Use of Certain Federal Funds Policy and Procedures

Policy Number: 100.005.01
Approved by: Senior Staff
Effective Date: February 2012

The purpose of this policy is compliance with the provisions of the Higher Education Opportunity Act of 2008 pertaining to lobbying and sections of individual federal grant award agreements pertaining to lobbying.

Policy

It is the policy of Scripps College that no federal funds may be used to pay any person for influencing or attempting to influence an officer or employee of the College or an officer or employee of CUC, in connection with any of the following federal actions:

  1. The awarding of any federal contract
  2. The making of any federal grant
  3. The making of any federal loan
  4. The entering into of any federal cooperative agreement, modification of any federal contract, grant, loan, or cooperative agreement.

It is the policy of Scripps College that no federal student aid funding may be used to hire a registered lobbyist or pay any person or entity for securing an earmark.

Procedures

The Business Affairs Office of the College serves as the compliance department for the policy in partnership with the Office of Financial Aid and the department managers of specific federal grants.

The College’s federal funding is audited annually by independent certified public accountants in compliance with OMB circular A-133.

The College’s general ledger chart of accounts and purchasing and disbursement policies and procedures serve as controls to ensure compliance.

The College uses unique segments of its chart of accounts to provide adequate distinct accounting for all federal funds received and disbursed.

In accordance with the purchasing policy and procedure, department budget managers approve all purchases. If the amounts exceed $5,000, the respective Scripps College Vice President must also approve such expenditures. If the amount exceeds $25,000 the President or CFO must also approve. These employees are regularly informed of the College policy regarding the purchase of lobbying services.