Establishment of Standards for Submission of Administrative and Financial Assistance Agreement Forms/Documents with Electronic or Digital Signatures by Email
Effective/ Notification Date: May 13, 2020
Purpose of Revision: EPA has revised the RAIN to remove the information pertaining to the disclaimer receipt e-mail mentioned in the original RAIN, which is now just an optional element depending on whether it is necessary based on the circumstances.
Policy Summary: As highlighted by the recent COVID-19 public health emergency, EPA recognizes that traditional mail service may not be a feasible option for EPA applicants/recipients to submit forms/documents (primarily post-award documents and not initial application submittals-see below) requiring signatures through traditional mail service. Therefore, EPA has established a process to use reasonable safeguards to ensure the validity of signatures on assistance agreement forms/documents (see List in the Related Resources below) submitted to EPA via e-mail.
It should be noted that forms/documents required to be submitted electronically with initial application packages via Grants.gov (absent a Grants.gov exception allowing an alternative submission method) shall follow the established submission process associated with that platform (See RAIN-2018-G07-R2). Further, the process addressed by this RAIN only applies to the assistance agreements forms/documents included in the list located in the Related Resource section below, which will be updated as necessary, and to forms/documents sent to EPA with electronic or digital signatures through e-mail. It does not apply to submissions through Grants.gov and it does not apply to forms/documents that do not require a signature.
EPA applicants/recipients may submit any of the forms/documents on the attached list via e-mail if not required to be submitted through Grants.gov as part of the initial application package. Applicants/recipients must submit the forms/documents using their organization’s e-mail address. Applicants/recipients are responsible for ensuring that the forms/documents they submit through e-mail containing an electronic or digital signature are signed by the appropriate and authorized person from their organization and are submitted to EPA through a means by which it is clear it is being sent from the organization’s email. EPA may check to verify that the forms/documents are signed and submitted by a person(s) from the applicant’s/recipient’s organization listed on the Key Contacts form using the applicants/recipients organizational e-mail address. In general, these are the minimum reasonable safeguards necessary to ensure the validity of the signed forms/documents. Depending on the circumstances additional reasonable safeguards may be necessary to ensure the validity of the signed forms/documents sent by e-mail.