If your Center for Independent Living receives a direct grant from Health and Human Services through the Administration on Community Living, then someone in your organization draws down funds to be directly deposited in your CIL’s bank account. This process is getting a lot of attention from the Office of Independent Living Programs, and you want to know what you can and cannot do.
Do make sure that you are authorized to draw funds before you need to do so. There is a process for being the identified person, and you don’t want the cash crunch of waiting until the last minute and then discovering you still have to get registered as the person who can draw. (You can assign two people to the task, each with their own registration, so that you don’t run into a situation where no one can draw. Typically the second person is a board member as a back up.)
Don’t draw down using your predecessor’s user ID and password, even if they left it for you or left it memorized on the computer you are using. During the process you certify that you are the person who signed in, so make sure that is true.
Do draw down the amount you will need for the expenses charged to the grant. An easy way to do this is to draw down to cover the expenses for which checks were written, drawing the properly allocated amount for the specific grant. A monthly draw or a draw that coincides with payroll makes sense since payroll is your largest expense. Have your bookkeeper or accountant run a report of the checks written and the total charged to each funding source. If you do this once or twice a month you will keep up with your actual expenses.
Don’t draw down in excess of what you are spending in that period. You cannot use your draw to borrow money to pay other expenses, or to build a reserve. You should draw from your Part C grant only what you are charging to the grant, both direct and indirect expenses. This includes only the appropriate share of the expenses that are shared. If you are having difficulty getting money on time from other funding sources you must resolve those with the entities funding the programs.
Do maintain a clearly labeled PDF of the payroll, payroll overhead calculation, other direct costs and indirect cost allocation be kept to support each draw. These should be retained for three years after the year of the draw.
Do realize that your program officer at ACL is reviewing the information related to your draws. There should not be a pattern, an equal amount drawn each time. You should be drawing based on actual expenses, not based on budgeted expenses or 1/12 every month.