Workforce Recovery Training Program

Policy and Procedure Manual Version: 2.5

2/25/2021

My signature indicates approval of the Policy and Procedure Manual.

Approved by: ________________________________ Florida Department of Economic Opportunity

Approved by: ________________________________

Director of Workforce & Community Development

Approved by: ________________________________ Grant Program Manager

Table of Contents 1. Purpose ..................................................................................................................................................... 5

2. Introduction .............................................................................................................................................. 5

3. Version Policy and Change Policy ............................................................................................................. 6

3.1 Manual Change Process ...................................................................................................................... 6

4. Procurement Policies and Procedures ...................................................................................................... 6

4.1 Procurement Plan ............................................................................................................................... 7

5. Contract Administration Policies and Procedures .................................................................................... 9

5.1 Contract Administration ................................................................................................................... 10

6. Financial Management Policies and Procedures .................................................................................... 11

6.1 Financial Management...................................................................................................................... 12

6.2 FSCJ Standards .................................................................................................................................. 13

6.3 Accounting System ............................................................................................................................ 13

6.4 Controls ............................................................................................................................................. 14

6.5 Audit Requirements .......................................................................................................................... 14

7. Monitoring Policies and Procedures ....................................................................................................... 14

7.1 Performance Tracking ....................................................................................................................... 16

7.2 Grant Utilization Monitoring ............................................................................................................. 17

7.3 Risk Assessment and Mitigation ....................................................................................................... 17

7.3.1 Risk Log ...................................................................................................................................... 17

7.3.2 Risk Management Plan Template .............................................................................................. 17

7.4 Activity Work Plan Review ................................................................................................................ 18

7.5 Quality Assurance ............................................................................................................................. 18

7.5.1 Applicant File Reviews ................................................................................................................... 18

7.5.2 Participant Feedback and Satisfaction Survey ............................................................................... 18

7.6 Affirmative Action Plan monitoring .................................................................................................. 19

8. Recordkeeping Policies and Procedures ................................................................................................. 20

8.1 FSCJ Records Policy ........................................................................................................................... 22

8.2 File Structure ..................................................................................................................................... 22

8.3 Data ................................................................................................................................................... 23

9. Duplication of Benefits Policies and Procedures .................................................................................... 24

9.1 Supplanting Funds ............................................................................................................................. 24

9.2 Duplication of Benefits Verification Process ..................................................................................... 24

9.3 Subrogation Agreement .................................................................................................................... 25

9.3.1 Overpayment/duplication of benefits recapture process ......................................................... 25

10 Application Intake Policies and Procedures ........................................................................................... 25

10.1 Application process ......................................................................................................................... 26

11 Income Verification Policies and Procedures......................................................................................... 26

11.1 Income verification process ............................................................................................................ 26

12 Eligibility Determination Policies and Procedures ................................................................................. 27

12.1 Eligibility determination process .................................................................................................... 28

13 Language Access Policies and Procedures ............................................................................................. 28

13.1 Access to services ............................................................................................................................ 28

13.2 Process for requesting/assessing language needs assistance ........................................................ 28

13.3 Access to ESOL Services .................................................................................................................. 29

14 Reporting Methodology Policies and Procedures .................................................................................. 29

14.1 Overview ......................................................................................................................................... 29

14.1.1 Programmatic Reporting Schedule .......................................................................................... 29

14.1.2 Required Programmatic Reporting Details .............................................................................. 29

14.1.2 Financial Reporting ...................................................................................................................... 31

15 Complaints and Grievances Policies and Procedures ............................................................................ 32

15.1 Complaints and Grievances............................................................................................................. 33

15.1.1 Complaint and grievance process ............................................................................................ 34

15.2 Log of complaints and grievances ................................................................................................... 35

16 Appeals Policies and Procedures ........................................................................................................... 35

16.1 Appeals ............................................................................................................................................ 35

16.1.1 Appeals process ........................................................................................................................... 36

16.1.2 Log of appeals .............................................................................................................................. 36

17 Detection and Prevention of Fraud, Waste and Abuse Policies and Procedures .................................. 36

17.1 Procedure ........................................................................................................................................ 37

17.2 Responsibility for Prevention and Internal Controls ....................................................................... 37

17.3 Reporting Improper Activities ......................................................................................................... 37

17.4 Investigation, Action and Results .................................................................................................... 38

17.5 Whistleblower Protection ............................................................................................................... 38

Exhibit A ...................................................................................................................................................... 39

Exhibit B ...................................................................................................................................................... 54

Exhibit C ...................................................................................................................................................... 58

Exhibit D ...................................................................................................................................................... 59

Exhibit E ....................................................................................................................................................... 70

Exhibit F ....................................................................................................................................................... 71

1. Purpose This Policies and Procedures Manual for the Florida State College at Jacksonville (FSCJ) is intended to assist program staff in developing, implementing, and administering the Hurricane Irma Workforce Recovery Training Program (WRTP). The manual provides program guidance regarding the general requirements that apply to processes, administrative and financial responsibilities, and the implementation and administration of the WRTP programs. It is the responsibility of the WRTP staff to ensure compliance with all provisions of this manual, Department of Economic Opportunity (DEO), Florida and federal rules and regulations, and the grant award agreement. WRTP staff will also carry out proper and efficient grant administrative practices. To ensure consistent application of the procedures outlined in this manual, this manual intends to provide a clear and concise understanding of the responsibilities associated with the WRTP program. It is anticipated that circumstances will arise that will require deviations from the processes outlined in this manual. In those instances, the reason for the deviations needs to be documented and included in the WRTP file. In some cases, these circumstances will require amending the Policies and Procedures Manual to include new or revised policies or procedures to accommodate these situations. WRTP staff will evaluate, and adjust if necessary, processes and plans on an annual basis to determine that its written practices align with desired outcomes.

This manual will be made available to applicants, participants, and the general public on the WRTP website.

If there are any questions, contact the FSCJ Workforce Recovery Training Program at:

Florida State College at Jacksonville Office of Continuing Workforce Education 601 West State Street Jacksonville, FL 32202 (904) 997-2545

2. Introduction Rebuild Florida Workforce Recovery Training Program: The Florida Department of Economic Opportunity's (DEO) Rebuild Florida Workforce Recovery Training Program was launched to make $20 million in funding available to local workforce development boards, educational institutions, and technical centers located in the communities most impacted by Hurricane Irma. The funding is to be used to launch or expand training programs for construction trades including roofing, masonry, carpentry, concrete finishing, plumbing, HVAC, electricity, heavy equipment operations, carpet laying, window installation, plastering, welding, and more, as outlined in the Request for Applications.

Rebuild Florida is a partnership of DEO and the U.S. Department of Housing and Urban Development. Launched in September 2018, Rebuild Florida uses federal funding for Florida’s long-term recovery efforts from the devastating impacts of natural disasters.

As Duval County was an area impacted by Hurricane Irma, the DEO awarded Florida State College at Jacksonville a Rebuild Florida Workforce Recovery Training Program grant totaling $1,525,379 to create a new program providing general construction trades preparation.

3. Version Policy and Change Policy Version history is tracked in the table below, with notes regarding version changes. The dates of each publication are also tracked in this table. Updates to this manual will be communicated to staff via the WRTP Microsoft Teams (MS Teams) site and the WRTP website.

Date Update Description 9/5/2020 Version 1.0 creation (SOP) 1/21/2021 Version 2.0 creation (Policy and Procedure Manual) 2/25/2021 Version 2.5 major revision prior to approval

3.1 Manual Change Process • Draft manual update; • Submit to grant team for feedback, update draft manual; • Submit draft manual to Director for feedback, review, and approval; • Add version change information to the table; • Complete DEO change form; • Submit manual and change form to DEO for feedback, review, and approval; and • Upon DEO approval,

o Update grant MS Teams site DEO Submission Status tab; o Add a post to the MS Teams site communicating the change and approval; o Email the updated copy of the manual to Communications to post on the website; and o Check that the update was made on the website

4. Procurement Policies and Procedures Per the Program Subrecipient Agreement, FSCJ will:

Submit all proposed procurement documents to the DEO Grant Manager at least fourteen (14) calendar days before public posting. DEO will review procurement documents for compliance with state and federal requirements and will approve procurement documents before public posting. FSCJ will request DEO’s approval for all professional services contracts and/or Agreements that will be reimbursed with CDBG-DR funds. Copies of the following procurement documents will be provided to DEO for review:

a. When publication of a Request for Proposal (RFP) is used as a means of solicitation, a copy of the advertisement, including an affidavit of publication;

b. DEO will either approve the procurement or notify the Subrecipient that the procurement cannot be approved because it violates State, Federal or local procurement guidelines. FSCJ will notify DEO in writing no later than 90 calendar days from the effective date of the Agreement if it will not be procuring any professional services or if it will be using non-CDBG-DR funds to pay for professional services.

Before the obligation or disbursement of any funds, except for administrative expenses and not to exceed $5000, FSCJ will complete the following:

• Submit for DEO’s approval the documentation required above for any professional services contract. FSCJ proceeds at its own risk if more than the specified amount is incurred before DEO approves the procurement. If DEO does not approve the procurement of a professional services contract, the local government will not be able to use CDBG-DR funds for that contract beyond $5,000.

• Conflicts of interest relating to procurement will be addressed according to 24 C.F.R. § 570.489(g). Title 24 C.F.R. § 570.489(h) will apply in all conflicts of interest not governed by 24 C.F.R. § 570.489(g), such as those relating to the acquisition or disposition of real property; CDBG-DR financial assistance to beneficiaries, businesses, or other third parties; or any other financial interest, whether real or perceived. Additionally, the FSCJ will comply with Chapter 112 FS.

Procurement and Contractor Oversight FSCJ will comply with the procurement standards in 2 CFR §200.318 - §200.326 when procuring property and services under the Agreement. FSCJ will impose its obligations under the Agreement on its contractors, specifically or by reference, so that such obligations will be binding upon each of its contractors.

FSCJ will comply with CDBG regulations regarding debarred or suspended entities, specifically including, 24 CFR 570.609 or 24 CFR 570.489(l) as appropriate. CDBG funds may not be provided to excluded or disqualified persons.

FSCJ will maintain oversight of all activities under the Agreement and will ensure that for any procured contract or agreement, its contractors perform according to the terms and conditions of the procured contracts or agreements, and the terms and conditions of the Agreement.

Competition All procurement transactions will follow the provisions of 2 C.F.R. §§ 200.318-200.326 and be conducted in a manner providing full and open competition. FSCJ will be alert to conflicts of interest as well as non-competitive practices among contractors that may restrict or eliminate competition or otherwise restrain trade. To ensure objective contractor performance and eliminate an unfair competitive advantage, contractors that develop or draft specifications, requirements, statements of work, invitations for bids, or requests for proposals will be excluded from competing for such procurements. Awards will be made to the responsible and responsive bidder or offeror whose proposal is most advantageous to the program, considering the price, quality, and other factors. Solicitations will set forth all requirements that the bidder or offeror will fulfill for the bid or offer to be evaluated by FSCJ. All bids or offers may be rejected if there is a sound, documented reason.

4.1 Procurement Plan In the event of a change in scope that requires procurement activities, FSCJ will follow Florida State College at Jacksonville Procurement Procedures With Federal Grant Funding (Exhibit A) guidelines, FSCJ Specification for Competitive Bidding (Exhibit B) and DOE Administrative Code 6A-14.0734 Procurement Requirements (Exhibit C), in addition to the procurement requirements specified in the Federally-Funded Community Development Block Grant Disaster Recovery (CDBG-DR) Workforce Recovery Training Program Subrecipient Agreement (Agreement). In the event that the Agreement requirements conflict with FSCJ guidelines, the Agreement will supersede FSCJ procurement guidelines.

• FSCJ doesn’t anticipate any procurement activity in excess of $4999. • No WRTP procurement activities have been initiated prior to Agreement execution.

1. FSCJ will submit all proposed procurement documents to the DEO Grant Manager at least

fourteen (14) calendar days prior to public posting. DEO will review procurement documents for compliance with state and federal requirements and must approve procurement documents prior to public posting.

2. The FSCJ will request DEO’s approval for all professional services contracts and/or Agreements that will be reimbursed with CDBG-DR funds. Copies of the following procurement documents must be provided to DEO for review:

a. When publication of a Request for Proposal (RFP) is used as a means of solicitation, a copy of the advertisement, including an affidavit of publication;

b. The FSCJ will notify DEO in writing no later than 90 calendar days from the effective date of the Agreement if it will not be procuring any professional services or if it will be using non-CDBG-DR funds to pay for professional services.

3. Prior to the obligation or disbursement of any funds, except for administrative expenses and not to exceed $5000, the FSCJ will complete the following:

a. Submit for DEO’s approval the documentation required in paragraph 3 for any professional services contract.

b. Comply with 24 C.F.R. part 58 and the regulations implementing the National Environmental Policy Act, 40 C.F.R. §§ 1500-1508.

4. Conflicts of interest relating to procurement will be addressed pursuant to 24 C.F.R. § 570.489(g). Title 24 C.F.R. § 570.489(h) will apply in all conflicts of interest not governed by 24 C.F.R. § 570.489(g), such as those relating to the acquisition or disposition of real property; CDBG-DR financial assistance to beneficiaries, businesses or other third parties; or any other financial interest, whether real or perceived. Additionally, the FSCJ will comply with, and the Agreement is subject to, Chapter 112 F.S.

5. The FSCJ will comply with the procurement standards in 2 CFR §200.318 - §200.326 when procuring property and services under the Agreement. The FSCJ will impose the FSCJ’s obligations under the Agreement on its contractors, specifically or by reference, so that such obligations will be binding upon each of its contractors.

6. The FSCJ will comply with CDBG regulations regarding debarred or suspended entities, specifically including, 24 CFR 570.609 or 24 CFR 570.489(l) as appropriate.

7. The FSCJ will maintain oversight of all activities under the Agreement and will ensure that for any procured contract or agreement, its contractors perform according to the terms and conditions of the procured contracts or agreements, and the terms and conditions of the Agreement.

8. In the procurement of supplies, equipment, construction and services pursuant to the Agreement, the FSCJ will comply with the conflict of interest provisions in DEO’s procurement policies and procedures. In all cases not governed by the conflict of interest provisions in DEO’s procurement policies and procedures, the FSCJ will comply with the conflict of interest provisions in 24 CFR 570.489(h).

9. All procurement transactions must follow the provisions of 2 C.F.R. §§ 200.318-200.326 and be conducted in a manner providing full and open competition. The FSCJ will be alert to conflicts of interest as well as noncompetitive practices among contractors that may restrict or eliminate competition or otherwise restrain trade. In order to ensure objective contractor performance and eliminate unfair competitive advantage, contractors that develop or draft specifications, requirements, statements of work, invitations for bids or requests for proposals will be excluded from competing for such procurements. Awards must be made to the responsible and responsive bidder or offeror whose proposal is most advantageous to the program, considering the price, quality and other factors. Solicitations will clearly set forth all requirements that the bidder or offeror must fulfill in order for the bid or offer to be evaluated by the FSCJ. Any and all bids or offers may be rejected if there is a sound, documented reason.

10. If the FSCJ contracts any of the work required under the Agreement, a copy of the proposed contract template and any proposed amendments, extensions, revisions or other changes thereto, will be forwarded to DEO for prior written approval. For each contract, the FSCJ will report to DEO as to whether that contractor or any subcontractors hired by the contractor, is a minority vendor, as defined in Section 288.703, F.S. The FSCJ will comply with the procurement standards in 2 C.F.R. §200.318 - §200.326 when procuring property and services under the Agreement.

5. Contract Administration Policies and Procedures Per the Program Subrecipient Agreement, FSCJ will:

If FSCJ contracts any of the work required under the Agreement, a copy of the proposed contract template and any proposed amendments, extensions, revisions, or other changes thereto, will be forwarded to DEO for prior written approval. For each contract, FSCJ will report to DEO as to whether that contractor or any subcontractors hired by the contractor, is a minority vendor, as defined in Section 288.703, F.S. FSCJ will comply with the procurement standards in 2 C.F.R. §200.318 - §200.326 when procuring property and services under the Agreement (refer to Attachment D).

FSCJ will include the following terms and conditions in any contract pertaining to the work required under the Agreement:

1. the period of performance or date of completion; 2. the performance requirements; 3. that the contractor is bound by the terms of the Agreement; 4. that the contractor is bound by all applicable State and Federal laws, rules, and regulations; 5. that the contractor will hold DEO and FSCJ harmless against all claims of whatever nature arising

out of the contractor’s performance of work under the Agreement; 6. the obligation of FSCJ to document in FSCJ’s reports the contractor’s progress in performing its

work under the Agreement; and 7. the requirements of 2 CFR Appendix II to Part 200 – Contract Provision for Non-Federal Entity

Contract Under Federal Awards.

FSCJ will comply with CDBG regulations regarding debarred or suspended entities (24 C.F.R. 570.489(l)), pursuant to which CDBG funds will not be provided to excluded or disqualified persons and provisions addressing bid, payment, performance bonds, if applicable, and liquidated damages.

FSCJ will maintain oversight of all activities performed under the Agreement and will ensure that its contractors perform according to the terms and conditions of the procured contracts or agreements and the terms and conditions of the Agreement.

A system for contract administration is maintained to ensure contractor conformance with the terms, conditions, and specifications of the contract, and to ensure adequate and timely follow up of all purchases.

The Program Manager will evaluate contractor performance and document, as appropriate, whether contractors have met the terms, conditions, and specifications of the contract.

The College will include, in addition to provisions to define a sound and complete agreement, the following provisions in all contracts. The following provisions are applied to subcontracts:

a. Contracts over the small purchase threshold fixed at U.S.C. 403(11) will contain contractual provisions or conditions that allow for administrative, contractual, or legal remedies in instances in which a contractor violates or breaches the contract terms, and provide for remedial actions as may be appropriate;

b. All contracts over the small purchase threshold will contain suitable provisions for termination by the College; and

c. Except as otherwise required by statute, an award that requires the contracting (or subcontracting) for construction or facility improvements will provide for the College to follow Florida Statutes, SREF, and its own requirements relating to bid guarantees, performance bonds, and payment bonds unless the construction contract or subcontract exceeds $100,000.

All negotiated contracts (except those for less than the small purchase threshold) awarded by FSCJ will include a provision to the effect that the recipient, ED, the Comptroller General of the United States, or any of their duly authorized representatives, will have access to any books, documents, papers, and records of the contractor which are directly pertinent to a specific program to make audits, examinations, excerpts, and transcriptions.

5.1 Contract Administration FSCJ’s will use the appropriate solicitation methods, contract types, and contract pricing as following [2CFR 200.318 and 2 CFR 200.323]:

• Only one of the solicitation methods (Small Purchase, Sealed Bid/formal advertising, Competitive Proposals, Noncompetitive Proposals) are employed for each procurement.

• Requirements for the applicable solicitation method are followed. • Only the appropriate contract types (Purchase Order, Fixed Price, Cost Reimbursement) are

employed for each procurement. • A “cost plus a percentage of cost” or a “percentage of construction cost” type pricing will not be

used for contracts. • A “time and material” type contract is only used after a determination is made that no other

contract is suitable, and the contract includes a ceiling price that the contractor exceeds at its own risk.

• A contract is priced appropriately, as determined by contract services (Lump sum pricing, unit pricing, or reimbursement of costs).

• Purchase of unnecessary or duplicative items will be avoided. • Where appropriate, an analysis is made of lease and purchase alternatives to determine which

would be the most economical and practical procurement for the Federal Government. • Solicitations for goods and services provide for the following:

o A clear and accurate description of the technical requirements for the material, product, or service to be procured.

o Requirements that the bidder/offeror must fulfill and all other factors to be used in evaluating bids or proposals.

FSCJ’s will implement the Code of Conduct addressing the following [2CFR 200.318(c)]:

• No employee, officer, or agent of FSCJ will participate in the selection, or the award administration of a contract supported by Federal funds if he or she has a real or apparent

conflict of interest, including conflicts of interest involving any member of his or her immediate family, partner, employer, or potential employer.

• Officers, employees, or agents will neither solicit nor accept gratuities, favors, or anything of monetary value from contractors, potential contractors, or parties to subcontracts.

• Penalties, sanctions, or other disciplinary actions for violations. • Policies regarding organizational conflicts of interest, if the entity has a parent, affiliate, or

subsidiary organization that is not a state, local government, or Indian tribe. • FSCJs’ Procurement policies and procedures include require that staff review proposed

procurements for cost reasonableness, including [2 CFR 200.323]: o To avoid unnecessary purchases; o To avoid duplicative purchases, and o Ensure costs are reasonable.

FSCJ’s policies and procedures address how staff review proposed procurements to ensure contractors are eligible. The review determines that awards are not made to any party which is debarred or suspended or is otherwise excluded from or ineligible for participation in Federal assistance programs. Information may be verified in the Excluded Parties List System in the System for Award Management. [2 CFR 180, 2 CFR 200.205, Appendix II to Part 200(I)] FSCJ’s WRTP procurement policies and procedures require that:

• Affirmative efforts will be undertaken to use women’s business enterprises, minority firms, and labor surplus firms when possible. [2 CFR 200.321]

• All disputes relating to procurement actions will be handled, resolved, and disclosed. [2 CFR 200.318(k)]

• All procurements will be conducted using full and open competition unless an exclusion applies. [2 CFR 200.319]

• Ensure that unfair competitive disadvantages are eliminated in procurements. [2 CFR 200.319(a)]

Solicitations will meet the following requirements:

• Incorporate a clear and accurate description of the technical requirements for the product or service to be procured.

• Identify all requirements the offerors will fulfill and all other factors to be used in evaluating bids or proposals. [2 CFR 200.319(c)]

6. Financial Management Policies and Procedures Per the Program Subrecipient Agreement, FSCJ will:

Financial Management

FSCJ’s financial management system complies with the provisions of 2 C.F.R. part 200 (and particularly 2 C.F.R 200.302 titled “Financial Management”), Section 218.33, F.S., and will following:

1. Accurate, current, and complete disclosure of the financial results of this project or program.

2. Records that identify the source and use of funds for all activities. These records contain information about grant awards, authorizations, obligations, unobligated balances, assets, outlays, income, and interest.

3. Effective control over and accountability for all funds, property, and other assets. FSCJ will safeguard all assets and assure that they are used solely for authorized purposes.

4. Comparison of expenditures with budget amounts for each Request for Funds (RFF). As appropriate, financial information is related to performance and unit cost data.

5. Written procedures to determine whether costs are allowed and reasonable under the provisions of the 2 C.F.R. part 200 (and particularly 2 C.F.R. 200 Subpart E titled “Costs Principles”) and the terms and conditions of the Agreement.

6. Cost accounting records that are supported by backup documentation.

6.1 Financial Management Florida State College at Jacksonville will maintain records of expenditure funds from all sources and will be prepared to provide DEO with explanations and records that connect any and all expenditures to the corresponding program budget. This includes 24 CFR 570.502 and 2 CFR 200.302 which state the Uniform Administrative Requirements, Cost Principles, and Audit Requirements that are applicable for federal awards. This includes keeping all of the required documentation during the agreement and no longer than 6 years after the termination of the subrecipient agreement and the submission of performance and evaluation reports.

Accounting record entries including asset tracking, requisitions, vouchers, procurement card transactions and time and effort forms are stored with the college’s ERP system.

Each transaction submitted by the Program Manager will be reviewed for compliance and approved by the college’s Project Accounting Office before moving forward for approval by the AVP of Workforce Development and associated departments including purchasing and accounts payable. The Project Accounting Office also manages budgets for grant funded projects, including projections of the financial needs across programs.

The AVP of Workforce Development and programmatic staff working within this division report to the VP for Online and Workforce Education, who reports to the College President. Separately, the VP of Finance and staff—including the Project Accounting Office— report to the College President.

This division of labor ensures the segregation of duties between the programmatic staff and the finance staff. For a visual representation, please see the organizational chart here.

The financial management will include accurate and complete disclosure of financial results in accordance the reporting requirements set forth in 2CFR 200.328 which states the data elements collected and the intervals of reporting must comply with the standards set by the Executive Office of the President, Office of Management and Budget.

The college will capture the following activities:

• Amount budgeted; • Advances/reimbursements received to date; • Program income & other miscellaneous receipts; • Actual expenditure/disbursements;

• Current encumbrances/obligations; and • Unpaid request for payments.

Florida State College at Jacksonville will comply with audit requirements, as specified in the subrecipient agreement, which states that a single or program-specific audit must be conducted if $750,000 or more in federal awards are expended within a fiscal year. The most recent single audit report is available here dated February 16,2021, which covered the fiscal year ending on June 30, 2020.

The auditors are expected to act in accordance with auditing standards generally accepted in the United States of America; applicable standards contained in Government Auditing Standards, issued by the Comptroller General of the United States; and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

6.2 FSCJ Standards FSCJ has financial management systems in place to comply with the following standards:

• Provide effective control over and accountability for all funds, property, and other assets; • Identify the source and application of funds for federally-sponsored activities, including records

and reports that: o Verify the “reasonableness, allowability and allocability” of costs; and o Verify that funds have not been used in violation of any of the restrictions or prohibitions

that apply to the federal assistance (through the use of budget controls and adequate accounting records).

o Permit the accurate, complete, and timely disclosure of financial results per reporting requirements.

6.3 Accounting System CDBG funded agencies will maintain records that adequately identify the source and application of funds provided for financially assisted activities. Each agency will maintain adequate accounting records that meet various standards, including cost principals and financial management, that are compliant with 24 CFR 570.502 and 2 CFR 200.302, and all other applicable laws and regulations.

The College is required to have accounting records that sufficiently identify the source and application of CDBG funds provided to them. To meet this requirement, the College’s accounting system includes the following elements:

• Chart of accounts - This is a list of account names and the numbers assigned to each of the account names. The names describe the type of transactions that will be recorded in each account (e.g., an account titled “cash” denotes that only transactions affecting cash should be recorded in that account). The account number is required by most accounting software programs and is assigned to an account name to group similar types of accounts. For example, all asset accounts will begin with a “1” and all liability accounts will begin with a “2”. A typical chart of accounts will generally include the following categories: assets, liabilities, fund balance, revenues, and expenses.

• Cash receipts- Cash receipts document when funds were received, in what amounts, and from what sources.

• Cash disbursements - Cash disbursements document when an expense was incurred, for what purpose, how much was paid, and to whom it was paid.

• Payroll journal - A payroll journal documents payroll and payroll-related benefit expenses on salaries and benefits, including distinguishing between categories for regulatory purposes.

• General ledger - A general ledger summarizes the activity and financial status of all the accounts of an organization. Information is transferred to the general ledger after it is entered into the appropriate journal. Entries transferred to the general ledger should be cross-referenced to the applicable journal to permit the tracing of any financial transaction. All non-subsystem journal entries must be properly approved and supported by source documentation. Documentation must show that costs charged against CDBG were: o Incurred during the effective period of the agreement with HUD; o actually paid out (or properly accrued); or o Expended on eligible items; and o Approved by the appropriate official(s) within the organization.

6.4 Controls FSCJ has controls in place, including multiple-step approval for all purchases, journal entries, and invoice submissions to reduce the opportunity for someone to perpetrate or conceal errors or irregularities in the normal course of duties.

The following controls are in place to ensure the accuracy and validity of financial records:

• Access: Confidential online records are limited to staff requiring access to complete job functions through system security. Access is reviewed periodically to ensure each employee’s continued need for the data. Physical barriers are in place to limit access to only authorized employees to blank forms and assets (cash).

• Approvals: All disbursements require approvals before transactions can be completed. • Reconciliation: Periodic reconciliations are performed to validate the financial records. • Inventory: An annual inventory is performed to verify physical assets. • Documentation: Accounting record entries are supported with applicable documentation such

as receipts, invoices, checks, bank records, etc.

6.5 Audit Requirements Financial Audits are conducted annually and in accordance with applicable standards by the Florida Auditor General. Audit findings and recommendations are given timely and appropriate resolution. [2 CFR 200.501-507] As a condition of receiving Federal funds, the OMB requires, as described in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), an audit of the State’s financial statements and major Federal awards programs. FSCJ audits may be found at https://flauditor.gov/pages/Reports.aspx.

7. Monitoring Policies and Procedures Per the Program Subrecipient Agreement, FSCJ will:

Monitor and ensure services are provided in sufficient quantity and quality to meet all requirements and objectives. This includes, but is not limited to, monitoring the following:

a. Frequency and availability of activities, including times and locations, to meet the needs of the target population;

b. Fiscal controls to ensure all funds are expended in accordance with the Agreement and all relevant state and federal policies and regulations, including, but not limited to, 2 CFR 200, Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and 24 CFR 570;

c. Programmatic monitoring including, but not limited to, program integrity, reach, and effectiveness, staffing and educator standards, and evaluation, training progress and completion, communication from oversight managerial level to direct programming level, completion of all tasks and requirements outlined in the Agreement, and corrective action, as necessary;

d. Partner and/or subcontractor performance; e. FSCJ staff performance; f. Participant outcomes, including, but not limited to, attendance, program completion rates,

course grades (if applicable), certification rates, employment, and job retention; and g. Participant feedback and satisfaction, to be obtained via survey questionnaires developed by

FSCJ and approved by DEO before use. All participants will be provided the opportunity to complete a survey questionnaire.

Single Audit: FSCJ will be audited as required by 2 CFR part 200, subpart F when it is expected that the FSCJ's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in §200.501 Audit requirements.

Inspections and Monitoring: FSCJ will permit DEO and auditors to have access to the FSCJ's records and financial statements as necessary for DEO to meet the requirements of 2 CFR part 200.

FSCJ will submit to monitoring of its activities by DEO as necessary to ensure that the award is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the Agreement.

This review will include:

1. reviewing financial and performance reports required by DEO; 2. following-up and ensuring that FSCJ takes timely and appropriate action on all deficiencies

pertaining to the Federal award provided to FSCJ from DEO detected through audits, on-site reviews, and other means; and

3. issuing a management decision for audit findings pertaining to this Federal award provided to FSCJ from DEO as required by 2 CFR §200.521.

Corrective Actions: FSCJ will be subject to reviews and audits by DEO, including onsite reviews of FSCJ as may be necessary or appropriate to meet the requirements of 42 U.S.C. 5304(e)(2). DEO may issue management decisions and may consider taking enforcement actions if noncompliance is detected during audits. DEO may require FSCJ to take timely and appropriate action on all deficiencies pertaining to the Federal award provided to FSCJ from the pass-through entity detected through audits, on-site reviews, and other means. In response to audit deficiencies or other findings of noncompliance with the Agreement, DEO may impose additional conditions on the use of the CDBG-DR funds to ensure future compliance or provide training and technical assistance as needed to correct noncompliance.

In addition to reviews of audits conducted in accordance with 2 CFR 200 Subpart F - Audit Requirements, and section 215.97, F.S., as revised, monitoring procedures may include, but not be limited to, on-site visits by DEO staff, limited scope audits as defined by 2 CFR §200.425, or other procedures. By entering into the Agreement, FSCJ has agreed to comply and cooperate with any monitoring procedures or processes deemed appropriate by DEO. In the event DEO determines that a limited scope audit of FSCJ is appropriate, FSCJ will comply with any additional instructions provided by DEO staff to FSCJ regarding such audit. FSCJ will comply and cooperate with any inspections, reviews, investigations or audits deemed necessary by the Chief Financial Officer (CFO) or Auditor General.

FSCJ will permit DEO and auditors to have access to its records and financial statements as necessary for DEO to meet the requirements of 2 C.F.R. part 200.

FSCJ will submit to monitoring of its activities by DEO as necessary to ensure that the grant is being used for authorized purposes in compliance with Federal statutes, regulations, and the terms and conditions of the Agreement.

This review will include:

1. reviewing financial and performance reports required by DEO; 2. following-up and ensuring that FSCJ takes timely and appropriate action on all deficiencies

pertaining to the Federal award provided to FSCJ from DEO as detected through audits, on-site reviews, and other means, and

3. the issuance of a management decision for audit findings pertaining to this Federal award provided to FSCJ from DEO as required by 2 C.F.R. §200.521.

7.1 Performance Tracking FSCJ grant staff will monitor performance based on the projected LMI vs actual LMI student enrollments and service provided. No more than 2 non-LMI students will be enrolled in Training Services per month. Corrective action will be taken when the total projected is greater than the actual in any of the categories.

Projected Unduplicated Participants Per Month

Actual Unduplicated Participants Per Month

VLI LI MI Non-LMI Total VLI LI MI Non-

LMI Total

Training Services (Construction

Trades) 2 3 3 2 10

Completing Training (Construction

Trades) 2 3 3 2 10

Support Services 2 3 0 0 5

Career Services 2 3 3 2 10

Employed at Exit 2 2 2 1 7

7.2 Grant Utilization Monitoring An Excel spreadsheet will be used to monitor grant utilization every quarter. The spreadsheet will contain the following information:

• Grant Start Date • Grant End Date • Expense Budget • Encumbered/Obligated • Actual Expenses • Available/Unexpended • Percent Expended • Percent of Time Lapsed • Months Remaining

A grant utilization review will take place when the percent expended (actual expense/expense budget) falls outside of the 30% acceptable range compared to the percent of time-lapsed (grant days lapsed/total grant days).

7.3 Risk Assessment and Mitigation 7.3.1 Risk Log When a risk is identified by one of the monitoring tools, the risk will be logged on an Excel spreadsheet then assigned a score based on the probability that the risk will occur (1-low to 5-high) and impact the success of the grant (1-low to 5-high). Risks will be assigned a risk level and action as follows:

Risk Score Risk Level Action 1 - 4 Minimum risk Acceptable risk, no action required 5 - 6 Some risks Monitor, reassess risk score weekly 7 - 8 High risk Create risk management plan including mitigation, communicate with

FSCJ grant leadership; request technical assistance from DEO 9 - 10 Show stopper Create risk management plan including mitigation, communicate with

FSCJ grant leadership and DEO 7.3.2 Risk Management Plan Template A risk management template will be used to assess, manage and mitigate the risk. The template consists of the following sections:

• Purpose • Risk Identification • Risk Analysis • Risk Response

• Risk Monitor and Control • Definitions of Risk Probability and Impact • Reporting and Communications • Mitigation and Contingency Planning

7.4 Activity Work Plan Review The SharePoint Activity Work Plan task list will be kept up to date by grant staff and monitored monthly to ensure compliance.

7.5 Quality Assurance Grant staff will perform file reviews and utilize data collected during the review process to improve program processes and procedures.

7.5.1 Applicant File Reviews A checklist will be created and stapled to the outside of each applicant’s folder. The form will include:

• List of all applicant forms • A statement certifying that all forms filled out completed and all required documentation is

included in the file • A line for certifying signature and date

The checklist will be completed for 25% randomly selected applicant files monthly, with results being used to improve the process as needed.

7.5.2 Participant Feedback and Satisfaction Survey A participant feedback and satisfaction survey will be created to assess the quality of the programs offered. Survey results will be used to improve program offerings to better meet the needs of the target population. Survey questions will include:

• Does the frequency of class offerings meet your needs? Yes|No • Are classes available for enrollment? Yes|No

• Are classes offered at convenient times? Yes|No • Are classes offered at convenient locations? Yes|No

Survey participants will be asked to provide free text explanations for all “No” answers.

7.6 Affirmative Action Plan monitoring Grant staff will monitor the following:

• Grant staff will annually review and examine the effectiveness of the affirmative action program and its compliance with Executive Order 11246.

• A copy of this plan will be made available for review by all departmental heads and employees via the grant’s website.

• A copy of the grant’s Affirmative Action Policy Statement shall be posted in an area accessible in the Case Manager’s office and on the grant’s website.

• All grant employment advertisements will contain a statement that “The FSCJ is an Affirmative Action/Equal Opportunity Employer” and encourages minority and women-owned firms to apply.

• Grant-related bid documents shall contain a clause that the FSCJ will not award a contract to any contractor or supplier covered by Executive Order 11246 who refuses to comply with the EEO clause.

• The College’s grant Standard Instructions to Bidders for Construction, Materials, and Supplies, will state that the successful bidder will certify to compliance with all applicable equal employment opportunity laws and regulations, that acceptance of the contract shall constitute compliance.

• The policy statement will be included in the grant’s Personnel Rules. • A listing of various agencies, institutions, and newspapers, as available, will be contacted in the

event of a position vacancy occurrence with the grant. This listing, which will be used to assist in disseminating employment opportunities, will be modified to enhance the affirmative outreach efforts of the grant.

Also, grant staff will:

1. Monitor all records of referrals, hires, terminations, transfers, and promotions at all levels of the grant to ensure that the grant’s nondiscrimination policy is carried out.

2. Design and implement reporting systems that will permit continuous grant monitoring of Equal Employment Opportunity progress and will serve to provide management with requisite data in that regard. Further, such systems will be used to: a. Measure the effectiveness of the grant’s progress; b. Indicate any need for additional remedial action; and c. Determine the degree to which the grant’s objectives and goals have been achieved.

3. Review the results obtained with grant staff at quarterly meetings, report on progress as required, and develop recommendations for improvements as necessary.

4. Maintain the following documents as a component of the internal audit process: a. Applicant File; b. Personnel Activity File; and c. Employment Applications.

The FSCJ has established a discrimination complaint procedure and will take prompt and reasonable action to investigate and eliminate discrimination when found.

8. Recordkeeping Policies and Procedures Per the Program Subrecipient Agreement, FSCJ will:

Records

The FSCJ’s performance under the Agreement is subject to 2 C.F.R. part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

Representatives of DEO, the Chief Financial Officer of the State of Florida, the Auditor General of the State of Florida, the Florida Office of Program Policy Analysis and Government Accountability, and representatives of the Federal government and their duly authorized representatives will have access to any of FSCJ’s books, documents, papers and records, including electronic storage media, as they may relate to the Agreement, to conduct audits or examinations or make excerpts or transcriptions.

FSCJ will maintain books, records, and documents in accordance with generally accepted accounting procedures and practices which sufficiently and properly reflect all expenditures of funds provided by DEO under the Agreement.

FSCJ will retain sufficient records to show its compliance with the terms of the Agreement and the compliance of all contractors, subcontractors, and consultants paid from funds under the Agreement for six (6) years from the date DEO issues the final closeout for this award. FSCJ will also comply with the provisions of 24 CFR 570.502(a)(7)(ii). FSCJ will further ensure that audit working papers are available upon request for six (6) years from the date DEO issues the final closeout of the Agreement unless extended in writing by DEO. The six years may be extended for the following reasons:

1. Litigation, claim or audit initiated before the six-year period expires or extends beyond the six years, in which case the records will be retained until all litigation, claims or audit findings involving the records have been resolved.

2. Records for the disposition of non-expendable personal property valued at $1,000 or more at the time of acquisition will be retained for six (6) years after final disposition.

3. Records relating to real property acquired will be retained for six (6) years after the closing on the transfer of title.

FSCJ will maintain all records and supporting documentation for itself and for all contractors, subcontractors, and consultants paid from funds provided under the Agreement, including documentation of all program costs in a form sufficient to determine compliance with the requirements and objectives of the scope of work and all other applicable laws and regulations.

FSCJ will either (i) maintain all funds provided under the Agreement in a separate bank account or (ii) ensure that its accounting system will have sufficient internal controls to separately track the expenditure of all funds from the Agreement. Provided further, that the only option available for advanced funds is to maintain such advanced funds in a separate bank account. There will be no commingling of funds provided under the Agreement with any other funds, projects, or programs.

FSCJ, including all of its employees or agents, contractors, subcontractors, and consultants to be paid from funds provided under the Agreement, will allow access to its records at reasonable times to representatives of DEO, the Chief Financial Officer of the State of Florida, the Auditor General of the

State of Florida, the Florida Office of Program Policy Analysis and Government Accountability or representatives of the Federal government or their duly authorized representatives. “Reasonable” will ordinarily mean during normal business hours of 8:00 a.m. to 5:00 p.m., local time, Monday through Friday.

FSCJ acknowledges that it is subject to Florida’s Government in the Sunshine Law (Section 286.011, F.S.) with respect to the meetings of the FSCJ’s governing board or the meetings of any subcommittee making recommendations to the governing board. FSCJ hereby agrees that all such aforementioned meetings will be publicly noticed, open to the public, and the minutes of all the meetings will be public records made available to the public in accordance with Chapter 119, F.S

Public Record Responsibilities.

In addition to the FSCJ’s responsibility to directly respond to each request it receives for records, in conjunction with the Agreement and to provide the applicable public records in response to such request, FSCJ will notify DEO of the receipt and content of all such requests by sending an email to PRRequest@deo.myflorida.com within one (1) business day from receipt of the request.

FSCJ will keep and maintain public records required by DEO to perform its responsibilities. FSCJ will, upon request from DEO’s custodian of public records, provide DEO with a copy of the requested records or allow the records to be inspected or copied within a reasonable time at a cost that does not exceed the cost provided by Chapter 119, F.S., or as otherwise provided by law. FSCJ will allow public access to all documents, papers, letters, or other materials made or received by FSCJ in conjunction with the Agreement, unless the records are exempt from Article I, Section 24(a) of the Florida Constitution and Section 119.07(1), F.S. For records made or received by FSCJ in conjunction with the Agreement, FSCJ will respond to requests to inspect or copy such records in accordance with Chapter 119, F.S. For all such requests for records that are public records, as public records are defined in Section 119.011, F.S., FSCJ will be responsible for providing such public records per the cost structure provided in Chapter 119, F.S., and in accordance with all other requirements of Chapter 119, F.S., or as otherwise provided by law.

The Agreement may be terminated by DEO for refusal by FSCJ to comply with Florida’s public records laws or to allow public access to any public record made or received by FSCJ in conjunction with the Agreement.

FSCJ will notify DEO verbally within twenty-four (24) chronological hours and in writing within seventy-two (72) chronological hours if any data in its possession related to the Agreement is subpoenaed or improperly used, copied, or removed (except in the ordinary course of business) by anyone except an authorized representative of DEO. FSCJ will cooperate with DEO, in taking all steps as DEO deems advisable, to prevent misuse, regain possession or otherwise protect the State’s rights and the data subject’s privacy.

FSCJ acknowledges that DEO is subject to the provisions of Chapter 119, F.S., relating to public records and that reports, invoices and other documents FSCJ submits to DEO under the Agreement constitute public records under Florida Statutes. FSCJ will cooperate with DEO regarding DEO’s efforts to comply with the requirements of Chapter 119, F.S.

If FSCJ submits records to DEO that are confidential and exempt from public disclosure as trade secrets or proprietary confidential business information, such records should be identified as such by FSCJ before submittal to DEO. Failure to identify the legal basis for each exemption from the requirements of Chapter 119, F.S., before submittal of the record to DEO serves as FSCJ’s waiver of a claim of exemption.

FSCJ will ensure public records that are exempt or confidential and exempt from public records disclosure requirements are not disclosed except as authorized by law for the duration of the Agreement term.

RECORD RETENTION. FSCJ will retain sufficient records demonstrating its compliance with the terms of the Agreement for five (5) years from the date the audit report is issued, or six (6) state fiscal years after all reporting requirements are satisfied and final payments have been received, whichever period is longer, and will allow DEO, or its designee, CFO, or Auditor General access to such records upon request. FSCJ will ensure that audit working papers are made available to DEO, or its designee, CFO, or Auditor General upon request for six (6) years from the date the audit report is issued, unless extended in writing by DEO. Also, if any litigation, claim, negotiation, audit, or other action involving the records has been started before the expiration of the controlling period as identified above, the records will be retained until completion of the action and resolution of all issues which arise from it, or until the end of the controlling period as identified above, whichever is longer.

8.1 FSCJ Records Policy See Exhibit D, FSCJ Board Policy – Records

In case the policies contained in the FSCJ Board Policy conflict with those contained in the Program Subrecipient Agreement, the Program Subrecipient Agreement will supersede the FSCJ policy. In the case of document retention requirements, the document with the longest timeframe will be used.

8.2 File Structure Electronic files will be stored on the grant’s Microsoft SharePoint Team site in a document library. The documents will also be accessible via the grant’s Microsoft Teams site. Document library access will be limited to FSCJ grant stakeholders. A log of the name, role, employee id, and reason for the request, as well as approval status (approved|denied) and protected personal information (PPI) (Yes|No) will be maintained. Most users will be granted visitor access, allowing them to view all documents. Documents considered by FSCJ to contain PPI will be restricted in a secure folder with only those staff requiring access permitted.

All records will be maintained electronically unless otherwise required by the Program Subrecipient Agreement. The SharePoint document library file structure will be as follows:

• PROGRAM MANAGEMENT o Internal monitoring and quality assurance reports; o State or federal monitoring or audit reports; o Timesheets or other documentation of program administration staff time spent specifically

to this program; o Funding Approval/Grant Agreement o All contract amendments and supporting documentation o All DEO approved grant-related documents not listed

• FINANCIAL MANAGEMENT

o Financial and performance reports o Invoices o Supporting documentation for vendor payments o A bank statement that includes the canceled check or evidence of electronic funds transfer

• ENVIRONMENTAL REVIEW RECORD

o DEO approved Environmental Review Exempt/CENST Form

• EQUAL OPPORTUNITY o Total direct beneficiaries, including a breakdown of LMI, female heads of household,

Hispanic, and minorities o All equal opportunity/civil rights complaints and grantee’s response to these complaints

• PROCUREMENT AND CONTRACT MANAGEMENT

o DEO approved Procurement Manual o Copies of all RFFs and supporting invoices reference with check numbers, dates and

amounts paid o Excluded vendor list o Small purchase contracts o Listing of all vendors solicited, including MBE, WBE, and price o quotations o Copy of specifications provided to vendors o Executed contract, invoices, and all other purchasing documents o Photos of purchased items, as applicable

• STUDENT TRACKING SYSTEM (ACCESS RELATIONAL DATABASE)

o Student name, contact, and demographic information o Student class enrollment information, status o Student attendance o Program completion rates o Certification rates o Log of assistance provided o Log of applications processed o Log of approval and denial determinations o Log of complaints and grievances o Log of appeals o Student job placement verification/employer information o Job retention information

• STAKEHOLDER/CONSTITUENT COMMUNICATIONS

o All criticisms, complaints, and grantees’ responses to these criticisms and complaints o Agenda and meeting notes from Community and Employer Advisory Committees o DEO approved Public Outreach Plan

• STUDENT FOLDER

o Electronic files o Hardcopy files

8.3 Data The data contained in the table below will be maintained in an Access database.

Data Category Purpose Frequency Source PPI (Y|N) Applicant Contact To communicate with

the applicant Daily; updated as needed

DEO database Y

Applicant Demographics Tracking Daily DEO database Y Applicant Eligibility Monthly Progress;

Quarterly Progress Report

Daily DEO database Y

Student Information Monthly Progress; Quarterly Progress Report

Event-driven FSCJ SIS Y

Student Assistance Monthly Progress; Quarterly Progress Report

Event-driven Grant database – Assistance Log

Y

Appeals Monthly Progress; Quarterly Progress Report

Event-driven Grant database – Appeals Log

Y

Complaints/Grievances Monthly Progress; Quarterly Progress Report

Event-driven Grant database – Complaints/ Grievances Log

Y

Employment Monthly Progress; Quarterly Progress Report

Event-driven Grant database – Placement and Retention Logs

Y

9. Duplication of Benefits Policies and Procedures Per the Program Subrecipient Agreement, FSCJ will:

Duplication of Benefits. FSCJ will not carry out any of the activities under the Agreement in a manner that results in a prohibited duplication of benefits as defined by Section 312 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act of 1974 (42 U.S.C. 5155 et seq.) and described in Appropriations Acts. FSCJ will comply with HUD’s requirements for duplication of benefits, imposed by the Federal Register Guidance. FSCJ will carry out the activities under the Agreement in compliance with DEO’s procedures to prevent duplication of benefits.

9.1 Supplanting Funds FSCJ will utilize grant funds to supplement rather than supplant funds otherwise available. Grant funds will only be utilized after all other funds available to provide benefits to the participant for the same purpose have been expended. Any supplanting of funds will be treated as a duplication of benefits or fraud, waste, and abuse, and is subject to recapture under the terms of the Agreement. All grant participants dually enrolled in any FSCJ program will be flagged for review.

9.2 Duplication of Benefits Verification Process As a part of eligibility determination, FSCJ will conduct a duplication of benefits screening for any individual applying for services through the grant. The duplication of benefits process includes

verification of assistance received relating to disaster recovery, workforce training, or other assistance provided for the same or similar purpose as the grant disclosed on the participant application. FSCJ will maintain duplication of benefits records for individual applicants.

As a part of the initial interview and in addition to the information contained on the grant application, applicants will be screened to ensure that benefits are not duplicated.

In the unlikely event that grant recipients begin receiving other hurricane Irma workforce training relief funds during their program participation, as part of the class sign-in sheet, students will be required to attest to the fact that they have not and are not currently receiving any other hurricane Irma workforce training relief funds. As part of the program exit process, the end of grant assessment will contain a question asking if the student is currently receiving any other hurricane Irma workforce training relief funds.

9.3 Subrogation Agreement As a part of the onboarding process, all approved and enrolled grant students will be asked to sign the subrogation agreement acknowledging that any overpayment or duplication of benefits will be subject to recapture. The agreement will be signed before benefits or services are provided. The signed agreement will be scanned and placed in their student folder.

9.3.1 Overpayment/duplication of benefits recapture process If a grant student is determined to have received Federal financial workforce training assistance related to Hurricane Irma and that duplication of benefits has occurred, FSCJ will:

• remove the duplicated grant coverage for the student and recalculate their WRTP tuition coverage;

• reimburse DEO; and • set up a debt on the student account for the overpaid tuition and items paid by the grant and

received by the student.

10 Application Intake Policies and Procedures Grant applications will be accepted from the start date of the grant through March 31, 2023.

The WRTP program application is the only application that will be used to access WRTP program services and benefits. FSCJ will not substitute any other application for the official application. While FSCJ may request that institution-specific forms be completed, those forms will not be required from applicants.

All participants must agree to the following to receive assistance:

• Sign a release so that information provided by the participant applicant may be reviewed, disclosed, released, and shared as necessary to verify information and process the application.

• The participant applicant and each household member 18 years of age or older are required to sign the release.

• Sign a fraud acknowledgment certifying that information provided by the participant applicant is true and correct, under penalty of law.

• Sign a subrogation agreement acknowledging that any overpayment or duplication of benefits will be subject to recapture.

10.1 Application process 1. Interested individuals will be able to access the official Workforce Recovery Training Program

(WRTP) application by clicking the “Apply Here” button on the WRTP page at www.rebuildflorida.gov.

a. The online participant application is only for participants. Grant staff will not use the online participant application to submit applications.

2. During the application process, individuals may be prompted to complete and submit forms with their application.

a. PDF copies of these forms will be available on the WRTP page at www.rebuildflorida.gov.

3. To support access by individuals with limited English proficiency, pdfs of the application and all forms are provided in English, Spanish, and Haitian Creole.

a. Only English language forms may be submitted. b. Spanish and Haitian Creole language forms are for informational purposes only.

4. Individuals who need assistance completing an application may contact grant staff by phone, email, or in person.

a. In cases where the applicant is unable to apply online, grant staff will create a New Participant Application to start a new application on behalf of an applicant.

5. The applicant will complete initial eligibility screening questions, if they pass initial eligibility, they will register for the program.

6. After completing registration, the applicant will complete the application. 7. Grant staff will check Azure daily for new applications.

a. If it is determined during application processing that the application is incomplete, including missing information or documentation, the grant staff must notify the applicant in writing of all missing information and provide instructions on how the applicant can submit the information.

8. Grant staff is responsible for maintaining the official record of the complete application, including any additional information provided after the initial submission.

a. Submitted application data compiled in a daily digest will be downloaded by grant staff. b. After application data is downloaded, this information may be uploaded into the grant’s

MS Access database for applicant processing, eligibility determination, enrollment, and participant tracking.

11 Income Verification Policies and Procedures Grant activities carried out by FSCJ will meet the national objective to benefit low- and moderate-income persons. To meet this national objective, at least fifty-one (51) percent of participants served will meet low- and moderate-income requirements, following published HUD income limits, as updated annually and made available by HUD. To comply with the national objective, FSCJ will verify income for any individual applying for services through the WRTP.

11.1 Income verification process In verifying income, grant staff uses source documentation as evidence of annual income including review of documents and third-party verification. Income eligibility is determined based on total household income and total household size.

Income documentation will be obtained through the intake process. The Applicant will provide the necessary information to calculate income based on LIM. Source documentation will be obtained and third-party verification will be used as needed to verify claims or other eligibility criteria through the program on occasions that source documentation is not available. Applicants will be provided a list of any additional documentation needed at the time of the application interview and will have 30 calendar days to return documentation before their application will be moved to an inactive status. Additional time may be provided for documentation that is not readily available to the Applicant, on a case-by-case basis.

The adjusted gross household income will be determined and verified following the grant agreement. Approved documents will be collected for all household members as applicable. Dependents and their potential income will be recorded. Income will be recorded for all household members and combined to calculate a total household income.

When every possible, grant staff will use Federal Income tax forms for the most recent year. If the applicant did not file an income tax return, then the Income Self-Attestation Form or Zero Income Self-Attestation Form will be used to determine Low-Mod Income as established by HUD and updated annually.

All documents provided by the Applicant for verification of income will be copied and placed in the Applicant’s file to accompany their income calculation documentation.

The following income sources will be considered:

A. Wages, salaries, tips, commissions, etc.; B. Self-employment income from own nonfarm business, including proprietorships and

partnerships; C. Farm self-employment income; D. Interest, dividends, net rental income, or income from estates or trusts; E. Social Security or railroad retirement; F. Supplemental Security Income, Aid to Families with Dependent Children, or other

public assistance or public welfare programs; G. Retirement, survivor, or disability pensions; and H. Any other sources of income received regularly, including Veterans' (VA) payments,

unemployment compensation, and alimony.

12 Eligibility Determination Policies and Procedures Applications are reviewed by grant staff. Only the information in the Rebuild Florida WRTP participant application, including supporting documentation, will be considered for the determination of eligibility for program services and benefits. The grant staff will make the determination on eligibility based on these program guidelines and the grant’s policies and procedures.

Eligibility for WRTP services and benefits may only be determined on the following criteria:

• At least 18 years of age or older; • Authorized to work in the United States; and • Income

Priority for WRTP services and benefits will be given for the following mandatory criteria:

• Veterans and eligible spouses and dependents, following federal regulations • Income (LMI applicants)

FSCJ will ensure that LMI limited clientele national objective of at least 51 percent of participants served must be LMI by limiting the number of above LMI class enrollments to two per month.

FSCJ will comply with the requirement that eligibility determination is an inherently governmental function that must be carried out by a governmental entity.

12.1 Eligibility determination process Application files that have had all required documents submitted will undergo an eligibility review to include income eligibility and calculation. The Case Manager will conduct the initial eligibility review ensuring all required documents are present, complete, and verified. Completed files will be submitted to the Program Manager for review and approval.

Applicants whose files indicate that the applicant is eligible to receive grant funds will be approved by the Program Manager. As part of the approval process, applicants will be sent letters indicating their approved status and outlining the next steps. Applicant status in the MS Access will be changed to approved and the information will be added to the Approval and Denial Determination Log. Applicant files will be scanned and stored on the grant SharePoint site; the paper file will be retained.

Applicants whose files are determined to be ineligible by the Program Manager will be sent a letter detailing the reason for the denial including:

• Reason for denial; and • A clear explanation of how the denial complied with WRTP policy, the agreement and/or law. • Right to appeal (see Appeals Policies and Procedures)

Applicant status will be updated in the MS Access database and appropriate log. Applicant files will be scanned and stored on the grant SharePoint site; the paper file will be retained.

Incomplete files will be returned to the Case Manager with a memo describing the deficiencies.

13 Language Access Policies and Procedures Per the Program Subrecipient Agreement, FSCJ will:

FSCJ will ensure that all required HUD CDBG-DR and program requirements are met regarding providing access to services in English, Spanish, and Haitian Creole, as well as, document the process for requesting or assessing alternative language needs.

13.1 Access to services The grant will provide program training with access to Spanish or Haitian Creole translation services to include screening, training program documents, classroom instruction, and support services.

13.2 Process for requesting/assessing language needs assistance When an application is received from an applicant indicating that primary language is something other than English, grant staff will interview the student to assess their level of English comprehension.

Students requiring language assistance in Spanish or Haitian Creole will be provided translation services to include screening, training program documents, classroom instruction, and support services.

13.3 Access to ESOL Services If the student requests language assistance or staff feel the student may need assistance, the student will be offered the opportunity to participate in the English for Speakers of Other Languages (ESOL) Program at FSCJ. If the student chooses, the grant will pay for one 15-week course of English for Speakers of Other Languages (ESOL) Program services costing $30. The program is offered morning, afternoon, and evening at various sites. FSCJ’s ESOL program includes:

1. Pretests students in both listening and reading for placement with the Comprehensive Adult Student Assessment System (CASAS) exam (the lower of the two skill areas determines the level for student placement)

2. Focuses on reading, writing, speaking, listening, vocabulary, grammar, and conversation to prepare students to use English for everyday life

3. Is designed to teach students to listen, speak, read, and write English in seven life-skills topics: Communication, Civics, Family and Community Resources, Employment, Consumer Education, Health and Nutrition, Transportation and Travel, and Safety and Security

14 Reporting Methodology Policies and Procedures Per the Program Subrecipient Agreement, FSCJ will:

FSCJ will provide DEO with all reports and information outlined in Attachment G, Reports. The monthly reports and administrative closeout reports will include the current status and progress of FSCJ and all subcontractors in completing the work described in the Scope of Work and the expenditure of funds under the Agreement. Upon request by DEO, FSCJ will provide additional program updates or information. If all required reports and copies are not sent to DEO or are not completed in a manner acceptable to DEO, payments may be withheld until the reports are properly completed.

14.1 Overview The grant will maintain accurate files and records of programmatic and financial reporting and will retain all pertinent documentation. Compliance will be maintained following the reporting requirements as outlined in the Agreement.

14.1.1 Programmatic Reporting Schedule Report Name Frequency Due Monthly Progress Report Monthly Ten (10) calendar days after the end of each

month Affirmative Action Report Monthly Ten (10) calendar days after the end of each

month Contract and Subcontract Activity form Biannually April 15 and October 15 Internal monitoring and quality assurance report

Monthly Ten (10) calendar days after the end of each month

Quarterly Report Quarterly By the 10th of every April, July, October, and January

14.1.2 Required Programmatic Reporting Details Monthly Progress Report

The Monthly Progress Report (Exhibit E) will include:

Deliverable No. 1 – Training and Career Service Delivery

• Sign-in sheets that include the class date, class agenda, name and signature of the participant(s), name and signature of the instructor or Subrecipient staff certifying participant(s) attendance;

• Sign-in sheets that include the support service, career service, or other service provided, date service provided, name and signature of the participant(s), and name and signature of Subrecipient staff certifying that services were provided in accordance with the Agreement; and

• Participant progress reports, program completion certification, or other evidence of satisfactory progress.

Deliverable No. 2 – Program Management and Oversight

• Log of assistance provided, including date, name of person assisted, and method of delivery (phone, email, in person);

• Log of applications processed, including date application submitted and date of issuance of notice of eligibility determination; and accompanying notice(s) of acceptance, denial, or incompleteness;

• Log of complaints and grievances, including date received, case origin, participant or applicant name, case description, point of contact, status, resolution action, and resolution date; and

• Log of appeals, including date received, participant or applicant name, appeal description, point of contact, status, determination on appeal, and determination date.

Deliverable No. 3 – Program Administration

• Internal monitoring and quality assurance reports; • State or federal monitoring or audit reports; and • Timesheets or other documentation of program administration staff time spent specific to this

program.

Affirmative Action Report

• When a grant vacancy takes place: o Documentation of out-reach efforts to attract a diverse candidate pool; o Demographic matrix of applicants, interviewed candidates and selected individual

• Terminations, transfers, and promotions of grant staff: o Report demographic data

The following documents will be maintained for reporting purposes:

• Applicant File; • Personnel Activity File; • Employment Applications.

Contract and Subcontract Activity form

See Exhibit F

Internal Monitoring and Quality Assurance Report

The Program Manager will assess program performance through monthly monitoring desk reviews. The monitoring outcomes may be shared with DEO upon request or if technical assistance is required to resolve identified issues. FSCJ will notify DEO if any monitoring results impact reporting or compliance. Monitoring will be documented with the following:

• Number of applicant files reviewed • Number of eligibility issues found • Approval/rejection response times vs. agreement frame • Class attendance vs. enrollment • Program completion 6 weeks/8 weeks/10 weeks • Student survey results satisfied vs. dissatisfied • Summary of issues identified

Issues identified during the program performance monitoring will be tracked on the grant’s MS Teams site as either open or resolved. Resolved issues will contain the outcome and recommendations for change in process/policy as needed.

Quarterly Report

Report on program services and performance will include the following:

• Demographics (Race, Ethnicity, Age, Gender); • Citizenship/work eligibility; • Income level (Extremely Low, Very Low, Low, Moderate and Above); • Female head of household; • Individuals determined eligible to receive WRTP services; • Enrollment in a training program; • Type of training program; • Occupation related to training; • Activity start and end dates; • Support services; • Training completion; • Credential / certificate earned; • Entered employment at completion (includes occupation, wages, employer); and • Employment retention.

14.1.2 Financial Reporting Financial statements and reporting must be complete, current, reviewed periodically, and provide complete disclosure of the financial results of each Federally-sponsored project or program.

Reports related to HUD CDBG-DR will include the items listed below. All of these items are available for access within the Peoplesoft system utilized by Florida State College at Jacksonville:

• Amount budgeted; • Advances/reimbursements received to date; • Program income & other miscellaneous receipts; • Actual expenditure/disbursements;

• Current encumbrances/obligations; and • Unpaid request for payments.

15 Complaints and Grievances Policies and Procedures Per the Program Subrecipient Agreement, FSCJ will:

Citizen Complaints

The goal of the State is to provide an opportunity to resolve complaints in a timely manner, usually within fifteen (15) business days as expected by HUD, if practicable, and to provide the right to participate in the process and appeal a decision when there is a reason for an applicant to believe its application was not handled according to program policies. All guidelines and websites will include details on the right to file a complaint or appeal and where to get more information about the process for filing a complaint or beginning an appeal. Complaints or grievances, except complaints alleging unlawful discrimination, must be filed first with FSCJ. FSCJ will have policies and procedures relating to the process for appeals and will make these policies and procedures available to applicants and participants.

The Subrecipient will handle complaints by conducting:

a. Investigations as necessary; b. Resolution; or c. Follow-up actions.

If the complainant is not satisfied by the FSCJ’s determination, then the complainant may file a written appeal by following the instructions issued in the letter of response. If, at the conclusion of the appeals process, the complainant has not been satisfied with the response, a formal complaint may then be addressed directly to the DEO at:

Office of Disaster Recovery, Special Deputy of Appeals Division of Community Development Department of Economic Opportunity 107 East Madison Street Caldwell Building, MSC-160 Tallahassee, FL 32399

Complaints or grievances relating to actions or decisions made by DEO may be filed with DEO. Individuals may file a written complaint through the Office of Disaster Recovery email at CDBGDR@deo.myflorida.com, via the online complaint form available at http://www.rebuildflorida.gov, or by postal mail to the following address:

Attention: Rebuild Florida Constituent Services Division of Community Development Florida Department of Economic Opportunity 107 East Madison Street The Caldwell Building, MSC 160 Tallahassee, Florida 32399

The Florida Office of Disaster Recovery operates in accordance with the Federal Fair Housing Law (The Fair Housing Amendments Act of 1988). Anyone who feels he or she has been discriminated against may

file a complaint of housing discrimination: 1-800-669-9777 (Toll-Free), 1-800-927-9275 (TTY) or www.hud.gov/fairhousing. Complaints alleging non-housing discrimination and equal opportunity complaints may be filed at 404-331-5140, complaintsoffice04@hud.gov, or

Atlanta Regional Office of FHEO U.S. Department of Housing and Urban Development Five Points Plaza 40 Marietta Street, 16th Floor Atlanta, GA 30303-2806

Also, grant staff will:

• Accept, track, process, review, and respond to complaints and grievances. • Log of complaints and grievances, including date received, case origin, participant or applicant

name, case description, point of contact, status, resolution action, and resolution date.

15.1 Complaints and Grievances Complaints or grievances may be filed regarding any concerns that participants or participant applicants may have with the procedures followed and services provided by the grant. Procedural and service complaints/grievances will be addressed by the Grant Program Manager. Complaints/grievances alleging unlawful discrimination should be filed directly with the FSCJ Chief Officer, Diversity/Equity & Inclusion. Individuals may file a written complaint through:

Program Manager lynn.larson@fscj.edu Florida State College at Jacksonville Deerwood Center DWC-B2247 9911 Old Baymeadows Road Jacksonville, FL 32256

FSCJ Chief Officer, Diversity/Equity & Inclusion equityofficer@fscj.edu Florida State College at Jacksonville Human Resources Administrative Offices 501 W. State Street Jacksonville, Florida 32202

The complaint should be in writing and contain information about the concern, including a description of the problem and desired outcome. No particular format of the complaint is required but should include the participant or participant applicant’s name and contact information. Alternative means of filing complaints, such as personal interviews or a tape recording of the complaint, will be made available upon request. Spanish/Haitian Creole translation services will be provided upon request.

Within 5 working days after receipt of the complaint, the Grant Program Manager will meet with the complainant to discuss the complaint and the possible resolutions. Within 10 working days of the meeting, the Grant Program Manager will provide a written response, and when possible, offer options for substantive resolution. All responses will include instructions on how to appeal the Program Manager's decision. If due to an ongoing investigation, a response cannot be provided within 10 working days, the complainant/grievant will be provided a status every 5 working days until a final determination is made.

If the complainant is not satisfied by the Subrecipient’s determination, then the complainant may file a written appeal by following the instructions issued in the letter of response. If, at the conclusion of the

appeals process, the complainant has not been satisfied with the response, a formal complaint may then be addressed directly to the DEO at:

Office of Disaster Recovery, Special Deputy of Appeals Division of Community Development Department of Economic Opportunity 107 East Madison Street Caldwell Building, MSC-160 Tallahassee, FL 32399

Complaints or grievances relating to actions or decisions made by DEO may be filed with DEO. Individuals may file a written complaint through the Office of Disaster Recovery email at CDBGDR@deo.myflorida.com, via the online complaint form available at http://www.rebuildflorida.gov, or by postal mail to the following address:

Attention: Rebuild Florida Constituent Services Division of Community Development Florida Department of Economic Opportunity 107 East Madison Street The Caldwell Building, MSC 160 Tallahassee, Florida 32399

The Florida Office of Disaster Recovery operates in Accordance with the Federal Fair Housing Law (The Fair Housing Amendments Act of 1988). Anyone who feels he or she has been discriminated against may file a complaint of housing discrimination: 1-800-669-9777 (Toll-Free), 1-800-927-9275 (TTY) or www.hud.gov/fairhousing. Complaints alleging non-housing discrimination and equal opportunity complaints may be filed at: 404-331-5140, complaintsoffice04@hud.gov, or

Atlanta Regional Office of FHEO U.S. Department of Housing and Urban Development Five Points Plaza 40 Marietta Street, 16th Floor Atlanta, GA 30303-2806

15.1.1 Complaint and grievance process • Accept – a complaint/grievance is considered accepted the day that it is received by the Grant

Program Manager • Track – all accepted complaints/grievances are entered into the log • Process – the grant Program Manager will interview the complainant/grievant within 5 working

days • Review – a review, including investigation, will take place after the interview • Respond to complaints and grievances – the grant Program Manager will provide a written

response to the complaint/grievance within 10 working days. The response will include instruction on how to appeal the Program Manager's decision. If an investigation has not been completed with 10 working days, the complaint/grievance will receive status updates every 5 working days until a final determination is made.

15.2 Log of complaints and grievances A Microsoft Access log will be used to track complaints and grievances. The log will include the following fields:

• Date received • Case origin • Participant or applicant name • Case description • Point of contact • Status • Resolution action • Resolution date

16 Appeals Policies and Procedures Per the Program Subrecipient Agreement, FSCJ will:

• Accept, track, process, review, and issue decisions on appeals. • Log of appeals, including date received, participant or applicant name, appeal description, point

of contact, status, determination on appeal, and determination date.

16.1 Appeals Appeals may be filed only upon the deliverance of an adverse program decision regarding eligibility, benefits, or closure of an application, and only within the parameters set by the appeals procedure. Participants may not appeal the program policy. If an individual is denied program services or benefits and desires to appeal, the individual should first file the appeal with the FSCJ Program Manager who made the initial eligibility decision.

All appeals must be filed with the FSCJ Program Manager first. Any appeals filed with DEO before a final determination on the appeal has been made by the FSCJ Program Manager will be forwarded to the FSCJ Program Manager for handling. Written appeals should be sent to:

Program Manager lynn.larson@fscj.edu Florida State College at Jacksonville Deerwood Center DWC-B2247 9911 Old Baymeadows Road Jacksonville, FL 32256

All appeal must be in writing and must include:

• Reason for appeal; • A clear explanation why the denial was contrary to applicable laws or regulations or in

some other way inequitable; • The reason why the individual is believed to be eligible for the service or benefit that was

denied, delayed, reduced, modified, or terminated;

• Proposed remedy sought by the individual;

• Name, contact address, and contact telephone number of individual filing appeal; and • Signature and date.

An appeal initiated by a participant or participant applicant with the FSCJ Program Manager will follow written appeal procedures, which may include, but may not be limited to, informal interview, escalation to the grant program Director review, or other administrative review.

A written decision will be provided to the appellant within 15 working days, including the final determination of the appeal and the right to appeal to DEO.

If, after following the FSCJ’s appeal procedure, an individual wishes to appeal the final determination to DEO, an appeal may be filed with DEO. All appeal letters must be submitted in writing within 30 days of the date of the denial letter via U.S. Mail to:

Attention: Rebuild Florida Constituent Services Division of Community Development Florida Department of Economic Opportunity 107 East Madison Street The Caldwell Building, MSC 160 Tallahassee, Florida 32399 Email: CDBGDR@deo.myflorida.com

16.1.1 Appeals process • Accept – an appeal is considered accepted the day that it is received by the Grant Program

Manager • Track – all appeals are entered into the log • Process – the grant Program Manager will interview the appellant • Review – a review will take place after the interview; the appeal may be referred to another

FSCJ department for review • Issue decisions on appeals – A written decision will be provided to the appellant within 15

working days.

16.1.2 Log of appeals A Microsoft Access log will be used to track appeals. The log will include the following fields:

• Date received • Participant or applicant name • Appeal description • Point of contact • Status • Determination on appeal • Determination date

17 Detection and Prevention of Fraud, Waste and Abuse Policies and Procedures FSCJ is committed to aggressively detecting and eradicating fraud, waste, and abuse to ensure that grant administered programs provide services effectively and efficiently and that taxpayer funds are protected. Each employee, provider, vendor, contractor, consultant, partner, citizen, and applicant has a

role and responsibility to ensure that service delivery complies with local, state, and federal laws and policies and that any incidents are reported immediately for investigation and resolution.

FSCJ will investigate all allegations regarding eligibility, disbursement of funds, or any other allegations of fraud or noncompliance. Where appropriate, the FSCJ will assist federal, state, and local agencies in investigations.

17.1 Procedure Fraudulent, unethical and dishonest acts involve a willful or deliberate act or omission with the intention of obtaining an unauthorized benefit, service or property of value from FSCJ through deception, misrepresentation or other unethical or unlawful conduct (“Improper Activities”). Examples of Improper Activities include, but are not limited to:

1. Forgery or unauthorized alteration of documents or computer records; 2. Falsification or misrepresentation of reports internally to management or externally to

regulatory agencies; 3. Falsification or misrepresentation of time sheets, travel claims for reimbursement or other

expense reimbursement claims; 4. Authorizing or receiving compensation for time not worked; 5. Misappropriation of funds, supplies or other assets; 6. Engaging in unauthorized activity that results in a real or apparent conflict of interest; 7. Unauthorized use or disclosure of confidential, proprietary or protected information to

unauthorized individuals; 8. Removal of FSCJ property, records or other assets from the premises without supervisory

approval; 9. Unauthorized use or destruction of College property, records or college assets, and 10. Taking information and using it or providing information to others that would lead to identity

theft.

17.2 Responsibility for Prevention and Internal Controls 1. Supervisors are responsible for establishing and maintaining proper internal controls that will

provide for the security and accountability of the resources entrusted to them. Such controls include, but are not limited to, ensuring that:

a. incompatible duties are properly separated, b. financial transactions are properly authorized and approved, c. reports of financial activity are periodically reviewed for completeness and accuracy, d. official personnel actions (ex: appointments, terminations, promotions) and employee

time and leave is properly authorized and approved, e. assets are physically secured, f. computer passwords are protected and not shared, g. confidential and sensitive information is protected from unauthorized access, and h. employees are effectively supervised.

2. In addition, employees shall be cognizant of the risks and exposures inherent in their area of responsibility, take appropriate steps to help mitigate those risks and be aware of the related symptoms of Improper Activities. Employees shall be alert to the possibilities of Improper Activities and for any indication that Improper Activities are taking place.

17.3 Reporting Improper Activities 1. Any person may report Improper Activities or suspected Improper Activities of a College

employee. Allegations of Improper Activities may be reported anonymously. Any College employee who has knowledge of Improper Activities by the College, its trustees, employees or

independent contractors shall report such knowledge to the College. The employee is not responsible for investigating the activity or for determining fault or corrective measures; appropriate College officials are charged with these responsibilities.

2. Normally, a report by a College employee of allegations of Improper Activity should be made to the reporting employee's immediate supervisor or other appropriate administrator or supervisor within the operating unit. However, when there is a potential conflict of interest or for other reasons, such reports may be made to another College official whom the reporting employee may reasonably expect to have either responsibility over the affected area or the authority to review the alleged Improper Activity on behalf of the College.

3. All supervisors who receive such reports should immediately report them to the Chief Human Resources Officer, who in consultation with the supervisor and the appropriate Vice President and/or Campus President, or designees, will monitor and may participate in any resulting investigation. In all cases, the reporting employee shall not discuss the matter with anyone other than the person or office to whom the Improper Activity was reported.

4. Anonymous reports may also be made through the College’s Ethics and Equity hotline or visiting the Equity/Equal Access webpage or the FSCJ third-party reporting hotline at 833-650-0005 or http://www.lighthouse-services.com/FCSRMC.

17.4 Investigation, Action and Results The Office of Human Resources, in consultation with Business Services, the Office of General Counsel, and other departments as appropriate, will investigate allegations of Improper Activities in accordance with College policy and procedures. All records related to the reporting and investigation of Improper Activities will be maintain by the Office of Human Resources in accordance with College procedures and retention schedules.

1. Employees determined to have participated in any Improper Activities will be subject to disciplinary action in accordance with College policies and procedures.

2. Employees who knowingly make false allegations may be subject to disciplinary action. 3. Employees who report Improper Activities cooperate with the investigation of allegations are

protected against retaliation by the administration and other employees under federal and state law. The law may provide for the individual’s identity to remain confidential.

4. Employees who are dismissed for unethical, dishonest and fraudulent acts will not be eligible for rehire.

17.5 Whistleblower Protection 1. Pursuant to Florida Statute 112.3187, employees who report Improper Activities are protected

from retaliatory actions. Such employees may not be discharged, demoted or otherwise discriminated against as a reprisal for “whistleblowing”. These protections cannot be waived by any agreement, policy, form or condition of employment.

2. Any employee who believes he or she has been subjected to an adverse personnel action for (a) reporting Improper Activity, or (b) for refusing to engage in Improper Activity that would result in a violation of law ("Retaliation" or "Retaliatory Conduct"), should report such conduct, in a written and signed complaint, within sixty (60) days of its occurrence.

3. Such complaints shall also be made to the College’s Equity Officer, 501 W. State Street, Jacksonville, FL 32202; (904) 632-3221 or equityofficer@fscj.edu.

Any complaints or allegations of fraud, waste, abuse, or non-compliance reported to FSCJ involving grant participants or funds will be reported by the FSCJ Program Manager to the DEO Office of Inspector General.

Exhibit A

Exhibit B

Exhibit C

Exhibit D

Exhibit E

Exhibit F