The Office of Highway Safety Planning is required to comply with the National Highway Traffic Safety Administration (NHTSA) Appendix A to Part 1300 Certifications and Assurances to be eligible to receive federal traffic safety funds. As a result, the OHSP requires all subrecipients of these funds to abide by the same requirements for all grant projects funded by the NHTSA federal funds. Section 1 of this document is the verbatim regulations.
Additional State of Michigan, Michigan State Police (MSP), and Office of Highway Safety Planning policies are reported in Section 2.
Policies of the State of Michigan (SOM), Department of State Police, and Office of Highway Safety Planning (OHSP).
The subrecipient is not permitted to begin grant activity or receive reimbursement for said activity without an official award letter. The subrecipient shall not begin activities prior to the start date listed in their official award letter. Activity start dates shall not begin prior to October 1 of the fiscal year.
All correspondence to the OHSP regarding this project shall include the project number (example: 2027-PT-09-00).
Each grant is required to have a minimum of three separate individuals responsible for grant management: one serving as project director, one as a financial officer, and one as an authorizing official. A fourth individual may be added to the grant application as an agency contact. A change in the contact information for the project director, agency contact, financial officer, or authorizing official requires written notification to the OHSP within 10 business days of the change. The project director shall be responsible for making changes in the online grant management system, Michigan Grants System (MGX).
The OHSP is required by the NHTSA to evaluate and document the risk for each entity applying for federal grant funds prior to making an award. The subrecipient shall either register as a new entity/first time user or as an existing entity annually to recertify their Unique Entity Identifier (UEI) number in the online System for Award Management (SAM.gov) to be eligible for federal grants. The OHSP shall ensure active status and the entity is not suspended or debarred at the beginning of the fiscal year. Project Directors shall update their Fiscal Year 2027 (FY2027) online grant application with the active SAM.gov UEI.
The OHSP may conduct a monitoring review of highway safety grants in accordance with Title 2 of the Code of Federal Regulations (CFR) 200, the NHTSA regulations, and these Grant Management Requirements (GMRs) to determine adherence to project objectives, to review financial procedures, and to ensure compliance with grant requirements. All subrecipients are expected to cooperate with all reasonable requests for information as part of the monitoring review process.
The subrecipients shall take reasonable measures to safeguard protected personally identifiable information. “Subrecipients,” as used throughout this document, shall include all grantees, contractors, or participants. This information is based on what the NHTSA or the OHSP designates as sensitive, or that the subrecipient considers sensitive, consistent with applicable federal, state, and local laws regarding privacy and obligations of confidentiality as prescribed under 2 CFR Part 200.303.
All project proposals, applications, and amendments are required to be entered in MGX. The primary subrecipient is responsible for ensuring approved sub-subrecipients participating in a project sign and understand the NHTSA Certifications and Assurances as they have been required by the OHSP. “Sub-subrecipient” includes grantees, contractors, or participants receiving grant funds via a lead subrecipient agency. The primary subrecipients that pass funds through to sub-subrecipients are responsible for monitoring their activities to ensure that federal awards are used for authorized purposes in compliance with federal program laws, regulations, and grant agreements, and that performance goals are being achieved. Monitoring can include, but is not limited to, financial document reviews, reviews of project progress, on-site visits, training, telephone calls, etc. The primary subrecipient organization is responsible for maintaining the signed copies of the Certifications and Assurances documents of their sub-subrecipients, and a subrecipient can be asked to present these documents to OHSP upon request. The subrecipient shall retain these documents per the State of Michigan Retention Policies.
In the event a subrecipient fails to comply with any provision in this funding agreement, the OHSP retains the right to impose sanctions, including withholding payments to the subrecipient until they comply, request reimbursement of previous payments, and/or cancel, terminate, or suspend a funding agreement.
Per Executive Directive No. 2019-09: A department, board, commission, or other agency within the executive branch of state government subject to supervision by the Governor under Article 5, § 8 of the Michigan Constitution of 1963 shall include in any agreement for the provision of a grant or loan involving state money to another person or entity a requirement that the person or entity and any contractor of the person or entity, subcontractor of the contractor, or subrecipient of the grant or loan, not discriminate against an employee or an applicant for employment in hiring, any terms and conditions of employment, or matters related to employment because of religion, race, color, national origin, age, sex, height, weight, marital status, partisan considerations, or a disability or genetic information that is unrelated to the person's ability to perform the duties of a particular job or position.
In addition to the federal certifications and assurances (page 9), the State of Michigan requires all subrecipients to use a seat belt. See MCL 257.710e.
In addition to the federal certifications and assurances (Appendix A to Part 1300, Title 23), the State of Michigan requires all subrecipients to drive hands-free, with some exceptions for emergencies. See MCL Section 257.602b.
All original electronic files, including designs, concepts, photographs, video, and audio financed with grant funds, shall be delivered to the OHSP by an agreed-upon due date between the OHSP and the subrecipient, including all sub-subrecipients and contractors. The OHSP will require one electronic file, such as a PDF, of any publications produced with traffic safety grant funds. The electronic file shall be maintained in the grant application within MGX. The OHSP will follow retention policies set out by the State of Michigan for all materials developed with state highway safety funds.
The items will remain the property of the OHSP and shall not be subject to copyright protection by the vendor or their agents. Items will be submitted to the OHSP immediately after production. The OHSP will hold the final grant reimbursement until all the above items have been submitted. The subrecipient, including all sub-subrecipients and contractors, shall not enter into an agreement that includes any time limits on rights for music, talent, artwork, or photography. The subrecipient, including all sub-subrecipients and contractors, shall inform all vendors, subcontractors, or their agents of this requirement before authorizing work to be performed.
All printed public information and education materials and videos are required to contain logos as designated by the OHSP, which are available in electronic formats upon request (see printing requirements below for more details). Publicly distributed materials, including audio, video, etc., shall include an OHSP disclosure. All materials, including audio and video materials and scripts, shall be submitted for review and approval by the OHSP prior to production.
All businesses performing printing services shall meet one of the following conditions:
See the State of Michigan Procurement Policy Manual (MPPM) Chapter 1 Section 3.15 for information regarding the State Printing Act.
All videos, print photography, or graphics shall depict drivers and passengers to be properly restrained by seat belts or child passenger safety devices unless the lack of restraints is for demonstration or educational purposes. Helmets and other protective equipment shall be depicted for motorcyclists, motorcycle passengers, and bicyclists.
Messaging costs that are of a public relations nature and designed in whole or in part to promote either an individual or an agency are prohibited and not eligible for reimbursement.
The purchase of program advertising space on television, radio, magazines, newspapers, billboards, etc., shall be pre-approved by the OHSP on a case-by-case basis.
The following items require prior approval of the grant’s OHSP program coordinator: flyers; posters; brochures; training curriculum, excluding those developed by nationally approved agencies (e.g., the NHTSA, International Association of Chiefs of Police); annual reports; and newsletters.
The following disclosures shall be placed on all public information and education materials within reasonable limitations of the platform across the following types of projects:
For research projects:
“This was prepared in cooperation with, and funding from, the Michigan Office of Highway Safety Planning (OHSP) and the United States Department of Transportation (USDOT), National Highway Traffic Safety Administration (NHTSA). The opinions, findings, and conclusions expressed are those of the author(s) and are not necessarily those of the Michigan OHSP or the USDOT NHTSA.”
For OHSP Internal Projects and Non-Research Projects:
“This material was developed through a project funded by the Michigan Office of Highway Safety Planning and the U.S. Department of Transportation, National Highway Traffic Safety Administration.”
Furthermore, there are specific requirements for acceptable use of linking to State of Michigan sites and resources. Entities and individuals linking to Michigan.gov shall not:
(1) capture Michigan.gov pages within frames;
(2) misinform users about the origin or ownership of Michigan.gov content;
(3) modify the content and present it as the content of Michigan.gov;
(4) portray any person, entity, or subject in a false or misleading light;
(5) imply that the state endorses your products or services; or
(6) violate any protected intellectual property rights to content on Michigan.gov.
For more information, visit Linking to Michigan.gov from External Websites.
Subrecipients and sub-subrecipients are not permitted to use the state’s Great Seal or Coat of Arms or any state department or agency logo for linking purposes.
Be aware that Michigan.gov and its subpages may change or be deleted at any time without notice. Subrecipients are solely responsible for the accuracy of their links.
To remain compliant with the Americans with Disabilities Act (ADA), subrecipients must comply with the below requirements:
The OHSP follows guidance set out by ADA Section 35.160.
State of Michigan employees are prohibited from using Artificial Intelligence (AI) platforms for any and all sensitive information. Grant-funded products shall not be stored or continuously updated via AI platforms. AI may be used for one-time, static development of materials.
If a subrecipient intends to use AI in the production of any grant-funded public-facing informational and/or educational materials, they must provide their Program Coordinator with the details of how AI will be utilized. Subrecipients must guarantee that no copyrighted materials are used in the produc
Progress reports and/or enforcement reports are required to be submitted throughout the grant period. The due dates for reports are specified in the grant approval letter and shall be submitted in the online grant management system. Progress reports shall describe activities undertaken to accomplish each project goal, the reason for non-activity, if necessary, activities planned for the next quarter, and obstacles encountered or anticipated. Progress reports shall be submitted and approved by the OHSP program coordinator for the OHSP to process financial reimbursement. For traffic safety enforcement projects, enforcement reports shall also be submitted in MGX for the OHSP to process and approve financial reimbursement. Non-compliance with any program requirements or special conditions may result in delay of reimbursement and/or grant termination.
Subrecipients can be called upon to return funds to OHSP if they receive their grant funds and are later determined to be out of compliance.
The final progress report is due on the date stated in the grant approval letter and shall include a summary of all activities and accomplishments for the entire grant period. The final report must include the following information:
Out-of-state travel requires prior written approval from the OHSP Program Coordinator, Section Manager, and Division Director. The OHSP Subrecipient Out-of-State Travel Request form, located in MGX, and appropriate supporting documentation shall be submitted at least 30 days in advance of anticipated travel. Financial commitment (e.g., travel arrangements, conference fees, hotel reservations) shall not be made prior to the OHSP approval.
If a project amendment is required, the subrecipient shall contact the OHSP program coordinator for prior approval.
Subrecipients shall have written and established policies and procedures listed below, where applicable, as required by Title 2 of the Code of Federal Regulations 200, and where otherwise outlined in these requirements. Subrecipients shall meet the standards outlined in:
Three (3) types of reports for federal grant projects have specific deadlines within MGX:
The OHSP Grants System Analyst will generate an email within three business days of a progress and financial reporting deadline via MGX Document Messages associated with the grant application. The recipients of the email will be the Agency Project Director, Agency Contact Person(s), and Agency Financial Officer (for FSRs only), with the OHSP Program Coordinator and OHSP Grant Monitor copied.
If there is no response or adequate information received by the deadline from the first notice, the OHSP Program Coordinator will generate the second delinquent notice from the MSP letterhead template within three business days of the deadline via MGX Document Messages associated with the grant application. They will include itemized details for what specifically is missing and is signed by the applicable OHSP Section Manager. The recipients of the email will be the Agency Project Director, Agency Contact Person(s), Agency Financial Officer, and the Agency Authorized Official, with the OHSP Program Coordinator, OHSP Grant Monitor, OHSP Financial Coordinator, OHSP Financial Manager, OHSP Grant Manager, and OHSP Planning Manager copied.
If there is no response or adequate information received by the deadline from the second notice, the OHSP Program Coordinator will author the final notice canceling the grant project on MSP letterhead, within three business days of the deadline via MGX Document Messages associated with the grant application. The information will need to be very specific to the grant and signed by the OHSP Director. This letter will be sent to the Agency Project Director, Agency Contact Person(s), Agency Financial Officer, Agency Project Staff, and the Agency Authorized Official and OHSP reviewers.
Other standards and restrictions that shall be adhered to by subrecipients and sub-subrecipients during overtime traffic enforcement include:
Compliance with the Federal Funding Accountability and Transparency Act (FFATA) of 2006 is required. Signed into law on September 26, 2006, the FFATA provides the public with a single, searchable database of federal awards. The OHSP is responsible for reporting data into the FFATA database for each NHTSA award that equals or exceeds $30,000. The FFATA reporting procedure also requires that each subrecipient agency maintain current registration in the federal SAM at https://www.sam.gov and obtain their Unique Entity Identifier (UEI).
The following are financial requirements for the subrecipients:
Only program activities and expenses detailed in the approved grant application and incurred during the grant period are eligible for reimbursement. Expenses incurred that are not detailed in the approved grant budget or outside of the grant period shall not be reimbursed. Costs cannot EXCEED the approved grant award.
Goods purchased through the grant shall be received in acceptable condition. If goods are not received in acceptable condition within 30 days prior to the grant ending date, the subrecipient shall contact the OHSP program coordinator.
The subrecipient shall use generally accepted accounting principles.
Costs charged to this grant cannot be charged to any other program.
All costs shall be actual and supported by source documentation. Financial reimbursement will be delayed until all supporting documentation is received by the OHSP.
A separate account or fund shall be established for this project. A separate account is required to be maintained by all agencies receiving grant funds from the OHSP, regardless of the dollar amount. In addition, the subrecipient receiving funds from the OHSP for multiple grant projects shall have a separate account for each grant project and funding type. It is the responsibility of the lead agency to ensure all sub-agencies meet this requirement. The general ledgers of the sub-agencies are not required to be submitted with requests for payment unless specifically requested by the OHSP.
Costs reported on the Financial Status Report (FSR) shall match the agency’s separate account or fund that has been established for this project within the agency's accounting system. Financial documents shall be sufficient to permit the preparation of reports required by general and program-specific terms and conditions, and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award.
Comingling of funds on either a program-by-program or project-by-project basis is prohibited. The subrecipient’s accounting system shall maintain a clear audit trail for each source of funding for each fiscal budget period and include the following:
Costs shall be net of all applicable credits such as purchase discounts, rebates, or adjustments of overpayments, or erroneous charges.
The following deviations from the approved budget require prior approval from the OHSP. Once approved, appropriate amendments will need to be made to the grant agreement in MGX.
Procurement Methods:
Documentation for costs shall be maintained for three years following final reimbursement.
Any program income received shall be used exclusively to further traffic safety project activities. Program income is defined as gross income earned by the prospective primary participant from grant-supported activities. Some examples are proceeds from the sale of items purchased or developed with grant funds, or revenue received from attendees at trainings or conferences paid for with grant funds. Per the Office of Management and Budget requirements, program income shall be utilized as an addition to the federal funding amount awarded for grant projects. It cannot be used as a deduction unless prior approval is received by the NHTSA Regional Administrator. Program income amounts shall be recorded in the online grants management system. Contact the OHSP for further information.
Local match is non-federal, in-kind costs that the subrecipient contributes to the grant project. The FAST Act 405(h) Nonmotorized Safety grant funds and the IIJA 405(g) Nonmotorized Safety grant funds require a minimum twenty percent (20%) local match for the entire grant project cost. Local match costs shall be supported with documentation on FSRs. With prior approval from the OHSP, program income may be used to meet the cost-sharing or matching requirement of the federal award. For additional information on local match or “cost sharing,” reference 2 CFR 200.306.
General Cost of Business/General Cost of Government (formerly referred to as Supplanting): The replacement of routine and/or existing expenditures with the use of state or federal grant funds for costs of activities that constitute general expenses required to carry out the overall responsibilities of a state or local agency or other subrecipient is general cost of business and is not allowable.
All other financial management requirements are listed in Title 2 of the Code of Federal Regulations 200.302 (Financial Management).
All OHSP projects are based on the cost reimbursement concept, i.e., state, local, or private funds shall be expended before reimbursement is provided.
Reimbursement is based on the submission and approval of progress, enforcement, and financial reports. All requested information should be submitted electronically through MGX.A financial report submitted to the OHSP by the subrecipient shall contain the following to be considered complete:
Financial reports are due, at a minimum, on a quarterly basis. Financial report due dates are specified in the grant approval letter. Financial reports shall be submitted even when the project experiences no costs. In this case, a "zero" financial status report shall be submitted. The submission of financial status reports is mandatory, and non-compliance can result in termination of the grant. Financial reports will be considered delinquent if not submitted by the due dates specified in the grant approval letter. The OHSP shall take all steps necessary to ensure that reimbursement payments are completed in a timely fashion. The OHSP authorizes the Michigan Department of Treasury to issue payments to subrecipients and vendors through the Statewide Integrated Governmental Management Applications system.
For other State of Michigan entities (e.g., Michigan State Police, Michigan Department of Transportation, Michigan Department of Health and Human Services), a Cost Accounting Receivable (CARE) document may not be submitted by the subrecipient for reimbursement. Instead, OHSP will prepare the CARE document to ensure accurate reimbursement of funds to the subrecipient. The OHSP may issue an exception to this requirement in writing if necessary.
The Project Director shall ensure that financial reports are submitted in compliance with reporting deadlines. If the financial report is submitted electronically without backup documentation, the report will be returned to the subrecipient for modifications to attach the appropriate backup documentation in MGX.
A delay in submitting supporting documentation may result in the suspension of all grant activity. Failure to submit cost statements with adequate supporting documentation prior to the fiscal year close-out deadline will result in non-reimbursement of those costs. Costs from one fiscal year cannot be paid in a subsequent fiscal year.
Required Audit – Subrecipients must submit to the Federal Audit Clearinghouse (FAC.gov) either a Single Audit, Financial Related Audit, or Audit Exemption Notice as described below. A Financial Related Audit is applicable to non-profit and not-for-profit subrecipients that are designated as subrecipients. If submitting a Single Audit or Financial Related Audit, subrecipients must provide explanations in writing for any audit findings that impact the OHSP-funded programs and submit a corrective action plan to address each finding on how they will correct the issues.
Single Audit – Subrecipients and sub-subrecipients that are a state, county/local government, or non-profit or not-for-profit organization that expend $1,000,000 or more in federal awards during the subrecipient’s and sub-subrecipient’s fiscal year, must submit a Single Audit to FAC.gov, regardless of the amount of funding received from the OHSP. The Single Audit must comply with the requirements of Title 2 of the Code of Federal Regulations, Part 200, Subpart F. The Single Audit reporting package must include all components described in Title 2 of the Code of Federal Regulations, Section 200.512(c).
Other Audits – The OHSP or federal agencies may also conduct or arrange for “agreed upon procedures” or additional audits to meet their needs.
Audit requirements do not apply to subrecipients that are for-profit organizations, per CFR 200.501(i).
(Refer to the following for specific requirements of budget cost categories. Only requirements for cost categories contained within your approved grant budget apply.)
Includes itemized monthly or hourly salary rate. Fringe benefits are included within the Personnel Costs budget line.
Payments for salaries and wages shall be supported by a time and attendance report, based on an after-the-fact distribution of time, which shows details of the activities performed. All time and attendance reports shall be signed by the employee and supervisor. Electronic signatures are accepted. OHSP has a template time and attendance report which can be provided upon request.
Federal guidelines prohibit using federal grant funds to pay for routine and/or existing state or local expenditures.
If the grant contains personnel services as part of the award, a job description for each position listed in the budget shall be available to the OHSP upon request.
For Non-Enforcement Grants
Agencies shall comply with all state labor laws.
The subrecipient shall have a written and established contracting policy that it will utilize when engaging in contracting services. At a minimum, this policy should include cost or price analysis, bid vs. buy decision process, bid acquisition methods (typically a request for proposal process), and contractor monitoring. The contracting policy should follow Title 2 of the Code of Federal Regulations, Part 200.318, 200.321, 200.323, 200.326, 200.330, and Appendix II to Part 200.
In the event a contractor/funding recipient fails to comply with any nondiscrimination provisions in this contract/funding agreement, the OHSP will have the right to impose such contract/agreement sanctions as it or the NHTSA determine are appropriate, including but not limited to withholding payments to the contractor/funding recipient under the contract/agreement until the contractor/funding recipient complies; and/or cancelling, terminating, or suspending a contract or funding agreement, in whole or in part.
Contractual services are services of individual consultants or consulting firms engaged in performing special services pertinent to highway safety. Contracts are allowable, when necessary, to achieve the goals of the grant agreement. Costs are allowable for products, highway safety consultants, personal services, and/or individuals for support services, provided applicable state and local procurement procedures are followed and documentation is available that describes the official contract and procurement practices. Contracts and procurements shall include “special provisions” as provided by the OHSP. The subrecipient is responsible for verifying contractor eligibility by checking the National List of Parties Excluded from Federal Procurement and Non-Procurement Programs list available at www.govinfo.gov or adding a self-certification clause or condition to the contract.
All subrecipients awarding contracts or sub-contracts shall comply with the terms and conditions of the Code of Federal Regulations, Part 200.317. A signed copy of the contract, including the fully listed federal certifications and assurances, shall be provided to the OHSP upon completion and is required for processing and approval of financial reimbursement requests.
The subrecipient awarding is responsible for managing all contracts issued using the OHSP grant funds, including:
The subrecipient awarding shall insert the following clauses in every solicitation for a subcontract or sub-agreement, contracts, and funding agreements which receive federal funds under this program.
During the performance of this contract/funding agreement, the contractor/funding recipient agrees:
In accordance with 2 CFR 200.322, the state and the vendor should, to the greatest extent practicable and consistent with law, provide a preference for the purchase, acquisition, or use of goods, products, or materials produced in the United States (including but not limited to iron, aluminum, steel, cement, and other manufactured products). The requirements of this section shall be included in all subawards, contracts, and purchase orders under federal awards. “Produced in the United States” means, for iron and steel products, that all manufacturing processes, from the initial melting stage through the application of coatings, occurred in the United States. “Manufactured products” means items and construction materials composed in whole or in part of non-ferrous metals such as aluminum; plastics and polymer-based products such as polyvinyl chloride pipe; aggregates such as concrete; glass, including optical fiber; and lumber.
In accordance with 2 CFR 200.216, the state and the vendor are prohibited from obligating or expending loan or grant funds to procure or obtain covered telecommunications equipment or services; extend or renew a contract to procure or obtain covered telecommunications equipment or services; or enter into a contract (or extend or renew a contract) to procure or obtain covered telecommunications equipment or services. As described in Section 889 of Public Law 115-232, “covered telecommunications equipment or services” means telecommunications equipment produced by Huawei Technologies Company or ZTE Corporation (or any subsidiary or affiliate of such entities); for the purpose of public safety, security of government facilities, physical security surveillance of critical infrastructure, and other national security purposes, video surveillance and telecommunications equipment produced by Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, or Dahua Technology Company (or any subsidiary or affiliate of such entities); telecommunications or video surveillance services provided by such entities or using such equipment; telecommunications or video surveillance equipment or services produced or provided by an entity that the Secretary of Defense, in consultation with the Director of the National Intelligence or the Director of the Federal Bureau of Investigation, reasonably believes to be an entity owned or controlled by, or otherwise connected to, the government of a covered foreign country; and systems that use covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system.
In implementing the prohibition under Section 889 of Public Law 115-232, heads of executive agencies administering loan, grant, or subsidy programs shall prioritize available funding and technical support to assist affected businesses, institutions, and organizations as is reasonably necessary for those affected entities to transition from covered telecommunications equipment or services, to procure replacement equipment or services, and to ensure that communications service to users and customers is sustained. When the recipient or subrecipient accepts a loan or grant, it is certifying that it will comply with the prohibition on covered telecommunications equipment and services in this section. The recipient or subrecipient is not required to certify that funds will not be expended on covered telecommunications equipment or services beyond the certification provided upon accepting the loan or grant and those provided upon submitting payment requests and financial reports. For additional information, see Section 889 of Public Law 115-232 and § 200.471.
Only eligible operating costs specifically listed in the approved grant budget will be reimbursed. These are costs not covered under other budget categories, including services not requiring contractual agreements and minor items such as laptops, conferences, membership fees and dues, office supplies, printing, and educational materials.
Automotive expenses submitted shall be based on actual costs incurred, that is, the actual miles driven multiplied by the current Internal Revenue Service (IRS) business mileage rate. With prior approval, reimbursement may be allowed based on the actual costs incurred for gasoline, maintenance, insurance, and other vehicle expenses.
Postage, telephone, and grant-related travel costs shall be documented by log or meter and submitted with the reimbursement request.
Training or conference registration costs should be included as Operating Costs, separate from the costs associated with traveling to such events.
Out-of-state travel funded by federal grant funds requires prior written approval by the OHSP Program Coordinator and/or the Division Director. A written request shall be submitted on the form provided in MGX. Requests shall be submitted at least 30 days in advance of anticipated travel. Financial commitment (e.g., travel arrangements, conference fees, hotel reservations) shall not be made prior to the OHSP approval.
The subrecipient will be reimbursed for approved travel costs (including mileage, meals, and lodging) budgeted and incurred related to services provided under this agreement. The subrecipient will follow all established and documented Travel Policies. These Travel Policies shall be in existence in advance of any budgeted and approved travel.
Reimbursements for travel (meals, lodging, mileage, etc.) cannot exceed the lesser of the subrecipient’s published travel rates or the allowable State of Michigan travel rates. Exceptions require the OHSP’s approval during the grant application process. Subrecipients requesting an exception shall attach their organization’s travel policy when the grant application is submitted. The policy shall be applicable to all organizational travel. Policies will be reviewed by the OHSP Fiscal Manager for approval and cannot exceed the current federal travel reimbursement ratio.
The SOM travel rates may be found at the following website: https://www.michigan.gov/dtmb/services/travel.
All equipment purchases with the NHTSA funds shall comply with the Buy America Act requirements before costs are reimbursed. Refer to section eleven under the heading Grant Management Requirements for specific terms of the Buy America Act: 34 CFR 75.615.
All equipment of $10,000 or more per unit, and any software purchase requests of the same dollar amount, require pre-approval from the NHTSA before purchase. This approval may come after the grant award and/or the start of the fiscal year.
For additional information on the federal definition of equipment, see 23 CFR 1300.31.
Items purchased for direct use by an agency or contractor (rather than for public distribution) over $10,000 per unit are categorized as equipment. Reference the federal law definition at 23 CFR 1300.31. Equipment is closely tracked pertaining to both federal and state regulations based on value and usable life.
Equipment is eligible for reimbursement as a direct expense chargeable to a specific project agreement, provided the equipment is needed to perform that project. A project for which equipment is needed shall be based on the identification of a specific safety problem in Michigan. No project may be created solely to purchase equipment. Proposed equipment purchases must be included in the application. All equipment requires pre-approval from the NHTSA before purchase. This approval may come after the start of the fiscal year.
The OHSP maintains an equipment log to track equipment purchased with federal funds based on use and value. When a subrecipient or sub-subrecipient needs to dispose of equipment, the OHSP Program Coordinator shall be contacted immediately, and the appropriate disposal policy shall be followed. Specific attention shall be given to the disposal of equipment that is still within its useful life.
Only eligible equipment specifically listed in the equipment section of the approved grant budget will be reimbursed. Equipment costs shall be reimbursed according to the match requirements as specified in the approved grant budget.
Equipment purchases shall be completed within the time specified in the approved grant. "Completed” means bids were solicited, accepted, and items have been ordered, received, and paid for during the grant period. If there is a reason the subrecipient is unable to meet this requirement, the OHSP Program Coordinator shall be contacted immediately.
Equipment purchased through this grant shall be used only for highway safety activities throughout its useful life, regardless of whether the project or program continues to be supported by the federal award.
Equipment with a cost of $10,000 or more shall be tracked by the subrecipient for inventory control purposes. In addition, the OHSP Equipment Record System Form with all applicable information completed shall be submitted with the prospective participant’s or subrecipient’s reimbursement request. The subrecipient shall make the equipment item available for physical review by the OHSP staff when requested.
The State of Michigan Financial Management Guide can be provided upon request by the OHSP.
If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost shall be allocated to the projects based on the proportional benefit. If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, the costs may be allocated or transferred to the benefited projects on any reasonable documented basis. Where the purchase of equipment or other capital assets is specifically authorized under a federal award, the costs are assignable to the federal award regardless of the use that may be made of the equipment or other capital assets involved when no longer needed for the purpose for which it was originally required.
If the equipment is to be disposed of or ceases to be used for highway safety activities, the subrecipient is required to contact the OHSP prior to such disposition action. The OHSP will use the State of Michigan Asset Disposal process which may require the asset(s) be returned to the state for sale, salvage, scrap, transfer, or destruction. The OHSP reserves the right to follow 2 CFR 200.313(e) Disposition. This section gives the awarding agency the right to transfer the property to another subrecipient who could utilize the equipment for their grant-related project. If no subrecipient can be found, the OHSP will contact the NHTSA for disposition instructions as the NHTSA could transfer the property to another state for utilization of the equipment.
The OHSP may allow the holder of the equipment to retain title to the equipment and reimburse the federal or state share of the fair market value of such equipment. The current fair market value shall be determined as follows:
Payments made for costs determined to be unallowable by either the federal awarding agency, cognizant agency for indirect costs, or pass-through entity, either as direct or indirect costs, shall be refunded (including interest) to the Federal Government in accordance with instructions from the federal agency that determined the costs are unallowable unless federal statute or regulation directs otherwise. See also Subpart D—Post Federal Award Requirements of this part, and Part 200.300 Statutory and National Policy Requirements through 200.309 Period of Performance.
The Subrecipient’s federally approved negotiated indirect cost rate may be used for traffic safety grants as applicable.
Title 2 CFR Part 200 provides guidance on indirect costs for subrecipients without a federally negotiated indirect rate as follows:
Additionally, 2 CFR Part 200 allows for multiple allocation base methods or direct allocation methods related to MTDC. Contact the OHSP fiscal staff for further inquiries.
The OHSP retains the right to terminate a grant for failure to meet the grant management requirements or for not satisfying project goals or objectives, which will be decided by an OHSP management review. When a grant is terminated by the OHSP, the subrecipient shall not be eligible to seek grant funding for a period of two fiscal years. To obtain a grant after the two fiscal year period, the subrecipient will be required to submit written assurance that the identified deficiencies have been corrected. Additionally, the agency may be required to submit monthly enforcement, progress, and/or financial reports to allow for increased financial monitoring. If a grant is terminated, the OHSP reserves the right to call for funds disbursed for the current fiscal year to be returned by the subrecipient and its lower tier subrecipients.
The subrecipient shall disclose to the OHSP in writing within 10 business days of receiving notice of any litigation, investigation, arbitration, or other proceeding (collectively, “proceeding”) involving subrecipient, a subcontractor, or an officer or director of subrecipient or subcontractor, or that arises involving these federal funds:
Other significant instances of fraud or abuse that are unrelated to this federal grant-funded project should also be disclosed to the OHSP within 90 days of awareness of an event or situation.
