What are key considerations for financial management in the ROSS program?
ROSS grants are cost-reimbursable, meaning that Service Coordinators incur program costs first, and then draw down grant funds for reimbursement. Drawdowns reimburse costs incurred for three types of activities:
- Salary and fringe benefits for Service Coordinators;
- Administrative costs; and
- Travel and training.
The first two categories account for the majority of program costs and drawdowns, and do not require advance approval from HUD. Advance approval from the HUD field office is required, however, before costs are incurred for travel and training.
Service Coordinators request grant funds through e-LOCCS, HUD’s electronic Line of Credit Control System. Once grant funds have been requested and transferred to the grantee’s account, they should be disbursed on a timely basis. Funds requisitioned through e-LOCCS must be disbursed within three calendar days of receipt. Drawdowns in amounts that exceed actual need may result in special procedures for payments. Persistent violations may lead to termination of the grant. The Service Coordinator should retain documentation for all drawdowns, as supporting evidence may be requested during a HUD monitoring visit or audit.
Field office manual review
At least two scenarios will trigger manual review of a request to draw down grant funds:
- When a given draw exceeds 10 percent of the total grant amount; or
- When a Service Coordinator requests more than one draw in a given month.
In both scenarios, e-LOCCS will automatically require HUD to manually review and approve the draw before funds are transferred. Until the draw is approved, the funds will be unavailable to the grantee. Service Coordinators should plan carefully to avoid these situations.
Accounting and financial systems
ROSS grantees must have financial systems that are able to manage the grant in compliance with HUD requirements. Specifically, accounting systems must allow grantees to track and monitor their expenses and provide adequate fund accountability, including tracking ROSS grant funds separately from any other program funds. See Section 200.302 of regulation 2 CFR 200 for additional detail about the requirements for financial management and documentation. Grantees should also review their ROSS Grant Agreement for additional restrictions on co-mingling of ROSS grant funds with funds from other government agencies or HUD programs.
ROSS grantees must submit an annual financial statement, Standard Form SF-425, showing their drawdowns during the course of the year. HUD uses this form to confirm that reported amounts align with draws already taken.