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Managing Your EPA Grant

This section provides you, the Grant Recipient, with important information and guidance to help you properly manage your assistance agreement -- from information on how to receive payment to requirements for closing your agreement.

EPA's grant regulations are located under Title 40 of the Code of Federal Regulations (CFR), Parts 7 and 29 through 47. Grant recipients must comply with the requirements in these regulations. EPA will provide guidance, if needed. Non-profit organizations and institutions of higher education are governed by 40 CFR Part 30; State and local governments are governed by 40 CFR Part 31.

The information provided below is not intended to replace the grant regulations but to serve as an additional resource for the Grant Recipient.

  1. Whom do I contact if I need assistance?
  2. How do I get paid?
  3. What grant regulations apply to my organization?
  4. How do I account for costs?
  5. How do I account for matching funds?
  6. What is program income and what are my responsibilities?
  7. What reports will I be required to submit?
  8. What records do I need to maintain and for how long?
  9. How do I differentiate between sub-awards and vendor transactions?
  10. What must I do to issue sub-awards?
  11. How do I avoid conflicts of interest when procuring goods and services with grant funds?
  12. What must I do to procure goods or services with grant funds?
  13. Are there any rules regarding management of equipment and supplies that were purchased with grant funds?
  14. What additional requirements do I need to be concerned about regarding - Utilization of Disadvantaged Business Enterprises, Quality Assurance Management Plans/Quality Assurance Project Plans, and Single Audits?
  15. What if I need to make changes to my assistance agreement?
  16. What happens when the project is completed? How do I close my grant?
  17. What should I expect if my grant is reviewed or audited?

 

 

1. Whom do I contact if I need assistance?

U.S. Environmental Protection Agency - Region 4

61 Forsyth Street

Atlanta, GA 30303-8960
404-562-8400

 

Project Officer

The EPA Region 4 Project Officer (PO) is your primary point of contact. The PO's name and phone number are listed on page 1 of the grant agreement.

Administrative Issues

For questions concerning general administrative issues, contact your EPA Region 4 Grants Management Specialist. The Grants Specialist's name and phone number are listed on page 1 of the grant agreement.

Payment

For questions regarding the payment process, contact Sharen Rheinhardt, U.S. EPA Financial Specialist, Las Vegas Finance Center, Phone:  (702) 798-2471, FAX:  (702) 798-2423.

Disadvantaged Business Enterprise (DBE)

For questions concerning EPA's goal for selecting MBEs or WBEs, contact EPA Region 4's Coordinator for Small and Disadvantaged Business Utilization, Charles Hayes, at 404-562-8733.

Civil Rights

For civil rights related questions, contact EPA Region 4's Office of Civil Rights at 404-562-9738.

Quality Assurance

For questions concerning quality assurance requirements, contact the EPA Region 4 QA Office at 706-355-8553 (Marilyn Thornton) or 706-355-8568 (Denise Goddard).

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2. How do I get paid?

When EPA awards a grant to your organization, you will receive two signed original grant agreement documents. The most important step at that time is for your authorized representative to sign both copies of the agreement, which indicates your acceptance of the award. One copy of the signed agreement must be returned to the EPA Region 4 Grants Office within 21 days. The other copy should be kept for your records.

After EPA has received the signed copy, you will be able to request payment for grant-related expenses using one of the following payment methods: ASAP or Requests for Reimbursement using SF 270 or SF 271.

Automated Standard Application for Payments (ASAP)

ASAP is an all-electronic payment and information system developed jointly by the U.S. Treasury and the Federal Reserve Bank. Your "one time" enrollment in ASAP is accomplished by contacting the U.S. Treasury's Philadelphia Regional Financial Center at 215-516-8021.

Once you are enrolled in the system by Treasury, EPA will then establish your grant account. You may use the on-line process or a telephone voice response system to request payment from EPA. Payment requests are approved or rejected automatically based on the amount of available funds and/or the grant expiration date.

With ASAP, you may also view account data on-line, such as up-to-the-minute account balances, account history, and the status of payment requests. For more information on ASAP, see "Links to Other Related Information".

Requests for Reimbursement

To request payment under a non-construction grant, complete the Request for Advance or Reimbursement form (SF 270) and mail it to the EPA Region 4 Finance Office. If you have questions about this form, please contact the EPA Project Officer listed on your grant agreement.

To request payment under a grant involving construction (e.g., Special Appropriation Projects), complete the Outlay Report and Request for Reimbursement for Construction Programs form (SF 271) and mail it to your EPA Region 4 Project Officer, along with your invoices.

All reimbursement payments are made through Direct Deposit. Therefore, you will need to enroll by completing the ACH Payment Enrollment Form (SF 3881) and fax (or mail) it to the EPA Las Vegas Finance Center at 702-798-2423.

For construction grants, after the initial request for reimbursement, you must enroll and use the ASAP payment method discussed above.

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3. What grant regulations apply to my organization?

The general grant regulations and Office of Management and Budget (OMB) Circulars listed below apply to all EPA assistance programs (by recipient type - e.g., State, non-profit). Recipients should familiarize themselves with these documents to ensure that they are in compliance with the requirements. Additional regulations for specific EPA programs (listed below) may also apply; contact your EPA Project Officer or program representative for details.

Code of Federal Regulations (CFR)

The CFR is organized by Title, Chapter, and Part. EPA grant regulations are found at:

GENERAL GRANT REGULATIONS

PROGRAM SPECIFIC GRANT REGULATIONS

For more information, see "Links to Other Related Information".

OMB Circulars

The following OMB Circulars may apply to the management of your EPA grant:

For more information, see "Links to Other Related Information".

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4. How do I account for costs ?

You are required to adequately track and document all grant expenses. You should consider the following in order to establish a system which meets Federal requirements:

 

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5. How do I account for matching funds?

Many of EPA's grant programs require the grantee to contribute a non-federal cost-share or to match the Federal funds provided for the project.

Match requirements may be satisfied by any combination of the following:

To be counted as match, contributions must meet all of the following criteria:

The following may not be used as match:

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6. What is program income and what are my responsibilities?

Program income is gross income received by the grantee or sub-grantee directly generated by a grant supported activity or earned only as a result of the grant agreement during the grant period.

Examples of program income include, but are not limited to:

How to account for program income:

All program income should be deducted from the total grant expenses to determine net allowable grant expenses. However, when appropriate, EPA may add a condition to the grant at the time of award or amendment, authorizing one or more of the following uses of program income:

If program income is generated during the project period of the grant and that income was not anticipated at the time your grant was awarded, contact your EPA Project Officer immediately for guidance on the treatment of the income.

Recipients have no obligation to the Federal Government regarding program income generated after the end of the project period, unless the terms of the agreement or regulations provide otherwise.

 

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7. What reports will I be required to submit?

Periodic reports from your organization provide EPA with information regarding the status of your project. There are two basic types of reports that you will need to submit: Administrative and Technical.

ADMINISTRATIVE REPORTS

FFRs provide an accounting of the obligations and expenditures incurred for the approved project or work plan during the budget period. Unless otherwise required by your grant agreement, FFRs must be submitted annually and should be mailed to your EPA Region 4 Grants Specialist. Within 90 days after the grant ends, a final FFR which summarizes total expenses must be submitted to U.S. EPA, LVFC, POB 98515, Las Vegas, NV 89193-8515 . All of your bills must be paid by the time the final FFR is submitted.

Standard FFR form 425 (SF-425) must be used. Instructions for completing this form can be found at: http://www.whitehouse.gov/omb/grants_forms

Supplemental Guidance for Preparation of FFRs

What is an obligation?

An obligation is an indebtedness or liability to pay for costs such as personnel, travel, equipment, and supplies and must be incurred during the budget period of the assistance agreement. Obligation is not to be confused with expenditure or cash disbursement.

What is an unliquidated obligation?

An unliquidated obligation is an obligation that has been incurred but not yet paid.

What is an unobligated balance?

An unobligated balance is the difference between the total authorized grant amount and the total amount of obligations (outlays and unliquidated obligations) incurred by the recipient during the budget period of the assistance agreement.

Unless the recipient sends a written request for extension, all obligations should be liquidated within 90 days after the end of the grant period. A final FFR report must be prepared when all obligations have been liquidated.

Item #6 - Final Report

This should be checked "YES" only if the FFR shows "0" unliquidated obligations on Line 10d. If an amount is shown on Line 10d, the FFR is "INTERIM" and NOT "FINAL."

Item #10 - Transactions

Leave columns I and II blank. All figures should be placed in Column III - Cumulative.

Item #10a - Total Outlays

Enter the total project outlays for the budget period. Total outlays must be supportable by accounting records.

Item #10b - Recipient Share of Outlays

Subtract the amount in Line 10c from the amount in Line 10a to determine your share of the outlays. Insert that amount here.

Item #10c - Federal Share of Outlays

Multiply the percent of project costs that EPA has agreed to pay as stated in your assistance agreement by the amount in Line 10a. Enter that amount here. Please indicate the percent in a blank space on Line 10c.

Item #10d - Total Unliquidated Obligations

Enter a total of all obligations that have not been paid and check "NO" in Item #6 above. Attach to your FFR a list of these obligations and a schedule of anticipated liquidation dates. If you have no unliquidated obligations, enter "0" and check "YES" in Item #6 above.

Items #10e and f - Recipient Share And Federal Share of Unliquidated Obligations

Enter the recipient and Federal shares of any unliquidated obligations here. Using the same percentage as in Line 10c, calculate the Federal and recipient shares of unliquidated obligations. Lines 10e and f must equal Line 10d. For 100% federally funded awards, there will be no recipient share.

Unless the recipient sends a written request for extension, all obligations should be liquidated within 90 days after the end of the grant's budget period. A final FFR report must be prepared when all obligations have been liquidated.

Item #10g - Total Federal Share

Enter the sums of Lines 10c and f.

Item #10h - Total Federal Funds Authorized For This Funding Period

Enter the amount of federal funds authorized on your assistance agreement for the budget period covered by this FFR.

Item #10i - Unobligated Balance of Federal Funds

Show unobligated balance of federal funds (Line h minus Line g).

Item #12 - Remarks

Clean Air Act Recipients - Enter all non-recurrent costs included on Line 10g. Each item purchased and the unit cost must be reported. Equipment purchases with a unit acquisition cost of $5,000 or more are considered non-recurrent.

(To receive funds under CAA Section 105, an agency must expend annually, for recurrent Section 105 program expenditures, an amount of non-federal funds at least equal to such expenditures during the preceding fiscal year. See 40 CFR 35.146 - Maintenance of Effort.)

FCTRs (forms SF 272 and SF 272A) are used to monitor your cash on hand to ensure that you do not have excessive amounts in your account. FCTRs should be submitted every 6 months (as of June 30 and December 31) to your EPA Las Vegas Finance Center.

The MBE/WBE Utilization Report, EPA Form 5700-52A, provides information concerning the dollar amount of procurement (both contracts and small purchases) that you directed to MBEs/WBEs. The report must be submitted each year to the EPA Region 4 Small and Disadvantaged Business Utilization Coordinator, according to the frequency specified in your award document.

TECHNICAL REPORTS

You will be required to submit periodic reports on your progress in meeting your workplan commitments.  Generally, your work plan for the project or a condition on your grant award will specify the frequency and types of reports that are required and what they should contain. If a final technical or performance report is required, it is due to the EPA Project Officer within 90 days after project completion.

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8. What records do I need to maintain and for how long?

Financial records, technical reports, grant work products, and all other supporting documents for your grant must be kept for three years from the date the grant was closed by EPA.

Exceptions:

The Federal Government has the right to timely and unrestricted access to any and all records that pertain to the grant award.

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9. How do I differentiate between sub-awards and vendor transactions?

Sub-Awards

Sub-awards are awards of financial assistance made by the primary grantee to eligible sub-recipients for the purpose of providing support or stimulation to accomplish a public purpose. This includes financial assistance when provided by any legal agreement, whether it is referred to as a contract or a grant. Sub-award agreements are sometimes referred to as "Pass-Through" funds.

A sub-award should be used if the sub-recipient:

Vendor Transactions

Vendor transactions are the purchases of goods and services, typically acquired through either purchase orders or contracts. They are not considered to be sub-awards. Grant recipients must follow the grant procurement requirements when purchasing goods and services. For additional information, refer to the section entitled "What must I do to procure goods and services with grant funds".

A vendor transaction should be used when:

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10. What must I do to issue sub-awards?

Sub-awards should be written agreements and include the following items:

All sub-recipient awards must be closely monitored. Your organization is responsible for ensuring that these awards are used for purposes in compliance with federal laws, regulations, and grant program requirements. Your organization is also responsible for ensuring that the performance goals are achieved and the project is completed.

Keeping detailed records of your monitoring activities is highly recommended!

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11. How do I avoid conflict of interest when procuring goods and services with grant funds?

No employee, officer, or agent of your organization may participate in the selection, award, or administration of a procurement action if a conflict of interest would or would appear to be involved.

Conflicts of interest occur when an employee, officer, or agent, any member of his/her immediate family, his/her partner, or an organization which employs or is about to employ any of these individuals, has a financial or other interest in the firm selected for an award.

Your organization must have a written standard of conduct to provide guidance for employees regarding their conduct in the award and administration of procurement. The standard should also include disciplinary actions that will be applied if an employee violates these written standards.

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12. What must I do to procure goods or services with grant funds?

Grantee organizations are required to have written procedures which cover all procurement actions and which comply with Federal requirements. The procurement regulations at 40 CFR 31.36 apply to State, local government, and Tribal recipients; 40 CFR 30.40 through 30.48 apply to university and non-profit recipients. These regulations contain standards which help ensure that materials and services are obtained in compliance with applicable Federal statutes and Executive Orders. (Recipients of Superfund grants must comply with the appropriate Superfund regulations, 40 CFR Subpart M or Subpart O.)

States should follow the same policies and procedures they use for procurement with their non-Federal funds. They must ensure that each purchase order and contract includes the clauses required by the regulations at 40 CFR 31.36(i).

Some of the major points contained in the procurement regulations include:

-require, where appropriate, an analysis of lease versus purchase alternatives to determine which is the most economical and practical

-ensure that solicitations provide:

-a clear description of the technical requirements

-the basis for contractor selection

-justification for lack of competition, if applicable

-the basis for award cost or price

Section 31.36(i) and Section 30.48 contain contract provisions that must be included in all contracts that exceed the small purchase threshold, which is currently $100,000. The Appendix to CFR Part 30 contains additional procurement provisions, some of which apply to all contracts, including small purchases.

When procuring goods or services with EPA grant funds, recipients are required to use and document a competitive process. How do I compete?

-Estimated cost < $100K may use formal advertisement or direct contact of 3 known vendors.

In certain instances, exceptions to the competitive requirement may be allowed. The exceptions are:

Both exceptions may require prior EPA approval. Contact your EPA Project Officer before making binding commitments.

Finally - Documentation of the steps and decisions that led to the award of each contract is extremely important !

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13. Are there any rules regarding management of equipment and supplies that were purchased with grant funds ?

It is important that you understand the difference between equipment and supplies, since the treatment of and accounting for each is somewhat different.

Equipment

Equipment is non-expendable personal property having a useful life of more than one year and a cost of $5,000 or more per unit.

What do I do if I purchased equipment under my grant?

States may use, manage, and dispose of equipment purchased in accordance with State laws and procedures. All other organizations must adhere to the following:

How do I dispose of equipment (items which are no longer needed)?

When no longer needed for the original project, the equipment may be used in other activities currently or previously supported by a Federal agency.

When actually disposing of equipment items which are no longer needed for the original project or for other Federally funded activities, the following applies:

Supplies

Supplies are considered to be all tangible, personal property other than equipment.

What do I do if I purchased supplies under my grant?

If, upon termination or completion of the grant, you have a remaining inventory of supplies with a total fair market value greater than $5,000, you will be required to reimburse EPA for its share of the value of the inventory.

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14. What additional requirements do I need to be concerned about regarding - Utilization of Disadvantaged Business Enterprises, Quality Assurance Management Plans/Quality Assurance Project Plans, and Single Audits?

Utilization of DBE's

EPA grant programs promote the utilization of small, small-rural, minority-owned, and women-owned business enterprises for all procurement actions (i.e., the purchase of supplies, equipment, or services.) Each EPA grant document lists the "fair share" objective that your organization should try to achieve. You must ensure that opportunities are made available to DBE's, whenever possible, and may do that by following the 6 affirmative steps listed below:

You and your contractor(s) should maintain documentation of your efforts to comply with these requirements.

EPA also needs to know how successful you were. Therefore, you must periodically report to EPA on your utilization of MBEs/WBEs for procurement of good and services (using form SF 5700-52A). For additional information, refer to the section entitled "What reports will I be required to submit."

For additional information on Small and Disadvantaged Business Utilization, please visit the following website:

http://www.epa.gov/osbp/dbe_team.htm

Quality Assurance Management Plans and Project Plans

If your project involves environmentally related measurements or data generation, you must develop and implement quality assurance practices sufficient to produce data that is adequate to meet project objectives and to minimize loss of data due to out-of-control conditions or malfunctions.

Contact the EPA Region 4 QA Office or your EPA Project Officer to discuss requirements of Quality Assurance Management Plans and Project Plans.

Single Audits

All non-Federal entities that expend $500,000 or more in Federal funds in one year are required to conduct a single or program-specific audit for that year. The audits are to be conducted in accordance with the provisions of OMB Circular A-133. We recommend that you refer to the Circular for further information.

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15. What if I need to make changes to my assistance agreement?

Budget or Program Revisions

There are certain budget and program changes that require prior approval by EPA. A detailed discussion of these requirements may be found in the regulations at 40 CFR 31.30 and 30.25.

For Part 31 recipients, some of the changes requiring prior approval by the EPA Award Official through a grant amendment include:

For Part 30 recipients, some of the changes to your award that require prior approval of the  EPA Award Official through a grant amendment are:

Your EPA program office or Project Officer may make the following approvals by letter:

Time Extensions

If you will not be able to complete the project within the original project period, it is important that you discuss the situation with your EPA Project Officer as soon as possible.

Part 31 recipients (i.e., States, locals, Tribes) may request an extension by submitting a written request to the EPA Region 4 Project Officer at least 60 days before the project period expires. Your request should provide information regarding the reason why the project will not be completed on time and why it is necessary to continue the project. The request should also specify the additional length of time needed for completion.

Part 30 recipients (i.e., non-profits and universities) may extend their agreements one time for up to 12 months without prior approval.

Exceptions:

Part 30 recipients must notify the EPA Project Officer in writing with the supporting reasons and revised expiration date at least 10 days before the expiration date specified in the award.

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16. What happens when the project is completed? How do I close my grant?

It is EPA policy that all assistance agreements be closed within 180 days of the project end date or completion of the project. You have 90 calendar days after the project is completed to submit all the required financial, performance, and any other reports or deliverables. A Closeout Checklist is provided under the forms section of this website to assist Grant recipients in this process. During this closeout process, any excess funds paid to you must be returned to EPA. Contact your EPA Region 4 Grants Specialist for guidance if you need to return money to EPA.

When all the close out requirements have been satisfied, the EPA Grants Office will issue a final letter to notify you that the grant is officially closed. This letter will also provide information about your responsibility for retaining records after the grant is closed. For additional information, refer to the section entitled "What records do I need to maintain, and for how long".

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17. What should I expect if my grant is reviewed or audited?

As part of EPA's oversight of your assistance agreement, your project may be selected for a review and/or an audit. The review or audit could occur either during the course of the project or as part of the final close-out phase of the grant. Generally, the reviews and audits completed by EPA are as follows:

EPA Region 4 Grants Management Office (GMO)

For grants awarded by EPA Region 4, the GMO is responsible for the administrative oversight of your agreement. Part of this responsibility may include the on-site review of your administrative operations. The overall purpose of an on-site visit by the GMO is to:

When the review is complete, a report will be issued to your organization detailing any concerns and recommendations. The GMO will work with you to resolve those concerns.

EPA Office of the Inspector General (OIG)

Your assistance award may be audited by the EPA OIG. These audits generally involve the review of all financial documentation (e.g., accounting reports, contracts, invoices) in support of the total grant-related expenses incurred by your organization.

After an audit is completed, the OIG recommends the acceptance and/or disallowance of costs in a report issued to EPA Region 4. Based on the OIG's recommendation and input from your organization, the EPA Regional Administrator will make a final determination of allowable costs under the project.

If, either through a review or audit, it is determined that you have incurred costs which are found to be unallowable in accordance with OMB Cost Principles and/or cannot be supported by source documentation (e.g., contracts, invoices, cancelled checks), you may be required to reimburse EPA for those costs.

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General Accounting Office (GAO)

Your agreement may also be subject to review by the GAO.

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