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Standards for Financial Management Systems

Commingling of Funds

Although Federal regulations do not require physical segregation of cash deposits, the accounting systems of all recipients and subrecipients must ensure that agency funds are not commingled with funds from other Federal agencies.

  • You must account for each award separately.
  • Recipients and subrecipients are prohibited from commingling funds on either a program-by-program or project-by-project basis.
  • Funds specifically budgeted and/or received for one project may not be used to support another.
  • If your automated general ledger accounting system cannot comply with this requirement, you should establish a system to adequately track funds according to each budget category.

information iconFinancial Management Tip

Some programs, such as the Justice Assistance Grant program, require the deposit of funds into a trust fund. In addition, sometimes a high-risk designation will require a recipient to segregate awards into separate bank accounts.

Example

How a recipient can avoid commingling funds:

A recipient with three awards has a bank account with a balance of $47,948. The subsidiary accounting ledgers for the cash account clearly show how much cash is available for each award: for award 1, $15,000; for award 2, $30,068; and for award 3, $ 2,880.

Sample Ledger Award 1 Award 2 Award 3
Grant Award $23,500.00 $50,000.00 $10,800.00
Program Income $1,169.00 0.00 0.00
In-Kind 0.00 0.00 0.00
Total Project $24,669.00 $50,000.00 $10,800.00
Personnel/Direct Labor $4,750.00 $10,600.00 $1,950.00
Fringe @ 33% Actual $1,567.50 $3,498.00 $643.50
Subtotal $6,317.50 $14,098.00 $2,593.50
Travel 0.00 $45.00 0.00
Equipment 0.00 $3,610.00 $4,606.50
Supplies $2,042.50 $263.80 0.00
Contractual 0.00 0.00 0.00
Other $430.00 $103.20 0.00
Indirect @ 10% Actual $879.00 $1,812.00 $720.00
Total Expense $9,669.00 $19,932.00 $7,920.00
Cash Balance $15,000.00 $30,068.00 $2,880.00

If your accounting system does not make it possible to identify funds and expenditures with a particular program (with the identification supported by source documentation), a site visit or an audit of that program may result in those costs being questioned or disallowed.

Example

How a recipient can make sure that funds and expenditures are clearly identifiable with specific programs within the accounting system:

A recipient has three active awards and four staff members who charge a portion of their time to all three awards. One expense account with payroll costs for all four staff members is not sufficient for purposes of accounting for each award. Each staff member must complete time and attendance records which clearly show the time each spent on each award by name or code; the recipient must maintain the time and attendance records and use them to distribute actual payroll costs to each award.

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