Tips for Completing EPA Form 4700-4

Pursuant to a permanent injunction issued by the U.S. District Court for the Western District of Louisiana on August 22, 2024, EPA will not impose or enforce any disparate-impact or cumulative-impact-analysis requirements under Title VI against any entity in the State of Louisiana. Click here for additional and updated information.

Preaward Compliance Review Report for All Applicants and Recipients Requesting EPA Financial Assistance

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New Form Review Process — effective 1/1/2023
Tips
Guidance
Samples
Other Resources

New Form Review Process — effective 1/1/2023

Effective January 1, 2023, EPA staff will use a revised process to review Form 4700-4, “Preaward Compliance Review Report for all Applicants and Recipients Requesting EPA Financial Assistance” (Form)[1]

Under this revised process, if a Form has not been completely filled out or the answers on the Form do not reflect that the applicant is in compliance with its civil rights obligations as required by our regulation, the EPA reviewer will contact the Point of Contact listed on the Form for additional information. If the applicant is not able to show that it is in compliance, it will be required to agree in writing to come into compliance. The agreement must be reached before the award processing will continue, but it will provide the applicant time even after the award has been made to complete the required actions. Failure to enter into or to fulfill the terms of the agreement may result in delay in the processing of the award and/or a finding of noncompliance and action to deny, suspend, annul, or terminate the award under 40 C.F.R. § 7.130.
Any Form submitted for a new award that is reviewed after January 1, 2023, will be reviewed under the new process. This may include Forms submitted prior to January 1, 2023, but your organization will still have until January 1 to be in compliance with its civil rights obligations. If an applicant is not in compliance when it fills out the Form but can demonstrate compliance when contacted after January 1, there will be no impact on the award other than the time required to contact your organization to obtain the compliance information.
This process will enforce compliance with the civil rights obligations identified in the Form 4700-4 and allow EPA staff to more effectively carry out EPA’s obligation to make a preaward compliance determination under 40 C.F.R. § 7.110. If you have questions, please submit them to 4700-4_Form_Questions@epa.gov.

[1] All applicants for EPA financial assistance are required to submit the Form, including federally recognized Tribal applicants. However, for purposes of the pre-award review or any post-award audits of 4700-4 responses, ECRCO will not review whether federally recognized Tribes are in compliance with these foundational requirements. Nevertheless, ECRCO would welcome the opportunity to provide technical assistance should federally recognized Tribes wish to develop a non-discrimination program.

ECRCO will review compliance with foundational requirements by Tribal education programs. See 42 U.S.C. 2000d 4a(2) (Title VI covers all the operations of federally funded schools and universities).

Tips

EPA Form 4700-4 is required of all applicants for EPA assistance. These tips address some of the most frequently asked questions that EPA receives or the most common errors on the Form. These tips are not a substitute for the instructions on page 3 of the Form; please review those instructions for additional guidance.

Be sure to answer every question. Failure to answer every question will result in a delay in the review of your Form.
If a question does not apply to you, put “NA” so the reviewer knows that it is not applicable. Do not leave questions blank.

For example, question XI asks if your organization has grievance procedures. If the organization has fewer than 15 employees and is not an education program or activity you should put “NA” for your response. If the organization has grievance procedures even when not required under these criteria, you may provide the requested information about the procedures.

[NOTE: if your answer to question VI is “No,” follow the instructions on the Form and skip questions VI. (a) and (b) rather than putting “NA.”]
Grants.gov allows you to re-use forms, a feature which will allow you to import EPA Form 4700-4 information from another application workspace (see this Grants.gov Tutorial for instructions on how to reuse forms).

If you reuse the information, be sure that all the information is up-to-date and accurate, including the Point of Contact in question I.C. When you submit the application, the form will be signed and dated accordingly.
The Point of Contact listed in question I.C. must be someone familiar with the information requested on the Form and who can answer any follow-up questions. Be sure the contact information is current.
Do not include personally identifiable information (PII) on this form, for example, Social Security numbers, student ID numbers, dates of birth, etc.
For questions III and IV, do not include employment discrimination complaints filed under Title VII of the Civil Rights Act unless the award you are applying for will be used in:
1. a program whose purpose is to create employment, or
2. a program that is subject to section 13 of the Federal Water Pollution Control Act Amendments of 1972, and the employment discrimination complaint alleged discrimination based on sex.
For question XI, grievance procedures should relate to how an applicant handles complaints that allege discrimination in an applicant’s programs or activity based on race, color, national origin (including limited English proficiency), sex, age, or disability. It is not responsive to this question to cite grievance procedures that solely relate to Title IX of the Education Amendments of 1972 (sex discrimination in educational institutions) or Title VII of the Civil Rights Act (employment) complaints.