&EPA United States Army Corps of Engineers September 1983 United States Environmental Protection Agency Office of Water Program Operations (WH-547) Washington DC 20460 Operating Procedures for "Monitoring Construction Activities"-- at Projects Funded under the Environmental Protection Agency's Construction Grants Program ------- OPERATING PROCEDURES FOR MONITORING CONSTRUCTION ACTIVITIES AT PROJECTS FUNDED UNDER THE ENVIRONMENTAL PROTECTION AGENCY'S CONSTRUCTION GRANT PROGRAM U.S. Army Corps of Engineers/ U.S. Environmental Protection Agency September 1983 ------- TABLE OF CONTENTS Page 1. Purpose 1 2. References 1 3. General 2 4. Interim Inspection 2 5. Frequency of Inspections 2 6. Related Activities 3 7. Preconstruction Conference 3 8. Documentation and Preparation 4 9. Interim Inspection Procedures 5 10. Scope of Interim Inspections 6 11. Grant Management and Record Keeping 7 12. Construction Management 9 a. Progress Charts and Schedules b. Payment Requests c. Change Orders d. Claims 13. Construction 13 a. Quantity b. Quality 14. Final Construction Inspection 15 15. Reporting 15 16. Follow-up 17 Appendix A - Inspection Related Functions I Appendix B - Grantee Files II Appendix C - Guide to Grantee's Cost Accounting and Internal Control System IV Appendix D - Contract Administration Checklist VI Appendix E - Construction Management Evaluations (CMEs) and Project Management Conferences (PMCs) VIII ------- -1- 1. PURPOSE: The primary purpose of this document is to provide general operating guidance to "Agencies" (Corps/States/EPA) performing construction inspections and related activities on projects funded under the Environmental Protection Agency's Construction Grants Program. The Corps, State or EPA representative ("Inspector") is the person(s) responsible for conducting official project inspections to determine grantee compliance with program requirements during the construction phase of a Step 3 grant. 2. REFERENCES: a. 40 CFR Parts 30, 33 and 35. b. EPA Handbook of Procedures (Second Edition). c. EPA Construction Grants 1982 (CG-82) d. ER 415-2-4, Corps Support for EPA Construction Grants Program, October 1, 1983. e. EPA Regional Guidance Documents. f. EPA/Corps of Engineers Interagency Agreement. g. EPA/Corps Regional Interagency Agreements. h. State Delegation Agreements. i. EPA Construction Inspection Guide (1976, 3 volumes). j. (EPA) Management of Construction Change Orders -- A Guide for Grantees (1983). ------- -2- k. EPA Construction Management Evaluation (CME) Manual (1983). 1. (EPA) Accounting Guide for Construction Grants (October, 1977). 3. GENERAL; The Agency role in the EPA Construction Grants Program will vary according to the status of the delegation of grant management functions in individual States. The re- commendations contained herein should be considered as guidance and modified as necessary in view of the specific responsibilities and procedures outlined in State Delegation Agreements and EPA/Corps Regional Interagency Agreements. It is expected that these Agreements, as appropriate, will be revised or supplemented to reflect this guidance. 4. INTERIM INSPECTION; The purpose of the interim inspection is to determine if the grantee is effectively managing its construction grant by: (a) meeting all standard and special grant conditions, (b) maintaining adequate record keeping and accounting systems, and (c) providing adequate construction and contract management, including maintenance of project schedules and construction quality control. Also, as appropriate and in keeping with the limits of his responsibility, the Inspector will provide the grantee with needed grants management advice and assistance. 5. FREQUENCY OF INSPECTIONS; The frequency with which projects are inspected should be determined by the rate of progress being achieved and the nature of problems or issues arising during construction. Generally, each project should be inspected monthly. Where the project is found to be progressing well and the grantee has demonstrated a high level of project management capability, bi-monthly or even quarterly visits may suffice. ------- -3- 6. RELATED ACTIVITIES; Appendix A lists related grant management functions, some of which may be evaluated during an interim inspection. While this guidance document does not attempt to cover all aspects of these functions, some peripheral discussion is included where the function has a direct relationship to the interim inspection. 7. PRECONSTRUCTION CONFERENCE: The preconstruction conference is the first meeting which will be attended by all parties involved in construction of the project. (The preconstruc- tion conference should be followed or preceeded by a Project Management Conference (PMC); see Appendix E). The Inspector should use the preconstruction conference to advise the participants of the Agency role in the grants program and to establish procedures and responsibilities for the interim inspection process. The following are typical points that should be clarified during this meeting: a. Points of contact with the grantee and grantee's management staff. Determine from the grantee who should be contacted on interim inspection matters. The grantee's "Authorized Representative" should be notified of formal actions. A list of contacts should also include the State/EPA project officers and the resident engineer/inspectors(s). An understanding should be developed regarding clear cut lines of authority and responsibility. b. Grantee/State/Corps/EPA interrelationships. c. Access to the work will be provided to representa- tives of the Corps, EPA and State whenever it is in progress, and the contractor will provide proper facilities as required by the Inspector. ------- -4- d. Schedules and notification procedures. e. Flow of documents, e.g., payment requests, change orders, inspection reports. f. Change order review and approval process. g. Payment review process, including development of payment schedules. h. Where appropriate, distinctions between Corps/State/EPA roles in construction monitoring and O&M activities. i. Use of an EPA approved form or format for formal inspection reports submitted by the Corps. Since the Agency's tie to the project is with the grantee (through the construction grant), and the contract is between the grantee and the contractor, Agency contacts with or influence on the project must be made with or exercised through the grantee or his authorized representative. Direct contact with the contractor by the Inspector or any other Agency representative should be limited to the minimum necessary to gain a full understanding of contract matters. 8. DOCUMENTATION AND PREPARATION: The Inspector will need copies of various grant and contract documents in order to prepare for and conduct interim inspections. Arrangements should be made to obtain, as needed, the following: a. Copies of the grant award documents with all standard and special conditions and amendments. ------- b. Copies of approved contract plans and specifications and all addenda. c. Copies of engineering services contracts. d. Copies of executed construction contracts with com- pleted bid schedule, notice to proceed, and approved change orders. e. Access to all payment requests, including backup documentation. f. Copies of all milestone approval letters and other pertinent grant and contract correspondence. g. Copies of construction permits. 9. INTERIM INSPECTION PROCEDURES; The Inspector should become thoroughly familiar with the project by examining the plans and specifications, the construction grant agreement(s), and other available documents. Due to limited resources, it may not be possible to thoroughly review every aspect of grant and contract management at each interim inspection. On larger projects the Inspector may have to select areas to review at each inspection such that, over the life of a project, all significant aspects of grant and construction management, and construction quality, quantity and initial operability will be covered. However, every effort should be made to look over the entire construction site at each visit. On smaller projects only a total inspection should be considered a complete inspection. ------- -6- The nature of the program also requires that the Inspector become familiar with various engineering disciplines in order to inspect the civil, mechanical and electrical portions of a project. On some larger or more complex projects, it may be necessary to draw on the expertise of specialists within the Agency to assure adequate inspection coverage. Inspections should be coordinated in a timely manner with all interested parties; however, the number of participants should be limited to those having direct responsibility for grant and/or contract management. Keep in mind that the grantee has the ultimate responsibility for the project and all coordination should be through its designated representatives. All inspection activities should be conducted in a courteous and professional manner. In addition to pointing out deficiencies, the inspection should be used to provide assistance (as appropriate) to the grantee in grant related matters. Where the Corps is performing inspections, the State should be notified as provided for in procedures set forth in the Regional Interagency Agreement. Generally, written notice is given to the State at least two weeks in advance of the specific inspection. Provision should also be made for inspections which are not announced to the grantee. The frequency of unannounced inspections will be determined by the Inspector's findings or information brought to his attention. 10. SCOPE OF INTERIM INSPECTIONS; There are three major areas of project management that must be covered during the course of interim inspections. These include: (a) grant management and record keeping, (b) contract administration and (c) con- struction quantity and quality. These items are discussed in detail in Pars. 11-13, below. ------- 11. GRANT MANAGEMENT AND RECORD KEEPING; The grantee has the ultimate responsibility for management of its construction grant. Some grantees handle the entire grant management process with their own forces, while others may utilize the services of their consulting engineer or private accountants and attorneys. The Inspector must first determine the responsibilities and authorities of the various grantee representatives and the location of all files. Generally, grant management files are maintained in the grantee's office and the consulting engineer's office. Construction records will normally be located at the job site. The inspection should ascertain: a. Are authorities and responsibilities for managing the grant adequately defined, and are all aspects of grant management appropriately assigned? b. Are payment requests and funds being properly managed (timely requests and disbursements)? c. Are grant standard and special conditions being met? Milestone activities which are conditions of EPA pay- ments should especially be monitored in advance of the milestone date and the grantee advised accord- ingly. The requirements for most milestone activi- ties vary as the Federal laws and regulations have changed over the years. The Inspector should always check the grant requirements of the particular project being inspected. Typical milestone submittals include: (1) Final plan of operation. (2) Final operation and maintenance manual. ------- —8 — (3) Compliance dates for special grant conditions. (4) NPDES compliance schedules dates. (5) Budget/project period (dates). (6) Initiation of operation date. (7) Performance certification date. (8) MBE/WBE compliance documentation: submittal dates. d. Are grant records complete, segregated, orderly and up-to-date? A review of the grantee's record keeping system should be made during the first interim inspection and may be repeated during later inspections. The purpose of this review is not to audit the contents of the files, but to evaluate the results of advice given during the PMC on the content, methods, and procedures and thus assure that the grantee's filing system will facilitate the final payment, EPA audits and grant closeout. Appendix B contains further discussion of this item and a checklist for review of files. (Provide the grantee with a copy of EPA's Accounting Guide for Construction Grants, 1977). Generally, the requirements of 40 CFR 30.800 and 30.805 include maintaining records which provide an accurate, current, and complete disclosure of the financial transactions of the grant. These records should show the amount, receipt, and disposition of all grant related funds, and the total costs (both direct and indirect) of the project. These records must be maintained in a manner that separates allow- ------- -9- able and unallowable project costs. The Inspector should check to see that the grantee's records fulfill these require- ments. (On large grants, he may wish to enlist assistance from an auditor.) See Appendix C. 12. CONSTRUCTION MANAGEMENT; Resident services and contract management are normally furnished under a service contract by a consulting engineer. Some grantees may perform inspections using their own forces. Appendix D is a checklist of typical items that should be monitored by the Inspector. This is not meant to be all inclusive, and the Inspector should review the requirements of the construction contract documents and the engineering services contract to determine other points of interest. The following items should receive special emphasis during an inspection, since they could significantly impact the overall progress and fiscal status of the grant: a. Progress Charts and Schedules - The contractor is normally required to submit a progress chart to the grantee and keep it current. The Inspector should determine that a progress chart has been prepared for each contract and that it reasonably reflects proposed and actual progress. If it appears that the contrator is behind schedule, the grantee should be notified and advised to take appropriate action to require the contractor to outline his plan to meet the schedule and to require timely completion. All such actions should be carefully documented. (40 CFR 35.2204 (b) (3) requires a formal grant amendment for significant changes to the project schedule.) The grantee should be cautioned not to take any action that could result in a claim for acceleration or for delay of the progress of work. If it appears that the contractor will not complete the work within the ------- -10- required completion date, the grantee should be advised that assessment of liquidated damages as a contract requirement is an option which may be exercised only by the grantee. It should also be stressed that it is in the grantee's interest to assess liquidated damages. EPA will not participate in inspection costs beyond the EPA approved contract completion date unless the time extension is authorized by an approved change order. If the project completion date is delayed, a grant amendment will be required if costs incurred after the initial completion date are to be considered for EPA participation. b. Payment Requests - The grantee's payment requests to EPA should include only that backup documentation required by EPA. Documentation which should be available for review includes the contractor's periodic partial payment request, engineer's invoices, and miscellaneous costs. The Inspector should review the contractor's payment request and compare it to conditions at the job site to assure that the quantities for which payment is being requested generally conform to visual observations of actual progress. This should not be done in minute detail, although the Inspector should develop a tracking system to satisfy himself that the amounts claimed by the contractor on payment requests are reasonably accurate. This would also include verification of any stored materials and change order work claimed on the request. (Change orders must be properly executed and approved by all agencies having authority before EPA reimbursement can be made.) ------- -II- EPA normally permits retainage to be withheld on the contractor's partial payment requests. The Inspector should review the terms of the contract to assure that the specified retainage clause is being properly administered, and, near the end of project, that the grantee is retaining only an amount sufficient to protect its interests in completing the project. The Inspector's review of the grantee's payment request should be coordinated with the overall EPA grant payment review and approval process. Change Orders - Change orders represent a major area of concern in the grants program (Ref.j). The Inspector should be alert to conditions that might give rise to the need for change orders, so he can advise the grantee on how best to proceed, manage costs and facilitate approval. During interim inspections the following areas should be emphasized, particularly with small grantees. (1) Provide advice to the grantee on the need for the proposed change/ as appropriate. (2) Assure that the grantee is processing change orders in a timely fashion, including those for time extensions. (3) Advise the grantee on what is required during the review process on such matters as prior approval, proper format, justification, working estimates, records of negotiation, reasonable pricing, etc. ------- -12- (4) Assure that the resident inspector or engineer has copies of all executed change orders. (5) Become knowledgeable of the facts regarding the change order to assist later in the review pro- cess . (6) If other than a State, the Agency should coordinate with the State. (7) Inspect the completed change order work. d. Claims - A claim is any written demand by the contractor for additional costs or time. Most claims are settled prior to extensive litigation or arbitra- tion and are treated as routine change orders. It is the occasional claim that is not settled that is of special concern to EPA. As in the case of change orders, the Inspector should advise the grantee on matters concerning all claims. The same factors listed in Par. 12.c, above, must be addressed in the processing of claims, with special emphasis on timely and accurate documentation by the grantee. However, when it appears that the contracting parties cannot agree on a mutual settlement, the Inspector should immediately advise the project manager (EPA/State/Corps) that the claim may result in litigation or arbitration. Costs associated with litigating claims may be allowable if the work is determined to be otherwise allowable and the costs were not incurred as a result of grantee mismanagement or errors by its consultant(s). ------- -13- (See Appendix A to Subpart I (40 CFR).) Prior approval and, in some cases, a grant amendment are required for EPA participation in litigation costs associated with claims. A grantee should be advised to contact the project officer for complete details on allowable costs and procedures for handling formal claims. The Inspector should not attempt to engage in negotiations or manage the situation for the grantee. The grantee should be encouraged to perform an independent analysis of the issues and negotiate settlement of those issues which have merit. 13. CONSTRUCTION: Quantity - An important purpose of the interim in- spection is to assure that the project is constructed in accordance with the approved plans and specifica- tions. The Inspector must review the contract documents and develop a system for documenting completed activities. Each interim inspection should address work added since the last inspection and address prior deficiencies. The cumulative effect should be to greatly reduce the total effort on the final construction inspection. Over the life of the project, all significant aspects of the pro- ject should have been covered. The Inspector should keep in mind that much of the work accomplished between inspections will be concealed as the construction progresses and thus not be accessible for inspection. His efforts should be directed more toward the overall project and on major structures, major equipment and operating systems rather than on minor components or details. ------- -14- b. Quality - Responsibility for quality control (QC) may rest with the contractor, the resident engineer, or, as in most cases, a combination of the two. The Inspector should determine from the contract documents the extent of QC responsibility that each party has. Following are items that should be given special attention during the interim inspection: (1) Review the resident inspector's daily reports or diary. Check the reports prepared since the last interim inspection to see what deficiencies may have been noted and what actions were taken (and recorded in the daily log) to correct the deficiencies. (2) Review contractor certified submittals of shop drawings on a selective basis to assure that they meet the requirements of the contract documents. The submittals should be processed by the grantee's engineer* in a timely manner and copies furnished to the resident engineer. (3) Review concrete, soil compaction and other QC tests required by the contract. If any tests failed, determine what action was taken by the resident engineer. (4) Review documentation on performance tests to assure compliance with contract documents. * Engineer accepts, accepts with reservations or requests resubmittal. ------- -15- (5) Make selective field observations, in addition to the overall field inspection, to determine that QC requirements are being carried out. (6) Any deficiencies noted should be reported to the grantee or its representative and included in the trip report. Hazards to public health, safety and welfare should be corrected as soon as possible. 14. FINAL CONSTRUCTION INSPECTION; Although the final construc- tion inspection is considered to be a separately delegable activity by EPA, it is so interrelated with interim inspec- tions that it needs to be addressed in this guidance document. As discussed above, each interim inspection is simply one step toward the final construction inspection. If interim inspections are properly conducted and documented, the final construction inspection should be simply a formality to wrap up loose ends and address any uncorrected construction deficiencies. The Inspector should use his judgment on the necessity for follow-up inspections on construction deficiencies. Major deficiencies may require one or more follow-up inspections, while minor ones should be left for the consulting engineer to certify prior to the construction closeout. Commitments on the time required to correct deficiencies should be obtained. 15. REPORTING; Every interim inspection should be documented with a written report. Formats and procedures may vary according to Regional agreements and Agency policy. As a minimum, each report should address the following: a. Basic grant information. ------- -16- b. Basic contract information. c. Status of grant. d. Status of each contract. e. List of attendees. f. List of deficiencies noted since last report with recommended actions for resolution. g. Comments on status of any previous deficiencies. h. List of known disputes, claims or potential claims or change orders. Any deficiencies that are to be noted on the report are to be discussed with the grantee and engineer during the interim inspection to assure that there is a clear understanding of the matter and what should be done to correct the problem. Grant management procedures for resolution of deficiencies will depend on the status of delegation in each State. Distribution of interim inspection reports will also be subject to Regional agreements. Generally, the State, the grantee and its consulting engineer should be furnished copies. The contractor should not be furnished copies of inspection reports, since it could mistakenly interpret comments as directives that would prejudice the grantee's contracting authority. Reports should be transmitted by letter, the content of which should identify significant findings and/or construction deficiencies. The transmittal letter should be short, concise and able to stand on its own merit. ------- -17- 16. FOLLOW-UP; The Inspector should determine who is responsible for taking various corrective actions and have a system for assuring that the responsibile official(s) is advised and does, in fact, act. ------- APPENDIX A - INSPECTION RELATED FUNCTIONS The following are separately delegable functions that may be per- formed by the Corps, the State, EPA or a combination. Each is closely related to functions performed during interim inspections. The Inspector should review the Regional and State delegation agreements and be familiar with the activities, responsibilities, and authorities (if any) that distinguish each of these functions from those of the related portions of the interim inspection. Some may be accomplished during the interim inspection. 1. Overall grant management. 2. Approval of contract documents and authority to award. 3. Preconstruction conferences. 4. Project Management Conference (PMC). 5. Review and approval of progress payments. 6. Review and approval of change orders. 7. Conventional/extended Construction Management Evaluation (CME). 8. WBE/MBE tracking. 9. Claims resolution assistance. 10. Outlay management. 11. Review and approval of O&M manual and final Plan of Operation. 12. Final project inspection. APPENDIX A Page 1 of 1 ------- -II- APPENDIX B - GRANTEE FILES A well organized and properly maintained filing system is essential to the proper administration of an EPA construction grant. It will also prove to be invaluable during the final audit and closeout of a project. This list of recommendations is not meant to be all inclusive, but serves to point out the typical problem areas experienced by EPA reviewers on past projects. 1. All files for each Step 3 EPA grant should be maintained separately from any other Step 1, Step 2 or Step 2+3 EPA grant. 2. All EPA files should be maintained separately from any other agency files (FmHA, HUD, etc.). 3. All files should clearly distinguish between EPA allowable and unallowable items. 4. All files should be neatly organized by subject matter in separate folders and located in a file cabinet or drawer. 5. Contents of individual folders should be filed in a timely manner and in chronological order. APPENDIX B Page 1 of 2 ------- APPENDIX B - GRANTEE PROJECT FILE TOPICAL SUBJECT LISTING (SAMPLE) Grant Administration Documents Construction Management Records Accounting Source Documents 0 USEPA Grant Offer & Conditions 0 Grant Amendments 0 State NPDES Permit 0 Auth, to Award 0 Interagency Agree- ments 0 Plan of Operation 0 User Charge System 0 Contracts & Sub- agreements 0 Flood Disaster Protection Act 0 Sewer Use Ordinance 0 O&M Manual 0 Davis-Bacon Act Compliance 0 Force Account Approvals 0 EEO, MBE/WBE Requirements 0 Real Property Acquisition Documents 0 Pretreatment Systems 0 Emergency Pre- paredness Plans 0 Maintenance Management Systems 0 Copeland Act 0 As-Bid Construction Contracts 0 Bid Tabs 0 Executed Contract Agreements & Sup- porting Documents Schedule 0 Progress Payments 0 Change Orders 0 Claims 0 Inspection Reports 0 Materials Test Reports 0 Meeting Minutes 0 Correspondence 0 SubmittaIs Logs 0 As-Built Drawings 0 Equipment War- ranties 0 Payment Schedule 0 Outlay Reports 0 Force Account Payroll Records 0 Invoices 0 Property Control Fixed Assets Records 0 Cash Income Re- ceipts 0 Cash Disburse- ments (Cancelled Checks) 0 Construction Dis- bursements 0 Transaction Appro- val Records 0 Bank Statements APPENDIX B Page 2 of 2 ------- -IV- APPENDIX C - GUIDE TO GRANTEE'S COST ACCOUNTING AND INTERNAL CONTROL SYSTEM 1. Does the grantee1s organization provide for separation of responsibilities for operations review from control over financial transactions? 2. Has the grantee established project accounting records to record, on a current basis, all incurred costs applicable to EPA work? 3. Are books and records used to document and control construc- tion fund receipts and cash disbursements? 4. Do the grantee's books and records conform to a uniform accounting system? Are accounting procedures documented? a. Is a general ledger with control accounts used? b. Are subsidiary cost accounts established to segregate project costs? c. Are grant unallowable costs segregated in the grantee's accounting system? d. Does the accounting system differentiate between unallowable and allowable, and direct and indirect costs? 5. Are project costs summarized and reconciled with control accounts contained in the grantee's general ledger? APPENDIX C Page 1 of 2 ------- -V- APPENDIX C 6. Are written approvals given for each step of the disbursements review process? 7. Is appropriate documentation maintained to support all direct charges to the project? 8. Is change order work separately identified in the respective project cost records? 9. Are the project cost records used as the basis for: a. The grantee's "Outlay Report and Request for Reimbursement"? b. The consultant's request for reimbursement? 10. Are the grantee's accounting records subjected to an indepen- dent audit at least once every two years? 11. Are cost and price analyses of contractor proposals carried out in accordance with EPA grant regulations? APPENDIX C Page 2 of 2 ------- -VI- APPENDIX D - CONTRACT ADMINISTRATION CHECKLIST 1. Limits of inspection service provided. 2. Daily inspection report is prepared and adequate; follow-up actions on deficiencies are properly noted. 3. Approved plans and specifications on site. 4. As-built drawings are maintained. 5. Shop drawing register is established and maintained. 6. Progress schedule is posted and current. 7. Contractor's progress is monitored. 8. Stored materials register is established and maintained. 9. Delays are documented and action taken to improve progress. 10. Copies of all executed change orders on site. 11. Project sign located in prominent position. 12. Wage rates and EEO notice posted by contractor. 13. Continuous operation of existing plant assured; bypassing during construction (if applicable) is justified and approved by State Agency. 14. Construction (quality and quantity) conforms to plans and specifications and latest payment request. APPENDIX D Page 1 of 2 ------- -VII- APPENDIX D 15. Materials properly stored and protected. 16. Materials testing is being performed and documented. 17. Performance testing is being performed and documented. 18. Payrolls are submitted weekly and reviewed. 19. Environmental effects mitigation implemented. 20. Required submittals identified, scheduled, coordinated. 21. Claims file established; claims investigations documented. 22. Materials acceptances/rejections documented. 23. Contractor notified of required retesting and/or replacement? 24. Materials testing/replacement documented? APPENDIX D Page 2 of 2 ------- -VIII- APPENDIX E - CONSTRUCTION MANAGEMENT EVALUATIONS (CMEs) AND PROJECT MANAGEMENT CONFERENCES (PMCs) A CME is a thorough evaluation (on-site) of all aspects of project management and is generally conducted when construction is 40% - 60% complete. The CME should be held earlier (20% - 40% stage) if a PMC has not been conducted. The objective of CMEs is to evaluate grantees' management of construction grant projects and, through this process, gain insight into the overall management of the construction grant program as well as into practices which bring about the reduction of waste, fraud and mismanagement of Federal funds. Typically, the on-site CME should be conducted by a three or more member team composed of staff from the EPA Regional Office (who will generally serve as team leader), the State Agency and the Corps. The team leader would be responsible for reviewing grantee records, procurement procedures and grant management procedures in the grantee's office. Reviews by the other team members would be concentrated on the project field records, construction management procedures, and physical construction. A conventional CME is expected to take four or five days to complete. Where larger, more complex projects are involved, an extended CME — with a five to ten day review period — would be required. APPENDIX E Page 1 of 2 ------- -IX- APPENDIX E The Program Management Conference (PMC) is conducted to provide guidance to grantees on record-keeping requirements, construction management techniques and overall grant project management procedures. It is generally one to three days in duration, depending on the capabilities of the individual grantee, and should be conducted before the start of construction on virtually all Step 3 and Step 2+3 projects. The conduct of the PMC is an appropriate function for the Corps or State agency. Normally, it should be held immediately after the preconstruction conference and concentrate on the detailed requirements of construction grant project management. However, in certain cases it may be beneficial to conduct portions of the PMC (records system, accounting system, grant conditions review, etc.) prior to the preconstruction conference. A PMC is not required for projects already under construction. Procedures for conducting CMEs and PMCs are described in the CME manual (REF.K). APPENDIX E Page 2 of 2 ------- |