicited, advertised and opened on Monday, October 28, 2019 at 3 PM. Two qualified bids were received as follows: RTW Management $1,270,000.00 Limousines of South Florida $1,419,774.00 The proposals were based on qualifications for work to be performed in areas of Public Transit within the City limits for residents and visitors for predetermined stops throughout the City and on an as-needed basis determined by the City for special events. This is a widely used service with approximately 24,000 riders per month. JSK/gf Attachments: Exhibit"A" Bid Tabulation Sheet Exhibit "B" General Questions Responses JSK19018 RESOLUTION NO. 2019- A RESOLUTION OF THE CITY COMMISSION OF THE CITY OF AVENTURA, FLORIDA AWARDING AND LETTING A BID/CONTRACT FOR BID NO. 20-10-17-3, CITY OF AVENTURA MUNICIPAL TRANSIT SERVICES FOR CITY WIDE SHUTTLE SERVICE TO RTW MANAGEMENT FOR THE INDIVIDUAL BID PRICE AS CONTAINED IN EXHIBIT "A" ATTACHED; AUTHORIZING THE CITY MANAGER TO EXECUTE ASSOCIATED CONTRACT; AUTHORIZING THE CITY MANAGER TO TAKE NECESSARY AND EXPEDIENT ACTION TO CARRY OUT THE AIMS OF THIS RESOLUTION; PROVIDING FOR THE APPROPRIATION AND ALLOCATION OF FUNDS FOR SAID BID AWARD; AND PROVIDING FOR AN EFFECTIVE DATE. WHEREAS, the City Manager of the City of Aventura, Florida has, pursuant to the various laws of the State of Florida and the Code of the City of Aventura, properly solicited and accordingly accepted bids for BID NO. 20-10-17-3 CITY OF AVENTURA MUNICIPAL TRANSIT SERVICES FOR CITY WIDE SHUTTLE SERVICE; and WHEREAS, sealed bids have been submitted to and received by the City pursuant to the City's invitation to bid/notice to bidders, specifications, proposals and requirements for the project/work as cited above; and WHEREAS, staff has determined that RTW Management has submitted the lowest responsible and responsive bid for said project/work; and WHEREAS, the City Commission, upon the recommendation of the City Manager, is therefore desirous of awarding said bid/contract to said lowest responsible and responsive bidder. NOW THEREFORE, BE IT RESOLVED BY THE CITY COMMISSION OF THE CITY OF AVENTURA, FLORIDA: Section 1. That bid/contract for BID NO. 20-10-17-3, CITY OF AVENTURA MUNICIPAL TRANSIT SERVICES FOR CITY WIDE SHUTTLE SERVICE is hereby awarded to RTW Management, at the bid price as contained in the attached bid documents. City of Aventura Resolution No. 2019- Section 2. That the City Manager is hereby authorized to execute, on behalf of the City, a contract by and between the party embodying the terms, conditions, and specifications as set forth in the subject Invitation to Bid/Notice to Bidders, bid specifications, bid proposal and bid requirements, or if a City prepared contract was part of said bid proposal, said parties shall execute said prepared contract on behalf of the City. Section 3. That the City Manager is hereby authorized and requested to take all necessary and expedient action to carry out the aims of this Resolution in awarding this bid/contract. Section 4. That the funds to be allocated and appropriated pursuant hereto and for the purpose of carrying out the tenets of this Resolution shall be from Budget Line Item Number account no. 120-5401-541.34-55. Section 5. That this Resolution shall become effective immediately upon its adoption. The foregoing Resolution was offered by Commissioner , who moved its adoption. The motion was seconded by Commissioner , and upon being put to a vote, the vote was as follows: Commissioner Denise Landman Commissioner Dr. Linda Marks Commissioner Gladys Mezrahi Commissioner Robert Shelley Commissioner Howard Weinberg Vice Mayor Marc Narotsky Mayor Enid Weisman PASSED AND ADOPTED this 21th day of November, 2019. Page 2 of 3 City of Aventura Resolution No. 2019- ENID WEISMAN, MAYOR ATTEST: ELLISA L. HORVATH, MMC CITY CLERK APPROVED AS TO LEGAL SUFFICIENCY: CITY ATTORNEY Page 3 of 3 CITY OF AVENTURA BID TABULATION MUNICIPAL TRANSIT SERVICES Bid # 20-10-17-3 Bid Opening After 3:00 pm on Monday, October 28, 2019 Limousines of RTW South Florida MANAGEMENT TOTAL ANNUAL FEE FOR EACH TWELVE MONTH PERIOD FOR FIXED ROUTE A. SERVICES $1,419,774.00 $1,270,000.00 B. PER HOUR COST FOR FIXED-ROUTE MINIBUS SERVICE AS REQUESTED BY THE CITY $ 64.50 $ 60.00 PER HOUR COST OF 32 PASSENGER BUS SERVICE FOR CITY SENIOR C. TRAVEL PROGRAMS TO AREA ATTRACTIONS AND MUSUEMS, ETC; $ 95.00 $ 70.00 APPROXIMATELY 12 PER YEAR D PER HOUR COST OF MINI BUS SERVICE FOR SPECIAL EVENTS WITHIN THE C17Y $ 64.50 $ 70.00 Providing Mini Bus Service using Alternate Fuels Hourly Hourly Fee Annual Fee Fee Annual Fee Propane N/A N/A N/A N/A Compressed Natural Gas N/A N/A $140,000. SAME HRLY - RATE APPLY Hybrid-Electric N/A N/A N/A N/A Electric N/A N/A $900.000. SAME HRLY RAPE,APPLY Alternate As the Total additional fee Per Hour for providing service using Low Floor # 1: Buses (Indicate Mfg. & Model confirm it has been Altoona tested as a 5 year N/A BLANK vehicle) AS THE TOTAL ADDITIONAL FEE PER HOUR FOR PROVIDING AUTOMATED Alternate PASSENGER COUNTING CAPABILITY AND INFORMATION AS DESCRIBED IN $1.10 $0.66 # 2: SECTION 3 of 3.5 (4) OF THE SPECIAL CONDITIONS AS THE TOTAL ADDITIONAL FEE PER HOUR FOR PROVIDING SECURITY Alternate CAMERAS AS DESCRIBED IN SEC I ION 3.3.2.2 (P) OF THE SPECIAL $0.85 NO FEE(WE ALWAYS USE # 3: CONDITIONS THESE CAMERAS) Offers listed from the vendors herein are the only offers received timely as of the above opening date and time. All other offer submitted in response this solicitation, if any, are hereby rejected as late. OCTOBER 28 2019 INDRA SARJU, PURCHASING ACiENT DATED Joseph Kroll From: Indra Sarju Sent: Friday, November 1, 2019 10:38 AM To: Joseph Kroll Subject: Fw: Bid#20-10-17-3 - Municipal Transit Services Questions See below for RTW Response Indra K Sarju, CPPB Purchasing Agent City of Aventura 19200 W. Country Club Drive Aventura, FL 33180 Phone #:305-466-8925 Fax#: 305-466-8939 Email: sarjui(r)cityofaventura.corn From:George Goates<ggoates@rtwmanagement.com> Sent:Thursday,October 31, 2019 2:57 PM To: Indra Sarju<sarjui@cityofaventura.com> Subject: RE: Bid#20-10-17-3-Municipal Transit Services Questions Indra, I apologize for the delay. I was helping the City of Scottsdale with their NTD reporting. Below are our answers to the City's questions: 1.Where is your company's base station going to be located in Aventura, FL? 2126 Fillmore St, Hollywood, FL 33020 2.Who will be your firm's on-site supervisor for complaints and scheduling? Dylan Heimer will be on site full time. Dylan is the second in charge at our Scottsdale operations where he,along with the site manager,oversees 51 drivers and twenty one buses in a seven-day-per-week operation. Dylan is more than ready to manage an operation of this size. Dylan holds a CDL, in case he ever needs to drive.We have protocol in place to ensure that he does not need to drive, but he is there as the ultimate backstop. Dylan has developed an excellent rapport with our passengers in Scottsdale and we are excited about the prospect of his services in Aventura. 3. Is your company aware that the buses for gas engines have to be replaced after they reach 125,000 miles? Yes,we read that in addendum#3. RTW replaces buses every five years,which normally reflects our contract term. 125,000 miles per bus, based on the current number of miles the contract requires is just under five years of driving. In order to say under 125,000 miles during the first five years, RTW will have to rotate in an eighth bus.This will not be a problem. RTW operates a fleet of 63 vehicles most of them are Ford/Starcraft cutaway buses. 4.Where will the bus services and maintenance be done? RTW has a fleet maintenance agreement with Ford. Metro Ford will maintain our vehicles to the strictest manufacturer's recommendation and use only Ford OEM parts.Air conditioning in these buses can be challenging especially in heat and humidity,so we will use Creative Bus Sales in Davie, because they are experts in Bus AC,which has distinct challenges of long hoses and a large volume to keep cool. RTW knows these buses well and how to keep then running in top shape. Because we don't run buses past five years,we limit the potential problems the vehicle may have. 5.Does your firm's have any reference that is located in South Florida? RTW does not have any current operations in South Florida, but in the last 24 months, RTW has taken over three operations:Scottsdale,AZ; Dallas,TX;and Baltimore, MD. In all three instances RTW has performed much better than the previous operator. Please reach out to any of our customers to learn more about what it is like to work with RTW. RTW has three keys to success: Recruiting,Structure and Monitoring. RTW spends a lot of time and effort to recruit the best talent pool possible. Our HR calls inbound job applicants within 15 minutes and sets up an in-person interview as quickly as possible. RTW has clear processes and procedures,so that drivers know what to do in all situations. We also connect drivers to a manager via radio, in case the driver needs any assistance. RTW monitors the speed,safety and courteous driving habits of drivers. Drivers receive real-time feedback for any unsafe habits,which is the most effective way to create safe drivers. Please let me know if you have any further questions or need any additional information. I am available anytime to discuss. Kind regards, George Goates I President Email:ggoates@RTWmanagement.com Direct:801.819.3691 Website: www.RTWManagement.com From: Indra Sarju<sarjui@cityofaventura.com> Sent:Wednesday,October 30, 2019 7:25 AM To:George Goates<ggoates@rtwmanagement.com> Subject: Re: Bid#20-10-17-3-Municipal Transit Services Questions Will do. Indra K Sarju, CPPB Purchasing Agent City of Aventura 19200 W. Country Club Drive Aventura, FL 33180 Phone #:305-466-8925 Fax#: 305-466-8939 Email: sarjuiccityofaventura.con7 From:George Goates<ggoates@rtwmanagement.com> Sent:Tuesday,October 29,2019 1:07 PM To: lndra Sarju<sarlui@citvofaventura.com> Subject: RE: Bid#20-10-17-3-Municipal Transit Services Questions Indra, 2 Thanks for the note. I'll get back with you ASAP. If any additional questions come up, please feel free to add them to the list. Best, George 801.819.3691 From: Indra Sarju<sarjui@cityofaventura.com> Sent:Tuesday, October 29, 2019 8:56 AM To:George Goates<ggoates@rtwmanagement.com> Subject: Bid#20-10-17-3-Municipal Transit Services Questions Importance: High Good Morning Mr. Goates; Attached is listed of questions that the City would to have answers, please respond on or before 4:00 PM, Thursday, October 31, 2019. Thank you. Indra K .Saiju, CPPB Purchasing Agent City of Aventura 19200 W. Country Club Drive Aventura, FL 33180 Phone #:305-466-8925 Fax#: 305-466-8939 Email: sarjui(c cityofaventura.com 3 CITY OF AVENTURA OFFICE OF THE CITY MANAGER MEMORANDUM TO: City Commission FROM: Ronald J. Wasson, City Manager DATE: November 15, 2019 SUBJECT: Resolution Approving Charter Schools USA Charter School Program (CSP) Grant Policies and Procedures Manual November 21, 2019 Special City Commission Meeting Agenda Item c RECOMMENDATION Charter Schools USA requests approval of their Charter School Program (CSP) Grant Policies and Procedures Manual so it can be submitted to the Miami-Dade School District for Charter School Compliance and Support. In your capacity as the Governing Board for the Don Soffer Aventura High School, I recommend approval of this manual. If you have any questions, please feel free to contact me. RJW/ Attachment RESOLUTION NO. 2019- A RESOLUTION OF THE CITY COMMISSION OF THE CITY OF AVENTURA, FLORIDA, ACTING IN ITS CAPACITY AS THE GOVERNING BOARD FOR THE DON SOFFER AVENTURA HIGH SCHOOL, APPROVING THE ATTACHED CHARTER SCHOOLS USA CHARTER SCHOOL PROGRAM (CSP) GRANT POLICIES AND PROCEDURES MANUAL; AUTHORIZING THE EXECUTION OF NECESSARY DOCUMENTS; PROVIDING FOR IMPLEMENTATION; AND PROVIDING FOR AN EFFECTIVE DATE. WHEREAS, the City's Don Soffer Aventura High School (DSAHS), a municipal charter school, desires to adopt the attached Charter Schools USA Charter School Program (CSP) Grant Policies and Procedures Manual as required by certain grant applications; and WHEREAS, the City Commission, acting in its capacity as the governing board of DSAHS, finds that approval of the attached Charter Schools USA CSP Grant Policies and Procedures Manual is in the best interest of the City. NOW THEREFORE, BE IT RESOLVED BY THE CITY COMMISSION OF THE CITY OF AVENTURA, FLORIDA, AS FOLLOWS: Section 1. That the foregoing "WHEREAS" clauses are ratified and confirmed as being true and correct and are made a specific part of this Resolution. Section 2. That the Charter Schools USA CSP Grant Policies and Procedure Manual, as attached hereto, is hereby approved and adopted by the City Commission of the City of Aventura, Florida, acting in its capacity as the governing board for the Don Soffer Aventura High School. Section 3. That the proper City and School officials are hereby authorized to execute the Charter Schools USA CSP Policies and Procedure Manual, in substantially the form attached hereto. Section 4. That the City Manager is hereby authorized to do all things necessary to carry out the aims of this Resolution. Section 5. That this Resolution shall take effect immediately upon adoption. The foregoing Resolution was offered by Commissioner , who moved its adoption. The motion was seconded by Commissioner , and upon being put to a vote, the vote was as follows: Commissioner Denise Landman Commissioner Dr. Linda Marks Commissioner Gladys Mezrahi Commissioner Robert Shelley Commissioner Howard Weinberg Vice Mayor Marc Narotsky Mayor Enid Weisman City of Aventura Resolution No. 2019- PASSED AND ADOPTED this 21st day of November, 2019. ENID WEISMAN, MAYOR ATTEST: ELLISA L. HORVATH, MMC CITY CLERK APPROVED AS TO LEGAL SUFFICIENCY: CITY ATTORNEY Page 2 of 2 *4.10 A4p%� CHARTER SCHOOLS, USA Charter School Program Grant Policies & Procedures Manual TABLE OF CONTENTS Preface................................................................Page 3 Conflict of Interest Policy...........................................Pages 3-6 Member Annual Conflict of Interest Form........................Page 7 Purchasing Policy......................................................Pages 8-14 Internal Controls.............................. ........................Pages 15-17 Accounting, Reporting, and Inventory Control...... ............Pages 18-25 Enrollment and Admissions Policy......... ............ ...........Pages 26-27 Governing Board Approval of Revised Procedure Manual.....Page 28 2 PREFACE Don Soffer Aventura High School (DSAHS or "School") is a municipal charter school of the City of Aventura(the "City"). DSAHS is subject to the regulations of the City as applicable. DSAHS' School Charter with the Miami- Dade County School Board, and the City Code's procurement and ethics requirements, and the applicable provisions of the Miami-Dade County Ethics Code, shall be incorporated herein. In the event of a conflict, the stricter provisions shall control and be applied. CONFLICT OF INTEREST POLICY City of Aventura Board of Commission Article I Purpose The City Commission serves as the Governing Board of Directors for DSAHS. As members of the DSAHS Board of Directors ("Members" or collectively the "Governing Board"), the City Commissioners, individually and collectively, shall be subject to the provisions of Florida law pertaining to the avoidance of conflicts of interest in holding public office, including,but not limited to, Part III of Chapter 112, Florida Statutes, Code of Ethics for Public Officers and Employees, as may be amended from time to time. The purpose of this Conflict of Interest Policy is to define Member obligations and ensure Governing Board compliance with the law. This policy is intended to supplement but not replace any applicable state and federal laws governing conflict of interest applicable to nonprofit and charitable organizations. Article II Prohibited Financial Interest 1. Prohibited Financial Interest Prohibited Financial Interests are deemed a Conflict of Interest. Members shall not have a financial interest in the School either directly or indirectly, through business, employment, investment, or family. Such prohibited financial interests include: a An ownership interest or investment in any entity with which the School has a transaction or arrangement; b. A compensation arrangement with the School or with any entity or individual with which the School has a transaction or arrangement;or c. A potential ownership or investment interest in, or compensation arrangement with, any entity or individual with which the School is negotiating a transaction or arrangement. Compensation includes direct and indirect remuneration as well as gifts or favors. Soliciting gifts or favors from vendors, entities or individuals seeking, or who are in a position to seek, business from the School is likewise prohibited. 3 This provision does not prohibit a Member from performing services for or being employed by another governmental entity, which has a contract with DSAHS. Such employment does not necessarily implicate a conflict. Each scenario will be subject to ethics review to receive a case-by-case determination. Members will receive training on this topic during the Governing Board's annual ethics training. 4 Article III Procedures Conflict of Interest 1. Duty to Disclose In connection with any conflict of interest with an item of Governing Board action, a Member must disclose the existence of the conflict prior to any vote on such action. 2. Recusal of Self A Member must recuse himself or herself from involvement in any decision or discussion regarding any action in which the Member believes he or she has a conflict of interest, and absent him/herself from the meeting for that item. 3. Violations of the Conflicts of Interest Policy a If, after hearing the Member's response and after making further investigation as warranted by the circumstances, the Governing Board or committee determines the Member has failed to disclose an actual or possible conflict of interest, it shall take appropriate disciplinary and corrective action. The Governing Board shall adhere to applicable City rules and regulations for violations of this Conflict of Interest policy. Article IV Records of Proceedings The minutes of the Governing Board shall contain: a. The names of the persons who disclosed or otherwise were found to have a conflict of interest relating to a Governing Board action. b. The names of the persons who were present for discussions and votes relating to the action, the content of the discussion, and a record of any votes taken in connection with the proceedings. Article Comnensation No Member shall receive compensation, directly or indirectly, from the School. Article VI Annual Statements 1. Each Member shall annually sign a statement which affirms such person: a. Has received a copy of the conflicts of interest policy. b. Has read and understands the policy. c. Has agreed to comply with the policy. 2. The Governing Board shall regularly and consistently monitor and enforce compliance 5 with this policy by reviewing annual statements and taking such other actions as are necessary for effective oversight. 6 Member Annual Conflict of Interest Statement Name: Date: I affirm the following (please initial): I have received a copy of the Organization's Conflict of Interest Policy. (initial) I have read and understand the policy. (initial) I agree to comply with the policy. (initial) Member PURCHASING POLICY Procurement Standards/Expenditure of Grant Funds - Expenditures of grant funds shall be through the purchasing, finance or payroll department processes in place of non❑grant funds, but shall have additional requirements as noted below to ensure full compliance with federal cost principles. General Procurement Standards-CSUSA shall comply with all Education Department General Administrative Regulations (EDGAR) federal regulations in the management of federal grant awards and state❑administered grants. All purchases of equipment,materials and supplies will be made in accordance with all applicable laws and regulations, including state guidance where applicable (e.g., Chapter 287, Florida Statutes), 2 CFR §200.318(a), Governing Board policy and any school purchasing procedures. All employees involved in purchasing are expected to be familiar with these requirements. The CSUSA Charter Fiscal Agent will ensure that written specifications for desired products are descriptive, clear and incorporate the quality requirements and service needs of CSUSA schools. Unless otherwise mandated by federal or state guidance, once proper procurement protocol is adhered to,CSUSA does not require a minimum number of bids, proposals or quotes required for the selection of vendor from whom to purchase apparatus, goods, supplies and equipment (whether formally or informally bid). However, the Governing Board encourages the School Operations Administrator(SOA)or Procurement Manager to obtain at least two (2)bids, proposals or quotes when feasible. Except as otherwise required by law or specified by the Governing Board,the CSUSA Director of Procurement is delegated the authority to award contracts for the purchase of equipment, material and supplies, involving amounts up to $100,000. Any purchases or contracts involving expenditures greater than this amount must be approved by the Governing Board. The CSUSA Director of Procurement and any additional staff deemed appropriate by the director will review submissions of bids, proposals or quotes to determine if they are responsive to the CSUSA school specifications and will make recommendations to the director. The director will award the contract based upon such recommendations or will make a recommendation to the Governing Board for award of the contract. The Grant Coordinator must approve purchases over $3,000 prior to encumbrance. The SOA and or Federal Grant Coordinator may authorize up to$3,000 without prior approval of the director as allowed per the school's budget(including local, state and federal approved budgets). The Grant Coordinator may approve small local and state purchases up to$500 per the school's budget. Equipment,materials and supplies are purchased in accordance with the following requirements. Formal Bids($90,000 or more)-The purchase of apparatus, supplies,materials or equipment for expenditures of$90,000 or more must be secured through the competitive bid process governed by federal and state guidance(e.g., Section 287.057,Florida Statutes). The Procurement Manager or State Director, in consultation with the C S U S A Director of Procurement and City Manager is authorized to determine the best method for formally bidding a product or,as appropriate,utilizing one of the exceptions to formal bidding as provided below in section E. The Procurement Manager will oversee the use of any purchasing method and will ensure that all state requirements are met, including advertisement,sealed bids,maintaining records and public opening of bids. The Governing Board authorizes the use of newspaper advertisement, electronic advertisement or both for formal bids;however,the Procurement Manager has the authority to determine which method will be used for a specific purchase or categories of purchases. Awards will be made to the lowest responsible bidder(s)whose bid/proposal meets the requirements and criteria 8 set forth by CSUSA schools, taking into consideration quality, performance and the time specified in the proposal for the performance of the contract. 9 To be eligible for an award of a contract subject to federal and state guidance, the contractor and its subcontractors, if any, must demonstrate compliance with all applicable provisions of federal and state guidance,including the responsibility to use E-Verify.All contracts awarded must be in writing. The Governing Board permits the use of the following processes for contracts that require formal bidding. 1. Competitive Sealed Bids—A competitive sealed bid(or invitation to bid) may be used to request the cost of particular goods by providing detailed specifications in advance. 2. Reverse Auction-Pursuant to federal and state guidance,(1),CSUSA schools may use reverse auctions as an alternative to sealed bid procedures. For purposes of this policy,reverse auction means a real-time purchasing process in which bidders compete to provide goods at the lowest selling price in an open and interactive environment. The Procurement Manager or State Director in consultation with the CSUSA Director of Procurement,will determine whether reverse auctions are appropriate for a specific purchase or category of purchases. To conduct a reverse auction,the Procurement Manager may use a third parry, may use the state's electronic procurement system or,if appropriate equipment is available,may conduct the auction via school equipment. 3. Exceptions to Formal Bids—Any of the processes outlined below in section E can be used in lieu of formal bidding,if all requirements of state law are met. Informal Bids($5,000 to$90,000)-The purchase of apparatus,supplies,materials or equipment for expenditures of $5,000 to $90,000 must be secured through the informal bidding process governed by federal and state guidance. The Procurement Manager, in consultation with the State Director and City Manager is authorized to determine the best method for informally bidding a product. The Procurement Manager will oversee the use of any purchasing method and will ensure that all state requirements are met, including maintaining records of all bids submitted. Awards will be made to the lowest responsible bidder(s) whose bid or proposal meets the requirements and criteria set forth by CSUSA schools,taking into consideration quality,performance and the time specified in the proposal for the performance of the contract. 1. Competitive Sealed Bids—Informal bid requirements may be met using sealed bids. The purchasing officer may utilize the methods for formal competitive bids provided in section A or may determine other appropriate methods for soliciting sealed bids. The bid specifications will include the time, date and place for opening bids. No advertisement for bids is necessary (unless the formal bid process is used);however,the purchasing officer may advertise for bids as he/she deems appropriate. 2. Quotations — Informal bid requirements may be met by the solicitation of quotes from prospective vendors. Quotations may be solicited and submitted via telephone, fax, email or website. Telephone quotes must be placed in writing before a final contract will be awarded. Written quotations must be on the vendor's letterhead or an official quotation. 3. Reverse Auction—A reverse auction may be used to solicit informal bids, consistent with the process provided in Formal Bids,Reverse Auction explained above. 4. Exceptions to Informal Bids—Any of the processes outlined below in section E can be used in lieu of informal bidding,if all requirements of state law are met. Purchases for less than$5,000 1. Micro Purchases 2 CFR§ 200.67-Acquisition of supplies,the aggregate dollar amount of which does not exceed$10,000(or$2,000 in the case of acquisitions for construction subject to the Davis- Bacon Act or$2,500 for acquisitions involving services). Micro-purchases may be awarded without soliciting competitive quotations but must be distributed equitably among qualified suppliers. Equitability will 10 be ensured through electronic bidding, maintenance and use of various catalogs and requests for good or services via the school website, and solicitation to various vendors, especially small, minority women-owned businesses and labor surplus area firms. 2. Purchases for equipment, materials and supplies costing less than $5,000, but more than $3,000, purchases will be made under conditions,which foster competition among potential vendors. Purchase decisions should be made after considering price, quality, suitability for specified need and timeliness of delivery and performance. Records of all informal bids will be kept and will be available for public inspection. Such records will include the date the bid is received,from whom it is received,and for what item. Electronic Bidding: Pursuant to federal and state guidance, CSUSA schools may receive bids electronically in addition to or instead of paper bids. If electronic bids are used for purchases that must be formally bid, procedures for receipt of electronic bids must be designed to ensure the security,authenticity and confidentiality of the bids to at least the same extent as provided with paper bids. The Procurement Manager, in consultation with the State Director and City Manager,will determine whether electronic bidding is appropriate for a specific purchase or category of purchases. Exceptions to the Formal and Informal Bidding Requirements: CSUSA SCHOOLS may utilize the following purchasing options instead of pursuing competitive bidding for non-federal purchases. Formal or informal bidding is not required if any of these processes are used. The Procurement Manager is responsible for gathering information to document the basis for the use of any exceptions to the competitive bidding requirements. The Procurement Manager, in consultation with the State Director,will determine whether using one of the following exceptions is appropriate for a specific purchase or group of purchases. 1. Purchases from Other Governmental Agencies — Pursuant to federal and state guidance, CSUSA schools may contract for the purchase, lease or other acquisition of apparatus, supplies, materials, or equipment from any other federal, state or local governmental agency. 2. Special Emergencies—Pursuant federal and state guidance, competitive bidding is not required in cases of special emergencies involving the health and safety of people or their property. For an emergency to exist under the statute, the following factors must exist: (1)the emergency must be present, immediate and existing; (2)the harm cannot be averted through temporary measures; and(3)the emergency must not be self-created by CSUSA schools. 3. Competitive Group Purchasing_— Pursuant to federal and state guidance, CSUSA schools may make purchases through a competitive bidding group purchasing program,through which another entity uses a competitive process to establish contracts on behalf of multiple entities at discount prices. 4. State Term Contract—Pursuant to federal and state guidance, CSUSA schools may purchase products included in state term contracts with the state vendor for the price stipulated in the state contract, if the vendor is willing to extend CSUSA schools the same or more favorable prices,terms and conditions as established in the state contract. 5. Sole Source Items — Pursuant to federal and state guidance, upon approval of the Governing Board, CSUSA schools may purchase an item through a single/sole source contract under the following circumstances: (1)when performance or price competition is not available; (2)when a needed product is available from only one source of supply;or(3)when standardization or compatibility is the overriding consideration. When requesting a purchase under the sole source exception, the State Director will provide the Governing Board with documentation that justifies the use of the exception. 6. "Piggybacking" or Previously Bid Contracts—Pursuant to federal and state guidance, upon approval of 11 the Board of Education, CSUSA schools may purchase from any supplier that, within the previous 12 months,has contracted to furnish the needed item to the federal government,to any state government,or to any agency or political subdivision of the federal government or any state government. Before recommending a purchase using the piggybacking exception,the Procurement Manager will ensure that the following requirements are met: (1) the price and other terms and conditions of the contract are at least as favorable as the prior contract; (2) the contract was entered into following a bid process substantially similar to that required by Florida Statutes; (3)the same vendor is used; and(4)notice of intent to award the contract without bidding is publicly advertised at least 10 days prior to the regularly- scheduled Governing Board meeting at which the contract will be approved. Before approving the contract,the Governing Board must determine that using the contract is in the best interest of CSUSA schools. Purchases of Information Technology Goods and Services — Pursuant to federal and state guidance, CSUSA schools may purchase or lease information technology through contracts established by the State Office of Information Technology Services. The Procurement Manager will work with the information technology department to ensure that any such purchases meet the needs of CSUSA schools In addition, CSUSA schools also may purchase information technology goods and services by using a request for proposal(RFP)Pursuant to federal and state guidance„provided that the following requirements are met: (1) notice of the request is provided consistent with the formal bidding notice requirements and (2) contracts are awarded to the person or entity that submits the best overall proposal as determined by the Procurement Manager. The RFP should describe the scope of work, general terms and conditions, specifications of the product needed by CSUSA schools, and the application process. The information technology supervisor will assist the purchasing officer in reviewing the responsiveness of any RFP submitted pursuant to this subsection. RFPs will be evaluated using the "best value"method as defined in federal and state guidance, so that the school can select the most appropriate technological solution to meet CSUSA schools 's objectives. However, in situations where the purchasing officer considers the purchase to be highly complex or is unable to clearly determine what the optimal solution for CSUSA Schools is,the"solution-based solicitation"or"government- vendor partnership"method may be used. The Procurement Manager may negotiate with the proposer to obtain a final contract that meets the best needs of CSUSA Schools, as long as the alterations based on such negotiations do not deprive proposers/potential proposers of the opportunity to compete for the contract and do not result in the award of the contract to a different person or entity than it would have been if the alterations had been included in the RFP. 7. Gasoline, Fuel and Oil Purchases —Pursuant to federal and state guidance, CSUSA schools may purchase gasoline, fuel and oil products without using formal competitive bidding. However, such purchases are subject to the informal bidding requirements described above. 8. Used Products—Pursuant to federal and state guidance, CSUSA schools may purchase previously used apparatus, supplies, materials or equipment without using formal competitive bidding. Before purchasing used products, the Procurement Manager will ensure that the products are in good, usable condition and will be sufficient to meet CSUSA school's needs for a reasonable period. Historically Underutilized Businesses 2 CFR§200.321: CSUSA schools affirms its commitment to encourage the participation of historically underutilized businesses in purchasing functions, especially small, minority, women-owned businesses and labor surplus area firms pursuant to federal grant requirements. CSUSA schools will take the following affirmative steps to assure the use of historically underutilized businesses when possible: 1. Placing qualified small and minority businesses and women's business enterprises on solicitation lists. 12 2. Assuring that small and minority businesses, and women's business enterprises are solicited whenever they are potential sources. 3. Dividing total requirements, when economically feasible, into smaller tasks or quantities to permit maximum participation by small and minority businesses,and women's business enterprises. 4. Establishing delivery schedules, where the requirement permits, which encourage participation by small and minority businesses,and women's business enterprises. 5. Using the services and assistance, as appropriate, of such organizations as the Small Business Administration and the Minority Business Development Agency of the Department of Commerce. Requiring the prime contractor,if subcontracts are to be allowed,to take the affirmative steps listed in 1 through 5. Contract cost and price 2 CFR§200.323: For procurement subject to federal funding, CSUSA schools will perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold($250,000)including contract modifications. The method and degree of analysis is dependent on the facts surrounding the procurement situation,but as a starting point,CSUSA schools will make an independent estimate before receiving bids or proposals. The cost analysis or price analysis,as appropriate for the situation,will be documented in the procurement files. Accordingly, CSUSA schools performs a cost or price analysis in connection with every federal procurement action in excess of$250,000 including contract modifications,as follows: Cost Analysis► Noncompetitive Contracts: A cost analysis involves a review of proposed costs by expense category, and the federal cost principles apply, which includes an analysis of whether the costs are allowable, allocable,reasonable,and necessary to carry out the contracted services. In general: • A cost analysis must be used for all noncompetitive contracts,including sole source contracts. • The federal cost principles apply. • All noncompetitive contracts must also be awarded and paid on a cost-reimbursement basis,and not on a fixed-price basis. • In a cost-reimbursement contract,the contractor is reimbursed for reasonable actual costs incurred to carry out the contract. • Profit must be negotiated as a separate element of the price in all cases where there is no competition. When performing a cost analysis,profit is negotiated as a separate element of the price. To establish a fair and reasonable profit, consideration is given to the complexity of the work to be performed, the risk borne by the contractor, the contractor's investment, the amount of subcontracting, the quality of its record of past performance,and industry profit rates in the surrounding geographical area for similar work. Price Analysis♦ Competitive Contracts: A price analysis determines if the lump sum price is fair and reasonable based on current market value for comparable products or services. In general: • A price analysis can only be used with competitive contracts and is usually used with fixed-price contracts. It cannot be used with noncompetitive contracts. • Compliance with the federal cost principles is not required for fixed-price contracts,but total costs must be reasonable in comparison to current market value for comparable products or services. A competitive contract may be awarded on a fixed-price basis or on a cost-reimbursement basis. If awarded on a cost-reimbursement basis, the federal cost principles apply and costs are approved by expense category, and not a lump sum. A cost analysis will be completed for any noncompetitive contract over$250,000. A price analysis will be used for all competitive contracts over $250,000. The analysis will be conducted by the CSUSA Director of 13 Procurement or the designated staff member for the contract. Analyses should include prior procurements and other market research. The analysis should yield an acceptable price range prior to receiving bids/proposals. Administrative oversight is provided by the Chief Financial Officer. Costs or prices based on estimated costs for contracts are allowable only to the extent that costs incurred,or cost estimates included in negotiated prices would be allowable costs under the federal cost principles. Rebates and credits 2 CFR§200.406-Applicable credits refer to those receipts or reduction-of expenditure type transactions that offset or reduce expense items allocable to the Federal award as direct or indirect costs. Examples of such transactions include: purchase discounts,rebates or allowances, recoveries or indemnities on losses, insurance refunds or rebates, and adjustments of overpayments or erroneous charges. To the extent that such credits accruing to or received by CSUSA schools relate to allowable costs, they must be credited to the Federal award either as a cost reduction or cash refund,as appropriate. Contractor Oversight 2 CFR §200.318(b)_ CSUSA Schools strive to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders and to ensure proper administration of contracts as follows: Contractors 2 CFR §200.330(b)_ A contract is for the purpose of obtaining goods and services for the use CSUSA schools and creates a procurement relationship with the contractor. A procurement relationship between CSUSA Schools and a contractor is established when the Contractor: ■ provides the goods and services within normal business operations; ■ provides similar goods or services to many different purchasers; ■ normally operates in a competitive environment; ■ provides goods or services that are ancillary to the operation of the Federal program;and ■ is not subject to compliance requirements of the Federal program as a result of the agreement, though similar requirements may apply for other reasons. All the characteristics listed above may not be present in all cases, and therefore best judgment must be used in classifying each agreement as a sub award or a procurement contract. 14 INTERNAL CONTROLS Internal Controls-The CSUSA internal control procedures over financial management shall be made available to all staff involved in the management of federal grant funds.The internal control procedures shall be included as part of the annual audit,reviewed on at least an annual basis, and updated as appropriate. If any weakness in an internal control is detected, the internal control procedures shall be revised to incorporate the weakness(es) at either the annual review or as the need arises dependent upon the severity(materiality)of the weakness. Adequate internal control is a key defense (but no guarantee) against fraud, waste and program abuse. All CSUSA staff have a responsibility to reduce the risk of fraud, waste and program abuse by implementing effective internal controls that adequately safeguards assets. In the event of conflict between these standards and federal statute or regulation, the federal statute or regulation will apply. Individuals who suspect fraud, waste,or program abuse may report the matter to the State Director. In accordance with the Grants Management Common Rule codified by the U.S.Department of Education(DOE) at 34 CFR § 80,CSUSA must maintain effective internal control and accountability for all grant and sub grant cash,real and personal property,and other assets.CSUSA staff must adequately safeguard all such property and must assure that it is used solely for authorized purposes. The Office of Management and Budget (OMB) Circular A-133 Compliance Supplement is a useful tool in defining what constitutes "effective internal controls" in that it provides guidance for understanding and evaluating internal control.The guidance in Part 6 of the OMB Circular A-133 Compliance Supplement reflects the definition and description of internal control as published by the Committee of Sponsoring Organizations (COSO)of the Treadway Commission in its report,"Internal Control-Integrated Framework" (COSO Report). Components of Internal Control- Internal controls shall be designed, implemented and evaluated based on the ability of the controls to provide reasonable assurance for compliance with applicable requirements in a cost-effective manner. The OMB Circular A-133 Compliance Supplement ( the "Compliance Supplement") provides assistance in complying with internal control and audit requirements by identifying types of compliance requirements and describing for each, the objective of internal control and certain characteristics of internal control that, when present and operating effectively,may ensure compliance with program requirements.The guidance,however,is not intended as a"checklist of required internal controls characteristics."Judgment will need to be exercised in determining the most appropriate and cost-effective internal control in a given environment or circumstance to provide reasonable assurance for compliance with program requirements. The types of compliance requirements are primarily described in Parts 3 and 6 of the Compliance Supplement. Part 3 provides fourteen types of compliance requirements that it identifies as being generic to most federal programs that are administered by entities subject to the audit requirements of OMB Circular A-133. Part 6 describes internal control characteristics for thirteen of these fourteen types of compliance requirements (all except those pertaining to special tests and provisions).The five components of internal control are: ■ Control Environment. The control environment "sets the tone of an organization and influences the control consciousness of its people."It provides structure and discipline and forms the foundation for all other components of internal control. 15 ■ Risk Assessment. Risk assessment refers to the "identification, analysis, and management of risks relevant to the preparation of financial statements that are fairly presented in conformity with generally accepted accounting principles [GAAP] (or another comprehensive basis of accounting)." ■ Control Activities. Control activities are the policies and procedures that help ensure that management's directives are carried out. ■ Information and Communication. The identification capture and exchange of information in a form and timeframe that enables people to carry out their responsibilities. ■ Monitoring. In relation to the Committee Sponsoring Organizations of the Treadway Commission (COSO)report and Statements on Auditing Standards(SAS) 78,monitoring refers to the process used to assess the quality of internal control performance over time. Fraud, Waste or Abuse - Fraud, program abuse, including waste, possible illegal expenditures, unlawful activity, violations of law,rules, or policies and procedures occurring under any grant are prohibited. Suspicion of such misuse must be reported to the State Director or designee no later than five business days from the date of discovery of such act. Following internal investigation, CSUSA may elevate any report to the appropriate federal or state authority for action including,but not limited to: ■ Further investigation ■ Referral for prosecution under the federal or state laws ■ Other corrective action,as may be appropriate CSUSA shall ensure the confidentiality of all reports of violations as listed above except as provided by law or court order.No retaliation shall be taken against any person filing a report. Bonds - If the granting agency requires that CSUSA in support of the Local Education Agency(LEA) or school obtain bonding and/or insurance for a specific project, CSUSA shall ensure that the bonds are obtained from a company that holds a certificate of authority as specific in 31 CFR § 223, Surety Companies Doing Business with the United States. The Director of Finance,or designee, shall be responsible for obtaining insurance and/or bonding,as appropriate. Payment-Payments to vendors shall be made promptly in accordance with federal regulations and state law. If the LEA receives an advance payment from a federal granting agency,the Grant Coordinator shall ensure that the advanced funds are expensed in a timely manner. Excess funds may earn interest,which may require return to the federal granting agency if the interest meets the federal threshold. The LEA or schools shall always seek reimbursement for federal grants. The Grant Coordinator shall coordinate with the LEA or schools to prepare and submit a"drawdown" of federal grant funds only after the payments have been made and distributed to the vendor via mail,e❑payables or other delivery method. The drawdown of expended funds shall be net of all rebates,refunds,contract settlements,audit recoveries and interest earned, as appropriate.The Grant Coordinator working with the SOAs shall be responsible for preparing the drawdown of federal grant funds. All drawdowns shall be reflected on the grant financial management ledger and recorded on the general ledger as a receivable when the drawdown process is complete, and funds are received. Upon receipt the funds will be posted to the cash account. 16 Cost sharing or matching funds - The Grant Coordinator over each federal grant award shall ensure that requirements for cost sharing and/or matching funds are approved through the grant approval process prior to the submission of the grant. At a minimum,the Grant Coordinator,Director of Finance,and /State Director(or designee)must approve the commitment of all cost sharing and matching grant funds. If cost sharing or matching funds are required as part of a federal grant award, the required direct or in-kind expenditures should be recorded and tracked on the grant financial management ledger. If matching grant funds are required in the General or Operational Fund,the LEA or school shall utilize a sub❑object to separately track the expenditures for reporting and compliance purposes. All staff paid with cost sharing and matching funds, shall be subject to the Time and Effort Documentation requirements. Cost sharing and matching funds that are as a result of donated services or supplies,shall be recorded and tracked in accordance with the federal regulations(2 CFR§200.306). Program Income-The LEA or school will not generate any program income as part of a federal grant award. The LEA or school will not retain any program income earned through a federal grant program. Period of performance (Obligations) - All allowable grant expenditures shall be incurred during the grant period of performance (i.e. formal approval or begin date and end date/last date of expenditures) of the federal grant award as designated on the Notice of Grant Award (NOGA) issued by the state or district. The Grant Coordinator shall notify the State Director, School Principals, SOAs and the Directors of Finance and Accounting of the grant periods for each federal grant award to ensure compliance as noted below: ■ No employee shall be hired and paid from federal grant funds except during the federal grant period. ■ No purchase obligation shall be made from federal grant funds except during the federal grant period. ■ No payroll or non[]payroll expenditures shall be made from federal grant funds except during the federal grant period. All obligations with federal grant funds must occur during the grant period of performance. Obligations that occur before or after the grant period of performance are not allowable costs. The obligations must be liquidated in accordance with the grant deadlines, especially as they relate to the final drawdown of federal grant funds. The Grant Coordinator shall monitor the expenditures during the grant period of performance to ensure that the funds are spent in a systematic and timely manner to accomplish the grant purpose and activities. 17 ACCOUNTING,REPORTING,AND INVENTORY CONTROL Financial Management: The grant financial management ledger will be used track budgets, commitments, obligations and expenses for all federal, state, local and private sector grant expenditures. The grant financial management ledger shall be maintained in a manner that provides adequate internal controls over the data integrity,security and accuracy of the financial information. The information maintained shall include all grant allotments,periods of performance,grant type,LEA or school name and location,authorizations,obligations,unobligated balances,assets,expenditures,income and interest and be supported by source documentation. All expenditures of federal grant funds shall be in managed in accordance with CSUSA's written procedures such as cash management, accounts payable,purchasing, travel, allowable costs,capital asset tracking,contract management,and other procedures,as appropriate. The financial management system shall be utilized to store, maintain, and report all required federal grant information. Consequently,the Grant Coordinator shall ensure that access to the data is restricted to authorized individuals in accordance with the grant focused data and access requirements specified in this manual. In addition, the Grant Coordinator shall retain all federal grant records in accordance with the records retention requirements also set forth in this manual. The Grant Coordinator shall be responsible to ensure that all grant records are retained, stored and accessible,as appropriate. A list of all federal grant awards shall be maintained to include all EDGAR required data and LEA or school LI required information listed below: ■ The Catalog of Federal Domestic Assistance(CFDA)title and number ■ Federal award identification number and year ■ Name of the Federal or state agency issuing the grant ■ Name of the pass-through entity issuing the grant,if applicable On at least a quarterly basis,the State Director, School Principal, SOA and Grant Coordinator shall review the status of each federal, state or private sector grant fund. The review shall include a comparison of budget to expenditures. Grant Tracking and Financial Reporting - Grant expenditures will be separately identified from operating fund expenditures through the use of designated general ledger subaccounts. Each subaccount represents a separate, segregated fund for the recording of all applicable revenues and expenditures for each fund. Drawdown of Grant Funds: The Grant Coordinator working closely with the SOAs shall on at least a quarterly basis,or as allowed or required by the State or District guidelines,drawdown grant funds that have been expensed in accordance with the State or District grant guidelines.The drawdown shall be for all expenditures to date,less grant funds received to date,as verified using a grant financial management ledger. The expenditures shall be net of all refunds, rebates, discounts, credits, and other adjustments, if any. If the LEA has opted to operate under the cash reimbursement program guidelines,the LEA shall submit a drawdown of federal grant funds only when an expenditure has been made as evidenced by distribution of a paycheck to a grant funded staff member or mailing, a❑paying, or delivering a payment to a vendor. At no time shall the Grant Coordinator or SOA drawdown any"advanced" cash payments,unless specifically allowed by the granting agency. The drawdown of grant funds from the granting agency shall be initiated by the Grant Coordinator or SOA. A detailed summary grant financial management ledger of each grant fund should be 18 generated to determine if the LEA is entitled to drawdown funds(i.e. if the granting agency owes the LEA any funds). If the LEA has funds available for draw❑down, a detailed general grant financial management ledger should be generated initiated by the SOA and validated by the Grant Coordinator for review and approval. If a grant has a matching requirement, the LEA shall draw Eldown only the allowable amount after verifying compliance with the level of matching expenditures. The Grant Coordinator review shall consist of the following: ■ A review of the detailed grant financial management ledger for any unusual charges or reclassification of expenditures. ■ A test sampling of either unusual or large expenditures to ensure that the expenditures are allowable and were reviewed and approved by all designated staff within the approved grant period of performance. ■ Monitor the percentage of expenditures❑or utilization rate to❑date to ensure that the grant funds are expensed on a timely basis throughout the grant period. The Grant Coordinator may disallow grant fund expenditures that appear to be made outside of the grant period of performance or so late in the grant period that the LEA and its student did not benefit from the delayed expenditure. ■ Authorize, in writing,the SOA to drawdown the available grant funds. Upon approval from the Grants Coordinator and the SOA shall prepare the paper or electronic drawdown request. The amount of the receivable shall be recorded on the grant financial management ledger and a copy of all supporting documentation such as the detailed grant financial management ledger and other supporting documentation shall be filed for audit purposes. The Directors of Finance and Accounting shall review the drawdown documentation and the grant financial management ledger and shall compare the documentation to the receipts from the State/District. Following this review, the Directors of Finance and Accounting will post the grant receipts to the general ledger. The Grant Coordinator and SOAs shall be responsible to ensure that the requested drawdown amounts do not exceed a grant❑specific budgeted line item. The final draw❑down of grant funds from the granting agency shall be made within the allowable or specified timeframe. The grant liquidation guidelines shall be adhered to in making final payment for all goods and services received and placed into service before the end of the grant period. The draw down process shall be the same as a monthly or periodic draw down, except that all refunds, rebates,credits,discounts or other adjustments to the grant financial management ledger must be recorded prior to submitting the final draw down request.There shall be no outstanding purchase orders or pending liquidations at the time of the final drawdown of grant funds. The final draw❑down shall be reviewed and approved in the same manner as a periodic drawdown. Federal regulations (2 CFR §200.415) requires that the LEA certify the accuracy of the annual and fiscal reports or vouchers requesting payments be signed by the authorized individual(s). The Grant Coordinator, School Principal, and State Director shall jointly certify every draw❑down of funds, including the final expenditure report. If a manual entry is required,the following statement will be added following signatures: "By signing this report, we certify to the best of our knowledge and belief that the reports are true, complete and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the federal award. We are aware that any false,fictitious, or fraudulent information or omission of any material fact, may subject us to criminal, civil, or administrative penalties for fraud,false statements or false claims." If a final draw[]down deadline is missed,the Grant Coordinator shall contact the granting agency to determine if a process exists to request a filing deadline extension. The receivable from the granting agency shall be recorded in the accounting general ledger.The same process for preparation and posting of the general ledger 16 entry as a periodic drawdown shall be adhered to. The revenues realized and the expenditures should be equal at the time of the final drawdown of grant funds. Receipt of Grant Funds- All CSUSA staff, especially those assigned with federal grant duties, shall adhere to the Cash Management Procedures. Specifically, all cash received shall be deposited, recorded reconciled by multiple individuals to ensure segregation of duties. The Director of Accounting and Finance shall record all grant fund receivables upon receipt from the granting agency. The receipt of grant funds shall be posted to the general ledger to the appropriate receivable account code.In the event that the grant funds received do not match the recorded receivable, the Director of Finance shall coordinate with the Grant Coordinator who in turn shall resolve the discrepancy or contact the granting agency to determine the discrepancy. If the granting agency has reduced and/or increased the grant funds paid to the LEA,a general ledger adjustment shall be posted to the appropriate revenue and receivable accounts. The Director of Accounting and Finance shall prepare the adjusting journal ledger entry and shall post the entry to the finance general ledger. The LEA will not maintain grant funds in a separate bank account. Tracking and Recording Receivables - On at least a monthly basis, the finance department, Accounting Coordinator, shall review all pending receivables. Aged receivables, defined as greater than 60 days from the date of recording, shall be investigated and resolved by contacting the Grants Coordinator who in-turn will contact the granting agency. At the end of the fiscal year,all known and measurable receivables shall be recorded to the general ledger to the appropriate grant code. The Director of Accounting shall prepare the journal ledger entry and shall post the entry to the general ledger. Grant Compliance Areas: The Grant Coordinator shall ensure that LEAs and schools are compliant with all provisions and assurances of all grant programs. In addition, the all shall comply with grant requirements such as supplement not supplant,indirect cost,and maintenance of effort spending levels. Supplement Not Supplant-The term supplement,not supplant is a provision common to many federal statutes authorizing education grant programs. There is no single supplement, not supplant provision. Rather, the wording of the provision varies depending on the statute that contains it. Although the definition may change from statute to statute,supplement not supplant provisions basically require that grantees use state or local funds for all services required by state law, state DOE rules, or local policies and prohibit those funds from being diverted for other purposes when federal funds are available.Federal funds must supplement—add to, enhance, expand,increase, extend—the programs and services offered with state and local funds. Federal funds are not permitted to be used to supplant take the place of, replace—the state and local funds used to offer those programs and services. The LEA process to ensure that all grant-funded activities are supplemental shall be a collaborative effort between the Grants Coordinator, State Director, School Principal, SOA and other appropriate departments. All person shall be aware of the supplement not supplant provisions. The Grants Coordinator shall review and approve all purchase orders(and non' ]purchase order payments). The Grant Coordinator review shall include a determination if the planned purchase and/or expenditure meet one of the following guidelines: ■ The grant funds will be used to enhance, expand, or extend required activities. Examples may include before/after tutoring, additional research❑based instructional programs, or other supplemental expenditures not required by state law or local policy. ■ The grant funds will be used for specific grant activities included the grant application that are above and beyond the activities funded with local funds. ■ The grant funds will be used to supplemental grant activities as noted on the school-wide plan, school strategic plan or school improvement plan. 17 Program specific supplement not supplant provisions shall be complied with in addition to the overall federal fund's requirements. Reporting Requirements - The Grant Coordinator shall ensure that all reporting requirements for grant programs are met within the established timelines. Completion of the reports may require the collaboration of several departments, such as noted below: ■ Programmatic reports such as activity, progress and evaluations—Grants Coordinator, School Principal,SOA ■ Expenditure reports such as interim, draw down and final expenditure reports—Grants Coordinator, School Principal, SOA,Accounting and Finance departments,and Accounts Payable Department ■ Compliance reports such as Comparability, Maintenance of Effort, Indirect Cost, etc.— Grants Coordinator, School Principal, SOA,Accounting and Finance departments ■ Special Staff reports—Grants Coordinator,School Principal, SOA The Grant Coordinator shall ensure that all reporting requirements have been completed by the appropriate LEA, school,or CSUSA staff member. Grant Monitoring and Accountability-The LEA shall ensure that all grant funds are consistently monitored throughout the grant period.The monitoring shall include,but not be limited to: ■ Compliance with federal requirements such as cost principles,audit,reporting requirements,etc. ■ Monitoring of grant expenditures are properly documented and meet all allowable costs ■ Monitor grant performance such as internal controls,audit findings,over/under expenditures,etc. ■ Implement strategies to deter, mitigate and eliminate waste and fraud in the expenditure of grant funds The Grant Coordinators for each federal, state and local grant, working with the State Directors, school Principals and the Accounting and Finance Departments, shall be responsible for the programmatic and evaluation and financial compliance. The Grant Coordinators shall monitor the timing of grant activities throughout the grant period,especially as they relate to the desired outcomes. The Grant Coordinators, school Principals, SOAs collectively shall monitor the timing of grant expenditures, especially as they relate to the period of availability of grant funds. If either the grant activities or grant expenditures reflect that the LEA or school will not accomplish the grant activities during the grant period,the Grant Coordinators shall work collaboratively with the appropriate activities to develop an action plan to ensure that the federal grant goals are met. The oversight of grant activities and expenditures shall include,but not be limited to,the following: ■ Cost overruns or high unit costs ■ Construction projects—certification of project completeness (as evidenced and approved by the oversight activity) ■ Significant developments that may result in an inability to complete the grant activities The Grant Coordinator with the LEA shall maintain documentation to support all grant expenditures and provide the documentation upon request to the LEA's external auditors, granting agency or other oversight agency, as appropriate. Audit findings or deficiencies shall be addressed in a timely manner upon receipt of the notification. The Grant Coordinator, State Director, School Principal shall work collaboratively to develop and implement a Corrective Action Plan to resolve the findings or deficiencies. The State Director,or designee shall approve the Corrective Action Plan and monitor the timely implementation of corrective strategies. 18 The Grant Coordinator in coordination with the LEA shall disclose to the granting agency if any federal grant funds have been subject to fraud or theft.Corrective actions,as appropriate,shall be implemented to remedy the loss of grant funds due to fraud or theft. Remedies for Non❑Compliance-CSUSA, specific LEA and schools may be subject to consequences due to non❑compliance with federal regulations. All Grant Coordinators, LEAs and schools shall strive to maintain compliance, but shall respond appropriately to all notifications of noncompliance from the federal or state granting agency or pass through agency. CSUSA shall notify the City Manager of all notifications of noncompliance. Grant Closeout Procedures -The Grant Coordinators shall submit all grant closeout documents to the State DOE, granting agency or pass❑through agency, as appropriate. Grant closeout procedures shall include, but not be limited to: ■ Ensure that no obligations are made after the grant period end date ■ Liquidate all obligations incurred during the grant period ■ Submit the final grant program performance report as required ■ Submit the final grant expenditure report as required ■ Drawdown all the expensed grant funds ■ Match the grant expenditure draw❑downs with the supporting financial records ■ Certify that the final drawdown of federal grant funds is accurate ■ Refund any excess grant funds, interest, or other payables to the granting agency or pass-through agency ■ Account for any real and/or personal property on hand at the end of the grant period Grant Funded Equipment Property Records 2 CFR§200.313(d)(1)-CSUSA Schools will maintain property records for all grant funded and operational funded equipment and computing devices/technological items that include: • Description of the property • Serial number or other identification number • Source of funding for the property(grant type) • Grant tag number • Title Holder of Equipment • Acquisition date • Cost of the property • Percentage of Federal participation in the project costs for the Federal award under which the property was acquired • Equipment of location • Use of the property • Condition of the property • Disposition data including the date of disposal and sale price of the property. 19 The SOA, the School Principal, the Information Technology (IT) Technician and the Grant Coordinator will maintain a combined property record,which includes all information listed above. The information,including entering property into the fixed asset inventory and making adjustment to the inventory, is accomplished by the SOA, the School Principal, the IT Technician and the Grant Coordinator. CSUSA will provide the City Manager a copy of the property records When inventory is received, it is inspected by the SOA,the School Principal, the IT Technician and the Grant Coordinator to determine whether the inventory is in good condition and that it matches the purchase order, and the corresponding invoice. The equipment shall immediately be placed in a secured area. Inventory of all equipment must be completed within two working days following the receipt of the equipment.The SOA,the School Principal,the IT Technician and the Grant Coordinator logs the inventory into the property management system. The inventory control sheet is kept with the SOA,the School Principal,the IT Technician and the Grant Coordinator.CSUSA will provide a copy of the inventory control sheet to the City Manager. All inventoried equipment including computing devices and other highly desirable mobile devices such as laptops,smart phones,and tablets are to be tagged and tracked.The SOA,the School Principal,the IT Technician and the Grant Coordinator will be responsible for ensuring equipment is tagged. Physical Inventory-A physical inventory of the property is taken,and the results reconciled with the property records at least once every two years.2 CFR§200.313(d)(2).The SOA,the School Principal, the IT Technician and the Grant Coordinator assigns the physical inventory to teachers in the classrooms where the equipment is located. The inventory will be performed at the end of every school year and signed off by the State Director or designee when completed. The results of the inventory will be reported to the SOA,the School Principal,the IT Technician and the Grant Coordinator. The SOA,the School Principal,the IT Technician and the Grant Coordinator reconciles discrepancies between the inventory and the property records by updating the property records as needed and documenting any property that is damaged or missing for identification, repair or replacement as needed. They will maintain documentation of the physical inventory and reconciliation and sign off when the reconciliation is completed. Safeguarding Property Equipment-The SOA,the School Principal,the IT Technician and the Grant Coordinator will set up and manage a control system to insure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft will be investigated. 2 CFR §200.313(d)(3). Property may be taken off campus by students or staff. The person taking the property off site must coordinate with the School Principal and the SOA and sign and date a receipt statement upon departure and return. If student or staff takes property off campus and the item is lost or stolen while in their possession, said student or staff shall be responsible to repair or replace the lost or stolen item. The computing devises are tagged with the appropriate CSUSA identification and grant tag.Equipment that is lost or stolen is reported to the SOA, the School Principal, the IT Technician and the Grant Coordinator. They are then required to report it to the SOA, the School Principal,the IT Technician and the Grant Coordinator,where they or their designee will complete an investigation on the lost or stolen property. Interviews will be conducted, and/or a police report will be filed under the discretion of the State Director or City Manager and coordinated with the School Principal, and the Grant Coordinator,as part of the investigation process. A report regarding lost or stolen property will be completed by the person doing the investigation. The report will be filed with the property inventory records as well as with the grant records. In addition to possible criminal action the State Director or designee will determine what, if any, additional action is necessary. Replacement of 23 equipment will be obtained through the normal procurement functions, meet or exceed equipment specifications of the lost/stolen items. Replacement costs will be incurred through non-grant school funding. Disposition of property will be listed by the SOA, the School Principal, the IT Technician and the Grant Coordinator in the property records in the event the property is sold,lost or stolen,or cannot be repaired. Property that is sold, identified as lost or stolen, or cannot be repaired will be listed in the property records for three(3)years after the lost/stolen date. Maintaining Property Equipment- Staff to whom property equipment is assigned will monitor and maintain these items in good condition while in their possession. The SOA,the School Principal,the IT Technician and the Grant Coordinator should be contacted if an item is broken or not working properly. Equipment in need of repair is assessed by the SOA, the School Principal, the IT Technician and the Grant Coordinator to determine whether to repair or salvage. As part of this process the SOA, the School Principal, the IT Technician and the Grant Coordinator will determine if a warranty will apply to the repair, if not, they will obtain repair cost estimates. Generally,if the cost of repair exceeds half the cost of the restored value,then the equipment may be salvaged or donated.Other factors such as availability of the damaged item can be considered when determining whether a repair is appropriate. Disposition of Grant Funded Equipment — 2 CFR §200.313(e) - When original or replacement equipment acquired under a Federal award is no longer needed for the original project or program or for other activities currently or previously supported by a Federal awarding agency, except as otherwise provided in Federal statutes, regulations, or Federal awarding agency disposition instructions,CSUSA Schools will dispose of the equipment as follows: • Items of equipment with a current per unit fair market value of $5,000 or less may be retained, sold or otherwise disposed of with no further obligation to the Federal awarding agency.2 CFR§200.313(e)(1). • Items of equipment with a current per-unit fair-market value in excess of$5,000 may be retained by CSUSA Schools or sold.2 CFR§200.313(e)(2). • The Federal awarding agency is entitled to an amount calculated by multiplying the current market value or proceeds from sale by the Federal awarding agency's percentage of participation in the cost of the original purchase. • If the equipment is sold,the Federal awarding agency may permit CSUSA Schools to deduct and retain from the Federal share $500 or 10 percent of the proceeds, whichever is less, for its selling and handling expenses. The SOA, the School Principal, the IT Technician and the Grant Coordinator with approval from the State Director or City Manager are responsible for determining how equipment will be disposed of. Any equipment owned exclusively by the City will be disposed pursuant to City 's surplus property rules. Possible sales procedures include on-site and govdeals.com auction. Auctions will be advertised online or in the local newspaper to ensure the highest level of exposure.If not being sold by auction the sale of the item will also be advertised online or in the local newspaper to ensure the highest level of exposure and there is no limit to the number of purchase offers that will be considered. The highest offer received in a reasonable amount of time will be accepted. All sales procedures will be performed in a manner to ensure the highest possible 24 return. 2 CFR§200.313(d)(5). CSUSA Schools will determine if the various state departments of instruction or education have specific equipment disposition forms required. If so, our schools will utilize these forms and ensure that are completed by the SOA,the School Principal,the IT Technician and the Grant Coordinator and kept on file with the SOA. 25 ENROLLMENT AND ADMISSIONS POLICY DSAHS will admit students of any race,color,nationality and ethnic origin,religion, sexual orientation, or gender. Pursuant to § 1002.33(10)(b), Fla. Stat., DSAHS will enroll an eligible student who submits a timely application unless the number of applications exceed the capacity of a program, class, grade level,or building.In such cases,all applicants who submit an application by the enrollment deadline will have an equal chance of being admitted through a random selection process. In addition, all applicants will need to submit the required documentation listed in the Student Progression Plan. Enrollment also follows § 1002.33(7)(a)8,Fla. Stat.,which includes enrolling students according to racial/ethnic balance provisions. However, DSAHS will comply with the Controlled Open Enrollment statute (F.S. 1002.31(2)(a)),which allows a parent from any school district in the state whose child is not subject to a current expulsion or suspension to enroll his or her child in and transport his or her child to the school, as long as the school has not reached capacity. In accordance with§ 1002.33(10)(d),Fla. Stat.,DSAHS may give enrollment preference to the following populations: • Students who are the children of an active-duty member of any branch of the US Armed Forces. • Students who are siblings of a student enrolled in DSAHS. If siblings apply together and one sibling receives an offer, the other sibling will also receive an offer as long as there is room in their grade level. If there is no room in the sibling's grade level,they will be given preference on the waiting list. Sibling is defined as individuals who share both guardianship and residency. • Students who reside in the City of Aventura. • Students who reside in Miami-Dade County. • Students who are the children of a CSUSA employee that is employed at DSAHS. All preference categories are published prior to conducting the lottery, and applicants entitled to receive a placement preference are identified prior to the lottery. Preferences granted are subject to review and verification, and DSAHS reserves the right to rescind acceptance offers if the preference status is not verified or validated. Siblings who are applying for the first time receive preference only after one of the siblings has been selected in the lottery and accepts their offered seat. Student applications are made available online through the enrollment management system(accessible on DSAHS's website). The enrollment management system accepts student applications and monitors the number of applications submitted for each grade level. The enrollment management system manages all aspects of the enrollment process, including online applications, application verification, sibling applicant record linking, admission preference management, manual and computerized lottery options, waitlist management, data exports, and statistical reporting. Parents with limited technology or internet access will be given the opportunity to use the resources available at DSAHS to submit an application. If they cannot travel to DSAHS,they will have the option to call the school and allow a staff member to assist them with completing an application. Upon submission of an application, the applicant's age, sibling linking (if applicable), and preferences are verified. At each phase of the admission process, the appropriate correspondence is generated and communicated to each applicant either via email,phone,or mail if necessary. The data is monitored and reports are created to determine the need for a lottery,waitlists,and letters of acceptance. If at the end of the open enrollment period there is an over subscription for any grade level, a lottery is conducted. The number of seats available is determined by the capacity minus the number of students who re-commit. This is in compliance with § 1002.33(10)(b), Fla. Stat. The lottery is system generated and will be conducted for all grades in which the number of applicants exceed the number of available seats. 26 Once all open seats have been randomly filled, the remaining applicants are placed on the waitlist in order of the lottery results and in accordance with assigned preferences. All offers of enrollment are made in the order of the lottery results and the established waitlist.Applicants selected through the lottery will have seven(7)days after the offer of enrollment is made to accept the offer. Should an applicant not accept the offer of enrollment within seven(7)days,the offer will be rescinded. Thereafter,an offer will be made to the next eligible applicant. Offers are not made to a student who is not properly entitled to the next available seat.Applicants who submit an application after the enrollment deadline are placed on the waitlist in order of preference and submission date. If an accepted applicant decides not to attend DSAHS, the slot is given to the first eligible applicant on the waiting list. All accepted applicants are provided with registration requirements. Documentation required by Miami-Dade County Public Schools will be collected for review and verification. In the event that an applicant was not included in the lottery but should have been,an adjustment will be made in placement on the waitlist or an offer of an enrollment. In the event an applicant was offered a seat in the lottery and provided incorrect information that led to a selection, the applicant's offer is rescinded and the applicant is placed on the waitlist according to the lottery pool number. Application submissions are accepted on an ongoing basis and a confirmation of the submission is sent to parents within 24 hours. Communication with prospective students is generated as appropriate. In addition, DSAHS will conduct entrance interviews with students after enrollment and registration is completed. 27 CERTIFCATION OF GOVERNING BOARD RESOLUTION The undersigned duly elected Mayor or Vice Mayor of City of Aventura certifies that the Commission at a duly held meeting, which was held on the-date-listed-below, at which a quorum was present, approved the CSP(Charter Schools Programs) Grant Policies and Procedures Manual. I certify that this Resolution was duly adopted by the City of Aventura Commission as the Governing Board of the School on the 21" day of November, 2019. Dated Mayor or Vice Mayor 28