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EPA Closeout Policy for Grants and Cooperative Agreements

August 27, 1992

EPA CLOSEOUT POLICY FOR GRANTS AND COOPERATIVE AGREEMENTS

Introduction

Part I: Purpose and Objectives

Part II: Basic Closeout Requirements for Grants and Cooperative Agreements

A. Roles and Responsibilities

B. GICS Requirements

C. Notification and Follow Up

Part III: Program Specific Requirements

A. State Revolving Fund Program

B. Superfund

C. Construction Grants

Part IV: Record Retention Requirements

Part V: Audit Resolution and Disputes

Appendix A: Listing of Existing EPA Closeout Regulations, Policies, and Related Guidance

Appendix B: Listing of GICS Data Elements Used in Closeout

Appendix C: Types of Construction Grant Awards

 

PART I PURPOSE AND OBJECTIVE

The purpose of this document is to establish EPA policy for closing out completed grants and cooperative agreements for all EPA Assistance Programs.

Closeout is the systematic process by which EPA determines that all required technical work under a grant or cooperative agreement has been completed by the recipient and EPA, and all applicable administrative requirements met. Protection of the government's interest and prudent grants administrative practices require that sufficient time and effort be devoted to the closeout process.

This document includes the closeout requirements basic to all grants and cooperative agreements, the roles and responsibilities of EPA and its recipients, and the specific closeout requirements unique to the Superfund, Construction Grants, and the State Revolving Fund (SRF) Programs.

The procedures to follow for timely closeout of all completed projects are contained in 40 CFR Part 31 Subpart D, 40 CFR Part 30 Subpart H, 40 CFR Part 35.6780, and the EPA Assistance Administration Manual (Chapter 40). This policy supplements and clarifies existing agency closeout policy.

EPA should close out non-construction grant projects within 180 days after receipt of all required reports and other deliverables. Delays can unnecessarily tie up obligated but unexpended funds. Also, closeout becomes more difficult with the passage of time because persons responsible for managing various aspects of a project may resign, retire, or transfer; memories of events are less clear; the interests of the Project Officer and Project Manager may shift to other priorities; and award documents may become lost or destroyed.

For Construction Grants, closeout should occur within six months of the last grant action which can be any one of the following actions:

 

PART II BASIC CLOSEOUT REQUIREMENTS FOR GRANTS AND COOPERATIVE AGREEMENTS

A. Roles and Responsibilities

This section outlines the basic closeout roles and responsibilities of the Recipient, the Program Office, the Grants Management Office (GMO) and the Financial Management Office (FMO).

Recipient

1. Complete all work satisfactorily and timely as specified in the assistance agreement.

2. Submit the following required reports to EPA within 90 days after the project completion date:

  • Final Technical Report
  • Final Financial Status Report (Standard Form 269 or 269A)
  • Federally Owned Property Report, if applicable
  • Invention Disclosure Report (EPA Form 3340-3), if applicable
  • Final Request for Payment (Standard Form 270), if applicable
  • Final EPA ACH Payment Request, if applicable
  • Outlay Report and Request for Reimbursement (Standard Form 271), if applicable
  • Property Inventory of all Federally Owned Property, if applicable
  • Final Minority Business Enterprise/Women Business Enterprise Report (Standard Form 334), if applicable

3. Submit a written request to EPA's award official to request an extension of time to the 90 day period required for submittal of the FSR (or other required reports), along with a justification for the extension.

4. Submit all manuals, plans, specifications, data, or other deliverables as required in the assistance agreement to EPA, or make the deliverables available for EPA inspection.


The Program Office (Project Officer)

1. Review and approve all technical reports, including final technical/performance reports in accordance with the requirements of the award and the statement of work.

2. Ensure that any/all deliverables required under the award are received when required by the award, and are acceptable.

3. Certify to the GMO within 90 days of completion of the project that all work has been satisfactorily completed. For continuing programs, specific work elements may be carried forward and funded in the next year provided the recipient submits an application with an acceptable workplan. For additional information, refer to Comptroller Policy Announcement N. 88-09, "Disposition of Unobligated Balance of Assistance Awards."

4. Certify to the GMO within 90 days of project completion that all tehnical (programmatic) award conditions have been met.

The Grants Management Office (GMO)

1. Ensure receipt of final certification of project completion from the project officer, receipt of all required reports including the final FSR, MBE/WBE, invention disclosure, and Federally owned property reports, and compliance with all terms and conditions of the grant.

2. Provide property disposition instructions (as necessary) to recipients, and ensure receipt/acceptability of property inventory report; and ensure reimbursement to EPA of its proportionate share of equipment or supply inventories, if applicable.

3. Receive and approve the Final Financial Status Report (except for construction grants) and:

  • ensure timely receipt and distribute copies to program and finance offices as necessary;
  • review and analyze FSR's contents, including recipient's cost share;
  • maintain/update current information in the Grants Information and Control System (GICS), i.e., FINANCIAL-STATUS-CODE, FINANCIAL-STATUS-DATE, and ACTION-CODE;
  • ensure that financial data on FSR is reconciled with the Integrated Financial Management System (IFMS);
  • determine allowability of any reported indirect costs based on the provisions of the assistance agreement and the final negotiated indirect cost rate;
  • determine amount of any unliquidated obligations and/or funds owed to EPA by the recipient and provide instructions to the FMO for the disposition of those funds.

4. Request final audit (if applicable and required for closeout)

5. Prepare close-out amendment.

  • Ensure receipt of request for final payment; review and approve appropriateness of such payments and notify the FMO to process or deny the payment.
  • Ensure compliance with Agency's carryover policy.
  • Ensure that the FMO makes necessary adjustments to IFMS and deobligates any unliquidated obligations as appropriate.
  • Complete Assistance Adjustment Notice (EPA Form 5700-42) or Assistance Amendment and distribute to FMO and Program Offices.

6. Prepare close-out letter

  • Issue final close-out letter to recipient and provide copies to the appropriate Project Officer and FMO.

7. Retire file and follow appropriate record retention requirements. (See page 11, Part IV)


Financial Management Office (FMO)

1. Assist GMO in reconciling IFMS data with reported FSR data.

2. Review close-out amendment and either deobligate any unliquidated obligations, or bill the recipient for any funds due EPA; establish an accounts receivable if appropriate and perform follow-up collection efforts.

3. Make necessary entries to IFMS for any deobligations and collections.

4. Approve/process final payment request.

B. The Grants Information and Control Systems (GICS) Requirements

The Grants Information and Control System (GICS) is EPA's official assistance information management system and plays an integral part in the closeout process. It provides grants managers with information to manage and track progress on grant agreements. The system contains a collection of closeout data elements to track a grant's progress through the closeout process. Grant specialists update the closeout milestones in GICS by accessing the appropriate closeout screens in EPA's Automated Grants Document Systems, i.e. the Regional Automated Grants Document System (RAGDS), the Headquarters Automated Grants Document System (HAGDS), the Fellowship Automated Document System (FADS), and the Interagency Agreement Management System (IAMS), as each milestone is achieved. The most frequently used closeout milestones for non-construction grants are incorporated into a Table below. Appendix B contains definitions for these milestones and general information on the closeout screens used for Construction Grants. Further information on these data elements can be found in the GICS Data Dictionary [GIRD] and the Headquarters and Regional procedural manuals.

* COMP-LTR-SENT-CODE/DATE (M1)

* FINANCIAL-STATUS-CODE/DATE (M5)

* REAL-PROPERTY-CODE/DATE (L7)

* PERS-PROPERTY-CODE/DATE (L2)

* INVENTION-CODE/DATE (L4)

* FINAL-REPORT-CODE/DATE (L8)

* AUDIT-REQUEST-DATE (N8)

* AUDIT-RESULTS-CODE (N9)

* FINAL-AUDIT-DATE (91)

* ACTION-CODE/DATE


C. Notification and Follow Up

1. Closeout Notification

Monthly

The GMO should provide each Grants Specialist a Grants Information and Control Systems (GICS) printout each month which identifies those projects/agreements that are in the closeout process or are scheduled to end in the next 90-120 days. These printouts (Status Report of Projects Completed But Not Closed Out) list projects in sequence by project-end-date and indicate the status of each milestone event leading to close out and the date that it was entered as such.

90 Days Before End of Project Period

The Grants Specialist prepares for the EPA Project Officer a "completion alert" 90 days before the end of the project period. The memo requests information on whether the project/budget period needs to be extended or if the assistance award can be closed out.

2. Follow up Schedule

0-30 Days after Completion.

A letter requesting the necessary closeout reports should be mailed to the individual who accepted the most recent award document on behalf of the recipient, with a copy to the EPA Project Officer.

90 Days after Completion

The recipient will submit final progress (technical) reports to the Project Officer 90 days after the project's completion or end date, whichever comes first and notify the GMO of their receipt and acceptability. Other reports, including the final Financial Status Reports, are also due within 90 days, and should be submitted to the Grants Specialist. The Grants Specialist will then review those projects that have overdue reports (over 90 days) and determine whether another followup letter should be sent to the recipient. This letter must be tailored to address specific deficiencies of the project, e.g., what required deliverables were not received and are overdue? A copy of this letter should also be sent to the FMO\PO.

120 Days after Completion

If the recipient has not provided the information required for closeout 4 months after completion of the project, the Grants Specialist should confer with the Project Officer and send another follow-up letter. This letter shall be signed by the RA/ARA or Director, GAD (for headquarters projects), and addressed to the head of the recipient organization, with a copy to the FMO\PO. It should provide a chronology of earlier efforts to obtain the materials required by the agreement, enclose a copy of previous reminders and follow-up correspondence, and establish a specific date (suggest 2 to 3 weeks) for receipt of a response.

180 Days after Completion

Closeout should be completed within 6 months (180 days) after the end of the agreement. When closeout has been completed, the Award Official should provide the recipient with the closeout letter or a letter of final determination, with copies to the FMO and PO. (See Disputes Section in Part V)

Part III: Program Specific Requirements

A. State Revolving Fund Loan Program

This section defines the basic policy on the timing of capitalization grant closeout and highlights specific SRF requirements. Capitalization closeout procedures parallel closeout procedures for continuing program grants.

In general, closeout will occur at the end of each capitalization grant's budget period, i.e. when all the cash is drawn down from that grant providing, however, that the audit for the State fiscal year in which the last cash draw occurred has been issued and any findings resolved. Closing a capitalization grant will not mean that all statutory work and regulatory requirements have been satisfied. For example, a Region may decide to closeout a capitalization grant before an equivalency project has met all of its equivalency requirements [Sixteen Title II requirements CWA, Title VI §602(b)(6)]. Nor will closeout indicate that all the "work" agreed to in the assistance agreement has been completed or that all the loans have been repaid. Rather, closeout will indicate that EPA is satisfied that the State has established a viable and fiscally sound SRF loan program. EPA will assure continued compliance with statutory and regulatory requirements by reviewing a State's Intended Use Plan [40 CFR 35.3150], reviewing a State's Annual Report [CWA Title VI, §606(d)], by performing annual oversight visits of the State's operations [CWA Title VI, §606(e)], and by receiving audits of the program [CWA Title VI, §606(b)]. If, however, a State is found to be out of compliance with any part of Title VI or the implementing regulations, 40 CFR Parts 31 and 35, Subpart K, and corrective action has not been initiated by the State, a grant cannot be closed out. To close out a capitalization grant, the GMO, in conjunction with the Project Officer (the SRF Coordinator) would follow the requirements as specified in Part II.


B. Superfund

The following are the additional steps each GMO must follow in closing out a Superfund Cooperative Agreement. Superfund recipients are usually States, Political Subdivisions, or Federally Recognized Indian Tribes, and the closeout procedures in this section apply to these recipients. Recipients of other Superfund grants, such as; Research and Development; and Technical Assistance Grants (TAG), follow the closeout requirements for project-specific grants.

Superfund Cooperative Agreements

Superfund response Cooperative Agreements (CAs) provide funding from EPA to conduct the response activity at a Superfund site. These CAs can provide funding for the following types of activities:

  • Pre-Remedial Activities
  • Remedial Response Activities
  • Other Activities

    Preliminary Assessment (PA)
    Site Investigation (SI)
    Hazardous Ranking System (HRS)
    Remedial Investigation (RI)
    Feasibility Study (FS)
    Remedy Selection/Record of Decision (ROD)
    Remedial Design (RD)
    Remedial Action (RA)
    Removal Program
    Core Program
    Enforcement
    Support Agency

In a Superfund CA, closeout of the CA usually occurs when all work, as specified in the scope of work, has been completed. Due to the complexity and "umbrella-like" structure of Superfund CAs, closeout can often become an unduly complicated situation, with many activities taking place over extended periods of time. To improve our management of Superfund CA closeout, it is desirable to close out each diverse activity or operable unit as it is completed. As each activity or operable unit is completed, the activity would be designated as an "Activity Completion" and the same steps in the closeout process would be followed. In the case of a pre-remedial or a remedial CA, as each activity (or operable unit) is completed, activity completion (or operable unit completion) should take place for that discrete activity. This approach is a more manageable way to ultimately achieve closeout of the entire agreement.

Since many Superfund CAs last for many years and may include more than one site, it is important to initiate completion by activity, site, or operable unit. This will simplify the administrative closeout process later on when the entire agreement is closed out, and will help the cost recovery effort which may begin before all activities at the site are complete or when all sites under the multi-site are complete.

For a Superfund site-specific CA, if the CA is terminated when a responsible party takes over the cleanup or the lead changes from State to EPA, the CA should be closed out and any unliquidated obligations balance should be de-obligated.

A Superfund Core Program cooperative agreement provides funds to a State or Indian Tribe to conduct CERCLA implementation activities that are not assignable to specific sites, but are intended to support a State's (or Indian Tribe's) ability to participate in the CERCLA response program. In the Core Program, the CA is closed out when the activities identified in the scope of work are completed. Likewise for Enforcement, Support Agency, or Removal cooperative agreements. When all required work as specified in the scope of work has been completed, the CA should be closed out. To close out a Superfund CA, the GMO and PO must follow the requirements specified in Part II.

C. Construction Grants

Construction Grants are awarded to local municipalities to fund construction of waste water treatment plants. It is EPA policy to close out construction grants promptly; funds not needed on one project can be deobligated and reallotted to finance other treatment works projects. The Construction Grants Program is also different from other EPA programs because this is a delegated program. EPA is responsible for overall program management but most of the day-to-day administrative duties have been delegated to the State water pollution control agencies or the US Army Corps of Engineers. EPA Regional Offices retain some project-related decision authorities that are not legally delegable.

Eligible activities funded by construction grants can include facility plans (Step 1), plans and specifications (Step 2), and the building of a treatment plant (Step 3). A full listing of the different types of construction grants is included in Appendix C.

KEY COMPLETION/CLOSEOUT MILESTONES

Physical Completion: When the scope of the work is completed. For Steps 1 & 2, project completion and physical completion are synonymous. (For steps 2+3, 3, 7 & 9 project completion, physical completion, and construction completion are synonymous.)

Initiation of Operations (IO): When the wastewater treatment works becomes capable of operating for the purposes planned, designed and built. (Steps 3, 2+3, 7 & 9)

Project Performance Certification: One year after IO, the grantee certifies that the treatment facility is meeting project performance standards. (Steps 3, 2+3, 7 & 9) Please note that the project cannot be sent to audit until the certification is received.

Administration Completion: All administrative aspects of the project have been completed, final payment has been requested, eligible costs have been determined, all grant conditions have been satisfied and the audit has been requested. All excess balances (unliquidated obligations) should be deobligated at this point.

Audit: Project is sent to the Office of Audit, Office of Inspector General (OIG) for audit.

Audit Resolution: Audit resolution occurs when one of the following actions have been performed by the Regional Office:

***NOTE***

The time between physical completion and administrative completion can be no less than 14 months because the project performance certification period is one year after physical completion and initiation of operations. The project can not be sent to audit until after project certification. If the IG accepts the project for audit, it may be 24 months before the final audit report is issued.

PART IV: RECORD RETENTION REQUIREMENTS

EPA's Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments (40 CFR Part 31.42) establishes minimum records retention requirements for all assistance recipients. In general, a recipient must retain all financial records, supporting documents, accounting books and other evidence of assisted activities for three years from the date of the final Financial Status Report submission. If any litigation, claim, or audit is started before the expiration of the three year period, the recipient must maintain all appropriate records until these actions are completed and all issues resolved. The retention period starts on the day the recipient submits its final Financial Status Report. A recipient may always choose to implement stricter or longer retention periods to meet their own needs. For construction grants, the retention period starts the day the grantee submits the final payment request. For the SRF Program, official records include copies of the State/EPA agreements, SRF Intended Use Plans, SRF Operating Agreements, SRF Annual Reports, and SRF Program Evaluation Reports. Only the grant agreement can be retired after grant closeout. All other documents must be retained for Program Management purposes.

Superfund Assistance Agreements

Construction Assistance Agreements

ALL Other Assistance Agreements

PART V: AUDIT RESOLUTION AND DISPUTES

A. Audit Resolution - General Information

EPA Order 2750.2A (Management of EPA Audit Reports and Followup Actions) states that audit resolution must occur within 150 days of the final audit report issuance. Resolving audit findings, issues or exceptions is a multi-step process involving many different offices. Audits which cannot be resolved at the Regional or Headquarters level between the OIG and the Audit Action Official are referred to EPA's Audit Resolution Board.

EPA relies primarily on Single Audits of recipients carried out in accordance with the requirements of the Single Audit Act and Federal Audit policy expressed in OMB Circulars A-128 and A-133. Consistent with that policy, most assistance agreements will not receive individual final audits. A final audit is usually not a prerequisite for closeout.

All Superfund Cooperative Agreements are subject to audit by the Office of Inspector General. Projects may be audited prior to or even after closeout. The Program Office is usually responsible for requesting an audit. Closeout of all completed phases of response activities should be undertaken regardless of whether or not an audit is actually performed. However, any findings/issues arising from an audit must be resolved before the cooperative agreement can be officially closed out.

For Construction Grants, an audit request is sent to the appropriate Divisional Inspector General for Audit who determines if an audit will be conducted. For more detailed information on the steps involved in this process, refer to the appropriate Construction Grant Program Audit and Closeout Procedures.

The OIG will normally audit construction grants according to criteria published in the OIG Manual, Chapter 102 -- Audit Planning Appendix 6, Issued October 1984 and revised June 5, 1990.

If the OIG (EPA, contract CPA firm, State Auditor, or GAO) conducts an audit, the project cannot be closed out until the final audit is completed, all findings and recommendations are resolved, corrective actions are completed, and any outstanding debts are collected.

B. Disputes

Definition

Disputes are petitions of review filed by recipients asking EPA to reconsider decisions affecting assistance agreements.

Many (but not all) disputes between recipients and EPA concern the eligibility or allowability of a project or portions of a project for reimbursement by EPA under the provisions of the assistance agreement, usually resulting from an audit or other determination by EPA's award official.

Authority

Disagreements between EPA and applicants/recipients should be resolved at the lowest possible level by the EPA Project Officer and the appropriate Grants Specialist having the authority to resolve the dispute.

The applicable regulations depend on the award date of the grant agreement or amendment. If the award date is before October 1, 1988, 40 CFR Part 30 Subpart L applies. If the award date is after October 1, 1988, 40 CFR Part 31 Subpart F applies. Disputants may not ask EPA to review the following Agency actions:

1. Denials of requests for a deviation under 40 CFR Part 30, Subpart J;

2. Bid protest decisions under 40 CFR Parts 31/33;

3. National Environmental Policy Act decisions under 40 CFR Part 6;

4. Advanced wastewater treatment decisions of the Administrator;

5. Policy decisions of the EPA Audit Resolution Board; and

6. Debarment/suspension actions taken by the Director, Grants Administration Division.

Role of the Disputes Decision Official

The Award Official may act as the Disputes Decision Official (DDO) or appoint a senior EPA Official who is knowledgeable about EPA's assistance programs as the DDO. The DDO reviews and issues the final decision for all disputes. If an applicant or recipient disagrees with the Regional DDO's decision, the disputant may file a request for a review with the Regional Administrator (RA), who will in turn issue a written determination.

If an applicant or recipient disagrees with a RA's decision, they may request a review by the appropriate Assistant Administrator (AA). The AA in the appropriate media Program Office has the authority to review appeals of RA decisions. The AA will analyze the request to determine if it warrants further review. The AA will then notify the recipient in writing of their decision to review or not to review the disputed action. In the limited number of cases which are reviewed, the AA will also provide the results of the review at this time. The recipient may request reconsideration of any decision of the RA or AA.

Impact of Disputes on Closeout

Disputes can be very resource intensive and will bring the audit decision-making process under closer scrutiny. It is for this reason that the Audit Action Official should resolve all audit findings and avoid incomplete final determination letters (see Part V Audit Section). Inadequate or incomplete audit resolution can increase the number of disputes filed by recipients. Unresolved disputes further delay closeout of the award until the action or claim is settled.

VANESSA: -- C:\POLICY\CLOSEOUT
VINCE: -- C:\WP51\VINCEDOCS\CLOSE\CLOSEOUT

 

APPENDIX A

LISTING OF EXISTING EPA CLOSEOUT REGULATIONS, POLICIES, AND RELATED GUIDANCE

(1) 40 CFR Part 4 (Uniform Relocation Assistance), or 49 CFR Part 24 if applicable;

(2) 40 CFR Part 30 (for non-State and local government recipients);

(3) 40 CFR Part 31 (for State and local governments);

(4) 40 CFR Part 32 (Debarment and Suspension);

(5) 40 CFR Part 33 (Procurement for non-State and local government recipients);

(6) 40 CFR Part 34 (Restriction on Lobbying, interim final rule);

(7) 40 CFR Part 35 (State and Local Assistance);

(8) 40 CFR Part 40 (Research and Demonstration Grants);

(9) 40 CFR Parts 45 and 46 (Training and Fellowship grants);

(10) OMB Circulars A-102 (Grants and Cooperative Agreements to State and Local Governments) and A-128 (Audits of State and Local Governments);

(11) OMB Circulars A-110 (Grants and Cooperative Agreements with Institutions of Higher Education, Hospitals and Other Nonprofit Organizations), A-133 (Audits of Institutions of Higher Education and Other Nonprofit Institutions), and A-21 (Cost Principles for Universities;

(12) OMB Circulars A-87 (Cost Principles for State and Local Governments) and A-122 (Cost Principles for Nonprofit Organizations);

(13) Policy on Performance-Based Assistance (EPA policy memorandum dated May 31, 1985);

(14) Comptroller Policy Announcement No. 88-09 (Disposition of Unobligated Balance of Assistance Awards);

(15) EPA Directive 2750 (Management of EPA Audit Reports and Follow-up Actions).

(16) Chapter 40 of EPA's Assistance Administration Manual

(17) Construction grants Program For Municipal Wastewater Treatment Works Handbook of Procedures

(18) CG-250, Managing Construction Projects Student Manual; and

(19) The Strategy Paper for Closing Out the Construction Grant Program, dated 10/90 and formally released January, 1991.

 

APPENDIX B

GICS DATA ELEMENTS FOR CLOSING OUT NON-CONSTRUCTION GRANTS

GICS contains a series of data elements used to track grant closeout. This appendix provides definitions and applicable codes for the most commonly used data elements. Note: not all closeout data elements are available in RAGDS, FADS, or IAMS. It is GAD's intention to revise the GICS Data Dictionary and appropriate screens in the Automated Grants Document Systems to make all standard closeout data elements universally available.

COMP-LTR-SENT-CODE/DATE

A code indicating the most recent completion/follow-up letter sent to the recipient

For purposes of Closeout the following codes are applicable:

A Pre-completion reminder mailed
B Completion reminder mailed
C Reminder(s) to signatory of agreement
D Warning to President/chief officer of recipient organization
X Final determination recommendation prepared by Grants Operations Branch and forwarded for required approvals/concurrences

FINANCIAL-STATUS-CODE/DATE

A code indicating the status of the final financial status report (report of expenditures) submitted by the recipient. The date related to this code is contained in Final Financial Status Report Date (Ref No M5-A, Financial-Status-Date).

For purposes of Closeout the following codes are applicable:

DE Financial status report approved; FMC, Las Vegas requested to deobligate
DR Financial status report approved; EPA owes recipient; Recipient advised to draw down
NA Not applicable to this project/budget period
OU Financial status report approved; Recipient owes EPA; Requested to submit refund or adjust letter of credit
PU Financial status report approved; Recipient has paid EPA
RA Received an acceptable/approved report; Zero unobligated balance
RP Received report/acceptability to be determined
RU Received an unacceptable report; Follow-up to recipient initiated

PERS-PROPERTY-CODE/DATE

A code indicating the status of the personal property or equipment inventory purchased under a grant. The date related to this code is contained in Personal Property Inventory Date (Ref No L2-A, Pers-Property-Date).

For purposes of Closeout the following codes are applicable:

DI Disposition instructions issued; further action required
DW Disposition instructions being withheld by Grants Administration Staff
DX Disposition instructions executed/completed; no further property action required
NA Not applicable to this project
PD Project Officer provided disposition recommendation
PR Project Officer received report; Grants Administration staff awaiting disposition recommendation
RF Received and forwarded to Project Officer
RN Received negative report
RP Received positive report


REAL-PROPERTY-CODE/DATE

A code indicating the status of the real property inventory purchased under a grant. The date related to this code is contained in Real Property Inventory Date (Ref No L7-A, Real-Property-Date).

For purposes of Closeout the following codes are applicable:

DI Disposition instructions issued; further action required
DW Disposition instructions being withheld
DX Disposition instructions executed/completed; no further property action required
NA Not applicable to this project
PD Project Officer provided disposition recommendation
PR Project Officer received report; awaiting disposition recommendation
RF Received and forwarded to Project Officer
RN Received negative report
RP Received positive report


INVENTION-CODE/DATE

A code indicating the status of the invention report. The date related to this code is contained in Invention Report Status Date.
For purposes of Closeout the following codes are applicable:

NA Not applicable to this project/budget period
RF Received and forwarded to Office of General Counsel
RN Received negative report
RP Received positive report


FINAL-REPORT-CODE/DATE

A code indicating the status of the final report. The date related to this code is contained in Final Report Status Date (Ref No L8-A, Final-Report-Date).

For purposes of Closeout the following codes are applicable:

AA Report approved; confirmation in official project file; EPA Report Publication Number assigned and recorded in Report Publication Number (Ref No 40-A, Publication-No)
NA Not applicable to this project
PR Project Officer received report; awaiting peer review/approval; (Consider applicability of entering code "FR" in Action Step Code (Ref No 23-A, Action-Code) and date in Action Step Date (Ref No 24-A, Action-Date))
RF Received and forwarded to Project Officer
RU Received an unacceptable report; follow-up to recipient initiated


AUDIT-REQUEST-DATE

The date of the request for a financial audit of a non-Construction grant. Use of this element is limited to grants meeting certain select criteria and is not applicable to Single Audits. For Regions using Audit Request Code (Audit-Request-Code, Ref No N8-A), this is the date related to the code contained in that element.

Positions 1-2 - Year
" 3-4 - Month
" 5-6 - Day

AUDITS-RESULTS-CODE

A code indicating the status of the completion of the financial audit of a non-Construction grant. This element is not used for Single Audits. The date related to this code is contained in Audit Completion Date (Ref No N9-A, Audit-Results-Date).

For purposes of Closeout the following codes are applicable:

CA Cost analysis
FA Final audit
IA Interim audit
RN Received notice of cancellation of audit request
RP Received audit report

FINAL-AUDIT-DATE

The date a final audit is resolved satisfactorily.

Positions 1-2 - Year
" 3-4 - Month
" 5-6 - Day

ACTION-CODE/DATE

A code which identifies the current status and/or disposition of a prospective project, application, or active or completed project for which financial assistance has been requested or given. Codes are from the GICS-ACTION-CODE-TABLE [not GICS-ACTION-CODE-NON-TABLE] The date related to this code is contained in Action Step Date.

For purposes of Closeout the following codes are applicable:

FA Completion of all administrative work connected with an assistance agreement by the administering office. Applicable only to WWT Construction and State Revolving Fund (Project level).

FC Completed assistance agreement closed out: For EPA assistance agreements, letter issued by EPA to the recipient closing out the agreement.

FD Project completion: For assistance programs administered in Headquarters, the award official (Chief, Grants Operations Branch) has issued final determination to the recipient.

FR Project close-out complete except for approval of final project report and final disposition of property, if any. Applicable only to assistance programs administered in Headquarters.

FT Assistance terminated by EPA before completion. Termination letter sent from Grants Operations Branch or appropriate Regional grants administration staff to the recipient.

GICS SCREENS FOR CLOSING OUT CONSTRUCTION GRANTS

Closeout milestones for construction grants are found on a number of different screens in GICS. Screens include:

  • Post Award/Targeting (PTN) which tracks the completion of certain activities such as WWT Start, Initiation of Operation, development of the O&M Manual, Initiation of Administrative Completion.
  • Project Completion (PCN) which tracks a grant's progress through Physical Completion and Administrative Completion.
  • Payment Data (PDN) which tracks cumulative payment data.
  • Because Construction Grants is a delegated program, data entry can take place at the delegated State or in the Regional office. Regional procedures vary greatly.

 

APPENDIX C

Types of Construction Grant Awards

Step 1: Development of a facilities plan. No new awards were issued after 12/29/81. It is EPA policy that all Step 1 projects should have been completed by 9/30/85.

Step 2: Preparation of plans and specifications for a treatment works. No new awards were issued after 12/29/81. It is EPA policy that all step 2 projects should have been completed by 9/30/85.

Step 3: Building of treatment works and related services and supplies.

Step 2 + 3: Combination design and building of a treatment works and building related services and supplies.

Step 7: Combination design and building of a treatment works wherein a grantee awards a single contract for designing and building a treatment works.

Step 9: Construction of a State training wastewater facility combining design and building for operations and maintenance personnel.

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