Grant Mandatory Disclosures Policy

Policy Name: Grant Mandatory Disclosures Policy

Owner: Vice President for College Advancement

Author: Director of Foundation & Government Resources

Contact information:  Amanda Abrahamson Roseth, aabrahamson@css.edu

Effective Date: August 1, 2023

Next Review Date:

Applicable Laws, regulations, compliance: 2 CFR 200.113

I. Purpose

The purpose of this policy is to ensure compliance with the requirements for mandatory
disclosures outlined in 2 CFR 200.113. The mandatory disclosures outlined in this policy are conditions of accepting Federal awards. Failure to make required disclosures can result in action against the College including suspension or debarment.

II. Definitions

  • Administrative proceeding – A non-judicial process used to make a determination    of fault or liability. This does not include audits, site visits or corrective plans.
  • Award – A funding agreement or contract with an organization or agency outside of The College of St. Scholastica. Grants, fellowships, co-operative agreements, subawards, contracts, and similar arrangements are considered awards.
  • Conviction – Judgment or conviction of criminal offense by a relevant court.
  • Gratuity violation – The acceptance of any gifts or benefits from contractors, subrecipients, or others involved in a Federal award. Accepting unsolicited gifts of nominal value are not considered gratuity violations

III. Policy

The College of St. Scholastica will disclose to the awarding agency in writing and in a timely manner any of the following items that occur and impact or may impact a Federal award.
Notice of suspension or debarment of any CSS employee, contractor, subcontractor, or other individual otherwise associated with the federal award.

  • Violations of federal criminal law involving fraud, bribery, or gratuity violations
  • A criminal proceeding that resulted in a conviction.
  • A civil proceeding that resulted in a finding of fault and liability and payment of a monetary fine, penalty, reimbursement, resolution, or damages of $5,000 or more.
  • An administrative proceeding that resulted in a finding of fault and liability and payment of either a monetary fine or penalty of $5,000 or more or reimbursement, restitution, or damages in excess of $100,000.

All employees of The College of St. Scholastica must notify the Foundation & Government Resources office of such occurrences potentially impacting a grant award within 30 days. Human Resources and Finance staff will have specific responsibility to notify Foundation & Government Resources of any violations they are aware of that could impact a Federal award.

Foundation & Government Resources will coordinate the submission of appropriate disclosures to the respective Federal agency within 60 days of the violation. Foundation & Government Resources will also disclose such occurrences potentially impacting non-federal awards as required by the awarding agency. All disclosures will be reviewed by the Office of the President before submission.

IV. Individuals and entities affected by this policy

  • Foundation & Government Resources
  • Finance
  • Human Resources
  • Employees working on or with Federal awards 

V. Related documents, forms, and procedures 

Contact the Foundation & Government Resources office at grants@css.edu 

VI. History and updates

August 1, 2023: The policy was put into a new standard template. Headers and related documents and procedures were added if applicable. No substantive changes were made to content.

The College reserves the right to modify policies at any time, ensuring the involvement of relevant committees and constituents in the decision-making process (e.g., policy committee, faculty assembly, staff council, student government association, etc.).

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