AGENDA Sawmills Town Hall FY 2022-23 Budget Workshop Tuesday, April5,2 2022, 5:00 PM  Special Meeting oft the Sawmills Town Council  1. Call To Order 2. Invocation 3. Pledge of Allegiance 4. Adopt Agenda 5. Financial Update/ARPA A. ARPA Budget Ordinance B. ARPA Grant Project Ordinance C. Policy-Uniform Guidance Allowable Costs D. Non Discrimination Policy E. ARPA Premium Pay Policy 6. Discussion: Department Budget Needs A. Governing Body B. Administration D. Public Works E. Sanitation F. Streets (Powell Bill) G. Parks and Recreation H. Water Department I. Sewer Department 7. Discussion: Misc Items A. Code Enforcement B. Nuisance Abatement C. Community Garden D. Water and Sewer Rate Structure E. Employee COLA/Merit Increase  Mayor Pro Tem Clay Wilson  Mayor Pro Tem Clay Wilson Mayor Pro Tem Clay Wilson Finance Officer Karen Clontz Finance Officer Karen Clontz Finance Officer Karen Clontz Finance Officer Karen Clontz Finance Officer Karen Clontz Finance Officer Karen Clontz Town Manager Chase Winebarger  . PlanningyCommunity Development  Town Manager Chase Winebarger  8. Adjourn  Mayor Pro Tem Clay Wilson    CALDWELL COUNTY NORTH CAROLINA  TOWN OF SAWMILLS  Town of Sawmills Budget Ordinance Amendment  Be it Ordained by the Town Council of the Town of Sawmills, Caldwell County, North Carolina, the following Amendment to the Budget Ordinance for Fiscal Year 2021 -2 2022. Now, therefore, Be It Resolved the following Amendment is hereby Adopted:  Description Special Revenue Fund American Rescue Plan Act (ARPA)  Revenue $1,653,721.04  Fund3 3  Expenditures $1,653,721.04  General Government Expenditures  Fund 3  Explanation: To recognize the acceptance of the American Rescue Plan Act of 2021;  Coronavirus State and Local. Fiscal Recovery Funds.  This Budget Ordinance Amendment now. Adopted this the Sth day of April, 2022.  Approved: By:  By: ATTEST: Julie Good Town Clerk  Mayor, Town of Sawmills  Finance Officer, Town of Sawmills  Terry Taylor Town. Attorney and Fiscal Control Act. 272744.1  This instrument has been preaudited in the manner required by the Local Government Budget    CALDWELL COUNTY NORTH CAROLINA  TOWN OF SAWMILLS  Grant Project Ordinance for the Town ofTown of Sawmills American Rescue Plan BEI IT ORDAINED by the town council oft the Town of Sawmills, North Carolina that, pursuant to Section 13.2 of Chapter 159 of the General Statutes ofNorth Carolina, the following grant Section 1: This ordinance is to establish a budget for a project to be funded by the Coronavirus State and Local Fiscal Recovery Funds ofH.R. 1319 American Rescue Plan Act of2021 (CSLFRF). The Town of Sawmills has received the first tranche in the amount of$826,860.52 of CSLFRF funds. The total allocation is $1,653,721.04, with the remainder to be distributed to the town within 12 months. These funds may be used for the following categories of expenditures, to 1. Support public health expenditures, by funding COVID-19 mitigation efforts, medical expenses, behavioral healthcare, and certain public health and safety staff; 2. Address negative economic impacts caused by the public health emergency, including economic harms to workers, households, small businesses, impacted industries, and the 3. Replace lost public sector revenue, using this funding to provide government services to the extent of the reduction in revenue experienced due to the pandemic; 4. Provide premium pay for essential workers, offering additional support to those who have borne and will bear the greatest health risks because of their service in critical 5. Invest in water, sewer, and broadband infrastructure, making necessary investments to improve access to clean drinking water, support vital wastewater and stormwater  Act of 2021: Coronavirus State and Local Fiscal Recovery Funds  project ordinance is hereby adopted:  the extent authorized by state law.  public sector;  infrastructure sectors; and,  infrastructure, and to expand access to broadband internet.  Section 2: The following amounts are appropriated for the project and authorized for  expenditure:  Project Description Vaccination Incentive Program for Salaries Employees ($250 per employee Benefits who is fully vaccinated on or before December 31,2021) Premium Pay - ($100 per full time Salaries employee for each month worked Benefits 4/1/2020 to 1/31/2022) Administration Finance Department Public Works  Cost Object  Appropriation of CSLFRF Funds  $3,600.00 $300.00 $24,000.00 $7,000.00 $195,000.00 $82,000.00 $150,000.00 $90,000.00 $320,000.00  Salaries Benefits Salaries Benefits Salaries  272733.1    Benefits Salaries Benefits Salaries Benefits Salaries Benefits Total  $148,000.00 $135,100.00 $70,000.00 $245,000.00 $104,000.00 $58,000.00 $21,721.04 $1,653,721.04  Parks and Recreation Water Department Sewer Department  Section 3: The following revenues are anticipated to be available to complete the project:  CSLFRF Funds: General Fund Transfer: Total:  $1,653,721.04 $0 $1,653,721.04  Section 4: The Finance Officer is hereby directed to maintain sufficient specific detailed accounting records to satisfy the requirements of the grantor agency and the grant agreements. Section 5: The Finance Officer is hereby directed to report the financial status oft the project to Section 6: Copies oft this grant project ordinance shall be furnished to the Budget Officer, the Section 7: This grant project ordinance expires on December 31, 2026, or when all the CSLFRF funds have been obligated and expended by the town, whichever occurs sooner.  the governing board on a monthly/quarterlyll basis. Finance Officer and to the Clerk to Town Council.  272733.1    This Grant Project Ordinance now adopted this the 5th day of April, 2022.  Approved: By: ATTEST: Julie Good Town Clerk Terry Taylor Town. Attorney  By:  Mayor Pro Tem, Town of Sawmills  Finance Officer, Town of Sawmills  This instrument has been preaudited in the manner required by the Local Government Budget  and Fiscal Control Act.  272733.1    CALDWELL COUNTY NORTH CAROLINA  TOWN OF SAWMILLS  Policy for Allowable Costs and Cost Principles for Expenditure of American Rescue. Plan WHEREAS the Towno ofSawmills, has received an allocation offunds from the Coronavirus State and Local Fiscal Recovery Funds of H.R. 1319 American Rescue Plan Act of 2021 WHEREAS the funds may be used for projects within these categories, to the extent authorized 1. Support public health expenditures, by funding COVID-19 mitigation efforts, medical expenses, behavioral healthcare, and certain public health and safety staff; 2. Address negative economic impacts caused by the public health emergency, including economic harms to workers, households, small businesses, impacted industries, and the 3. Replace lost public sector revenue, using this funding to provide government services to the extent ofthe reduction in revenue experienced due to the pandemic; 4. Provide premium pay for essential workers, offering additional support to those who have borne and will bear the greatest. health risks because oftheir service in critical infrastructure 5. Invest in water, sewer, and broadband infrastructure, making necessary investments to improve access to clean drinking water, support vital wastewater and stormwater WHEREAS the ARP/CSLFRF are subject to the provisions of the federal Uniform Grant WHEREAS the Compliance and Reporting Guidance for the State and Local Fiscal Recovery  Act Coronavirus State and Local Fiscal Recovery Funds  (ARP/CSLFRF); and by state law.  public sector;  sectors; and,  infrastructure, and to expand access to broadband internet; and  Guidance, 2 CFR Sect. 200 (UG), as provided in the. Assistance Listing; and  Funds provides, in relevant part:  Allowable Costs/Cost Principles. As outlined in the Uniform Guidance at 2 CFR Part 200, Subpart E regarding Cost Principles, allowable costs are based on the premise that a recipient is responsible for the effective administration of Federal awards, application of sound management practices, and administration of Federal funds in a manner consistent with the program objectives and terms and conditions of the award. Recipients must implement robust internal controls and effective monitoring to ensure compliance with the Cost Principles, which are important for building trust and accountability. [ARP/CSLFRF) Funds may be, but are not required to be, used along with other funding sources for a given project. Note that [ARP/CSLFRF) Funds may not be used for a non-  271812.1    Federal cost share or match where prohibited by other Federal programs, e.g., funds may Treasury' 'sl Interim Final Rule and guidance and the Uniform Guidance outline the types of costs that are allowable, including certain audit costs. For example, per 2 CFR 200.425, a reasonably proportionate share of the costs of audits required by the Single Audit Act Amendments of 1996 are allowable; however, costs for audits that were not performed in accordance with 2 CFR Part 200, Subpart F are not allowable. Please see 2 CFR Part 200,  not be used for the State share for Medicaid.  Subpart E: regarding the Cost Principles for more information.  a. Administrative costs: Recipients may use funds for administering the SLFRF program, including costs of consultants to support effective management and oversight, including consultation for ensuring compliance with legal, regulatory, and other requirements. Further, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. Pursuant to the [ARP/CSLFRF Award Terms and Conditions, recipients are permitted to charge both direct and indirect costs to their SLFRF award as administrative costs. Direct costs are those that are identified specifically as costs of implementing the [ARP/CSLFRF program objectives, such as contract support, materials, and supplies for a project. Indirect costs are general overhead costs of an organization where a portion ofs such costs are allocable to the [ARP/CSLFRF] award such as the cost of facilities or administrative functions like a director's office. Each category of cost should be treated consistently in like circumstances as direct or indirect, and recipients may not charge the same administrative costs to both direct and indirect cost categories, or to other programs. Ifarecipient has a current Negotiated Indirect Costs Rate Agreement (NICRA) established with a Federal cognizant agency responsible for reviewing, negotiating, and approving cost allocation plans or indirect cost proposals, then the recipient may use its current NICRA. Alternatively, if the recipient does not have a NICRA, the recipient may elect to use the de minimis rate of 10 percent of the modified total direct costs pursuant to 2 CFR b. Salaries and Expenses: In general, certain employees' wages, salaries, and covered benefits are an eligible use Of[ARP/CSLFRF) award funds; and  200.414(f).  WHEREAS Subpart E oft the UG dictates allowable costs and cost principles for expenditure of  ARP/CSLFRF funds; and  WHEREAS Subpart E of the UG (specifically, 200.400) states that:  The application of these cost principles is based on the fundamental premises that:  (a) The non-Federal entity is responsible for the efficient and effective administration of the Federal award through the application of sound  management practices.  2  271812.1    (b) The non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions oft the Federal award. (c) The non-Federal entity, in recognition of its own unique combination of staff, facilities, and experience, has the primary responsibility for employing whatever form of sound organization and management techniques may be necessary in order to assure proper and efficient (d) The application of these cost principles should require no significant changes in the internal accounting policies and practices oft the non-Federal entity. However, the accounting practices oft the non-Federal entity must be consistent with these cost principles and support the accumulation of costs as required by the principles, and must provide for adequate documentation (e) In reviewing, negotiating and approving cost allocation plans or indirect cost proposals, the cognizant agency for indirect costs should generally assure that the non-Federal entity is applying these cost accounting principles on a consistent basis during their review and negotiation of indirect cost proposals. Where wide variations exist in the treatment of a given cost item by the non-Federal entity, the reasonableness and equity of (f) For non-Federal entities that educate and engage students in research, the dual role of students as both trainees and employees (including pre- and post-doctoral staff) contributing to the completion of Federal awards for research must be recognized in the application of these principles. (g) The non-Federal entity may not earn or keep any profit resulting from Federal financial assistance, unless explicitly authorized by the terms and  administration of the Federal award.  to support costs charged to the Federal award.  such treatments should be fully considered.  conditions of the Federal award;  BE IT RESOLVED that the Town Council of the Town of Sawmills hereby adopts and enacts the following US Cost Principles Policy for the expenditure of ARP/CSLFRF funds. ALLOWABLE COSTS AND COSTS PRINCIPLES POLICY OVERVIEW Title 2 U.S. Code ofFederal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, commonly called Uniform Guidance (UG), specifically Subpart E, defines those items of cost that are allowable, and which are unallowable. The tests of allowability under these principles are: (a) the costs must be reasonable; (b) they must be allocable to eligible projects under the Coronavirus State and Local Fiscal Recovery Funds of) H.R. 1319 American Rescue Plan Act of2021 (ARP/CSLFRF); (c) they must be given consistent treatment through application ofthose generally accepted accounting principles appropriate to the circumstances; and (d) they must conform to any limitations or exclusions set forth in these principles or in the. ARP/CSLFRF grant award as to types or amounts ofcost items. Unallowable items fall into two categories: expenses which are by their nature unallowable (e.g., alcohol), and unallowable activities (e.g., fund raising). The Town of Sawmills shall adhere to all applicable cost principles governing the use of federal grants. This policy addresses the proper classification ofboth direct and indirect charges to  3  271812.1    ARP/CSLFRF funded projects and enacts procedures to ensure that proposed and actual expenditures are consistent with the ARP/CSLFRF grant award terms and all applicable federal Responsibility for following these guidelines lies with the Town Manager and Finance Officer of the Town ofSawmills, who are charged with the administration and financial oversight ofthe ARP/CSLFR.Furher, all local government employees and officials who are involved in obligating, administering, expending, or monitoring ARP/CSLFRF grant funded projects should be well versed with the categories of costs that are generally allowable and unallowable. Questions on the allowability of costs should be directed to the Town Manager or Finance Officer of the Town of Sawmills. As questions on allowability of certain costs may require interpretation and judgment, local government personnel are encouraged to ask for assistance in  regulations in the UG.  making those determinations.  GENERAL COST ALLOWABILITY CRITERIA  All costs expended using ARP/CSLFRF funds must meet the following general criteria: 1. Bei necessary and reasonable for the proper and efficient performance and  administration ofthe grant program. necessary, consideration may be given to:  A cost: must be necessary to achieve a project object. When determining whether a cost is  Whether the cost is needed for the proper and efficient performance oft the grant Whether the cost is identified in the approved project budget or application. Whether the cost aligns with identified needs based on results and findings from a Whether the cost addresses project goals and objectives and is based on program A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision to incur the cost was made. For example, reasonable means that sound business practices were followed, and purchases were comparable to market prices. When determining  project.  needs assessment. data.  reasonableness of a cost, consideration must be given to:  Whether the cost is a type generally recognized as ordinary and necessary for the operation ofthe Town of Sawmills or the proper and efficient performance oft the The restraints or requirements imposed by factors, such as: sound business practices; arm's-length bargaining; federal, state, and other laws and regulations; Market prices for comparable goods or services for the geographic area.  federal award.  and terms and conditions oft the ARP/CSLFRF award.  4  271812.1    Whether individuals concerned acted with prudence in the circumstances considering their responsibilities to the Town of Sawmills, its employees, the Whether the Town of Sawmills significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably  public at large, and the federal government.  increase the ARP/CSLFRF award's cost.  2. Be allocable to the. ARP/CSLERF federal award. A cost is allocable to the ARP/CSLFRF award ift the goods or services involved are chargeable or assignable to the ARP/CSLFRF award in accordance with the relative benefit received. This means that the. ARP/CSLFRF grant program derived al benefit in proportion to the funds charged to the program. For example, if50 percent ofa local government program officer 's salary is paidwith grant funds, then the local government must document that the program officer Ifa cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. Ifa cost benefits two or more projects or activities in proportions that cannot be determined because ofthe interrelationship of the work involved, then the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Where the purchase of equipment or other capital asset is specifically authorized by the ARP/CSLFRE, the costs are assignable to the Federal award regardless of the use that may be made of the equipment or other capital asset involved when no longer needed for 3. Beauthorized and not prohibited under state or local laws or regulations. 4. Conform to any limitations or exclusions set forth in the principles, federal laws, ARP/CSLFRF award terms, and othér governing regulations as to types or amounts 5. Bec consistent with policies, regulations, and procedures that apply uniformly to both the ARP/CSLFRF federal award and other activities of the Town of Sawmills. Bea accorded consistent treatment. A cost MAY NOT be assigned to a federal award as a direct cost and also be charged to a federal award as an indirect cost. And a cost must be treated consistently for both federal award and non-federal award expenditures. 7. Be determined in accordance with generally accepted accounting principles  spent at least 50; percent ofhis/her time on the grant program.  the purpose for which it was originally required.  ofcost items.  (GAAP), unless provided otherwise in the UGG.  8. Be net of all applicable credits.  (a) The term "applicable credits" refers to those receipts or reduction of expenditures that operate to offset or reduce expense items allocable to the federal award. Typical examples of such transactions are purchase discounts; rebates or allowances; recoveries or indemnities on losses; and adjustments of overpayments or erroneous charges. To the extent that such credits accruing to and received by  5  271812.1    the local government related to the federal award, they shall be credited to the ARP/CSLFRF award, either as a cost reduction or a cash refund, as appropriate (b) Be consistent with the Town of Sawmills Program Income Policy at the time such  and consistent with the award terms.  policy is adopted.  9. Bea adequately documented. SELECTED ITEMS OF COST  The UGG examines the allowability of fifty-five (55) specific cost items (commonly referred to Thel Finance Officer and Town Manager, who are responsible for determining cost allowability, must be familiar with the Selected Items of Cost. The Town of Sawmills must follow the applicable regulations when charging these specific expenditures to the ARP/CSLFRF Finance Officer and Town Manager will check costs against the selected items ofcost grant. requirements to ensure the cost is allowable and that all process and documentation requirements are followed. In addition, State laws, Town of Sawmills regulations, and program-specific rules may deem a cost as unallowable, and the Finance Officer and Town Manager must follow those  as Selected Items of Cost) at 2 CFRS $200.420-475.  The  non-federal rules as well.  Exhibit A identifies and summarizes the Selected Items ofCost.  DIRECT AND INDIRECT COSTS  Allowable and allocable costs must be appropriately classified as direct or indirect charges. Itis essential that each item ofo cost be treated consistently in like circumstances either as a direct or Direct costs are expenses that are specifically associated with aj particular ARP/CSLFRP-eligible project and that can be directly assigned to such activities relatively easily with a high degree of accuracy. Common examples of direct costs include salary and fringe benefits of personnel directly involved in undertaking an eligible project, equipment and supplies for the project, subcontracted service provider, or other materials consumed or expended in the performance ofa Indirect costs are (1) costs incurred for a common or joint purpose benefitting more than one ARP/CSLFRP-eligible project, and (2) not readily assignable to the project specifically benefited, without effort disproportionate to the results achieved. They are expenses that benefit more than one project or even more than one federal grant. Common examples ofi indirect costs include utilities, local telephone charges, shared office supplies, administrative or secretarial Fori indirect costs, the Town of Sawmills may charge a 10 percent de minimis rate ofmodified total direct costs (MTDC). According to UGG Section 200.68 MTDC means all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and upi to the first $25,000 of each subaward (regardless oft the period of performance the subawards under the award). MTDC EXCLUDES equipment, capital expenditures, charges for patient care, rental  an indirect cost.  grant-eligible project.  salaries.  6  271812.1    costs, tuition remission, scholarships and fellowships, participant support costs and the portion of  each subaward in excess of$25,000.  SPECIAL PROVISIONS FOR STATE AND LOCAL GOVERNMENTS There are some special provisions of the UG that apply only to states, local governments, and  Indian Tribes.  $200.444 General costs of government.  (a) For states, local governments, and Indian Tribes, the general costs of government are unallowable (except as provided in S 200.475). Unallowable costs include: (1) Salaries and expenses of the Office of the Governor ofs a state or the chiefexecutive ofa local government or the chiefexecutive of an Indian tribe; (2) Salaries and other expenses of a state legislature, tribal council, or similar local governmental body, such asa a county supervisor, city council, school board, etc., whether incurred for purposes of legislation or executive direction; (3) Costs of the judicial branch of a government;  (4) Costs of prosecutorial activities unless treated as a direct cost to a specific program ifa authorized by statute or regulation (however, this does not preclude the allowability of other legal activities of the Attorney General as described in $ 200.435); and (5) Costso ofother general typesofgovemment services normally provided to the general public, such as fire and police, unless provided for as a direct cost under a program (b). For Indian tribes and Councils of Governments (COGs) (see definition for Local government in $ 200.1 ofthis] part), up to 50%ofsalaries and expenses directly attributable to managing and operating Federal programs by the chief executive and his or her staff  statute or regulation.  can be included in the indirect cost calculation without documentation. $200.416 COST ALLOCATION PLANS AND INDIRECT COST PROPOSALS.  (a)! For states, local governments and Indian tribes, certain services, such as motor pools, computer centers, purchasing, accounting, etc., are provided to operating agencies on a centralized basis. Since Federal awards are performed within the individual operating agencies, there needs to be a process whereby these central service costs can be identified and assigned to benefitted activities on a reasonable and consistent basis. The central (b) Individual operating agencies (governmental department or agency), normally charge Federal awards for indirect costs through an indirect cost rate. A separate indirect cost rate(s)proposal. foreach operating agencyis usually necessary to claim indirect costs under  service cost allocation plan provides that process.  Federal awards. Indirect costs include:  7  271812.1    (1) The indirect costs originating in each department or agency ofthe governmental unit (2) The costs ofcentral governmental services distributed through the central service cost (c)The requirements for development and submission of cost allocation plans (for central service costs and public assistance programs) and indirect cost rate proposals are contained  carrying out Federal awards and  allocation plan and not otherwise treated as direct costs.  in appendices V, VI and VII to this part. $200.417 INTERAGENCY SERVICE.  The cost of services provided by one agency to another within the governmental unit may include allowable direct costs of the service plus a pro-rated share of indirect costs. A standard indirect cost allowance equal to ten percent of the direct salary and wage cost of providing the service (excluding overtime, shift premiums, and fringe benefits) may be used in lieu of determining the actual indirect costs of the service. These services do not include centralized services included in central service cost allocation plans as described  in Appendix V to Part 200.  COST ALOWABIITYREVIEN PROCESS PREAPPROVAL COsT ALLOWABILITY REVIEW  Before an ARP/CSLFRP-funded project is authorized, the Finance Officer and Town Manager must review the proposed cost items within an estimated project budget to determine whether they are allowable and allocable and whether cost items will be charged as direct or indirect expenses. This review will occur concurrently with the review ofp project eligibility and before  obligating or expending any. ARP/CSLFRF funds.  Local government personnel must submit proposed ARP/CSLFRF projects to the Finance Officer and Town Manager for review. In addition to other required information, all proposed project submissions must delineate estimated costs by cost item. Along with a general review of project eligibility and conformance with other governing board management directives, the Finance Officer must review estimated costs for specific allowable cost requirements, budget parameters, indirect rates, fringe benefit rates, and those activities/costs that require pre-approval by the US Treasury. Ifap proposed project includes a request for an unallowable cost, the Finance Officer will return the proposal to the requesting party for review and, ifp practicable, resubmission Once a proposed project budget is pre-approved by the Finance Officer, the local government personnel responsible for implementing the project must conform actual obligations and expenditures to the pre-approved project budget.  with corrected cost items,  8  271812.1    POST-EXPENDITURE COST ALLOWABILITY REVIEW  Once an expenditure is incurred related to an eligible project, and an invoice or other demand for payment is submitted to the local government, the Finance Officer must perform a second review  to ensure that actual expenditures comprise allowable costs.  Alli invoices or other demands for payment must include a breakdown by cost item. The cost items should mirror those presented in the proposed budget for the project. Ifan invoice or other demand for payment does not include a breakdown by cost item, the Finance Officer will return the invoice to the project manager and/or vendor, contractor, The Finance Officer must review the individual cost items listed on the invoice or other Ifall cost items are deemed allowable and properly allocable, the Finance Officer must proceed through the local government's: normal disbursement process. Ifany cost item is deemed unallowable, the Finance Officer will notify the project management and/or vendor, contractor, or subrecipient that a portion of the invoice or other demand for payment will not bej paid with ARP/CSLFRF funds. The Finance Officer and/or Town Manager may in their discretion, and consistent with this policy, allow an invoice or other demand for payment to be resubmitted with a revised cost allocation. Ifthe local government remains legally obligated by contract or otherwise to pay the disallowed cost item, it must identify other local government funds to cover the disbursement. The Town of Sawmills' governing board must approve any allocation of The Finance Officer must retain appropriate documentation of! budgeted cost items per project and actual obligations and expenditures ofcost items per project.  or subrecipient for correction.  demand for payment to determine their allowability and allocability.  other funds for this purpose.  COST TRANSFERS  Any costs charged to the ARP/CSLFRF federal award that do not meet the allowable cost criteria must be removed from the award account and charged to an account that does not require Failure to adequately follow this policy and related procedures could result in questioned costs, audit findings, potential repayment of disallowed costs and discontinuance of funding.  adherence to federal UGG or other applicable guidelines.  9  271812.1    This policy now adopted this the 5th day of April, 2022.  Approved: By: Clay Wilson ATTEST: Julie Good Town Clerk Terry Taylor Town Attorney  By: Karen Clontz  Mayor Pro Tem, Town of Sawmills  Finance Officer, Town of Sawmills  This instrument has been preaudited in the manner required by the Local Government  and Fiscal Control Act.  Budget  10  271812.1    EXHIBIT A  Selected Items of Cost  Uniform Guidance General Reference  Allowability  Advertising and public relations costs  2CFR5200.421 Allowable with restrictions 2CFR5200.422 Allowable with restrictions 2CFRS200.423 Unallowable  Advisory councils Alcoholic beverages Alummi/aeactivites Auditservices Bad debts Bonding costs  2CFRS200.424 Not specifically addressed 2CFRS:200.425 Allowable with restrictions  2CFR5200.426  Unallowable  2CFR5200.427 Allowable with restrictions 2CFRS200.428 Allowable  Collection of improper payments Commencement and convocation costs Compensation- -personal: services Compensation-ffinge benefits Conferences Contingency provisions Contributions and donations  2CFR5200.429 Nots peclicalyaddressed  2CFR5200,430 Allowable with restrictions; Special conditions  apply (e8,5200.4300/5)  2CFR5200.431 Allowable with restrictions 2CFR5200.432 Allowable with restrictions 2CFR5200.433 Unallowable with exceptions  2CFR5200.434 Unallowable (made by non-federal entity); not  reimbursable but value may be used as cost sharing or matching (made to non-federal  entity)  Defense and prosecution of criminal and 2CFRS200.435 Allowable with restrictions  civil proceedings, claims,appeals and patent  11  271812.1    infringements Depreciation  2CFRS200,436 Allowable with qualifications 2CFR5200.437 Allowable with restrictions  Employee health andy welfare costs Entertainment costs  2CFR5200.438 2CFR5200.439  Unallowable with exceptions  Equipment and other capital expenditures  Allowability based on specific requirement  Exchange rates settlements costs  2CFR5200.440 Allowable with restrictions  Fines, penalties, damages and other 2CFR5200.441  Unallowable with  exceptions exceptions  Fund raising and investment management 2CFRS200.442 Unallowable with  Gains and losses on disposition of 2CFRS200.443 Allowable with restrictions  depreciable assets General costs of government Goods and services for personal use idle facilities and idle capacity Insurance and indemnification Intellectual property Interest Lobbying  2CFR5200.444 2CFRS200.445  Unallowable with exceptions Unallowable (goods/services); allowable (housing) withr restrictions  2CFR5200.446 Idle facilities - unallowable with exceptions;  Idle capacity allowable with restrictions  2CFR5200.447 Allowable with restrictions 2CFRS200.448 Allowable with restrictions 2CFRS200.449 Allowable with restrictions  2CFR5200.450  Unallowable  Losses on other awards or contracts  2CFR5200.451 Unallowable (however, theya are required tol be  included in the indirect cost rate base for  12  271812.1    allocation of indirect costs)  Maintenance and repair costs ofcomputing devices  2CFR5200.452 Allowable with restrictions  Materials and: supplies costs, including costs 2CFRS200,453  Allowable with restrictions  Memberships, subscriptions, and 2CFR5200.454 Allowable with restrictions; unallowable for  professionalactivity costs Organization costs Participant: supportcosts Plant and security costs Pre-award costs  lobbyingorganigations  2CFRS200.455 Unallowable except federal prior approval 2CFR5200.456 Allowable with prior approval of the federal 2CFR5200.457 Allowable; capital expenditures are subject to 2CFR5200.458 Allowable ifo consistent with other allowabilities  awarding agency $200.439  and with prior appoalafhaliadenainwaris  agency  Professional services costs Proposal costs  2CFR5200.459 Allowable with restrictions 2CFR5200.460 Allowable with restrictions 2CFR5200.461 Allowable with restrictions 2CFR5200.462 Allowable (ordinary and normal) 2CFR5200,463 Allowabie with restrictions 2CFR9200.464 Allowable with restrictions  Publication and printing costs Rearrangement and reconversion costs  Recruiting costs  Relocation costs of employees  Rental costs of real property and equipment 2CFRS200.465 Allowable with restrictions  Scholarships and student aid costs Selling and. marketing costs  2CFRS200,466 Not specifically addressed  2CFRS200.467  Unallowable with exceptions  13  271812.1    Specialized service facilities Student activity costs  2CFRS200.468 Allowable with restrictions  2CFR5200.469 Unallowable unless specifically provided for in  thet federal laward Ailowable with restrictions Allowable with restrictions Allowable for employee development  Taxes (including Value Added Tax) Termination costs Training and education costs Transportationcosts Travel costs Trustees  2CFR5200.470 2CFRS200.471 2CFR5200.472  2CFRS200.473 Allowable with restrictions 2CFR5200.474 Allowable with. restrictions 2CFRS200.475 Nots specifically addressed  14  271812.1    CALDWELL COUNTY NORTH CAROLINA  TOWN OF SAWMILLS  Town of Sawmills Non-Diserimination Policy  Recitals  WHEREAS, the Town of Sawmills has received an allocation of funds State Fiscal Recovery Fund" or "Coronavirus Local Fiscal Section 9901 ofthe American Rescue Plan Act  from the "Coronavirus Security Act, as added by  funds"), established pursuant to Sections 602 and 603 ofthe Recovery Social Fund" (together "CSLFRF  award").  of2021, Pub. L. No. 117-2 (the "ARP/CSLFRF  WHEREAS, CSLFRF funds are subject to the U.S. Department ofTreasury ("Treasury") regulations, including the Final Rule, the Award Terms and Conditions, and the Title VII WHEREAS, pursuant to the. ARP/CSLFRF Award Terms and Conditions, and as a condition of receiving CSLFRF funds, the Town of Sawmills agrees to follow all federal statutes and regulations prohibiting discrimination in its administration of CSLFRF under the terms conditions ofthe. ARP/CSLFRF award, including, without limitation, the following: and Title VIofthe Civil Rights Act of1964 (42 U.S.C. $8 2000d et seq.) and Treasury's implementing regulations at 31 C.F.R. Part 22, which prohibit discrimination on the basis ofrace, color, or national origin within programs or activities receiving federal financial ii. The Fair Housing Act, Title VIII of the Civil Rights Act of1968 (42 U.S.C. $8 3601 et seq.), which prohibits discrimination in housing on the basis ofrace, color, li. Section 504 oft the Rehabilitation Act of1973, as amended (29 U.S.C. S 794), which prohibits discrimination on the basis of disability under any program or activity iv. The Age Discrimination Act of1975, as amended (42 U.S.C. SS 6101 et seq.), and Treasury's implementing regulations at 31 C.F.R. Part 23, which prohibit discrimination on the basis ofage in programs or activities receiving federal financial assistance; and V. Title II ofthe. Americans with Disabilities Act of 1990, as amended (42 U.S.C. 88 12101 et seq.), which prohibits discrimination on the basis of disability under programs, activities, and services provided or made available by state and local governments or  implementing regulations at 31 C.F.R. Part 22.  assistance;  national origin, sex, familial status, or disability;  religion,  Federal financial assistance;  receiving  instrumentalities or agencies thereto.  RESOLVED, That the governing board of the Town of Sawmills hereby adopts and enacts the or facility that is supported in whole, or in part, by expenditures CSLFRF any program, to the activity,  following nondiscrimination policy, which shall apply to the operations of  ARP/CSLFRF award. 272724.1  pursuant    Nondiscrimination Policy Statement  Itis the policy oft the Town of Sawmills to ensure that no person shall, on1 the ground of race, color, national origin (including limited English Proficiency), familial status, sex, age, or disability, be excluded from participation in, be denied the befits of, or be otherwise subject to discrimination under any program or activity administered by the Town of Sawmills, including programs or activities that are funded in whole or part, with Coronavirus State and Local Fiscal Recovery Funds ("CSLFRF"), which the Town of Sawmills received from the U.S. Department ofTreasury ("Treasury") pursuant to Sections 602 and 603 ofthe Social Security Act, as added by Section 9901 oft the American Rescue Plan Act of2021, Pub. L.No. 117-2 (herein the  "ARP/CSLFRF award").  I.  Governing Statutory & Regulatory Authorities  As required by the CSLFRF Award Terms and Conditions, the Town of Sawmills shall ensure that each "activity,'  "facility," or "program" that is funded in whole, or in part, with CSLFRF and administered under the ARP/CSLFRF award, will be facilitated, operated, or conducted in compliance with the following federal statutes and federal regulations prohibiting discrimination.  These include, but are not limited to, the following:  Title VI oft the Civil Rights Act of1964 (42 U.S.C. 88 2000d et seq.) and Treasury's implementing regulations at 31 C.F.R. Part 22, which prohibit discrimination on the basis ofrace, color, or national origin under programs or activities receiving federal financial i. The Fair Housing Act, Title VIII of the Civil Rights Act of1 1968 (42 U.S.C. 88 3601 et seq.), which prohibits discrimination in housing on the basis of race, color, religion, ili. Section 504 ofthel Rehabilitation Act of1973, as amended (29 U.S.C. $ 794), which prohibits discrimination on the basis of disability under any program or activity receiving iv. The Age Discrimination Act of 1975, as amended (42 U.S.C. SS 6101 et seq.), and Treasury's implementing regulations at 31 C.F.R, Part 23, which prohibit discrimination on the basis of age within programs or activities receiving federal financial assistance; V. Title II oft the. Americans with Disabilities Act of 1990, as amended (42U.S.C. 8S 12101 et seq.), which prohibits discrimination on the basis of disability under programs, activities, and services provided or made available by state and local governments or  assistance;  national origin, sex, familial status, or disability;  federal financial assistance;  and  instrumentalities or agencies thereto.  22C C.F.R. $22.3 defines "program" and' "activity" as all operations of an entity, including local governments, that receive Federal financial assistance, andi the departments, agencies, or special purpose districts of the local governments to which Federal financial assistance is distributed. "Federal financial assistance" includes, among other things, grants and loans of federal funds. "Facility" includes all or any part ofstructures, equipment, or other real or personal property or interests therein, and the provision of facilities includes the construction, expansion,  renovation, remodeling, alteration, or acquisition off facilities.  272724.1    II. Discriminatory Practices Prohibited in the Administration ofthe ARP/CSLERF To ensure compliance with Title VII oft the Civil Rights Act of1964, and' Title 31 Code of Federal Regulations, Part 22, the Civil Rights Restoration Act of1987, and other pertinent nondiscrimination authorities, the Town of Sawmills shall prohibit, at a minimum, the following practices in its administration ofCSLFRF pursuant to the ARP/CSLFRF award: 1. Denying to a person any service, financial aid, or other program benefit without good 2. Providing to a person any service, financial aid, or another benefit which is different in quantity or quality, ori is provided in a different manner, from that provided to others 3. Subjecting aj person to segregation or separate treatment in any matter related to the receipt of any service, financial aid, or other benefit under the program; 4. Restricting a person in the enjoyment ofa any advantages, privileges, or other benefits enjoyed by others receiving any service, financial aid, or other benefit under the program; 5. Treating aj person differently from others in determining whether that person satisfies any admission, enrollment, quota, eligibility, membership, or other requirement or condition which persons must meet to be provided any service, financial aid, or other benefit 6. Implementing different standards, criteria, or other requirements for admission, enrollment, or participation in planning, advisory, contractual, or other integral activities 7. Adopting methods of administration which, directly or through contractual relationships, would defeat or substantially impair the accomplishment of effective nondiscrimination; 8. Selecting a site or location offacilities with the purpose or effect of excluding persons from, denying them the benefits of, subjecting them to discrimination, or with the purpose or effect of defeating or substantially impairing the accomplishment oft the 9. Discriminating against any person, either directly or through a contractual agreement, in any employment resulting from the program, a primary objective of which is to provide 10. Committing acts ofintimidation or retaliation, including threatening, coercing, or discriminating against any individual for the purpose ofinterfering with any right or privilege secured by any pertinent nondiscrimination law, or because an individual made ac complaint, testified, assisted, or participated in an investigation, proceeding, or hearing.  Award  cause;  under the program.  provided under the program;  to the program;  objectives ofTitle VI or related acts and regulations;  employment;  m. Reporting & Enforcement  1. The Town of Sawmills shall cooperate in any enforcement or compliance review activities by the Department of the Treasury. Enforcement may includei investigation, arbitration, mediation, litigation, and monitoring of any settlement agreements that may result from these actions. The Town of Sawmills shall comply with information  requests, on-site compliance reviews, and reporting requirements.  272724.1    2. The Town of Sawmills shall maintain a complaint log and inform the Treasury of any complaints of discrimination on the grounds ofrace, color, or national origin (including limited English proficiency covered by Title VIofthe Civil Rights Act of 1964 and implementing regulations and provide, upon request, a list ofall such reviews or proceedings based on the complaint, whether pending or completed, including the outcome. The Town of Sawmills shall inform the Treasury ifit has 3. Any person who believes they have been aggrieved by a discriminatory practice under Title VII has a right to file a formal complaint with the Treasury. Any such complaint must be in writing and filed with the Treasury's Title VI Coordinator within one hundred eighty (180) days following the date oft the alleged discriminatory 4. Any person who believes that because of that person's race, color, national origin, limited English proficiency, familial status, sex, age, religion, or disability that he/she/they have been discriminated against or unfairly treated by the Town of Sawmills in violation ofthis policy should contact the following office within 180  received no complaints under Title VI.  occurrence.  days from the date of the alleged discriminatory occurrence:  Town Manager Town of Sawmills 40461 US Hwy 321A Sawmills, NC28630  This policy now adopted this the 5th day of April, 2022.  Approved: By: Clay Wilson ATTEST: Julie Good Town Clerk Terry Taylor Town Attorney  By: Karen Clontz  Mayor Pro Tem, Town of Sawmills  Finance Officer, Town of Sawmills  This instrument has been preaudited in the manner required by the Local Government Budget  and Fiscal Control Act.  272724.1    CALDWELL COUNTY NORTH CAROLINA  TOWN OF SAWMILLS  Town of Sawmills Premium Pay Policy Description  The American Rescue Plan Act of 2021 (ARPA) funds have been distributed among North Carolina counties and municipalities to assist with pandemic-related and essential infrastructure needs. An eligible expenditure ofthese funds includes the allowance of"Premium Pay" to eligible employees who perform essential work during the COVID-19 pandemic. Town employees have continued toj provide essential services since the onset ofthe pandemic when a State of] Emergency was declared in March 2020, and wasi revoked in January 2022. The Town has designated aj portion of the funding received from the ARPA towards a one-time premium payment to eligible Town employees continue to selflessly perform essential work and place themselves on the front line of the pandemic by responding to calls for service to assist local citizens and visitors experiencing medical emergencies, utility emergencies, environmental and refuse needs, and other crisis situations. Other essential work performed includes the daily documentation necessary to support the infrastructure of the Town, such as taking payments from citizens, processing daily receipts, processing payroll and vital COVID leave documentation, and other essential work requiring the regular physical handling ofdocumentation handled by the public or coworkers. For this valuable work, the Town is responding in part by creating this policy, which applies to all  employees.  eligible employees who have performed essential work for the Town.  Definitions  Eligible employee is defined by the Federal Final Rule as all local government employees, including full- and part-time permanent and temporary employees. Per the Final Rule, volunteers and public officials do not qualify. For the purpose of this policy, an eligible employee is an employee who is employed full-time, regular part-time, and/or  supplemental employees with the Town as ofFebruary 3, 2022. Essential work, as defined by the Federal Final Rule includes work that 1. was not performed while teleworking, AND  2. involves  regular in-person interactions with patients, the public, or coworkers ofthe regular physical handling ofitems that werel handled by, or are tol be handled by patients, the public, or coworkers oft the individual that is performing the  individual that is performing the work; or  work.  272742.1    Guidelines  1. State law prohibits premium payments to former employees who are no longer employed by the' Town, even ifthe former employee would otherwise qualify for retroactive premium 2. Premium payments willl be prorated based on months of employment with the Town since April 2020. Full-time employees hired as ofJanuary 31,2022 will receive $100 per month for each month worked since April 2020, with a maximum of $2,200. Regular part-time and supplemental employees hired as of January 31, 2022 will receive $40 per month for each month worked since April 2020, with a maximum of $880. Partial months of employment will be counted as one month; for instance, an employee hired on April 20, 2020 will be eligible for 22 months of premium pay. Employees that transitioned between full-time, regular part-time and/or supplemental status during the time period covered by this policy will be compensated on a pro-rated basis at the applicable rate established 3. All premium payments made to employees will be processed through the Town's payroll system in a lump sum and treated as wages. Premium payments are considered regular wages are subject to Federal and State taxes, as well as FICA and retirement. 4. All. ARPA funds expended are subject to most provisions ofthe Federal Uniform Guidance (UG) 2 CFR 200, including contracting, internal controls, and auditing. With respect to premium pay, this policy is intended to ensure compliance with 2 CFR 200.303. 5. As stated in the Federal Final Rule, premium pay should target low- and moderate-income employees. Premium payments for eligible employees whose total wage renumeration will exceed 150% ofthe State's average annual wage for all occupations will be funded by the Town's annual operating budget, expensed to the appropriate department for each 6. The Town will follow record retention practices required for all ARPA-funded expenditures and will submit periodic Project & Expenditure Reports as required to the US Treasury. The Finance Director will ensure the Town's compliance with the necessary US 7. Final decisions regarding amount of premium pay an employee is eligible to receive under this policy will be made at the discretion of the Town Manager. The Town Manager's Decision is final and is not eligible for review under the terms of ARTICLE X. GRIEVANCE PROCEDURE AND ADVERSE ACTION APPEAL in the Town of  pay according to the eligibility criteria established in this policy.  above.  employee.  Treasury Reporting Requirements for. ARPA funds.  Sawmills Personnel Policy.  272742.1    This policy now adopted this the Sth day of April, 2022.  Approved: By: Clay Wilson ATTEST: Julie Good Town Clerk Terry Taylor Town Attorney  By: Karen Clontz  Mayor Pro Tem, Town of Sawmills  Finance Officer, Town of Sawmills  This instrument has been preaudited ini the manner required by the Local Government Budget  and Fiscal Control Act.  272742.1