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Restricted Status (Formerly High-Risk) and Payment Requests

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Learn about what it means for a grant to have restricted status and the extra monitoring that SAMHSA requires for these grants.

What Does Restricted Status Mean?

SAMHSA uses the term “restricted status” to describe grantees that are financially unstable, have inadequate financial management systems, or are poor programmatic performers. Grants deemed restricted status require closer monitoring. Restricted status grants used to be called “high-risk.”

Organizations with restricted status grants:

  • Have their Payment Management System (PMS) accounts restricted
  • Must submit written Requests for Advance or Reimbursement (SF-270). Review the SF-270 Submission Guidelines on this page.
  • Must provide detailed explanations to support costs claimed that are not in the approved budget

For details regarding restricted status, refer to the special condition in your Notice of Award (NoA).

SF-270 Submission Guidelines

For processing the SF-270, grantees must adhere to the following guidelines for:

General Comments and Instructions

Organizations with grants classified as restricted status have their PMS accounts restricted. Before they can draw down from their PMS, these organizations must submit an SF-270 to the Division of Grants Management (DGM). Then they will receive prior approval for all expenditures and advances.

An SF-270 must cover at least a 30-day period, preferably a calendar month, but not more than a 60-day period, preferably two sequential calendar months. It may not be submitted more than 60 days after the end of the period covered by the SF-270. For example, a January SF-270 must be submitted no later than the end of March. Otherwise, DGM may not consider the SF-270. The grantee’s authorized organization representative (AOR) must sign the SF-270.

Your AOR, business official, and project director (PD) should work with an accountant who has experience handling federal grants. If you are struggling to submit the proper documentation, DGM will determine who is preparing the information for submission. If that person is not an accountant, DGM may require you to obtain the services of one. This person must have the appropriate knowledge, skills, and abilities to assist you with accounting for federal funds and the preparation of the SF-270.

Reimbursement Requests

When you submit your SF-270 to the DGM for reimbursement, it must include the following:

  • A Summary Schedule of Costs Claimed (SSCC) (PDF | 102 KB) that separates the costs being claimed by the categories from the most recently approved grant budget
  • An accounting system report, such as a Statement of Activities or detail transaction report by project, that lists the individual cost items that make up each budget category total being claimed in the SSCC
  • Source documentation supporting each individual cost item greater than $500 included in the accounting system report. Examples of source documentation include canceled checks, paid bills, payrolls, time and attendance records, and contract and subgrant award documents. You must submit this information so DGM can determine that the costs you claim on your grant are adequately documented and appropriately charged.

Advance Requests

If you are submitting an SF-270 to DGM to request an advance, the following must accompany it:

  • An SSCC that lists your estimated cash needs, in the amounts claimed column, by cost category from the most recently approved grant budget for the monthly advance period
  • A detailed explanation when the monthly advance being requested for a cost category is 25% more or 25% less than the approved amount divided by the 12 months in the budget period

Advance requests for all months other than the first month of the project periods must be accompanied by an SSCC, accounting system report, and source documentation if there are individual cost items greater than $500 for the prior month’s actual costs claimed under the grant.

Actual costs claimed for the prior month must either reduce or increase the current month’s advance amount, depending on whether the prior month’s costs deemed allowable were more or less than the prior month’s advance. If the prior month’s actual allowable costs were less than the advance received for the prior month, the current month’s advance will be reduced by the difference and vice versa.

For advance requests, follow the same procedures detailed in the last paragraph of the reimbursement requests section, with the exception of what is submitted to DPM regarding approved advance amounts. Grantees shall draw down approved advances on an as-needed basis, rather than all at once, to comply with federal cash management requirements.

SAMHSA reviews the costs claimed for allowability as well as consistency with the most recently approved grant budget and completes the amounts accepted, amounts not accepted, and explanation columns of the SSCC. Upon approval, SAMHSA submits the sum of the costs accepted on the SF-270 to DPM for drawdown.

Personnel Costs

Personnel costs are calculated by multiplying each employee’s hourly rate by the hours he or she worked on the grant for the period. The hourly rate used to calculate the salary and wages (S&W) for each employee must be consistent with the approved grant budget and be supported by payroll reports and time and attendance records. Additionally, the payroll reports must reflect the full S&W for each employee, the portion of the S&W charged to the grant, the deductions for fringe benefits, and payroll taxes.

The allocation of S&Ws to grants must be based on personnel activity reports, or timesheets, that:

  • Are maintained for each employee whose compensation is partly or fully charged directly to federal awards
  • Reflect an after-the-fact determination of the actual activity of each employee
  • Account for the total activity for which the employee is compensated
  • Are either signed by the employee or a supervisory official familiar with the employees’ activities
  • Are prepared at least monthly and coincide with one or more pay periods

Budget estimates do not qualify as adequate support for S&Ws charged to grants of non-profit organizations.

However, local and Indian Tribal governments may charge grants for S&Ws based on budget estimates provided that:

  • The estimates are compared to the actual costs at least quarterly
  • The estimates being charged are adjusted, at least quarterly, for variances exceeding 10%
  • The amounts charged are adjusted to actual costs annually
  • The charges are based on documented time studies approved by SAMHSA
  • The changes support S&Ws for employees working solely on one federal project via the preparation of certifications, that state 100% of the employees’ time was spent on that project, no less frequently than bi-annually
  • They report leave time or paid time off in timesheets by type, such as vacation, sick, holiday, bereavement, or jury duty. Specifically, identify the hours taken on each occurrence. Further, the leave time must be supported by an approved leave request.

As stated in the NoA and HHS Grants Policy Statement, any replacement of, or substantial reduction in, effort of the PD or other key grantee staff or sub-recipients requires prior written approval of the grants management officer.

Fringe Benefit Costs

You must support fringe benefit costs with detailed source documentation and be consistent with the approved grant budget or include an adequate explanation or justification. Unless you have an approved fringe benefit rate with the Division of Cost Allocation, fringe benefits may not be claimed using a rate (percentage) that is multiplied by S&W.

Supplies Costs

Supplies include property items costing less than $5,000, such as paper, pens, staples, clips, computers, and printers. These types of costs often benefit all of a grantee’s programs. If this is the case, and you have a negotiated indirect cost rate, you should not directly charge them on the SF-270. Rather, you should include them in the indirect costs that you claim on the SF-270.

If you do not have a negotiated indirect cost rate and the supplies benefit all of your programs, you should allocate these costs to your programs using an equitable base, such as a full-time equivalent (FTE). Do not base your indirect costs on the grant award amount or grant program costs. For instance, if the SAMHSA grant program has 3 FTEs and the grantee has a total of 10 FTEs, 30% of the supplies costs should be charged to the SAMHSA grant, as allowable in the SF-270.

If you can demonstrate that the supplies relate exclusively to the SAMHSA grant or to only a few programs along with SAMHSA’s, you can charge the entire amount or a larger portion of the costs to the SAMHSA grant. For instance, if you purchased a computer to be used by an employee who only works on the SAMHSA grant, it would be appropriate for you to charge the entire cost of the computer to the SAMHSA grant. However, if the employee worked on the SAMHSA grant and two other programs, it would be appropriate to charge a portion of the computer’s cost to the SAMHSA grant based on the employee’s average level of effort on that grant.

Equipment Costs

Equipment includes property items that have a useful life of more than a year and an acquisition cost of $5,000 or more. SAMHSA must provide prior approval for any equipment purchases of more than $25,000, including vehicle purchases. Unless the total acquisition is approved by SAMHSA in advance to purchase in a single grant year, the cost of all equipment items should be capitalized and charged to the SAMHSA grants over the useful life of the equipment.

Travel Costs

The appropriate management official must document prior approval for all travel, other than local mileage, by signing the travel authorization forms. The travel authorization must identify the purpose of the trip, the staff traveling, dates, mode of transportation, and the estimated costs. Travel costs are also subject to the following, unless otherwise justified:

  • Mileage, meals and incidentals, and lodging should be limited to the lesser of the rates published by the General Services Administration in the Federal Travel Regulation or the grantees’ policies and procedures.
  • Airfare should be limited to coach.
  • Car rental should be limited to mid-sized.
  • Grantees should reimburse their employees for travel costs based on timely submitted expense reports. These reports must separately list each expense by type as well as identify the trip’s traveler, purpose, destination, and dates. You should attach copies of the approved travel authorization and original receipts for expenses greater than $25 to your expense reports.

Expense reports for local mileage should include a log that lists the travel dates, purpose, departure locations, destinations, and number of miles traveled.

Contractual Costs

Contractual costs must be consistent with the approved budget and be supported by invoices that include the following:

  • Signature of the contractor or consultant
  • Approval signature by an appropriate grantee official
  • Hours being claimed for reimbursement, by date
  • Description of the services provided, by date
  • Rate of compensation

The invoice should be an official invoice or on the contractor’s or consultant’s letterhead paper. You may need to obtain a copy of the written agreement to determine the agreed-upon method of compensation and scope of services.

SAMHSA does not reimburse costs for fixed price contracts that simply take the total contract amount and divide by the period covered by the SF-270 if they were not competitively procured. Grants are made on a cost reimbursement basis. Therefore, contracts should be funded in the same manner, not using inflated amounts agreed to without any competition.

Contractors involved with the writing or preparation of the application cannot be compensated under the grant as the evaluator, project director, project coordinator.

Rent or Space Costs

The basis for rent or space costs should have been determined during the budget analysis. You may charge space costs to SAMHSA grants based on the space directly used for the grant or the FTEs that work on the grant versus total FTEs; however, you must describe the methodology used to allocate the rent in detail if multiple activities are operated in the space. Rent must be supported by a lease agreement. If the space is owned by grantee management or board officials or any related parties or entities, the rent may only be claimed up to the cost of ownership, not current market rates.

Purchase authorizations, orders, invoices, or receipts should support these costs. Limit credit card use to small amounts and specific types of expenditures, such as office supplies.

Indirect Costs

Indirect costs are costs incurred for common or joint objectives that you cannot readily identify with an individual project, program, or organizational activity. Examples include:

  • Supplies
  • Office utilities and space, including lease costs or cost of ownership
  • Janitorial services
  • Telecommunications, internet, website development, and information technology services
  • Administrative staff time, such as the executive director, fiscal and personnel staff, and office management

Grantees recover these costs by either using an indirect cost rate or charging them directly.

If you want to use an indirect cost rate, you must negotiate a rate with your audit agency, which is usually the HHS Division of Cost Allocation, except for Indian Tribes, whose audit agency is usually the Department of the Interior. The results of the negotiation are documented in an Indirect Cost Rate Agreement. The indirect costs you claim should be consistent with the rate agreement and be applied to the base identified. In this case, the SF-270 and SSCC should include a separate cost category for indirect costs.

If you elect to charge all costs directly, joint costs, which are costs that benefit multiple or all programs, must be allocated to each program using an equitable and consistent basis that most closely approximates the actual benefits received by each program. The basis cannot be the grant award amount or grant program costs.

Non-federal Matching

If you require non-federal matching, you must track expenditures and in-kind services being claimed in your accounting system. You must also provide a report from the accounting system along with detailed supporting documentation. Please note that the same allowability rules that apply to expenditures charged to federal awards also apply to expenditures and in-kind services claimed as matching. Therefore, if costs or activities are not allowable per the applicable cost principles, they cannot be accepted as non-federal matching.

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