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Implementation of Regional Consolidation of Grants Administration Functions

AUGUST 9, 1990

MEMORANDUM

SUBJECT: Implementation of Regional Consolidation of Grants Administration Functions

FROM: Charles L. Grizzle
Assistant Administrator

TO: Assistant Administrators
General Counsel
Inspector General
Associate Administrators
Regional Administrators
Staff Office Directors

This memorandum provides the implementing guidance for the Deputy Administrator's June 1, 1990, policy directive to centralize Regional Administrative Assistance management functions under the Assistant Regional Administrators. This guidance describes the fundamental roles and responsibilities for Regional Grants Management Offices.

The two attachments reflect the grants management offices responsibilities in administering grant regulations under 40 CFR Parts 30 - 35, and other grant regulations.

Attachment A summarizes the functions and activities for which Regional Grants Management Offices are responsible. Attachment B breaks down the functions into their constituent parts.

Please contact Harvey Pippen, Jr., Director, Grants Administration Division on
FTS 382-5240 if you have any questions.

Attachments

cc: Assistant Regional Administrators
Regional Grants Management Branch Chiefs

 

ATTACHMENT A

PREAWARD
AWARD AMENDMENTS ACTIVE GRANTS MANAGEMENT
CLOSEOUT
OVERSIGHT
AUDIT GRANTS MGMT.
DIRECTION

applicant/project officer guidance

application kit develop.

application receipt/review

negotiations meetings

award/ amendment/ IAG preparation

information management reports

terms and conditions

files mgmt

payment approval

information management

project status assessment

recipient guidance

report generation

procurement action review

statutory & regulatory compliance property accountability

technical reports

final FSR

close-out amendment

close-out documents

final payments

unliquidated obligations on-site reviews of financial, procurement and prop. Management systems for new and existing recipients

formal training to recipients and project officers

regular meetings entrance/exit conference

audit reports/ resolution

auditor/ management assistance

audit tracking

corrective actions followup

disputes staff development

internal policies and procedures

regulation, policy implemen-tation

regulation, guidance development

 

ATTACHMENT B

GRANTS MANAGEMENT ROLES AND RESPONSIBILITIES FOR ADMINISTERING GRANTS, COOPERATIVE AGREEMENTS AND
INTERAGENCY AGREEMENTS

PRE-AWARD/AWARD/AMENDMENTS

1. Applicant/Project Officer Guidance

  • inform applicants/project officers of administrative requirements
  • respond to questions from project officers and applicants
  • send out application kits

2. Application Kit Development

  • develop instructions
  • develop sample application and attachments
  • include attachments (e.g. MBE reporting, budget breakdown, changes from prior FY, air MOE)
  • include program specific instructions

3. Application Receipt/Review

  • receive original application from applicant
  • enter in GICS
  • distribute to other parties
  • assure application completeness and perform and document
    administrative/legal review (e.g. administrative assurances, authorized signatures, intergovernmental review, suspension & debarment, cost share/match levels and documentation, indirect cost agreement, MBE/WBE requirements)
  • conduct and document cost analysis of budget and back-up for allowability, allocability, reasonableness
  • ensure statutory and regulator compliance
  • coordinate administrative and programmatic reviews and assure that administrative deficiencies are communicated to and resolved by applicant/recipient

4. Negotiation/Meetings

  • participate/conduct annual negotiation, pre-application sessions with project officers and applicants
  • assure adequacy of prospective recipient's financial, procurement, and property management systems

5. Award/Amendment/IAG Preparation

  • assure receipt of project officer approval memo (decision memorandum)
  • review and pre-validate commitment notices
  • prepare grant document including cover letter and award
  • assure that appropriate congressional notification occurs
  • obtain appropriate signatures
  • ensure inclusion of all appropriate conditions (admin. & program)
  • mail out/distribute document
  • send to finance for obligation of funds
  • receive signed award document from recipient
  • distribute counter-signed award document
  • request LOC change
  • enter award data into GICS

6. Information Management

  • implement and maintain RAGDS/GICS/IAMS
  • assure quality control of data

ACTIVE GRANTS MANAGEMENT

1. Reports (e.g. Financial, Progress, Property, MBE/WBE)

  • ensure and track receipt of all reports
  • review/analyze for administrative impact and compliance with admin/program requirements in conjunction w/program
  • reconcile FSR with other financial reports
  • identify and take follow-up action if reports overdue, incorrect, or deficient

2. Terms and Conditions

  • ensure compliance with any terms or conditions
  • ensure and track receipt of any deliverables
  • identify and take follow up action if deliverables are overdue or deficient

3. Files Management

  • maintain a list of the location of all documents contained in the official file
  • create and secure official grants management award file
  • retire old files in compliance with Record Management Procedures

4. Payment Approval (LOC, Advance, Reimbursement)

  • identify and resolve discrepancies/issues (external and internal)
  • review advance/reimbursement requests (match, cost share, terms/ conditions, timeliness)
  • coordinate approval/disapproval with Program/Finance

5. Information Management

  • design milestone management tracking systems/develop reports
  • analyze trends, recommend action
  • manage grant workload
  • coordinate automated program grant information

6. Project Status Assessment

  • review finance report of grant balances
  • coordinate findings (externally, internally)
  • review rate of expenditure with percentage of work accomplished

7. Recipient Guidance

  • interpret/implement assistance policy
  • provide guidance, research

8. Report Generation

  • develop reports for program identifying status of unobligated and unliquidated funds
  • provide reports to program, finance, recipients

9. Procurement Action Reviews

  • assure compliance with EPA Procurement Regulations (e.g. Parts 31, 33) by reviewing individual procurement
    actions and recipients' procedures (e.g. cost and price analysis, contracts, model clauses) as necessary
  • follow up on any deficiencies or areas needing improvement
  • coordinate with program

10. Statutory and Regulatory Compliance (Including Managing Deviations)

  • ensure compliance
  • receive and analyze deviation requests for appropriateness
  • prepare recommendation for Director, GAD

CLOSE-OUT

1. Property Accountability

  • provide disposition instructions to recipients, if applicable
  • ensure receipt of property inventory report and review

2. Technical Reports (from Recipient and/or Project Officer; Final Report, End-of-Year, Mid-Year)

  • ensure receipt of reports, review
  • coordinate with project officers

3. Final FSR

  • maintain tracking system in GICS (e.g. FSR receipt date)
  • ensure receipt, distribute
  • review/analyze
  • reconcile with IFMS
  • review final FSR for any unliquidated obligations or any unobligated funds

4. Close-Out Amendment

  • prepare closeout amendment
  • ensure compliance with carryover policy
  • ensure Finance Office any necessary adjustment to IFMS to deebligate funds as appropriate

5. Close-Out Documents

  • prepare close-out documents (e.g. memos to project officers, forms, letters to recipients, Cincinnati)
  • prepare audit request before close-out if necessary
  • review all close-out documents and ensure final approval by the Award Official
  • send close-out letter to recipient

6. Final Payments

  • ensure receipt
  • review, approve

OVERSIGHT

1. On-Site Reviews of New and Existing Recipients for Financial, Procurement, Property Management Systems

  • prepare protocol
  • coordinate review with all involved parties
  • conduct review as well as opening/exit conferences with recipient
  • test transactions, as appropriate
  • prepare report
  • follow-up on findings and corrective actions

2. Conduct regular meetings with Program Managers and recipients

3. Formal Training to Recipients and Project Officers

  • develop materials
  • prepare training courses
  • conduct training
  • coordinate Headquarters sponsored training

AUDIT

1. Entrance/Exit Conferences

  • coordinate
  • attend

2. Audit Reports/Resolution

  • receive/distribute/review
  • coordinate agency position
  • resolve audit findings and disputes
  • prepare FDL, decision letters

3. Auditor/Management Assistance

  • pull documentation, answer questions
  • forewarn management and GAD (early warning system)
  • respond to semi-annual reports to Congress
  • serve as GAO liaison
  • develop regional procedural guidance
  • review/comment on new and revised audit regulations and guidance

4. Audit Tracking

  • maintain a system for. tracking audit status to ensure that 180 day deadline is met

5. Corrective Actions Follow-up

  • maintain system (MATS)
  • track milestones
  • coordinate with programs, recipients, Headquarters
  • ensure that all due dates are met

6. Disputes

  • coordinate with Program and ORC
  • develop Regional procedural guidance

GRANTS MANAGEMENT DIRECTION

1. Staff Development

  • provide for training for the GMO office
  • assess needs, (including task force participation) prepare, attend, participate, follow-up on National Meetings
  • attend and participate in National Grants Conferences and Branch Chiefs Meetings

2. Internal Policies and Procedures

  • develop
  • implement

3. Regulation/Policy and Guidance Development

  • comment
  • develop Regional policy/guidelines
  • participate on work groups

4. Regulation/Policy/Guidance Implementation

  • understand, educate, coordinate
  • implement
  • revise as needed

5. Internal Management

  • manage the GMO offices (e.g. workplan, performance standards)

| New National Term on Suspension and Debarment | Tips On Writing a Grant Proposal | Sample Indirect Cost Proposal Format For Nonprofit Organizations | EPA Organization Chart | Grant Award Activity Summary | Historical Information | OMB Circulars | Cross-Cutting Public Policies | Lobbying and Litigation | The Federal Grant and Cooperative Agreement Act of 1977 | Catalog of Federal Domestic Assistance | Competition for Assistance Agreements | MBE/WBE Utilization | Overview of the Award Document and Terms and Conditions | Use of a Universal Identifier by Grant Applicants | Responsibilities - Award Phase | Assistance Agreement Payment Process | Purchasing Supplies, Equipment and Services Under EPA Grants | Indirect Costs | Best Practices Guide for Conferences | Glossary | Return to the Grants and Debarment Home Page |

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