EPA Publication Number 202K09001
EPA Contract Number EP-W-08-042
TRIBAL, U.S. TERRITORIES AND
INSULAR AREAS ADMINISTRATIVE
AND FINANCIAL GUIDANCE MANUAL
FOR ASSISTANCE AGREEMENTS
"A Nation is a stable, historically developed community of people
who share territory, economic life, distinctive culture, and language."
Off ice of Environmental Justice, U.S. EPA
U.S. Environmental Protection Agency
Updated August 2013
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This manual was originally developed by the U.S.
Environmental Protection Agency for Tribal Nations, but
content also pertains to U.S. Territories and Insular Areas.
Exception: U.S. Territories and Insular Areas are treated
as states under Part 31 (and also under Part 35, Subpart A
for PPGs, unlike Tribes that are covered under Subpart B).
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Contents
CONTENTS 3
INTRODUCTION: LEARNER TIPS 7
TRAINING 7
MATERIALS 7
Activities Booklet 9
Qwizdom Actionpoint 9
MODULE 1: HOW IT ALL STARTS: THE GRANT APPLICATION PROCESS 12
THE GRANTS MANAGEMENT PROCESS 12
The Manual 12
EPA COOPERATIVE ASSISTANCE AGREEMENTS 13
THE GRANTS APPLICATION PROCESS 18
THE APPLICATION PACKAGE 19
Competitive Grants 19
THE TRIBAL NATION AND EPA ROLES 48
ATTACHMENT TO MODULE 1 51
Answers to Quizdom Actionpoint Questions 51
MODULE 2: ASSISTANCE AGREEMENTS 54
PRELIMINARY INFORMATION 54
THE AWARD 56
MANAGING THE PROCESS 58
APPLICATION AND REVIEW PROCESS 61
Assistance Agreement Awards 61
TERMS AND CONDITIONS 64
Administrative 64
Programmatic 64
High Risk 64
REPORTING AND MONITORING 66
Reports 67
Closeout Letter 67
Retention 67
ATTACHMENT TO MODULE 2 69
Answers to Quizdom Actionpoint Questions 69
MODULE 3: FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA) 72
OVERVIEW 72
REPORTING 76
IDENTIFICATION REQUIREMENTS 78
THE REPORTING SYSTEM 83
ATTACHMENT TO MODULE 3 93
Answers to Quizdom Actionpoint Questions 93
MODULE 4: GRANTS MANAGEMENT SYSTEMS 95
REQUIRED SYSTEMS 95
Standard Industry Classification (SIC) codes 97
SYSTEMS IMPLEMENTATION 98
INTERNAL REVIEW AND APPROVAL PROCESSES 100
Administration 101
Grants Management. 101
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Finance 102
Accounting 102
Human Resources 103
ORGANIZATIONAL POLICIES AND PROCEDURES 104
Organizational Chart 104
Documentation Process 105
Internal Controls 106
ATTACHMENT TO MODULE 4 108
Answers to Quizdom Actionpoint Questions 108
MODULE 5: ADMINISTRATIVE SYSTEM COMPONENTS Ill
ADMINISTRATIVE SYSTEM COMPONENTS ill
Personnel Ill
The Payroll Process 112
Benefits 114
Travel 119
PROCUREMENT AND PURCHASING 122
Price and Cost Analysis 127
Property Management System 130
COST SHARING, MATCHING, AND IN-KIND CONTRIBUTIONS 133
Cost Share 133
Match 133
In-Kind Contributions 136
Documentation 136
Waivers 137
RECORDS MANAGEMENT AND RETENTION 138
ATTACHMENT TO MODULE 5 140
Answers to Quizdom Actionpoint Questions 140
MODULE 6: FINANCIAL SYSTEM REQUIREMENTS 143
FINANCIAL SYSTEM REQUIREMENTS 143
FINANCIAL POLICIES AND PROCEDURES 144
ACCOUNTING PROCESSES 147
FINANCE TRACKING 149
Flexible accounting system 149
Chart of accounts 150
Document reference numbering system 150
GeneralJournal 150
General Ledger 151
FINANCIAL REPORTING 153
Financial Status Reports 157
ATTACHMENT TO MODULE 6 164
Answers to Quizdom Actionpoint Questions 164
MODULE?: ACCOUNTING POLICIES AND PROCEDURES 167
ACCOUNTING PERSONNEL 167
ACCOUNTING REQUIREMENTS 167
INTERNAL CONTROLS 168
DOCUMENTATION 170
BUDGET CONTROLS 171
Real Property 173
Equipment 173
COST PRINCIPLES 175
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Reasonable, Allocable, and Allowable Costs 175
Management Fees 178
Direct vs. Indirect Costs 178
Direct Costs 180
Indirect Costs 180
Financial Management Process 182
Enrollment Process for EPA-EFT. 184
CASH MANAGEMENT 184
ATTACHMENT TO MODULE 7 190
Answers to Self-Assessment Questions 190
MODULE 8: SOURCE DOCUMENTATION FOR PROCUREMENT AND PURCHASING 192
CRITICAL COMPONENTS OF ALLOWABLE COSTS 192
EXPENSING 193
Payroll 193
Travel authorization 195
Travel voucher 195
THE PROCUREMENT SYSTEM 196
THE PROCUREMENT/PURCHASING PROCESS 200
Examples of policies 200
Purchase orders and request forms 201
TRACKING DBEs 202
COST SHARING AND VALUATION 203
Cost sharing 203
Valuation of donated services 203
Valuation of donated supplies 204
CONFERENCES 205
ATTACHMENT TO MODULE 8 207
Answers to Self-Assessment Questions 207
MODULE 9: DISADVANTAGED BUSINESS ENTERPRISES (DBES) 209
OFFICE OF SMALL BUSINESS PROGRAMS (OSBP) 209
DISADVANTAGED BUSINESS ENTERPRISES (DBEs) 211
Six GOOD FAITH EFFORTS 213
Bidders List 216
DISADVANTAGED BUSINESS ENTERPRISE (DBE) CERTIFICATION 217
DISADVANTAGED BUSINESS ENTERPRISE (DBE) REPORTING 221
Contract Administration 232
FAIR SHARE OBJECTIVES 233
Negotiation 235
Adoption 237
Analyze the Market 239
Submit the determined fair share objectives 242
ATTACHMENT TO MODULE 9 245
Answers to Self-Assessment Questions 245
MODULE 10: ASSISTANCE AGREEMENT MONITORING AND CLOSEOUT 248
WORKING TOGETHER 248
Compliance Checklist 248
THE MONITORING PROCESS 252
AUDITING ASSISTANCE AGREEMENTS 253
EPA Audits 253
Internal Audits 253
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External Audits 255
CLOSEOUT REQUIREMENTS 259
RECORDS RETENTION 262
CONCLUSION 264
ATTACHMENT TO MODULE 10 265
EPA Administrative and Financial Onsite Review Questionnaire 265
Answers to Self-Assessment Questions 278
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Introduction: Learner Tips
Introduction: Learner Tips
Tribal, U.S. Territories and
Insular Areas Administrative and
Financial Guidance for
Assistance Agreements
Learner Tips:
Introduction to Learning Materials
and QuiidamActionpoint
Interactive System
Training
How will training help?
EPA training can help grant recipients manage
assistance agreement awards. Learn about grant
requirements and EPA expectations. Learn how to
manage an entire program, manage a specific piece
of the project, or refresh understanding of specific
tasks.
Grants management can be complicated. Get
training; it makes your job easier.
Training
Learn to:
° Manage EPA assistance agreement awards
" Comply with federal regulations
Contact your:
EPA Regional Grants Administrative
Office
EPA Regional Disadvantage Business
Enterprise (DBE) Coordinator
EPA Regional Grants Specialist (GS)
EPA Project Officer (PO)
When should people take the training?
Take the training before applying for an assistance
agreement award. If you already have an award,
sign up for training now. Regulations change; stay
informed.
Who should attend training?
ALL Tribal Nation or Consortia personnel
involved in EPA assistance agreement award
management should attend training, including but
not limited to:
The authorized certifying officials (i.e.,
those responsible for signing the
documents)
Department heads
Human resource managers
Local grant mangers
Managers of award proj ects
Finance and accounting staff
Office and bookkeeping staff
Office and bookkeeping staff should attend the
training if at all possible. Low cost and free sources
of training are available. Contact your EPA
regional office for training options.
Where can people get training?
Training sessions are offered in traditional face-to-
face workshops and conference settings. Training
is also offered online as individual web-based
training modules. Ask a Grants Specialist (GS) or
Project Officer (PO) for the program and location
that is right for you.
Materials
Manual
Appendix
Materials
What is included in the training?
Training includes a Manual with ten instruction
modules taught by Grants Management Specialists.
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Introduction: Learner Tips
Trainees receive an Appendix with examples of
forms and tools for managing an assistance
agreement award according to EPA regulations and
requirements.
Why is a training manual necessary?
The purpose of the training Manual is to help
Tribal Nations and EPA work together. The
manual explains what an assistance agreement
award is and how to manage one.
After completing the training learners should more
fully understand:
The assistance agreement award
Which regulations apply to an assistance
agreement award
How to administer an assistance
agreement award
How to financially manage an assistance
agreement award
The roles and responsibilities of both EPA
and the Tribal Nation
How to comply with:
Financial, accounting, and administrative
requirements
Cost principles
Regulations
"Terms and conditions"
The training Manual is designed to assist Tribal
Nations in the administrative and financial areas
when applying for assistance agreements, as well
as for tracking and reporting on the financial status
of work performed under those agreements. The
Manual is an excellent desk reference when
questions come up and you need answers fast. It
contains forms, sample narratives, instructions, and
answers to frequently asked questions.
What is in the Tribal Administrative and Financial
Guidance Manual for Assistance Agreements?
The Manual provides a set of standard operating
policies and procedures to guide administrative and
programmatic staff, Tribal Leaders and oversight
committees through the decision making process.
These guidelines are NOT intended to replace or
restrict the sovereignty of Tribal Nation.
Grants management training helps Tribal
administrators work effectively with EPA.
Assistance agreement award projects are easier to
manage when everyone understands the process.
This manual describes how the assistance
agreement award process works.
The Tribal Administrative and Financial Guidance
Manual for Assistance Agreements and training
program consists often (10) modules explaining:
1. The grant application process
2. Assistance agreements
3. Federal Funding Accountability and
Transparency Act
4. Grants management systems
5. Administrative system components
6. Financial system requirements
7. Accounting policies and procedures
8. Source documentation for procurement
and purchasing
9. Disadvantaged business enterprises
(DBEs)
10. Assistance agreement monitoring and
closeout
Learner Notes
Review the Manual Contents, so you
know how to find the information you
need when you need it.
What is in the Appendix?
The Appendix contains official EPA documents
and best practice examples. Most of what a Tribal
Nation might need to manage an assistance
agreement award is provided in either the Manual
or the Appendix.
See the manual's Appendix for:
Official forms
Applicable regulations
Glossary of terms
List of common acronyms
List of useful web sites
Sample policies and procedures
Federal rules and regulations
And much more...
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Introduction: Learner Tips
Learner Notes
Examine your copy of the Appendix, so
you know where to find documents
when they are explained.
Activities Booklet
What is the Activities Booklet?
Activities to help you better understand the
information learned in each Module can be found
online at www.petetribal.org in the Activities
Booklet. These Activities are designed to help you
apply the concepts you have learned throughout
this manual to your own organization.
Quizdom Actionpoint
MENU -On/Off
SEND
T,4 Clear
Answer Buttons
Qwizdom Actionpoint
How does Qwizdom work?
Face-to-face training sessions use an interactive
system for answering questions. All answers are
anonymous. There are no names associated with
any of the answers. No one will know how you
answered a question except you.
The instructor and data collection system group
answers together. This lets the instructor know how
well the information is being understood. Please
answer honestly.
Each trainee should receive a handheld Remote.
Use this Remote to answer questions during the
training. The instructor will prompt you when it is
time to answer a question.
How does the Remote work?
Wait until the instructor tells you to turn on the
Remote. Each presentation requires a short
initiation period to prepare the system for data
collection.
Turn the Remote on by pressing the MENU button.
The MENU button is just under the
screen on the left.
You may need to hold it down for
several seconds.
When you see the word QWIZDOM
appear on the Remote's screen, the
system is ready to use.
When it is time to answer a question, a list of
options will appear on the Remote's screen.
There is a two-step process for answering a
question:
First, press the button that
corresponds to your answer.
Yes and True answers use the button
marked with YES and T.
No and False answers use the button
marked with NO and F.
Answer A by pressing button number
1.
Answer B by pressing button number
2.
Answer C by pressing button number
3.
Answer D by pressing button number
4.
Answer E by pressing button number
5.
Second, press the SEND button.
The SEND button looks like two
arrows facing in different directions
and is located just below the MENU
button.
Once your answer is selected and sent to the
system, you will see either a checkmark (V) or an
* on the Remote's screen.
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Introduction: Learner Tips
The S means your answer is correct.
The * means your answer is
incorrect.
S and * means the answer was
received.
If the instructor has enabled this functionality, you
may choose to change your answer, if you wish.
You can only change an answer if the
instructor has not yet moved ahead in
the presentation to the answer slide.
To change an answer:
Press the CLEAR (C) button located
just under the screen on the right.
The answer options should again
appear on the Remote's screen.
Press the button with your new choice
and then the SEND button.
Again a ^or x will appear on the
Remote's screen.
Only your last answer will be
recorded by the system.
You should not need to use the forward or
backward arrow buttons.
To reset the Remote:
Press the MENU button until the
screen goes dark.
Press the MENU button again until
you see the word QWIZDOM.
Use your Remote to answer the following
questions.
Where in the Manual is tfie
Disadvantaged Business Enterprise
(DBE) program covered in detail?
A. Module 7
B. Modules
C. Module 9
D. Module 4
E. All of the above
Where in the Manual is the
Disadvantaged Business Enterprise
(DBE) program covered in detail?
A. Module 7
B. Modules
C. Module 9
D. Module 4
E. All of the above
(&'
'-
Explanation
Module 9: Though the DBE program is referenced
in several modules, it is covered in detail in
Module 9.
That's fine. Let's try another question just to be
sure we've got it figured out.
Let's test the Qwizdom process.
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Introduction: Learner Tips
Does the Appendix contain everything
a grantee needs to know?
A. Yes
B. No
Introductions
Name
Position
Role on your grants managementteam
Does the Appendix contain everything
a grantee needs to know?
A. Yes
B. No
Introductions
Please introduce yourself to the other learners. Tell
them your name, position, and role on your grants
management team.
For example:
Jane Juniper
Office Manager for the Wide River Indian
Community
Financial Officer for the Water Reclamation and
Irrigation Project
Great, everyone is ready to begin the training.
Explanation
The Appendix provides documents and examples
for assistance award management It cannot
possibly hold everything a grantee may need to
know. Regional EPA office personnel can answer
questions about specific awards and individual
circumstances.
Working with EPA isn't something Tribal Nations do for the government;
it is something they do for themselves.
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Module 1: How It All Starts: The Grant Application Process
Module 1: How It All Starts: The Grant Application Process
Tribal, U.S. Territories and
Insular Areas Administrative and
Financial Guidance for
Assistance Agreements
Module i:
How It AD Starts:
The Grant Application Process
i
Terms
Assistance Agreement
Award
Cooperative Agreement
Grant
The Grant Application Process
The Grants Management Process
There are four essential components to the
management of Environmental Protection Agency
(EPA) assistance agreement awards:
1. Startup - the application and review
process
1. Management Systems -
administrative and financial system
requirements
3. Financial Systems - accounting
policies and procedures
4. Closeout - Disadvantaged Business
Enterprise (DBE), monitoring and
closeout requirements
The Manual
The manual contains ten modules explaining how
each process works. It describes Environmental
Protection Agency (EPA) and Tribal Nation roles
and responsibilities.
In this manual, the terms assistance agreement,
cooperative agreement, award, and grant are
used interchangeably meaning federal funds
provided to a Tribal Nation for an agreed upon
purpose.
"Grants" is a universal term for both grant and
cooperative agreement whether the term refers to a
"grant recipient" or "grant award".
Eighty percent (80%) of knowledge is knowing
where to find the information.
Learner Notes
Examples of policies and quotes from
regulations are provided to help learners
develop their own policies. Also note that
examples are fictional; any similarity to
existing entities is purely coincidental.
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Module 1: How It All Starts: The Grant Application Process
EPA Cooperative Assistance
Agreements and Grants
EPA Authorized and Funded to Award Grant
EPA Cooperative Assistance
Agreements
What kinds of grants are available?
EPA offers two types of grants:
1. Non-competitive
2. Competitive
Non-Competitive
Applicants Select Opportunity
Applicants Apply
from EPA headquarters to regional offices and do
not require formal requests for proposals (RFPs).
For more information on non-competitive grants
visit the American Indian Environmental Office
(AIEO) website at
http://www.epa.gov/tribalportal/grantsandfunding/gap.ht
m. For more information on State and Tribal Grants
(STAG) visit
http://www.epa.gov/compliance/state/grants/index.html.
Competitive
Applicants Select Opportunity
Competitive
There are many competitive grants also available to
Tribal Nations. EPA encourages Tribal Nations to
take advantage of more funding opportunities
beyond the familiar non-competitive program
options. This Manual and training program are
designed to help Tribal Nations locate, apply for
competitive grants, and manage all types of
grants.
Non-competitive
Most Tribal Nations are familiar with non-
competitive grants, such as Indian General
Assistance Program (GAP or IGAP) grants to
federally-recognized Tribes and Tribal Consortia
for planning, developing, and establishing
environmental protection programs in Indian
country, as well as for developing and
implementing solid and hazardous waste programs
on Tribal lands. Other common non-competitive
grants are the Multimedia State and Tribal
Assistance Grants offered through the State and
Tribal Grants (STAG) program. These grants help
Tribal Nations build capacity to carry out
compliance assurance activities.
Discussion
How do you get funding?
Have you ever applied for and
received a competitive grant?
Non-competitive grants may constitute as much as
90 percent of a Tribal Nation's budget. Funds flow
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Module 1: How It All Starts: The Grant Application Process
The Birth of an Idea
For the t T.S. Environmental Protection Agency
(EPA) to announce an assistance agreement
opportunity, EPA must:
Be aulht >ri/ed by lu\v to filter inli > an agreement ti i
accomplish a task or objective.
° Have funds available to pay for the desired
environmental improvements established in the
law.
How does EPA determine which grants to offer?
In order for the U.S. Environmental Protection
Agency (EPA) to announce an assistance agreement
(i.e., grant) opportunity, it must first:
Be authorized by law to enter into an
agreement to accomplish a task or objective.
Have funds available to pay for the desired
environmental improvements established in
the law.
EPA develops programs to achieve specific
environmental goals. Those programs are funded
by the United States federal government. Specific
funding opportunities are offered to government,
education, public housing, non-profit, and for-
profit organizations as well as small businesses and
individuals. Native American Tribal Governments
and Intertribal Consortia are eligible as government
organizations for many assistance awards. This
manual provides guidance for Tribes eligible for
assistance awards as Federally Recognized Tribal
governments or as eligible Intertribal Consortia. In
some cases, Tribal organizations may be eligible
for assistance awards as non-profit organizations.
EPA provides funding opportunities for limited
periods of time to achieve specific purposes. An
applicant's project must address tasks or objectives
essential to the achievement of an established EPA
goal, like General Assistance Grants (GAP or
IGAP awards).
EPA Funding Announcements
Domestic Assistance
How does EPA promote competitive assistance
award programs?
After Congress authorizes and appropriates funds
for an assistance agreement program, EPA
Headquarters initiates the program's application
process by listing:
Programs in the Catalog of Federal
Domestic Assistance
Funding opportunity announcements at
Grants.gov
EPA regional program offices receive guidance
information from EPA national headquarters.
Some regional offices mail the funding
announcement to notify potential applicants. The
EPA program office coordinates any mailing of
funding announcements with the EPA Grants
Management Official. These procedures may vary
somewhat by region.
The funding announcement includes specific
instructions on:
Funding availability
Completing work plans and budgets
EPA program partners and contact
information
The deadline for submitting the assistance
agreement application
A good practice is to check the regional website,
check with regional office personnel for updates,
and be vigilant about checking Grants.gov. This
website makes it easy to find competitive grant
opportunities, many of which you may not have
considered before.
A Tribal Nation should regularly check out opportunities at Grants.gov.
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Module 1: How It All Starts: The Grant Application Process
How do we find a grant program that funds our
type of project?
The Catalog of Federal Domestic Assistance
(CFDA) is a government-wide collection of federal
programs, projects, services, and activities that
provide financial assistance or benefits to the
American public. The catalog contains information
about financial and nonfmancial assistance
programs administered by all federal agencies, not
just EPA.
The primary purpose of the catalog is to assist
potential applicants in identifying programs, which
meet specific objectives and list the criteria
required to obtain a grant. You may download a
copy of The Catalog of Federal Domestic
Assistance at https://cfda.symplicity.com/.
CFDA Program Descriptions
EPA funding program listings start \vith number 0>6.
Agency Name / CFDA* Agenc\Program
Environmental Piotection 4ency 66Q01 EPA Vii Pollution
I 66Jla EPA Etale Indool
1 SSJ23 EPA fnont T(an:
^ 6j£3j EPA f Surveys Sll
TWe
Contiol Piogiam Support
Radon Gfants
nsport Comrmsaion
Sufveys Studies Research Investigate
What kind of information is listed in the CFDA?
The catalog is organized by government agency,
and the EPA's catalog listings start with number
66.
When you have located a potential assistance
program for which you would like to receive more
information, locate the assistance program with
that CFDA number for a full description.
CFDA listings provide information on:
Objectives
Types of assistance
Uses and restrictions
Applicant eligibility
Beneficiary eligibility
Credentials/documentation
Pre-application coordination
Examples of funded projects
Eligibility
Federally recognized Tribal Nations are eligible
for many competitive grants.
Non-federally recognized Tribal Nations are also
eligible for some competitive grants.
Read the applicant eligibility paragraph
very closely.
Only apply to programs tor which the Tribal
Nation is eligible.
How do we know if we are eligible for a
program?
Tribal Nations are eligible for many grant
programs. View a list of EPA programs for Tribes
at
http://www.epa.gov/tribalportal/grantsandfunding/topics.
htm.
Both CFDA listings and Grants.gov
announcements contain applicant eligibility
paragraphs explaining who is eligible to apply for
funding under a specific grant program. Tribal
Nations are eligible to apply for some funding
opportunities that are not specifically established
for Tribes. Some of the funding programs may be
restricted to non-profits, hospitals, or institutions of
higher education.
For example, there is a lot of research
money available, but generally universities
are the only applicants eligible. If you have
a research project in mind, EPA suggests
you partner with a university.
A Tribal Nation must read the applicant eligibility
paragraph very closely so that they only apply to
programs for which they are eligible.
Non-federally recognized Tribal nations
are eligible for some grants.
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Module 1: How It All Starts: The Grant Application Process
How do we find a specific funding opportunity?
The Internet web site, Grants.gov lists most federal
grant opportunities. The "Advanced Search"
feature allows you to search by eligibility category.
Download an application at Grants.gov in response
to a funding opportunity announcement, complete
the form, gather the application materials, and mail
or email the application package to EPA. Track
your application through the review process on
Grants.gov.
Grants.gov is a website that helps grant applicants
to:
Find grant opportunities
Apply for grants
Track the application through processing
Receive answers to their questions
The funding announcement should contain an
overview, which includes the CFDA number and
other basic information. Eligible applicants need to
follow directions very carefully, as each funding
opportunity is unique. A responsible person,
designated or approved by a Tribal Nation's
governing body, needs to follow the instructions
included in the funding announcement. The
applicant must submit all required documents
within the time frames specified in the Grants.gov
listing. Any questions that arise can be answered
by the EPA contact person listed in the funding
announcement.
Learner Notes
Take a little time to visit http://grants.gov
and do Activity l.a. Activities are located
online at www.petetribal.org. These
exercises will help you to understand what
is presented and find key information later
when it is needed most.
Types of Competitive Grants
RTA Request for the Full Application
No final application is needed after selections ;ltv made.
RFP Request for Proposals
RFPs require an initial application proposal.
n After tin- applicant's proposal is selected a final application
is completed.
RFIP Request For Initial Proposals
An initial proposal is submitted and selected.
A fin.il proposal is siilunilledfora second selei tion process,
0 The seleetetl applicant must snl unit a final application.
There are three different types of competitive
grants:
1. RFA is a request for the full application.
No final application is needed after
selections are made.
2. RFP is a request for proposals. RFPs
require an initial application proposal.
After the applicant's proposal is selected a
final application is completed.
3. RFIP is a request for initial proposals. An
initial proposal is requested, selected
applicants are invited to submit a final
proposal. Final proposals undergo a
second selection process, and the selected
applicant must submit a final application.
CFDA is where you can find out about
general assistance programs.
Grants.gov is where you find out about
specific funding opportunities.
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Module 1: How It All Starts: The Grant Application Process
Select a Grant Opportunity
Accepting an EPA grant legally binds the
recipient to:
° IIse funds in the manner pr< >piised,
c Achieve the < ibjectives listed in the proposal, and
c Comph with federal regulations and award "terms
and conditions",
° To the best of their ability within the specified
lime period.
Which is the most reliable method for
locating available funding opportunities?
A. Catalog of Federal Domestic Assistance
B. Website "Grants.gov"
C. Funding announcement received by mail
D. Contacting F.PA headquarters or a regional
office
E. All of the above are correct.
!*!
m
Reflection
Consider your own situation.
How does your Tribal Nation learn
about available award programs?
Online at CFDA
Online at Grants.gov
Mailed funding announcement
Emailed funding announcement
What are the benefits and
drawbacks to each method?
Which method do you prefer and
why?
How does your Tribal Nation
determine which funding
opportunity to apply for?
Learner Notes
Use the Qwizdom system to answer a
question whenever you see the checkmark
symbol.
How do we know if the Tribal Nation is
eligible to apply?
A. As long as you don't use the money to lobby
government, you are eligible.
B. Check the applicant eligibility paragraph.
C. EPA will contact you if you are not eligible for
an award.
D. Tribal Nations are considered eligible as
nonprofit organizations.
E. All of the above are correct.
*J
The Grants Application Process
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 1: How It All Starts: The Grant Application Process
The Grants Application Process
How do we get an application kit?
Grants.gov funding announcements are how the
public learns about federal assistance opportunities.
An application kit includes all of the blank forms
an applicant might need to fill out when applying
for a grant.
Some EPA Regional Offices may mail
announcements directly to Tribal Nations. These
mailings come to the Nation as "requests for
proposals and applications" accompanied by
guidance on what is to be included in the
application package. Complete a request form, mail
it to your EPA regional office, and they will mail
you an application kit.
The grant application process and necessary forms
are explained online at
http://www.epa.gov/ogd/forms/fonns.htm. Application
kits are available from your EPA regional office or
online at http://www.epa.gov/ogd/AppKit/index.htm.
Sample forms are provided in the Appendix to this
manual.
You will need Internet access to work
effectively with EPA.
Four-fold Process
l. Select an assistance agreement.
2. Complete the required forms.
3. Write narrative statements that explain the
purpose to \vhieh you propose to put the
requested funds.
4. Create a detailed itemized budget for the
proposed project, if required.
How does the grant application process work?
The grant application process requires an applicant
to file official forms. EPA regional offices may
require additional forms. To be considered, a Tribal
Nation must meet the same requirements as any
other applicant. Applications are reviewed
according to the criteria specified in the Grants.gov
funding announcement.
The application process is four-fold:
1. Select an assistance agreement.
2. Complete the required forms.
4.
Write narrative statements that explain the
purpose to which you propose to put the
requested funds.
Create a detailed itemized budget for the
proposed project, if required.
The figure below lists the four components of the
application process and the documentation most
often requested. If applying for a competitive grant,
the SF 424 and narrative work plan may be all that
are required for the competitive process with other
forms requested after you are selected.
The funding opportunity you select may or
may not require these forms.
Read the announcement carefully.
Responsibilities Timeline: Application
Startup Manaiemerrt | dowout
report*
-M.nM.iiii
IW.K.M..I rl
lutwl ti.msfpfi number of
Mllnilll tlll.ll V?*U ^ HMKl
lhi.Wl.ll -.Mill-, (rvpllaBv
repom J-Wi
What is our role in the application process?
Applying for and administering assistance
agreements requires a Tribal Nation to have
policies and procedures in place to control the
grants application and management processes from
the time of the initial response, to EPA's program
announcement, through the final closeout of an
assistance agreement award. EPA does not
consider applications that arrive after the deadline
listed in the funding announcement.
When applying for awards, written grants
management policies and procedures ensure
compliance with:
Tribal Nation laws or administrative
requirements
Federal laws, regulations, or cost
principles
EPA program objectives
Grant application requirements
"Terms and conditions" after the award is
made
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
tast Updated April 2013
Page 18 of 279
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Module 1: How It All Starts: The Grant Application Process
The information presented in this manual includes
policies and procedures Tribal Nations need to
have in place to fully comply with financial and
administrative requirements when applying for
and/or accepting federal funds on any EPA
agreement. (Examples and explanations of policies
and procedures are provided throughout this
Manual and in the Appendix)
Don't let this happen to you.
The Application Package
What goes into an application package for
review?
The application package includes all of the
completed forms that the applicant sends to EPA
when applying for a grant. In order for a Tribal
Nation to receive assistance funds, they must go
through the application process.
Submit application materials on time!
Submission of Applications
Competitive grants may require submission of
Two separate application packages for
° Two separate review processes
i. Competitive proposal application and
2. Final application package
Look in the Funding Announcement for a list of
the required components.
What is the most important requirement of EPA's
competitive grant application process?
A. Define the "terms and conditions" of the award.
B. File financial reports.
C. Sign and date official forms.
D. Submit application materials on time.
E. All of the above are correct.
The Grants Application Process
Competitive Grants
You may have to submit two separate application
packages for two separate review processes
(competitive proposal application and final
application package). Competitive grants may
require submission of an initial and a final
application package. Look in the Request for
Proposal (RFP) for a list of the required
components.
Section IV contains proposal format and
content information.
Section V describes the criteria your
application will be evaluated against during
the competitive review process.
The application/proposal review is
conducted (in most cases) by a review panel.
o If selected:
The package will be sent to a
Project Officer and Grants
Specialist for review before the
award is offered.
OR
You may be asked to submit the
final application package to the
Project Officer and/or Grants
Specialist for further review.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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Module 1: How It All Starts: The Grant Application Process
EPA Headquarters and Regional Offices may
require additional items be included in the
application package. Additional requests are
necessary to accommodate variations in programs
and unique regional situations.
Tribal Nations must fill out the application
prepared by their EPA regional office.
The Application Package:
Typically Required Forms
''Standard Form 424
''Standard Form 424A or C (budget)
'Standard Form 4246 or D (assurances)
'EPA Form 4700-4
^ Narrative statement or work plan ^jj,«
''Detailed itemized budget
Which forms will we need?
Each application package contains standard forms
and certificates to be filled out. Forms and
materials required to apply vary from
announcement to announcement, so you should
check the funding announcement for specific
requirements.
Typical items that may be required in an
application for an EPA assistance agreement award
include:
Standard Form (SF) 424
Dun & Bradstreet, Data Universal
Numbering System (DUNS) number
Standard Form (SF) 424A or C (Budget)
Standard Form (SF) 424B or D (Assurances)
EPA Form 4700-4: Pre-award Compliance
Review Report
Narrative statement or work plan
Detailed itemized budget
Other forms may be required by the EPA
regional office, if applicable:
Environmental Impact Statement
(EIS) or Environmental Assess (EA)
Quality assurance narrative statement,
Biographical sketch of key personnel,
optional but recommended
Anti-Lobbying Form, if more than
$100,000 in federal funds are
awarded, required by some regional
offices (no longer required by federal
law)
Components of the work plan will
vary from program to program.
Copy of the negotiated indirect cost
rate agreement (if the Tribal Nation is
using an indirect cost rate)
Key contacts list, optional but highly
recommended
The above components are described in greater
detail in the sections that follow. Application
package examples are provided in the Appendix.
Standard Form 424
Standard Form (SF) 424 is the "face page" of the
EPA Application for Federal Assistance.
Page 3, Section 21 must contain the original
signature of the Tribal Nation's authorized
certifying official.
n Tribal official authorized t< > enter into legally
binding contracts
SF 424 (continued)
Section 21 must he signed by the Authorized Certifying (tfficial.
xv&r with *i* inuRlng 1* TO * I ttctfi
» EMrumn. tu i. Cod*. TIM *1
What purpose does Standard Form 424 serve?
Standard Form (SF) 424 is the "face page"
(summary) of the EPA application for federal
assistance. SF 424 is a six page document. Page
three (3) must contain the original signature of the
Tribal Nation's authorized certifying official (that
is the Tribal Nation's designated official authorized
to enter into legally binding contracts). Fill in each
section carefully. If a section does not apply to
your project, write NA in the space provided.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 1: How It All Starts: The Grant Application Process
OMB Number: 4040-0004
Expiration Date: 03/31/2012
Application for Federal Assistance SF-424
* 1. Type of Submission:
r~ Preapplication
|~~ Application
P Changed/Corrected Application
' 2. Type of Application:
New
[~~ Continuation
~ Revision
' If Revision, select appropriate tetterts
Other (Specify)
' 3. Date Received:
4. Applicant Identifier
Sa. Federal Entity Identifier.
1 5b. Federal Award Identifier:
State Use Only:
6. Date Received by State:
7. State Application Identifier:
8, APPLICANT INFORMATION:
* a. Legal Name:
* b. Employer/Taxpayer Identification Number {EIN/TIN.}:
* c. Organizational DUNE
d. Address:
' Street!:
Street2:
City:
County:
' State:
Province:
* Country:
" Zip / Postal Code:
e, Organizational Unit:
Department Name:
LJ'iv s on Name:
f. Name and contact information of person to be contacted on matters involving this application:
Prefix:
Middle Name:
* Last Name:
Suffix:
' First Name:
Title:
Organizational Affiliation:
* Telephone Number
Figure 1: SF 424 page 1
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013 Page 21 of 279
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Module 1: How It All Starts: The Grant Application Process
Application for Federal Assistance SF-424
9. Type of Applicant 1: Select Applicant Type:
Type of Applicant 2: Select Applicant Type:
Type of Applicant 3: Select Applicant Type:
' Other (specify):
* 10. Name of Federal Agency:
11. Catalog of Federal Domestic Assistance Number:
CFDA Title:
' 12. Funding Opportunity Number:
' Title:
13. Competition Identification Number:
14. Areas Affected by Project (Cities. Counties. States, etc.):
' 15. Descriptive Title of Applicant's Project:
Attach supporting documents as specified in agency instructions.
Figure 2: SF 424 page 2
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013 Page 22 of 279
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Module 1: How It All Starts: The Grant Application Process
Application for Federal Assistance SF-424
16. Congressional Districts Of:
* a. Applicant * b. Program/Project
Attach an additional list of Program/Project Congressionaf Districts if needed.
17. Proposed Project:
* a. Start Date: * b. End Date:
18. Estimated Funding (S):
* a. Federal
b. Applicant
* c. State
* d. Loca
' e. Other
* f. Program Income
' g. TOTAL
* 19. Is Application Subject to Review By State Under Executive Order 12372 Process?
f~ a. Tliis application was made available to the State under the Executive Order 12372 Process for review on
|~~ b. Program is subject to E,O. 12372 but has not been selected by trie State for review.
F c. Program is not covered by E.O. 12372.
* 20. Is the Applicant Delinquent On Any Federal Debt? (If "Yes", provide explanation.) Applicant Federal Debt Delinquency Explanation
|O Yes r No
21. 'By signing this application, I certify (1) to the statements contained in the list of certifications" and (2) that the statements
herein are true, complete and accurate to the best of my knowledge. I also provide the required assurances'* and agree to
comply with any resulting tenns if I accept an award. 1 am aware that any false, fictitious, or fraudulent statements or claims may
subject me to criminal, civil, or administrative penalties. (U.S. Code. Title 218. Section 1001)
Q " I AGREE
** The list of certifications and assurances, or an internet site where you may obtain this list, is contained n the announcement or agency
specific instructions.
Authorized Representative:
Prefix: * First Name:
Middle Name:
* Last Name:
Suffix:
Title:
* Telephone Number Fax Number:
' Email:
* Signature of Authorized Representative: * Date Signed:
Figures: SF 424 page 3
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 1: How It All Starts: The Grant Application Process
Application for Federal Assistance SF-424
' Applicant Federal Debt Delinquency Explanation
The following field should contain an explanation if the Applicant organization is delinquent on any Federal Debt. Maximum number of
characters that can be entered is 4,000. Try and avoid extra spaces and carriage returns to maximize the availability of space.
Figure 4: SF 424 page 4
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 1: How It All Starts: The Grant Application Process
Item:
Entry:
1.
Type of Submission: (Required): Select one type of submission in accordance with agency
instructions.
Pre-application
Application
Changed/Corrected Application - If requested by the agency, check if this submission
is to change or correct a previously submitted application. Unless requested by the
agency, applicants may not use this to submit changes after the closing date.
Type of Application: (Required) Select one type of application in accordance with agency
instructions.
New-An application that is being submitted to an agency for the first time,
Continuation -An extension for an additional funding/budget period for a project
with a projected completion date. This can include renewals.
Revision -Any change in the Federal Government's financial obligation or
contingent liability from an existing obligation, if a revision, enter the appropriate
letter(s). More than one may be selected. If "Other" is selected, please specify in
text box provided.
A. Increase Award
B. Decrease Award
C. Increase Duration
D. Decrease Duration
E. Other (specify)
3.
Date Received: Leave this field blank. This date will be assigned by the Federal agency.
4.
Applicant Identifier: Enter the entity identifier assigned buy the Federal agency, if any, or the
applicant's control number if applicable.
5a.
Federal Entity Identifier: Enter the number assigned to your organization by the Federal
Agency, if any.
5b.
Federal Award Identifier: For new applications leave blank. For a continuation or revision to an
existing award, enter the previously assigned Federal award identifier number. If a
changed/corrected application, enter the Federal Identifier in accordance with agency
instructions.
Date Received by State: Leave this field blank. This date will be assigned by the State, if
applicable.
State Application Identifier: Leave this field blank. This identifier will be assigned by the State,
if applicable.
Applicant Information: Enter the following in accordance with agency instructions:
a. Legal Name: (Required): Enter the legal name of applicant that will undertake the
assistance activity. This is that the organization has registered with the Central
Contractor Registry. Information on registering with CCR may be obtained by visiting
the Grants.Rov website,
b. Employer/Taxpayer Number (EIN/TIN): (Required): Enter the Employer orTaxpayer
Identification Number (EIN or TIN) as assigned by the Internal Revenue Service. If your
Figure 5: SF 424 page 5
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 1: How It All Starts: The Grant Application Process
organization is not in the US, enter 44-4444444.
c. Organizational DUNS: (Required) Enter the organization's DUNS or DUNS+4 number
received from Dun and Bradstreet. Information on obtaining a DUNS number may be
obtained by visiting the Grants.gov website.
d. Address: Enter the complete address as follows: Street address (Line 1 required), City
(Required), County, State (Required, if country is US), Province, Country (Required),
Zip/Postal Code (Required, if country is US).
e. Organizational Unit: Enter the name of the primary organizational unit (and
department or division, (if applicable) that will undertake the assistance activity, if
applicable.
f. Name and contact information of person to be contacted on matters involving this
applicant required), organizational affiliation (if affiliated with an organization other
on: Enter the name (First and last name than the applicant organization), telephone
number (Required), fax number, and email address (Required) of the person to contact
on matters related to this application.
9.
Type of Applicant: (Required) Select up to three applicant type(s) in accordance with agency
instructions.
A. State Government
B. County Government
C. City or Township Government
D. Special District Government
E. Regional Organization
F. U.S. Territory or Possession
G. Independent School District
H. Public/State Controlled Institution of Higher Education
I. Indian/Native American Tribal Government (Federally Recognized)
J. Indian/Native American Tribal Government (Other than Federally Recognized)
K. Indian/Native American Tribally Designated Organization
L. Public/Indian Housing Authority
M. Nonprofit
N. Nonprofit
O. Private Institution of Higher Education
P. Individual
Q. For-Profit Organization (Other than Small Business)
R. Small Business
S. Hispanic-serving Institution
T. Historically Black Colleges and Universities (HBCUs)
U. Tribally Controlled Colleges and Universities (TCCUs)
V. Alaska Native and Native Hawaiian Serving Institutions
W. Non-domestic (non-US) Entity
X. Other (specify)
10.
Name Of Federal Agency: (Required) Enter the name of the Federal agency from which
assistance is being requested with this application.
11.
Catalog Of Federal Domestic Assistance Number/Title: Enter the Catalog of Federal Domestic
Assistance number and title of the program under which assistance is requested, as found in
the program announcement, if applicable.
12. Funding Opportunity Number/Title: (Required) Enter the Funding Opportunity Number and
Figures: SF 424 page 6
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 1: How It All Starts: The Grant Application Process
title of the opportunity under which assistance is requested, as found in the program
announcement.
13.
Competition Identification Number/Title: Enter the Competition Identification Number and
title of the competition under which assistance is requested, if applicable.
C. Increase Duration D. Decrease Duration E. Other (specify)
14.
Areas Affected By Project: List the areas or entities using the categories (e.g., cities, counties,
states, etc.) specified in agency instructions. Use the continuation sheet to enter additional
areas, if needed.
15.
Descriptive Title of Applicant's Project: (Required) Enter a brief descriptive title of the project.
If appropriate, attach a map showing project location (e.g., construction or real property
projects). For pre-applications, attach a summary description of the project.
16.
Congressional Districts Of: (Required) 16a. Enter the applicant's Congressional District, and
16b. Enter all District(s) affected by the program or project. Enter in the format: 2 characters
State Abbreviation - 3 characters District Number, e.g., CA-005 for California 5th district, CA012
for California 12th district, NC-103 for North Carolina's 103rd district. If all congressional
districts in a state are affected, enter "all" for the district number, e.g., MD-all for all
congressional districts in Maryland. If nationwide, i.e. all districts within all states are
affected, enter US-all. If the program/project is outside the US, enter 00-000.
17.
Proposed Project Start and End Dates: (Required) Enter the proposed start date and end date
of the project.
18.
Estimated Funding: [Required) Enter the amount requested or to be contributed during the
first funding/budget period by each contributor. Value of in-kind contributions should be
included on appropriate lines, as applicable. If the action will result in a dollar change to an
existing award, indicate only the amount of the change. For decreases, enclose the amounts in
parentheses.
19.
Is Application Subject to Review by State Under Executive Order 12372 Process? Applicants
should contact the State Single Point of Contact (SPOC) for Federal Executive Order 12372 to
determine whether the application is subject to the State intergovernmental review process.
Select the appropriate box. If "a." is selected, enter the date the application was submitted to
the State.
20.
Is the Applicant Delinquent on any Federal Debt? (Required) Select the appropriate box. This
question applies to the applicant organization, not the person who signs as the authorized
representative. Categories of debt include: But may not be limited to; delinquent
audit disallowances, loans and taxes. If yes, include an explanation in an attachement.
21.
Authorized Representative: (Required) To be signed and dated by the authorized
representative of the applicant organization. Enter the name (First and last name required) title
(Required), telephone number (Required), fax number, and email address [Required) of the
person authorized to sign for the applicant. A copy of the governing body's authorization for
you to sign this application as the official representative must be on file in the applicant's
office. (Certain Federal agencies may require that this authorization be submitted as part of the
application.)
Figure 7: SF 424 page 7
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013 Page 27 of 279
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Module 1: How It All Starts: The Grant Application Process
The DUNS Number
Request a Dun and Bradstreet
Data Universal Numbering System (DUNS) number
1-866-705-5711Free
http://fedgov.dnb.com/webform/displavHomePage.do
How do we get the Data Universal Numbering
System (DUNS) number required to complete the
application?
The Dun and Bradstreet (D&B) Data Universal
Numbering System (DUNS) number is an
application requirement from the Office of
Management and Budget (OMB). Assistance
agreement applicants must have a DUNS number.
You can get a DUNS number in two ways:
1. By calling the toll-free DUNS
number request line at 1-866-705-
5711.
2. Online at http://www.dnb.com/
http://fedgov.dnb.com/webform/displavH
omePage.do.
Always check form expiration dates, and check
with EPA if there is a new version!
DUNS on SF 424
VpplitMliun fur H'dvrul A^isLant-f Sf-424
3 DatcKecnvcrf
': TJ1KlJf.
K0N
"3 CttumlHI
Q Rc1]MflL
*lf RCMMCU. vclecl jp(ctvii*!e Srtlertu
.
t E«vlovtt TiHpav* IdaaifieMiwi SuiUhtt (EJX.T1N1
s**~~ ""--v
f*c OifciudMtimul DUNS J
The due date for the application package must be
met for the application to be considered. The dates
and requirements vary for each funding
opportunity, so read the announcement carefully,
and be sure to post before the deadline.
For example: One funding announcement
requires a postmark by midnight on the
specified date. Another funding
announcement requires the application to be
received in the EPA office by 5:00 P.M. on
the due date.
A DUNS number will be issued in one business
day at no cost.
Learner Notes:
Visit the DUNS number registration site
online at
http://fedgov.dnb.com/webform/displayHomeP
age, do.
Learner Notes
The Employer/Taxpayer Identification
Number (BIN/TIN) also known as a
Federal Tax Identification Number (FEIN)
is an identification number used by the
Internal Revenue Service to identify a
business, just like a Social Security
Number is used to identify an individual.
The government uses this to keep track of
taxes.
Where do we put the DUNS number on the
application form ?
The revised EPA assistance agreement application,
Standard Form (SF) 424, includes a section for the
DUNS number. Some regional offices may still be
using an older version of the SF 424. If this section
is not provided on your version of the form, as a
temporary procedure, include the DUNS number in
SF 424 Section 5, the application information
address block.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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Module 1: How It All Starts: The Grant Application Process
Standard Form 424A
Budget Information for non-construction programs
GRANT PROGRAM, FUNCTION OR ACTIVITY
>. 1 'l.|.-.t I']. !**<'. !!,-..;,.[,-*
n. Personnel
b Fringe Benefits
t Tim-el
J Equipment
.- S,,H,1,H,
f Contractual
g Construction
1) iitli-i
1 Total Du-ect Charges (lulu of oa-6l>>
1 IlKlllPTt . ll:u-;'-s
k TOTALS (sum of 6innil6j)
d)
$125,224
$22,540
$=3.000
$0.00
$0.00
$0.00
$0.00
4.1.1, .,»
$1-8.862
*41.13»
$220,000
What is Standard Form 424A?
Standard Form (SF) 424 A is the budget page of the
EPA application for federal assistance. Requested
funding and/or cost share funds should be shown in
the "new or revised budget" category. (EPA no
longer makes budget adjustments for unobligated
funds-these funds are returned to headquarters
unless an extension is granted.)
Costs are estimated but specific and rounded to the
nearest dollar.
Costs are divided into two parts:
(1) personnel costs and
(2) non-personnel costs.
You may also have a part for (3) indirect
costs.
Costs are divided into two columns
(1) requested and
(2) match (non-federal funds).
Each cost category is detailed with budget
calculations shown on the form.
Tips on writing a grant proposal and examples of
proposed budgets are available online at
http://www.epa.gov/ogd/recipient/tips.htm.
Do not change or add cost categories
contained in the budget after it is approved.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 1: How It All Starts: The Grant Application Process
Table 1: Sample Proposal Budget Summary
BUDGET INFORMATION - Non-Construction Programs OMB Approval No. 0348-0044
SECTION A - BUDGET SUMMARY
Grant Program
Function or Activity
(a)
1. Indian Environmental
General Assistance
Program
2.
3.
4.
5. Totals
Catalog of Federal
Domestic Assistance
Number
(b)
66.926
Estimated Unobligated Funds
Federal
(c)
$0.00
Non-Federal
(d)
$0.00
New or Revised Budget
Federal
(e)
$220,000
$220,000
Non-Federal
(f)
$0.00
Total
(g)
$220,000
$220,000
SECTION B - BUDGET CATEGORIES
6. Object Class Categories
a. Personnel
b. Fringe Benefits
c. Travel
d. Equipment
e. Supplies
f. Contractual
g. Construction
h. Other*
i. Total Direct Charges (sum of6a-6h)
j. Indirect charges
k. TOTALS (sum of6i and 6j)
GRANT PROGRAM, FUNCTION OR ACTIVITY
(D
$125,224
$22,540
$23,000
$0.00
$0.00
$0.00
$0.00
$8,098
$178,862
$41,138
$220,000
(2)
(3)
(4)
Total
(B)
$125,224
$22,540
$23,000
$0.00
$0.00
$0.00
$0.00
$8,098
$178,862
$41,138
$220,000
7. Program Income
$0.00 1 $0.00 1 $0.00 1 $0.00 1 $0.00
Authorized for Local Reproduction Standard Form 424A (Rev 7-97)
Previous Edition Usable Prescribed by OMB Circular A- 102
' Other costs might include postage, insurance, professional association dues, periodical subscriptions, publications, and similar items not considered equipment or supplies.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 1: How It All Starts: The Grant Application Process
SECTION C - NON-FEDERAL RESOURCES
o (a)Grant Program
8.
9.
10.
11.
12. Total (SUM OF LINES 8-11)
(b)Applicant
(c)State
(d)Other Sources
(e) TOTALS
SECTION D - FORECASTED CASH NEEDS
13. Federal
14. Non-Federal
IB. TOTAL (sum of lines 13 and 14)
Total for 1st Year
$
$
1st Quarter
$
$
2nd Quarter
$
$
4th Quarter
$
$
SECTION E - BUDGET ESTIMATES OF FEDERAL FUNDS NEEDED FOR BALANCE OF THE PROJECT
(a) Grant Program
16.
17.
18.
19.
20. TOTAL (sum of lines 16-19)
FUTURE FUNDING PERIODS (Years)
(b) First
$
$ 0.00
(c) Second
$
$ 0.00
(d) Third
$
$ 0.00
(e) Fourth
$
$ 0.00
Section F - Other Budget Information
21. Direct Charges 22. Indirect Charges
23. Remarks:
Authorized for Local Reproduction
Figure 5: Standard Form 424A page 2
Standard Form 424A (Rev 4-2012) Page 2
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
Page 31 of 279
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Module 1: How It All Starts: The Grant Application Process
INSTRUCTIONS FOR THE SF-424A
Public reporting burden for this collection of information is estimated to average 180 minutes per response, including time for reviewing
instructions, searching existing data sources, gathering, and maintaining the data needed, and completing and reviewing the collection of
information. Send comment regarding the burden estimate or any other aspect of this collection of information, including suggestions for
reducing this burden, to the Office of Management and Budget, Paperwork Reduction Project (0348-0044), Washington, DC 20503.
PLEASE DO NOT RETURN YOUR COMPLETED FORM TO THE OFFICE OF MANAGEMENT AND
BUDGET. SEND IT TO THE ADDRESS PROVIDED BY THE SPONSORING AGENCY.
General Instructions
For continuing grant program applications, submit these
forms before the end of each funding period as required by
the grantor agency. Enter in Columns (c) and (d) the
estimated amounts of funds which will remain unobligated at
the end of the grant funding period only if the Federal grantor
agency instructions provide for this. Otherwise, leave these
columns blank. Enter in columns (e) and (f) the amounts of
funds needed for the upcoming period. The amount(s) in
Column (g) should be the sum of amounts in Columns (e) and
(i).
This form is designed so that application can be made for
funds from one or more grant programs. In preparing the
budget, adhere to any existing Federal grantor agency
guidelines which prescribe how and whether budgeted
amounts should be separately shown for different functions or
activities within the program. For some programs, grantor
agencies may require budgets to be separately shown by
function or activity. For other programs, grantor agencies
may require a breakdown by function or activity. Sections A,
B, C, and D should include budget estimates for the whole
project except when applying for assistance which requires
Federal authorization in annual or other funding period
increments. In the latter case, Sections A, B, C, and D should
provide the budget for the first budget period (usually a year)
and Section E should present the need for Federal assistance
in the subsequent budget periods. All applications should
contain a breakdown by the object class categories shown in
Lines a-k of Section B.
Section A. Budget Summary Lines 1-4 Columns (a) and
(b)
For applications pertaining to a single Federal grant program
(Federal Domestic Assistance Catalog number) and not
requiring a functional or activity breakdown, enter on Line 1
under Column (a) the Catalog program title and the Catalog
number in Column
(b). For applications pertaining to a single program requiring
budget amounts by multiple functions or activities, enter the
name of each activity or function on each line in Column (a),
and enter the Catalog number in Column (b). For applications
pertaining to multiple programs where none of the programs
require a breakdown by function or activity, enter the Catalog
program title on each line in Column (a) and the respective
Catalog number on each line in Column (b). For applications
pertaining to multiple programs where one or more programs
require a breakdown by function or activity, prepare a
separate sheet for each program requiring the breakdown.
Additional sheets should be used when one form does not
provide adequate space for all breakdown of data required.
However, when more than one sheet is used, the first page
should provide the summary totals by programs.
Lines 1-4, Columns (c) through (g)
For new applications, leave Column (c) and (d) blank. For
each line entry in Columns (a) and (b), enter in Columns (e),
(f), and (g) the appropriate amounts of funds needed to
support the project for the first funding period (usually a
year).
For supplemental grants and changes to existing grants, do
not use Columns (c) and (d). Enter in Column (e) the amount
of the increase or decrease of Federal funds and enter in
Column (f) the amount of the increase or decrease of non-
Federal funds. In Column (g) enter the new total budgeted
amount (Federal and non-Federal) which includes the total
previous authorized budgeted amounts plus or minus, as
appropriate, the amounts shown in Columns (e) and (f). The
amount(s) in Column (g) should not equal the sum of
amounts in Columns (e) and (f).
Line 5 - Show the totals for all columns used.
Section B Budget Categories
In the column headings (1) through (4), enter the titles of the
same programs, functions, and activities shown on Lines 1-4,
Column (a), Section A. When additional sheets are prepared
for Section A, provide similar column headings on each
sheet. For each program, function or activity, fill in the total
requirements for funds (both Federal and non-Federal) by
object class categories.
Line 6a-i - Show the totals of Lines 6a to 6h in each column.
Line 6j - Show the amount of indirect cost.
Line 6k - Enter the total of amounts on Lines 6i and 6j. For
all applications for new grants and continuation grants the
total amount in column (5), Line 6k, should be the same as
the total amount shown in Section A, Column (g), Line 6. For
supplemental grants and changes to grants, the total amount
of the increase or decrease as shown in Columns (l)-(4), Line
6k should be the same as the sum of the amounts in Section
A, Columns (e) and (f) on Line 5.
Line 7 - Enter the estimated amount of income, if any,
expected to be generated from this project. Do not add or
subtract this amount from the total project amount, Show
under the program
Figure 6: Standard Form 424A page 3
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013 Page 32 of 279
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Module 1: How It All Starts: The Grant Application Process
INSTRUCTIONS FOR THE SF-424A (continued)
narrative statement the nature and source of income. The
estimated amount of program income may be considered by
the Federal grantor agency in determining the total amount of
the grant.
Section C. Non-Federal Resources
Lines 8-11 Enter amounts of non-Federal resources that will
be used on the grant. If in-kind contributions are included,
provide a brief explanation on a separate sheet.
Column (a) - Enter the program titles identical to
Column (a), Section A. A breakdown by function
or activity is not necessary.
Column (b) - Enter the contributions to be made
by the applicant.
Column (c) - Enter the amount of the State=s cash
and in-kind contribution if the applicant is not a
State or State agency. Applicants which are a State
or State agencies should leave this column blank.
Column (d) - Enter the amount of cash and in-kind
contributions to be made from all other sources.
Column (e) - Enter totals of Columns (b), (c), and
(d).
Line 12 - Enter the total for each of Columns (b)-(e). The
amount in Column (e) should be equal to the amount on Line
5, Column (f), Section A.
Section D. Forecasted Cash Needs
Line 13 - Enter the amount of cash needed by quarter from
the grantor agency during the first year.
Line 14 - Enter the amount of cash from all other sources
needed by quarter during the first year.
Figure 7: Standard Form 424A page 4
Line 15 - Enter the totals of amounts on Lines 13 and 14.
Section E. Budget Estimates of Federal Funds Needed for
Balance of the Project
Lines 16-19 - Enter in Column (a) the same grant program
titles shown in Column (a), Section A. A breakdown by
function or activity is not necessary. For new applications and
continuation grant applications, enter in the proper columns
amounts of Federal funds which will be needed to complete
the program or project over the succeeding funding periods
(usually in years). This section need not be completed for
revisions (amendments, changes, or supplements) to funds for
the current year of existing grants. If more than four lines are
needed to list the program titles, submit additional schedules
as necessary.
Line 20 - Enter the total for each of the Columns (b)-(e).
When additional schedules are prepared for this Section,
annotate accordingly and show the overall totals on this line.
Section F. Other Budget Information
Line 21 - Use this space to explain amounts for individual
direct object class cost categories that may appear to be out of
the ordinary or to explain the details as required by the
Federal grant or agency.
Line 22 - Enter the type of indirect rate (provisional,
predetermined, final or fixed) that will be in effect during the
funding period, the estimated amount of the base to which the
rate is applied, and the total indirect expense.
Line 23 - Provide any other explanations or comments
deemed necessary.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013 Page 33 of 279
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Module 1: How It All Starts: The Grant Application Process
Standard Forms 424 B, C, and D
SF424B Assurances for Non-Construction
Programs
SF 4240 Budget Information for
Construction Programs
SF 4240 Assurances for Construction
Programs
EPA Form 4700-4
EPA Form 4700-4 is the Preaward Compliance
Re\iew Report.
It assures EPA that the award recipient is willing
and able to c< imply with EPA rules and
regulations.
What is Standard Form 4246?
Standard Form (SF) 424B assures the recipient's
project complies with regulation set forth by the
United States Office of Management and Budget.
Learner Notes
When the award becomes official, you
have agreed to comply with all of the
federal regulations listed on the form,
especially 40 CFR 31, 40 CFR 33, and
OMB Circular A-87, negotiate in good
faith with the EPA regional office, write
and follow compliant administrative
and financial policies and procedures,
and do your best to fulfill the terms and
conditions of the agreement.
What is Standard Form 424C?
Standard Form (SF) 424C is the budget
information submitted when the project involves
construction.
What is Standard Form 424D?
Standard Form (SF) 424D assures the recipient's
project complies with regulation set forth by the
United States Office of Management and Budget
when the project involves construction.
What is EPA Form 4700-4?
EPA Form 4700-4 is the Pre-award Compliance
Review Report. Completion of this form indicates
ability and willingness to comply with EPA rules
and regulations on civil rights compliance.
What other forms may be needed?
Some programs require the applicant to submit an
Environmental Assess (EA) and/or Environmental
Impact Statement (EIS). If required, the EPA
Regional Office will provide these forms or
information on how to obtain them.
A list of key contacts should be frequently updated
and kept on file. Copies should be provided to all
Tribal Nation grants management staff. A Contact
Information with Tracking Document and sample
Key Contacts List are provided in the Appendix.
The Grants Application Process
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
tast Updated April 2013 Page 34 of 279
-------
Module 1: How It All Starts: The Grant Application Process
OMB Approval No. 0348-0040
ASSURANCES - NON-CONSTRUCTION PROGRAMS
Public reporting burden for this collection of information is estimated to average 15 minutes per response, including time for reviewing
instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of
information. Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for
reducing this burden, to the Office of Management and Budget, Paperwork Reduction Project (0348-0040), Washington, DC 20503.
PLEASE DO NOT RETURN YOUR COMPLETED FORM TO THE OFFICE OF MANAGEMENT
AND BUDGET.
SEND IT TO THE ADDRESS PROVIDED BY THE SPONSORING AGENCY.
NOTE: Certain of these assurances may not be applicable to your project or program. If you have questions, please contact the
awarding agency. Further, certain Federal awarding agencies may require applicants to certify to additional assurances. If such is
the case, you will be notified.
As the duly authorized representative of the applicant, I certify that the applicant:
1. Has the legal authority to apply for Federal assistance
and the institutional, managerial and financial capability
(including funds sufficient to pay the non-Federal share
of project cost) to ensure proper planning, management
and completion of the project described in this
application.
2. Will give the awarding agency, the Comptroller General
of the United States and, if appropriate, the State,
through any authorized representative, access to and the
right to examine all records, books, papers, or
documents related to the award; and will establish a
proper accounting system in accordance with generally
accepted accounting standards or agency directives.
3. Will establish safeguards to prohibit employees from
using their positions for a purpose that constitutes or
presents the appearance of personal or organizational
conflict of interest, or personal gain.
4. Will establish safeguards to prohibit employees from
using their positions for a purpose that constitutes or
presents the appearance of personal or organizational
conflict of interest, or personal gain.
5. Will comply with the Intergovernmental Personnel Act
of 1970 (42 U.S.C. 4728-4763) relating to prescribed
standards for merit systems for programs funded under
one of the 19 statutes or regulations specified in
Appendix A of OPM=s Standards for a Merit System of
Personnel Administration (5 C.F.R. 900, Subpart F).
6. Will comply with all Federal statutes relating to
nondiscrimination. These include but are not limited to:
(a) Title VI of the Civil Rights Act of 1964 (P.L. 88-
352) which prohibits discrimination on the basis of race,
color or national origin; (b) Title IX of the Education
Amendments of 1972, as amended (20 U.S.C. 1681-
1683, and 1685-1686), which prohibits discrimination
on the basis of sex; (c) Section 504 of the Rehabilitation
Act of 1973, as amended (29 U.S.C. 794), which prohibits
discrimination on the basis of handicaps; (d) the Age
Discrimination Act of 1975, as amended (42 U.S.C. 6101-
6107), which prohibits discrimination of the basis of age; (e) the
Drug Abuse Office and Treatment Act of 1972 (P.L. 92-255), as
amended, relating to nondiscrimination on the basis of drug
abuse; (f) the Comprehensive Alcohol Abuse and Alcoholism
Prevention, Treatment and Rehabilitation Act of 1970 (P.L. 91-
616), as amended, relating to nondiscrimination on the basis of
alcohol abuse or alcoholism; (g) 523 and 527 of the Public
Health Service Act of 1912 (42 U.S.C. 290 dd-3 and 290 ee-3),
as amended, relating to confidentiality of alcohol and drug
abuse patient records; (h) Title VII of the Civil Rights Act of
1968 (42 U.S.C. 3601 et seq.), as amended, relating to
nondiscrimination in the sale, rental or financing of housing; (i)
any other nondiscrimination provisions in the specific statute(s)
under which application for Federal assistance is being made;
and (j) the requirements of any other nondiscrimination
statute(s) which may apply to the application.
7. Will comply, or has already complied, with the requirements
of Titles II and III of the Uniform Relocation Assistance and
Real Property Acquisition Policies Act of 1970 (P.L. 91-646)
which provide for fair and equitable treatment of persons
displaced or whose property is acquired as a result of Federal
or federally assisted programs. These requirements apply to
all interests in real property acquired for project purposes
regardless of Federal participation in purchases.
8. Will comply, as applicable, with provisions of the Hatch Act
(5 U.S.C. 1501-1508 and 7324-7328) which limit the political
activities of employees whose principal employment
activities are funded in whole or in part with Federal funds.
Previous Edition Usable
Figure 8: Standard Form 424B page 1
Authorized for Local Reproduction
Standard Form 424B (Rev 4-2012)
Prescribed by OMB Circular A-102
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013 Page 35 of 279
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Module 1: How It All Starts: The Grant Application Process
9. Will comply, as applicable, with the provisions of the
Davis-Bacon Act (40 U.S.C. 276a to 276a-7), the
Copeland Act (40 U.S.C. 276c and 18 U.S.C. 874),
and the Contract Work Hours and Safety Standards
Act (40 U.S.C. 327-333), regarding labor standards
for federally-assisted construction subagreement.
10. Will comply, if applicable, with flood insurance
purchase requirements of Section 102(a) of the Flood
Disaster Protection Act of 1973 (P.L. 93-234) which
requires recipients in a special flood hazard area to
participate in the program and to purchase flood
insurance if the total cost of insurable construction
and acquisition is $10,000 or more.
11. Will comply with environmental standards which
may be prescribed pursuant to the following: (a)
institution of environmental quality control measures
under the National Environmental Policy Act of 1969
(P.L. 91-190) and Executive Order (EO) 11514; (b)
notification of violating facilities pursuant to EO
11738; (c) protection of wetlands pursuant to EO
11990; (d) evaluation of flood hazards in flood plains
in accordance with EO 11988; (e) assurance of
project consistency with the approved State
management program developed under the Coastal
Zone Management Act of 1972 (16 U.S.C. 1451 et
seq.); (f) conformity of Federal actions to State
(Clean Air) Implementation Plans under Section
176(c) of the Clean Air Act of 1955, as amended (42
U.S.C. 7401 et seq.); (g) protection of underground
sources of drinking water under the Safe Drinking
Water Act of 1974, as amended (P.L. 93-523); and,
(h) protection of endangered species under the
Endangered Species Act of 1973, as amended (P.L.
93-205).
12. Will comply with the Wild and Scenic Rivers Act of
1968 (16 U.S.C. 1271 et seq.) Related to protecting
components or potential components of the national wild
and scenic rivers system.
13. Will assist the awarding agency in assuring compliance
will Section 106 of the National Historic Preservation Act
of 1966, as amended (16 U.S.C. 470), EO 11593
(identification and protection of historic properties), and
the Archaeological and Historic Preservation Act of 1974
(16 U.S.C. 469a-l etseq.).
14. Will comply with P.L. 93-348 regarding the protection
of human subjects involved in research, development, and
related activities supported by this award of assistance.
15. Will comply with the Laboratory Animal Welfare Act of
1966 (P.L. 89-544, as amended, 7 U.S.C. 2131 et seq.)
Pertaining to the care, handling, and treatment of warm
blooded animals held for research, teaching, or other
activities supported by this award of assistance.
16. Will comply with the Lead-Based Paint Poisoning
Prevention Act (42 U.S.C. 4801 et seq.) Which prohibits
the use of lead-based paint in construction or
rehabilitation of residence structures.
17. Will cause to be performed the required financial and
compliance audits in accordance with the Single Audit
Act Amendments of 1996 and OMB Circular No. A-133,
"Audits of States, Local Governments, and Non-Profit
Organizations."
18. Will comply with all applicable requirements of all other
Federal laws, executive orders, regulations, and policies
governing this program.
SIGNATURE OF AUTHORIZED CERTIFYING OFFICIAL
TITLE
APPLICANT ORGANIZATION
DATE SUBMITTED
Figure 9: Standard Form 424B page
Standard Form 424B (Rev.7-97) Back
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013 Page 36 of 279
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Module 1: How It All Starts: The Grant Application Process
OMB Approval No. 0348-0041
BUDGET INFORMATION - Construction Programs
NOTE: Certain Federal assistance programs require additional computations to arrive at the Federal share of project costs eligible for participation. If such is the case, you
will be notified.
COST CLASSIFICATION
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
Administrative and legal expenses
Land, structures, rights-of-way, appraisals, etc.
Relocation expenses and payment
Architectural and engineering fees
Other architectural and engineering fees
Project inspection fees
Site work
Demolition and removal
Construction
Equipment
Miscellaneous
SUBTOTAL (sum of lines 1-11)
Contingencies
SUBTOTAL
Project (program) income
TOTAL PROJECT COSTS (subtract #15 from #14)
a. Total Cost
$ .00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
0.00
.00
0.00
.00
0.00
b. Costs Not Allowable for
Participation
$ .00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
0.00
.00
0.00
.00
0.00
c. Total Allowable Costs
(Columns a-b)
$ 0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
FEDERAL FUNDING
17.
Federal assistance requested, calculate as
follows: Enter eligible costs from line 16c Mult
(Consult Federal agency for Federal percentage
share.)
Enter the resulting Federal share.
ply X %
$ 0.00
Previous Edition Usable
Figure 10: Standard Form 424C page 1
Authorized for Local Reproduction
Standard Form 424C (Rev 4-2012)
Prescribed by OMB Circular A-102
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
Page 37 of 279
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Module 1: How It All Starts: The Grant Application Process
INSTRUCTIONS FOR THE SF-424C
Public reporting burden for this collection of information is estimated to average 180 minutes per response, including time for reviewing
instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of
information. Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for
reducing this burden, to the Office of Management and Budget, Paperwork Reduction Project (0348-0041), Washington, DC 20503.
PLEASE DO NOT RETURN YOUR COMPLETED FORM TO THE OFFICE OF MANAGEMENT AND
BUDGET.
SEND IT TO THE ADDRESS PROVIDED BY THE SPONSORING AGENCY.
This sheet is to be used for the following types of applications: (l)New@ (means anew [previously unfunded] assistance award); (2)
"Continuation" (means funding in a succeeding budget period which stemmed from a prior agreement to fund); and (3) "Revised" (means
any changes in the Federal Government's financial obligations or contingent liability from an existing obligation). If there is no change in
the award amount, there is no need to complete this form. Certain Federal agencies may require only an explanatory letter to affect minor
(no cost) changes. If you have questions, please contact the Federal agency.
Column a. - If this is an application for a "New" project,
enter the total estimated cost of each of the items listed on
lines 1 through 16 (as applicable) under "COST
CLASSIFICATION."
If this application entails a change to an existing award,
enter the eligible amounts approved under the previous
award for the items under "COST CLASSIFICATION."
Column b - If this is an application for a "New" project,
enter that portion of the cost of each item in Column a.
which is not allowable for Federal assistance. Contact the
Federal agency for assistance in determining the
allowability of specific costs.
If this application entails a change to an existing award,
enter the adjustment [+ or (-)] to the previously approved
costs (from column a.) Reflected in this application.
Column - This is the net of lines 1 through 16 in columns
"a." and "b."
Line 1 - Enter estimated amounts needed to cover
administrative expenses. Do not include costs which are
related to the normal functions of government. Allowable
legal costs are generally only those associated with the
purchases of land which is allowable for Federal
participation and certain
services in support of construction of the project.
Line 2 - Enter estimated site and right(s)-of-way
acquisition costs (this includes purchase, lease, and/or
easements).
Line 3 - Enter estimated costs related to relocation
advisory assistance, replacement housing, relocation
payments to displaced persons and businesses, etc.
Line 4 - Enter estimated basic engineering fees related to
construction (this includes start-up services and preparation
of project performance work plan).
Line 5 - Enter estimated engineering costs, such as surveys,
tests, soil borings, etc.
Line 6 - Enter estimated engineering inspection costs.
Line 7 - Enter estimated costs of site preparation and
restoration which are not included in the basic construction
contract.
Line 9 - Enter estimated cost of the construction contract.
Line 10 - Enter estimated cost of office, shop, laboratory,
safety equipment, etc. to be used at the facility. If such costs
are not included in the construction contact.
Line 11 - Enter estimated miscellaneous costs.
Line 12 - Total of items 1 through 11.
Line 13 - Enter estimated contingency cots. (Consult the
Federal agency for the percentage of the estimated
construction costs to use.)
Line 14 - Enter the total of lines 12 and 13.
Line 15 - Enter estimated program income to be earned
during the grant period, e.g., salvaged materials, etc.
Line 16 - Subtract line 15 from line 14.
Line 17 - This block is for the computation of the Federal
share. Multiply the total allowable project costs from line
16, column "c.' by the Federal percentage share (this may
be up to 100 percent: consult Federal agency for Federal
percentage share) and enter the product on line 17.
SF-424C (Rev.7-97) Back
Figure 11: SF 424C, page 2
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013 Page 38 of 279
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Module 1: How It All Starts: The Grant Application Process
OMB Approval No. 0348-0042
ASSURANCES - CONSTRUCTION PROGRAMS
Public reporting burden for this collection of information is estimated to average 15 minutes per response, including time for reviewing
instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of
information. Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for
reducing this burden, to the Office of Management and Budget, Paperwork Reduction Project (0348-0042), Washington, DC 20503.
PLEASE DO NOT RETURN YOUR COMPLETED FORM TO THE OFFICE OF MANAGEMENT AND BUDGET.
SEND IT TO THE ADDRESS PROVIDED BY THE SPONSORING AGENCY.
NOTE: Certain of these assurances may not be applicable to your project or program. If you have questions, please contact the Awarding
Agency. Further, certain Federal assistance awarding agencies may require applicants to certify to additional assurances. If such is the case,
you will be notified.
As the duly authorized representative of the applicant, I certify that the applicant:
1. Has the legal authority to apply for Federal assistance,
and the institutional, managerial and financial capability
(including funds sufficient to pay the non-Federal share
of project costs) to ensure proper planning, management
and completion of the project described in this
application.
2. Will give the awarding agency, the Comptroller General
of the United States and, if appropriate, the State, through
any authorized representative, access to and the right to
examine all records, books, papers, or documents related
to the assistance; and will establish a proper accounting
system in accordance with generally accepted accounting
standards or agency directives.
3. Will not dispose of, modify the use of, or change the
terms of the real property title, or other interest in the site
and facilities without permission and instructions from
the awarding agency. Will record the Federal interest in
the title of real property in accordance with awarding
agency directives and will include a covenant in the title
of real property acquired in whole or in part with Federal
assistance funds to assure non-discrimination during the
useful life of the project.
4. Will comply with the requirements of the assistance
awarding agency with regard to the drafting, review and
approval of construction plans and specifications.
5. Will provide and maintain competent and adequate
engineering supervision at the construction site to ensure
that the complete work conforms with the approved plans
and
specifications and will furnish progress reports and such
other information as may be required by the assistance
awarding agency or State.
6. Will initiate and complete the work within the applicable
time frame after receipt of approval of the awarding
agency.
7. Will establish safeguards to prohibit employees from
using their positions for a purpose that constitutes or
presents the appearance of personal or organizational
conflict of interest, or personal gain.
8. Will comply with the Intergovernmental Personnel Act
of 1970 (42 U.S.C. 4728-4763) relating to prescribed
standards for merit systems for programs funded under
one of the 19 statutes or regulations specified in
Appendix A of OPM=s Standards for a Merit System
of Personnel Administration (5 C.F.R. 900, Subpart F).
9. Will comply with the Lead-Based Paint Poisoning
Prevention Act (42 U.S.C. 4801 et seq.) which
prohibits the use of lead-based paint in construction or
rehabilitation of residence structures.
10. Will comply with all Federal statutes relating to non-
discrimination. These include but are not limited to:
(a) Title VI of the Civil Rights Act of 1964 (P.L. 88-
352) which prohibits discrimination on the basis of
race, color or national origin; (b) Title IX of the
Education Amendments of 1972, as amended (20
U.S.C. 1681-1683, and 1685-1686), which prohibits
discrimination on the basis of sex; (c) Section 504 of
the Rehabilitation Act of 1973, as amended (29 U.S.C.
794), which prohibits discrimination on the basis of
handicaps; (d) the Age Discrimination Act of 1975, as
amended (42 U.S.C. 6101-6107), which prohibits
discrimination on the basis of age; (e) the Drug Abuse
Office and Treatment Act of 1972 (P.L. 92-255), as
amended, relating to nondiscrimination on the basis of
drug abuse; (f) the Comprehensive Alcohol Abuse and
Alcoholism Prevention, Treatment and Rehabilitation
Act of 1970 (P.L. 91-616), as amended, relating to
nondiscrimination on the basis of alcohol abuse or
alcoholism; (g) 523 and 527 of the Public Health
Service Act of
1912 (42 U.S.C. 290 dd-3 and 290 ee-3), as amended,
relating to confidentiality of alcohol and drug abuse
patient records; (h) Title VIII of the Civil Rights Act
of 1968 (42 U.S.C. 3601 et seq.), as amended relating
to nondiscrimination in the sale, rental or financing of
housing; (i) any other nondiscrimination provisions in
the specific statute(s) under which application for
Federal assistance is being made; and (j) the
requirements of any other nondiscrimination statute(s)
which may apply to the application.
Previous Edition Usable
Authorized for Local Reproduction
Standard Form 424D (Rev.7097)
Prescribed by OMB Circular A-102
Figure 12: SF 424D page 1
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013 Page 39 of 279
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Module 1: How It All Starts: The Grant Application Process
11. Will comply, or has already complied, with the
requirements of Titles II and III of the Uniform
Relocation Assistance and Real Property Acquisition
Policies Act of 1970 (P.L. 91-646) which provide for
fair and equitable treatment of persons displaced or
whose property is acquired as a result of Federal and
federally assisted programs. These requirements apply
to all interests in real property acquired for project
purposes regardless of Federal participation in
purchases.
12. Will comply with the provisions of the Hatch Act (5
U.S.C. 1501-1508 and 7324-7328) which limit the
political activities of employees whose principal
employment activities are funded in whole or in part
with Federal funds.
13. Will comply, as applicable, with the provision of the
Davis-Bacon Act (40 U.S.C. 276a to 276a-7), the
Copeland Act (40 U.S.C. 276c and 18 U.S.C.874), and
the Contract Work Hours and Safety Standards Act (40
U.S.C. 327-333) regarding labor standards of federally
assisted construction sub-agreements.
14. Will comply with flood insurance purchase
requirements of Section 102(a) of the Flood Disaster
Protection Act of 1973 (P.L. 93-234) which requires
recipients in a special flood hazard area to participate in
the program and to purchase flood insurance if the total
cost of insurable construction and acquisition is $10,000
or more.
15. Will comply with environmental standards which may
be prescribed pursuant to the following: (a) institution
of environmental quality control measures under the
National Environmental Policy Act of 1969
(P.L. 91-190) and Executive Order (EO) 11514; (b)
notification of violating facilities pursuant to EO 11738;
(c) protection of wetlands pursuant to EO 11990; (d)
evaluation of flood hazards in flood plains in
accordance with EO 11988; (e) assurance of project
consistency with the approved State management
program developed under the Coastal Zone
Management Act of 1972 (16 U.S.C. 1451 et seq.); (f)
conformity of Federal actions to State (Clean Air)
Implementation Plans under Section 176(c) of the Clean
Air Act of 1955, as amended (42 U.S.C. 7401 et seq.);
(g) protection of underground sources of drinking water
under the Safe Drinking Water Act of 1974, as amended
(P.L. 93-523); and (h) protection of endangered species
under the Endangered Species Act of 1973, as amended
(P.L. 93-205).
16. Will comply with the Wild and Scenic Rivers Act of
1968 (16 U.S.C. 1271 et seq.) related to protecting
components or potential components of the national
wild and scenic rivers system.
17. Will assist the awarding agency in assuring compliance
with Section 106 of the National Historic Preservation
Act of 1966, as amended (16 U.S.C. 470), EO 11593
(identification and protection of historic properties), and
the Archaeological and Historic Preservation Act of
1974 (16 U.S.C. 469a-l et seq.).
18. Will cause to be performed the required financial and
compliance audits in accordance with the Single Audit
Act Amendments of 1996 and OMB Circular No. A-
133, "Audits of States, Local Governments, and Non-
Profit Organizations."
19. Will comply with all applicable requirements of all other
Federal laws, executive orders, regulations, and policies
governing this program.
SIGNATURE OF AUTHORIZED CERTIFYING OFFICIAL
TITLE
APPLICANT ORGANIZATION
DATE SUBMITTED
Previous Edition Usable
Figure 13: SF 424D page 2
Authorized for Local Reproduction
Standard Form424D (Rev 4-2012) Back
Prescribed by OMB Circular A-102
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013 Page 40 of 279
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Module 1: How It All Starts: The Grant Application Process
Narrative Statement or Work Plan
^ Detailed description of components to be funded
^ Estimated years or full time equivalents and
amount of work per component
"'Commitments for each component and time
frames for completion
^List of outputs and outcomes
'Roles and responsibilities of recipient and EPA
^Performance evaluation process and reporting
schedule
Is there a form or required format for the
narrative statement (also known as a work plan)?
There is no standard format for the narrative
statement or work plan in the application. To be
considered for the grant award, it is essential that
the work plan address the requirements in the
funding announcement for cooperative agreements
and grants. Components and the format of the work
plan will vary from program to program. Read the
announcement carefully.
If a specific format is required by EPA on a
particular funding announcement, it will be stated
in the announcement. The work plan is tied to the
detailed budget explaining each point, so develop
the budget first.
The contents of project narratives required in a
funding proposal vary. Some announcements
require very basic information (especially in the
case of a Request for Initial Proposal (RFIP),
which only requires an initial proposal at first).
You will eventually need to include the
information listed below, if you are selected and
asked to submit a final application. You won't
necessarily have to have all of this for the first
proposal submission.
Work plans for EPA programs will most likely
contain the following:
Detailed description of Work Plan
components to be funded under the grant
Estimated work years or Full Time
Equivalents (FTEs) and funding amounts
for each Work Plan component
Work Plan commitments for each Work
Plan component and time frames for their
accomplishment
Performance evaluation process and
reporting schedule for "outputs" and
"outcomes" as defined by EPA Order for
Environmental Results
Roles and responsibilities of the recipient
and EPA in carrying out work plan
commitments
A sample narrative statement or work plan is
provided in the Appendix. The U.S. Environmental
Protection Agency's Policy on Environmental
Results Under EPA Assistance Agreements (EPA
Order 5700.7) is explained at
http://www.epa.gov/ogd/grants/assistance.htm and
available for download at
http://www.epa.gov/ogd/grants/award/5700.7.pdf.
Biographical Sketch
Biographical sketches
(if key personnel might
include:
" Education
Work liislon and
ivsponsihilitii.'S
Assist.HKv asrwiiK'nts
kf\ personnel have
managed
" Letters of support or
endorsement
sr
An up-to-date
resume may be
used in place of
the biographical
sketch for any or
all of key grant
personnel.
What is a biographical sketch ?
Biographical sketches of key personnel might
include:
Education
Work history and responsibilities
Assistance agreements key personnel have
managed
Letters of support or endorsement
An up-to-date resume may be used in place of
the biographical sketch for any or all of the key
personnel for the grant.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 1: How It AH Starts: The Grant Application Process
FORM Approved By OMB: No. 2030-0020 Expires 12-31-2011.
United States Environmental Protection Agency
Washington, DC 20460
Preaward Compliance Review Report for
All Applicants and Recipients Requesting EPA Financial Assistance
Note: Read instructions on other side before completing, form.
I. Applicant /Recipient {Name, Address, Slate, Zip Code).
EPA Project No.
II. Is the applicant currently receiving EPA assistance? (See * instructions on reverse side)
III. List all civil rights lawsuits and administrative complaints pending against the applicant/recipient that allege discrimination based on race.
color, national origin, sex, age. or disability. (Do not include employment complaints not covered by 40 C.F.R. Parts 5 and 7. See
instructions on reverse side.)
IV. List all civil rights lawsuits and administrative complaints decided against the applicant recipient within the last year that allege
discrimination based on race, color, national origin, sex, age, or disability and enclose a copy of all decisions. Please describe all corrective
action taken. (Do not include employment complaints not covered by 40 C.F.R. Parts 5 and 7. See instructions on reverse side.)
V. List all civil rights compliance reviews of the applicant/recipient conducted by any agency within the last two years and enclose a copy of the
review and any decisions, orders, or agreements based on the review. Please describe any corrective action laken. (40 C.F.R. ij 7.80(c)<3))
VI.* Does the applicant/recipient provide initial and continuing notice that it does not discriminate on the basis of race, color, national origin, sex.
age, or disability in its programs or activities? (40 C.F.R. § 5.140 and § 7.95) QH Yes Q No
a. Do the methods of notice accommodate those with impaired vision or hearing? Q Yes O No
b. Is the notice posted in a prominent place in the applicant's offices or facilities or, for education programs and activities, in appropriate
periodicals and other written communications? Q Yes Q No
c, Does the notice identify a designated civil rights coordinator? d| Yes Q No
VII. * Does the applicant/recipient maintain demographic data on the race, color, national origin, sex, age, or handicap of the population it serves?
(40 C.F.R. § 7.85(a))
VIII.* Does the applicant/recipient have a policy/procedure for providing access to services for persons with limited Enulish proficiency?
{40 C.F.R. Part 7, F..O. 13166)
!X.* If the applicant/recipient is an education program or activity, or has 15 or more employees, has it designated an employee to coordinate its
compliance with 40 C.F.R. Parts 5 and 7? Provide the name, title, position, mailing address, e-mail address, fax number, and telephone
number of the designated coordinator.
If the applicant/recipient is an education program or activity, or has 15 or more employees, has it adopted grievance procedures that assure
the prompt and fair resolution of complaints that allege a violation of 40 C.F.R. Parts 5 and 7? Provide a legal citation or Internet address
for, or a copy of, the procedures.
XL Will all new facilities or alterations to existing facilities be designed and constructed to be readily accessible to and usable by persons with
disabilities? \~] Yes. If no, explain Inm a regulatory exception (40 C.F.R. §_ 7.70) applies. D No
For (he Applicant/Recipient
I certify that the statements 1 have made on this form and all attachments thereto are true, accurate and complete. I acknowledge that any knowingly
false or misleading statement may be punishable by fine or imprisonment or both under applicable law. I assure that I will fully comply with all
applicable civil rights statutes and EPA regulations.
A. Signature of Authorized Official
B. Title of Authorized Official C. Date
For the U.S. Environmental Protection Agency
I have reviewed the information provided by the applicant/recipient and hereby certify that the applicant/recipient has submitted all information
required by 40 C.F.R. Parts 5 and 7; that based on the information submitted, this application satisfies 40 C.F.R. Parts 5 and 7; and that the applicant has
given assurance that it will fully comply with all applicable civil rights statutes and EPA regulations.
A. Signature of Authorized EPA Official
B. Title of Authorized EPA Official C. Date
EPA Form 4700-4 (Rev. 03/2008). Previous editions are obsolete.
Figure 14: EPA Form 4700-4 Page 1
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013 Page 42 of 279
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Module 1: How It All Starts: The Grant Application Process
Instructions for EPA FORM 4700-4 (Rev. 03/2008)
General
Recipients of Federal financial assistance from the U.S.
Environmental Protection Agency must comply with the
following statutes and regulations.
Title VI ot'the Civil Rights Acts of 1964 provides that no
person in the United States shall, on the grounds of race, color,
or national origin, be excluded from participation in, be denied
the benefits of, or be subjected to discrimination under any
program or activity receiving Federal financial assistance.
The Act goes on to explain that the statute shall not be
construed to authorize action with respect to any employment
practice of any employer, employment agency, or labor
organization (except where the primary objective of the
Federal financial assistance is to provide employment).
Section 13 of the 1972 Amendments to the Federal Water
Pollution Control Act provides that no person in the United
Stales shall on the ground of sex, be excluded from
participation in, be denied the benefits of, or be subjected to
discrimination under the Federal Water Pollution Control Act,
as amended. F.mployment discrimination on the basis of sex is
prohibited in all such programs or activities.
Section 504 of the Rehabilitation Act of 1973 provides lhat no
otherwise qualified individual with a disability in the United
States shall solely by reason of disability be excluded from
participation in, be denied the benefits of, or be subjected to
discrimination under any program or activity receiving Federal
financial assistance. Employment discrimination on the basis
of disability is prohibited in all such programs or activities.
The Age Discrimination Act of 1975 provides that no person
on the basis of age shall be excluded from participation under
any program or activity receiving Federal financial assistance.
Employment discrimination is not covered. Age
discrimination in employment is prohibited by the Age
Discrimination in Employment Act administered by the Equal
Employment Opportunity Commission.
Title IX ot'the Education Amendments of 1972 provides that
no person in the United States on the basis of sex shall be
excluded from participation in, be denied the benefits of, or be
subjected to discrimination under any education program or
activity receiving Federal financial assistance. Employment
discrimination on the basis of sex is prohibited in all such
education programs or activities. Note: an education program
or activity is not limited to only those conducted by a formal
institution.
40 C.F.R. Par! 5 implements Title IX of the Education
Amendments of 1972.
40 C.F.R. Part 7 implements Title VI of the Civil Rights Act
of 1964, Section 13 of the 1972 Amendments to the Federal
Water Pollution Control Act, and Section 504 of The
Rehabilitation Act of 1973.
The Executive Order 13166 (E.O. 13166) entitled; "Improving
Access to Services for Persons with Limited English
Proficiency" requires Federal agencies work to ensure that
recipients of Federal financial assistance provide meaningful
access to their LEP applicants and beneficiaries.
Items
"Applicant" means any entity that files an application or
unsolicited proposal or otherwise requests EPA assistance. 40
C.F.R. §§5.105,7.25.
"Recipient" means any entity, other than applicant, which will
actually receive EPA assistance. 40 C.F.R. §§ 5.105, 7.25.
"Civil rights lawsuits and administrative complaints" means
any lawsuit or administrative complaint alleging discrimination
on the basis of race, color, national origin, sex, age, or disability
pending or decided against the applicant and/or entity which
actually benefits from the grant, but excluding employment
complaints not covered by 40 C.F.R. Parts 5 and 7. For
example, if a city is the named applicant but the grant will
actually benefit the Department of Sewage, civil rights lawsuits
involving both the city and the Department of Sewage should
be listed.
"Civil rights compliance review" means any review assessing
the applicant's and/or recipient's compliance with laws
prohibiting discrimination on the basis of race, color, national
origin, sex, age, or disability.
Submit this form with the original and required copies of
applications, requests for extensions, requests for increase of
funds, etc. Updates of information are all that are required after
the initial application submission.
If any item is not relevant to the project for which assistance is
requested, write "NA" for "Not Applicable."
In the event applicant is uncertain about how to answer any
questions, EPA program officials should be contacted for
clarification.
* For applicants who are not current recipients of EPA
assistance, questions VI - X are for informational purposes
only, and will not affect applicant grant status. I lowever, if an
applicant is currently receiving EPA assistance, questions VI -
X must be answered. (40 C.F.R. Parts 5 and 7).
"Burden Disclosure Statement"
EPA estimates public reporting burden for the preparation of
this form to average 30 minutes per response. This estimate
includes the time for reviewing instructions, gathering and
maintaining the data needed and completing and reviewing the
form. Send comments regarding the burden estimate, including
suggestions for reducing this burden, to U.S. EPA, Attn:
Collection Strategies Division (MC 2822T), Office of
Information Collection, 1200 Pennsylvania Ave., NW,
Washington, D.C. 20460; and to the Office of Information and
Regulatory Affairs, Office of Management and Budget,
Washington, D.C. 20503.
The information on this form is required to enable the U.S.
Environmental Protection Agency to determine whether
applicants and prospective recipients are developing projects,
programs and activities on a nondiscriminatory basis as
required by the above statutes and regulations.
Figure 15: EPA Form 4700-4 Page 2
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013 Page 43 of 279
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Module 1: How It All Starts: The Grant Application Process
Jane Snow, Finance Director, is responsible for
maintaining a comprehensive accounts and records
system that provides financial information on a
timely basis. Jane manages all federal grant
budgets for the Tribal Nation. She has served on
the Tribal Council and as a member of the Board of
Directors for the Tribal College. Jane received her
Bachelor's Degree in business, focusing on finance
and accounting, from Fort Belknap College in
Harlem, Montana. Jane supervises three staff
members: an accountant, a secretary, and a file
clerk. Jane has held this position for five years.
Figure 16: Sample Biographical Sketch
What goes into a biographical sketch?
A. Disciplinary actions taken
B. Family connections \\ithin the Tribal Nation
C. Qualifications for the proposed position
D. Salary and benefits
E. Ail of the above are correct.
The Grants Application Process
I i.i major
!u
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Module 1: How It All Starts: The Grant Application Process
If the Tribal Nation is using an indirect cost rate,
this agreement must be included in the application
package. If the applicant does not have a current
indirect cost rate and wishes to use one, they
should arrange to negotiate an indirect cost rate
with their cognizant federal agency as soon as
possible. This process can take some time to
complete.
Learner Notes
Some Tribal Nations have space cost
allocation plans which pay for heat, power,
and so on. Do you?
Contract
A contract is a mutually binding legal
relati< inship < >hligating the seller to furnish the
supplies or services and the buyer to pay for
them, such as:
Suha wards
Joh Contracts
i '(iiisultunts
Purchase Orders
be documented to explain the absence of
competition.
If the project requires procurement from a sole-
source provider, then the recipient must notify the
EPA Project Officer before using the non-
competitive proposal purchasing method. The
Project Officer will likely ask for the proposed
contract and related information, including cost
information provided by the bidder and written
justification for the non-competitive method, for
EPA review.
Methods of procurement are explained in 40 CFR
31.36(d), provided in the Appendix.
What is a contract?
A contract includes procurement under a grant or
subgrant. A contract is a mutually binding legal
relationship obligating the seller to furnish the
supplies or services (including construction) and
the buyer to pay for them. It includes all types of
commitments that obligate the government to an
expenditure of appropriated funds and that, except
as otherwise authorized, are in writing. Contracts
include awards and job or task orders (including
purchase orders).
How are contracts itemized?
All contracts included in grant work are required to
have been procured in accordance with
procurement regulations regardless of when the
contract is awarded. Contracts must go through the
bidding process unless the applicant can provide
sole source justification. Sole source justification is
granted when it is determined that there is only one
source reasonably available. The one source must
Learner Notes
The more specific the budget, the less
confusion occurs, and less time is lost after
the award. Practice creating an itemized
budget plan in Activity l.b (online at
www.petetribal. org).
Which items are typically required to be
included in an application for an EPA
competitive assistance agreement award?
A. Standard Forms 424, 424A and B or C and D
B. EPA Form 4700-4
C. Detailed itemized budget
D. Narrative statement or work plan
E. All of the above are correct.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
tast Updated April 2013 Page 45 of 279
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Module 1: How It All Starts: The Grant Application Process
Sample Itemized Budget
Objectives
Salaries
Amou
Outre*
Cluster
Personnel
183,400
110,600
26,250
Fringe Travel Supplies
42,182 30,045 4,361
25,438 11,157 240
6,037 173,591 0
Other Indirect
33,145
6,822
10,125
69,760
44,743
60,653
362,893
199,000
276,656
FY09
FY10
'utreach/Air
FY09
FY10
FY09
FY10
TOTAL
Progn
Manager
Environme
Coordinator
Finance
Director
Administrative
Assistant
Subtotal
Fringe
Travel
60,000
9,500
22,450
11,000
102,950
25,978
53,550
0
23,900
3,000
80,450
16,204
10,000
2,500
9,555
12,000
34,050
7,832
16,450
12,00
31,110
17,000
76,550
17,606
11,250
11,250
2,587
15,000
15,000
3,450
140,000
24,000
87,000
69,250
320,250
73,657
FY09
FY10
Outreach/Air
FY09
FY10
FY09
FY10
TOTAL
Staff Em
Work
EnvXpt Work
GrntXpt PerD
Facilities
Panelists
Participants
TOTAL
Other
Categc
Regist. Fee
Facilitators
Panel Fees
EnvWrkXpert
EnvWrk
Grant
Food
Beverages
News/Reports
WkS Materials
TOTAL
1,248
1,290
1,414
1,480
2,073
18,880
1,248
1,230
1,182
1,470
5,475 4,212
57,864 115,727
26,385 3,660
S,945 4,212 57,864 115,727 214,793
FY09 FY10
2,160
9,375
600
4,500 3,000
5,300
3,960 1,000
22,50 1,000
27,545 5,600
i)utreach/Ai
FY09 FY10
2,624
2,099
2,099
6,822
TOTAL
FY09 FY10
3,375 6,750
3,375 6,750
2,760
50,092
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013 Page 46 of 279
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Module 1: How It All Starts: The Grant Application Process
Application Review and Approval Process
for Competitive Grants
l. Initial applications are submitted.
2. Review panel evaluates and recommends applications
to the selection official.
3. Selection official selects applicants that will be offered
an award.
4. Final applications are submitted (if necessary).
5. Grants Specialist and Project Officer review the
application to ensure compliance before making the
award.
Award documentispackaged with "terms and conditions'1
and senttotheawardrecipient.
The Application Review and Approval
Process
How does EPA manage assistance award
programs?
Every organization has a process for the orderly
flow of their work. EPA has a grants management
process for everything from the original inquiry,
request for assistance application, project
administrative and financial management, and
closeout of an award.
Most management assistance is provided by EPA
regional officials. However, online services are
available with new features added frequently. EPA
is moving all of its online award management
services to Grants.gov.
How does the review process work?
Most competitive grant applications are reviewed
by a team of readers. There are two review
processes for a competitive grant program. One is
during the competitive process, where a review
panel evaluates proposals and ultimately
recommends applications to the selection official.
The selection official selects applicants that will be
offered an award. The applicant must either submit
a final (full) application package, or if the
announcement required a full application to be
submitted initially, they might have to make some
minor modifications. Once the final application is
in, it goes through a second review process by the
Grants Specialist and the Project Officer to ensure
compliance before making the final award.
Which of the following is essential to the
EPA application and review process?
A. Writing narrative statements about the work
plan
B. Selecting an assistance agreement that is right
for you
C. Creating a detailed itemized budget with
indirect cost rate agreement
D. Completing all the required forms
E. All of the above are correct.
The Grants Application Process
Listmajor
costs
In direct cost
rate
agreement
Funding
announcement
Eligibility
Application kit
Workploji
Quality
assurance
narratKe
Biographical
sketches
SF4Z4
SF4£4AandB
EPA Fomi4-oo-4
EISorEA
Key con tacts list
What is required from Tribal Nations when
applying for assistance funding ?
Tribal Nations decide if they want to apply for
program funds. Read the funding announcement
for eligibility, restrictions, requirements, and
forms.
When the Tribal Nation decides to apply for a
specific funding award, they complete the
application package. The following items may or
may not be required in the initial application.
Requirement depends on whether the program
offers competitive or non-competitive awards. If
not required in the initial application, it will likely
be required in the final application.
If you are applying for a grant under a non-
competitive program or have already been selected,
you need only complete the one final application,
including the following items:
Standard Form 424 (application)
Standard Form 424A or C (budget)
Standard Form 424B or D (assurances)
Budget detail, work plan and required
certifications
Assurances and EPA Form 4700-4
"Preaward Compliance Review Report for
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013 Page 47 of 279
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Module 1: How It All Starts: The Grant Application Process
All Applicants Requesting Federal
Financial Assistance"
Applicants typically send one copy in addition to
the signed original completed assistance agreement
application to the EPA Grants Management
Official responsible for processing the application.
Check with your EPA Regional Office to find out
how they want you to apply.
Modules 2-10 explain the Tribal Nation's role
in greater detail.
The EPA Grants Management
Official administers the process.
Some GMO duties may be
delegated to the Grants
Specialist.
EPA Grants
Management
Official
(GMO)
Roles and Responsibilities
The Tribal Nation and EPA Roles
What is EPA's role in the grants application
process?
The application process demands active
participation and attention to detail on the part of
many key personnel. Once you are selected for a
competitive award, you will be assigned an EPA
Grants Specialist and Project Officer. Their contact
information is provided on the first page of the
award document and/or in the "terms and
conditions".
EPA regional staff often have more than one set of
responsibilities. Personnel may function in more
than one capacity or position. Roles and
responsibilities vary by region. If for any reason
your grant does not identify a specific person, call
the Regional EPA Office directly, and they will
refer you to the appropriate person.
What does the EPA Grants Management Official
do?
The EPA Grants Management Official administers
the process:
Checks the application
Sends a copy to the Project Officer
Reviews the official funding
recommendation from the Project Officer
The review must first be signed by the
appropriate EPA Approval Official
Completes the application review and
finalizes the award process
Some GMO duties may be delegated to the
Grants Specialist (GS).
The Grants Management Official manages the
entire grant process. The GMO is involved in all
administrative functions for the entire grant
process, including monitoring and closeout.
The EPA project officer manages
the work plan components of an
assistance agreement application.
EPA
Project
Officer
(PO)
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Module 1: How It All Starts: The Grant Application Process
What does the EPA Project Officer do ?
The EPA Project Officer manages the work plan
components of an assistance agreement
application:
Reviews the completed application and
work plan against EPA'S program
objectives and the guidance issued by
EPA in the Catalog of Federal Domestic
Assistance, Grants.gov, and regional
guidance letter
Negotiates any outstanding work plan
issues with the Tribal Nation
Provides EPA Approval Official with
recommendations on who should receive
funding
Once negotiations are complete, sends an
electronic "Funding Recommendation"
and "Funds Commitment Notice" to the
EPA Grants Management Official
The EPA grants specialist clarifies
administrative and financial
components of the application.
EPA
Grants
Specialist
(GS)
What does the EPA Grants Specialist do?
The EPA Grants Specialist clarifies administrative
and financial components of the application:
Reviews the application and budget for
accuracy as well as regulatory and
administrative requirements
Contacts the EPA official Project Officer
and/or the Tribal Nation for any additional
information, if necessary
Reflection
Consider your organization's unique
situation:
Who is your EPA grant
management official?*
Who is your EPA Project Officer?
Who is your EPA Grants
Specialist?*
*Some regions assign part or all of the
GMO responsibilities to a Grants
Specialist.
Learner Notes
You will want to keep track of all the
people involved in each project and their
contact information. A sample Contact
Information and Tracking Document is
provided in the Appendix and in Activity
2.d (www.petetribal.org') for keeping
information handy.
Which of the following responsibilities
are usually handled by the EPA Grants
Management Official?
A. Administrative and financial components of the
application and reviews for regulator}7
compliance
B. Oversight of the assistance agreement process
C. Review and approval of the work plan
^ ^""^
Questions?
Problems?
Call your Project Officer!
^ ;
Your assinnedttujecl officer and grants specialist
contacts.-. m h^|^^j on the assistance agreement
axvanl Jocumen
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 1: How It All Starts: The Grant Application Process
Which of the following responsibilities
are usually handled by the EPA Project
Officer?
A. Administrative and financial components of the
application and reviews for regulatory
compliance
B. Oversight of the assistance agreement process
C. Review and approval of the work plan
Which of the following responsibilities
are usually handled by the EPA Grants
Specialist?
A. Administrative and financial components of the
application and reviews for regulatory
compliance
B. Oversight of the assistance agreement process
C. Review and approval of the work plan
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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F
Module 1: How It All Starts: The Grant Application Process
Attachment to Module 1
Answers to Quizdom Actionpoint Questions
stion (bold font indicates correct ans\
Which is the most reliable method for locating available funding
opportunities?
A. Catalog of Federal Domestic Assistance
B. Website "Grants.gov"
C. Funding announcement received by mail
D. Contacting EPA headquarters or a regional office
E. All of the above are correct.
EPA lists available funding opportunities for assistance agreements at Grants.gov. The
site is updated frequently with new opportunities and provides the most accurate
information available. Don't miss your chance by waiting for information to come to
you.
18
How do we know if the Tribal Nation is eligible to apply?
A. As long as you don't use the money to lobby government, you are
eligible.
B. Check the applicant eligibility paragraph.
C. EPA will contact you if you are not eligible for an award.
D. Tribal Nations are considered eligible as nonprofit organizations.
E. All of the above are correct.
The Applicant Eligibility paragraph lists entities eligible for the assistance agreement
award.
25
What is the most important requirement of EPA's competitive grant
application process?
A. Define the "terms and conditions" of the award.
B. File financial reports.
C. Sign and date official forms.
D. Submit application materials on time.
E. All of the above are correct.
All of these are important, however, getting all the materials submitted by the deadline
is the most important requirement of the application process. Only applications
submitted on-time are considered for funding.
41
What goes into a biographical sketch?
A. Disciplinary actions taken
B. Family connections within the Tribal Nation
C. Qualifications for the proposed position
D. Salary and benefits
E. All of the above are correct.
Disciplinary actions, family connections, salary, and benefits should not be included in a
biographical sketch. EPA simply wants to know how qualified the person is for the work
they will be doing.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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estion (bold font indicates correct answer)
49
Which items are typically required to be included in an application for an EPA
competitive assistance agreement award?
A. Standard Forms 424, 424A and B or C and D
B. EPA Form 4700-4
C. Detailed itemized budget
D. Narrative statement or work plan
E. All of the above are correct.
xplanation
The items listed are typically required parts of a complete application package.
SF 424 and the narrative work plan are required for competitive applications.
Once you are selected, the other forms are required in order to actually receive an
award.
53
Which of the following is essential to the EPA application and review
process?
A. Writing narrative statements about the work plan
B. Selecting an assistance agreement that is right for you
C. Creating a detailed itemized budget with indirect cost rate
agreement
D. Completing all the required forms
E. All of the above are correct.
All of these components are necessary for a Tribal Nation to obtain an award.
62
Which of the following responsibilities are usually handled by the EPA Grants
Management Official?
A. Administrative and financial components of the application and
reviews for regulatory compliance
B. Oversight of the assistance agreement process
C. Review and approval of the work plan
The EPA Grants Management Official administers the process:
Checks the application
Sends a copy to the project officer
Reviews the official funding recommendations from the Project Officer that
are signed by the appropriate EPA Approval Official
Completes the application review and finalizes the award process
65
Which of the following responsibilities are usually handled by the EPA Project
Officer?
A. Administrative and financial components of the application and
reviews for regulatory compliance
B. Oversight of the assistance agreement process
C. Review and approval of the work plan
The EPA project officer manages the work plan components of an assistance agreement
application:
Reviews the completed application and work plan against EPA'S program
objectives and the guidance issued by EPA in the Catalog of Federal Domestic
Assistance, Grants.gov, and by the regional office
Negotiates any outstanding work plan issues with the Tribal Nation
Works with EPA Headquarters to decide to award an assistance agreement to
a specific Tribal Nation
Once negotiations are complete, sends a formal decision memorandum and
electronic funding order to the EPA
grants management official
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 1: How It All Starts: The Grant Application Process
estion (bold font indicates correct answe
68
Which of the following responsibilities are usually handled by the EPA Grants
Specialist?
A. Administrative and financial components of the application and
reviews for regulatory compliance
B. Oversight of the assistance agreement process
C. Review and approval of the work plan
Explanation
The EPA grants specialist clarifies administrative and financial components of the
application:
Reviews the application and budget for accuracy as well as regulatory and
administrative requirements
Contacts the EPA official project officer and/or the Tribal Nation for any
additional information, if necessary
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Module 2: Assistance Agreement Awards
Module 2: Assistance Agreements
Tribal, U.S. Territories and
Insular Areas Administrative and
Financial Guidance for
Assistance Agreements
Module 2:
Assistance Agreements
Assistance Agreements
Module l: The Grant
Agreements
Module 3: Federal Funding
> Module i
Module 7: Accounting Polic:
and Procedun
Module 8: Soi
Preliminary Information
Why does EPA give assistance agreement
awards?
A large part of the Environmental Protection
Agency (EPA)'s mission is to partner with
American Indians and Native Alaskans (AI/NA) to
protect the environment and public health. The
goals of this mission are accomplished by awarding
federal funds to Tribal Nations and Tribal
Consortia to conduct environmental programs and
projects.
Communication supports program goals and
objectives.
Close contact between
Region 8, EPA, and the
Center for Disease Control
(CDC) enabled students to
successfully complete a
hazardous waste operations
and emergency response
class. More students passed
the certification test than in
any previous training group.
(HAZWOPER class at Turtle
Mountain Community
College, Region 8, 2008)
Funds
In fiscal year 2010, more than $210
million dollars were available to Tribal
Nations and Consortia in assistance
agreement funding and technical
assistance for work related to
environmental projects.
Some grant programs require the grantee
to match all or a percentage of the federal
award.
How much money is awarded in assistance
agreements?
When EPA awards funds for a public purpose, it
uses a legal instrument, called an assistance
agreement, which may be either a grant or
cooperative agreement. The U.S. Government is
not substantially involved in projects funded by
grant agreements; involvement is greater in the
case of cooperative agreements. In fiscal year
2010, more than $210,000,000 were available to
Tribal Nations and Consortia in assistance
agreement funding and technical assistance work
related to environmental projects.
Many awards require the recipient to match funds
provided by the federal government. Match or cost
share requirements are identified in the Catalog of
Federal Domestic Assistance (CFDA) listing.
Match is not negotiated. The CFDA sets forth the
match requirements. There can either be a statutory
match, regulatory match, or match imposed as a
matter of policy.
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Module 2: Assistance Agreement Awards
For example, in a 100% or an even match, if the
grant totals $1,000,000, then the Tribal Nation is
required to contribute $1,000,000. Some grant
programs require the grantee to match a percentage
of the federal award. For example, the grant totals
$1,000,000 and the match is 25 percent; the
recipient must contribute $250,000 to cover project
costs. In general, match costs or contributions may
be provided by the Tribal Nation, state
government, or other entity. Any additional
funding provided by the grantee would constitute
voluntary match or leveraging. Contact your EPA
Project Officer to determine if match funds are
required.
More Than 55 EPA Programs
All of EPA's assistance agreement programs
are listed in the
(.'cilaloji ul Federal Lli imeslic Assistance fCFDA).
What kinds of assistance agreement programs
are available?
EPA's environmental statutes are the legal basis for
funding assistance agreements. All of EPA's
assistance agreement programs are listed in the
Catalog of Federal Domestic Assistance (CFDA),
which is maintained by the General Services
Administration (GSA). Currently, EPA has more
than fifty programs listed in the catalog.
What does your Tribal Nation need?
Plan ahead!
Policies, Procedures, and Processes"
Policy is a rule or goal, a course of action set by a
governing organization.
Procedure refers to the actions taken to conform
to a rule, a prescribed series of steps taken to
achieve the goal, or the way in which policy
goals are achieved.
Process refers to a formal set of operational tasks
performed or procedural steps taken, such as
regular duties performed the same way each
time.
What needs to be in place before the award is
received?
Does your program have the essential systems,
policies, procedures, and documentation necessary
for compliance with EPA assistance agreement
regulations? Establish internal control procedures
to ensure your systems can comply with federal
grant projects.
Policy is a rule or goal, a course of action set by a
governing organization. Policies apply to all
programs and projects.
Procedure refers to the actions taken to conform to
a rule, a prescribed series of steps taken to achieve
the goal, or the way in which policy goals are
achieved. Procedures are usually set by
administrative or management personnel to help a
department or project function efficiently.
Process refers to a formal set of operational tasks
performed or procedural steps taken, such as
regular duties performed the same way each time.
Processes are essential to effective completion of
repetitive tasks.
Use the EPA Administrative and Financial Onsite
Review Questionnaire (provided inActivity lO.c
and the Appendix) to periodically examine the
systems, procedures, and controls set up at the
organizational level. EPA Project Officers and
Grants Specialists, along with single auditors and
others periodically review for compliance but are
in no way a substitute for a sound fiscal system.
Sample policies and procedures are provided
throughout Module 7 and in the Appendix.
ifiMM
To be selected for an EPA assistance
agreement award, an applicant must:
^^^^^^^^^^^^^^^^^^^^^^^^^^B
Be eligible (e.g., satisfy all eligibility criteria)
Have systems in place for grant
management
Pro vide justifiable reasons why assistance
Supply a work plan, budget, and assurances
File a 11 application documents by Ihe
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Module 2: Assistance Agreement Awards
How do we receive an assistance agreement
award?
To receive an EPA assistance agreement award, an
applicant must:
Be eligible (e.g., satisfy all eligibility
criteria)
Have systems in place for grant
management
Provide justifiable reasons why assistance
is necessary
Supply a work plan, budget, and
assurances
File all application documents by the
required due date
Be selected for the award
Stay Off the High Risk List!
High risk designation does not
prohibit a Tribal Nation from
applying for and receiving awards,
but it can reduce their chances of
being selected to receive a new
award.
their ability to manage federal award funds.
Debarred entities cannot receive grant funding.
Debarred entities are listed in the System for
Award Management at httpsV/www. sam.gov.
Some grant programs require Tribal Nations to
obtain Treatment as a State (TAS) eligibility
approval. Programs that may require TAS
eligibility are listed at
http://www.epa.gov/tribal/laws/tas.htm. If you have
questions about the nature of TAS eligibility in a
certain grant program or you want to learn more
about Treatment as a State, contact your EPA
regional or program official. Contact information is
provided at
http://www.epa.gov/tribal/contactinfo/index.htm.
A Tribal Nation might NOT receive an EPA
assistance agreement award if the proposed
project involves an organization:
A. Never cited for non-compliance
B. Complies with regulations
C. Listed as a high risk agency
D. Never cited with high risk audit findings
E, All of the above are correct.
Most grant recipients have no trouble complying
with federal regulations. However, a few
experience problems that cause federal agencies to
question the recipient's ability to manage grants
effectively. Organizations that have a history of
difficulty with audits may be designated as high
risk for accounting reasons only. This level of risk
can usually be remedied by conducting a more in-
depth OMB Circular A-133 single audit.
Organizations that are unable to remedy these
problems in a timely manner may be required to
work more closely with EPA regional office staff.
High risk designation does not prohibit a Tribal
Nation from applying for and receiving awards, but
it can reduce their chances of being selected to
receive a new award. The debarred list does
prohibit a Tribal Nation from receiving awards, so
make sure your organization stays "off the list".
Talk to your regional EPA managers often.
If high risk problems continue, the organization
can be debarred. Organizations identified on the
debarred list have failed to comply with regulations
to the degree that federal agencies no longer trust
Responsibilities Timeline: Startup
The Award
We got the award! Now what do we do?
Congratulations on receiving an EPA assistance
agreement award. Everyone involved is responsible
for the success of the funded project. EPA wants to
help you make the most of this opportunity.
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Module 2: Assistance Agreement Awards
Learner Notes
This is a great time to stop and take a hard
look at a real award document. Review
your assistance agreement award. If you
do not have an award document, you may
use the example in Activity 2.a, located
online at www.petetribal.org.
Learner Notes
Visit the EPA website at
http://www.epa.gov. You will find some
exercises to do in Activity 2.b (found at
www.petetribal. org).
Who is responsible for the success of an
assistance agreement award program?
A. EPA
B. The Tribal Nation
C. Regional EPA Officers
D. Project Managers
E. All < if the ab< >ve are correct.
What types of assistance are available
to a Tribal Nation after receiving an
assistance agreement award?
A. Administrative and financial guidance manual
B. Training sessions
0. Web-based training modules
D. Regional support personnel
E. All of the above are correct.
EPA Assistance: More than Money
Where can we get more information?
Federal funding requirements are complex. EPA
provides assistance to help recipients meet those
regulations in a timely and professional manner.
The Tribal Administrative and Financial Guidance
Manual/or Assistance Agreements is just one of
the many types of assistance available. Training is
also available through your regional EPA office.
Visit the EPA website or contact your EPA
Regional Coordinator to learn about other types of
assistance.
Where can we learn how to manage
our award?
A. EPA website
B. EPA Regional Office
C. Guidance manual
D. Training
E. All of the above are correct.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 2: Assistance Agreement Awards
Managing the Process
What are the rules and regulations?
The alphabet soup of rules and regulations can be
confusing to even the most seasoned grants
manager. A little time spent examining them can
save a lot of time and trouble later on. Copies of
the applicable rules and regulations are provided in
the Appendix.
Learner Notes
This is a good time to become familiar
with the EPA rules and regulations with
which an award recipient is expected to
comply. Take a few minutes to learn how
to read them by completing Activity 2.c
(found online at www.petetribal.org').
When in doubt-
ask your EPA Project Officer.
Project Officers (PO)
focus on programmatic components like
work-plan accomplishments and budget.
Grants Specialists (GS)
focus on administrative and fiscal
components like written procedures and
accounting systems. "~~- ^~
How do we know if we are managing the
assistance agreement award correctly?
The Tribal Nation is responsible for evaluating its
own compliance during the life of the grant. EPA
Project Officers and grant specialists will also
evaluate compliance. Some responsibilities
overlap, such as compliance with "terms and
conditions" and revision of budgets. Project
Officers focus on programmatic components like
work-plan accomplishments and budget. Grants
Specialists focus on administrative and fiscal
components like written procedures and accounting
systems. If you are in doubt which person to
contact, you should contact your Project Officer
and pose your questions. They will let you know
whether you need to involve the Grants Specialist.
Contact List with Tracking Document
Surname FirstName
Responsibility
Title
Org.
Address
Gty
Phone
Email
State
Zip Code
Fax
Website
Questions
'
Comments
How can we keep track of all the people involved
in this process?
Create a list of contacts for each project. Keep
essential information handy.
Track dates for each contact made and
record what was discussed and decided in
your project file.
Track due dates for reports and project
evaluator visitation dates.
Record questions as they arise, so you have
them with you when you talk to the
responsible party.
Communicate with your Proj ect Officer
often.
Learner Notes
Activity 2.d (found online at
www.petetribal.org') asks you to copy
contact information from your award
document to the Contact Information with
Tracking Document. A full page Contact
Information with Tracking Document form
is provided in the Appendix. You may add
as many additional pages as necessary and
should update contact information often.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 2: Assistance Agreement Awards
American Indian Environmental
Office Tribal Portal
Who do we contact when we have a question?
There are a total of eleven (11) regional Grants
Administrative Units. One is located in
Washington, D.C. at EPA Headquarters. Ten are
located in EPA Regional Offices across the
country. Headquarters and regional office contact
information are listed in the Appendix.
Each Grants Management Office (GMO) has its
own unique website. Regional websites are
accessible through the EPA's main website
address, http://www.epa. gov/. Click on "Contact Us"
at the bottom of the page. Then click on the
number for your region or select your state/
territory from the drop-down menu. You can also
find EPA regional office contacts "where you live"
at the American Indian Environmental Office
Tribal Portal, http://www.epa.gov/tribalportal/. The
American Indian Environmental Office Tribal
Portal is under the American Indian Environmental
Office (AIEO) which is within the new Office of
International and Tribal Affairs (OITA).
Learner Notes
Visit the American Indian Environmental
Office Tribal Portal,
http://www.epa.gov/tribalportal/. Activity 2.e
(found at www.petetribal.org') asks you to
record contact information for your EPA
regional personnel from this website onto
your Contact Information with Tracking
Document form.
EPA Regional Offices
The Grants Specialist and Project Officer work in
the regional office that serves your area of the
country. They are your primary points of contact.
They can answer any questions you might have.
The Grants Specialist is designated during the
application process. The Grants Specialist is
responsible for ensuring administrative compliance
with regulations, statues, and policy.
You will be assigned a Project Officer during the
application process. If you already have an
established relationship with EPA, you probably
already have a Project Officer. The Project Officer
should be the person you go to first with any
program questions or concerns not covered in the
manual or explained on EPA websites.
EPA Project Officer Role
The EPA Project Officer (PC)) arranges:
|J Regular meetings
c Phone calls
1 Programmatic report filing deadlines
Significant changes in the project must be
negotiated \vith the PO.
What does the Project Officer do?
The Tribal Nation's Project Manager should be in
constant contact with its assigned EPA Project
Officer. Your EPA Project Officer is there to help
make your assistance agreement a success. They
can assist you with issues or questions that come
up as you are implementing your work plan and
help guide you through the applicable
requirements.
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Module 2: Assistance Agreement Awards
The EPA Project Officer arranges regular
meetings, phone calls, and programmatic report
filing deadlines with you. Significant changes in
the project must be negotiated with the Project
Officer. Significant changes are defined in other
sections of this manual. Contact information for all
persons involved in the project should be updated
regularly, at least once per year.
Map a Planning Calendar
Jen
Joe
Jan
taWm*
Feb
Mar
Apr
May
. -
Jun
Jul
Aug
*!««..
Sep
Oct
Mfcaa
Nov
Dec
Reporting requirements are explained in Modules
3, 6, and 9 of this manual.
Personnel work in tandem.
How do we contact EPA?
The only way for EPA to know if training is useful
to you is to receive feedback. Please share your
comments and suggestions by contacting EPA.
U.S. Environmental Protection Agency
Ariel RiosBuil ding
1200 PennsylvaniaAvaiue, X.W.
Washington, DC 20460
Tel: (202) 272-0167
TTY (speech- andhearing-impaired)
(202)272-0165
http:/.i1' inru- .epa.gov "Contact us'
A good way to keep track of important events
during the award period is to map out a Grants
Management Planning Calendar with your Project
Officer.
Learner Notes
Activity 2.f (online at www.petetribal.org')
asks you to draft a Grants Management
Planning Calendar for your award project.
If you do not have your award document,
you may use the sample work plan
provided for this exercise.
The above address is for EPft Headquarters. For specific questions contact your EPA Re-gk
Office. The address and contact information can be found in your grant award document.
Typical Reporting Schedule
Quality Assurance Plan
(if required by the program)
Workproduct/deliverables
(progress reports)
Disadvantaged Business Enterprise
(DBE) Utilization
(EPA Form 5700-52A)
U.S. EPA Payment Request
(EPA Form 190 or SF 271 for
construction)
Federal Financial Report
(SF 425)
Final Performance/Technical
Report
Final Federal Financial Report
(SF 425)
As stated n the aw
and condi ons," us
days after acceptin
As stated n the aw
and condi ons"
As stated n the aw
and condi ons"
Advance or reimbu
to two weeks
calendar year (Janu
Within 90 days afte
project period
Within 90 days afte
budget period
rd "terms
jally within 60
the award
rd "terms
rd "terms
se everyone
ary!5)
end of
end of
EPA Regional Office
EPA Regional Project Officer
DBE Regional Coordinator
LasVegas Finance Center
(LVFC)
(LVFC)
EPA Regional Project Officer
LasVegas Finance Center
(LVFC)
Application and Review Process
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 2: Assistance Agreement Awards
Application and Review Process
What do we need to know about assistance
agreement awards?
Assistance Agreement Awards
When an award is made, the recipient (that's you)
receives an award package.
An EPA assistance agreement award package
contains:
An award letter
The award document, explaining the
"terms and conditions" for your project
When does the agreement become legally
binding?
An assistance agreement award is a binding
agreement between the Tribal Nation and EPA.
Both parties promise to work closely together.
There are times when the Tribal Nation will need
to communicate with EPA:
At the start to initiate the project
During the project period when written
program and financial reports are due to
EPA
During compliance review audits when
EPA may visit to review the Tribal
Nation's policies and procedures as well
as the project files, which reflect
monitoring and tracking
During closeout
Read ALL information very carefully.
Recipients demonstrate their commitment
to carry out an award by either:
1. Drawing down funds within 21 days after the
EPA award or amendment mailing date; or
2. Not filing a notice of disagreement with the
award terms and conditions within 21 days
after the EPA award mailing/issuance date.
(Keep copies for your files.)
A Tribal Nation demonstrates commitment to carry
out an award by either:
1. Drawing down funds within 21 days after
the EPA award or amendment mailing
date; or
2. Not filing a notice of disagreement with
the award terms and conditions within 21
days after the EPA award mailing date.
Who is responsible for making sure the project
will meet award specifications?
The assistance agreement is part of a government-
to-government relationship and the authorized
certifying official should be an elected
representative of the Tribal Nation. It is the
authorized certifying official's responsibility to
read the award document very carefully to ensure
that all of the requirements as specified in the
assistance agreement award document are
understood and can be met.
These requirements include compliance with
federal regulations as stated in 40 CFR Part 31.
Regulations require the Tribal Nation to write
policies and procedures for administrative and
financial systems to meet these requirements.
The Authorized Certifying Official (the same
person who signed off on the proposal) must be:
Authorized by the Tribal Nation
Accountable to the Tribal Nation and EPA
Responsible for complying with agreed
upon "terms and conditions"
Does the award document need to be signed to
legally bind the Tribal Nation to the agreement?
A. Yes
B. No
C. Only if the award is greater than $50,000
D. Only if the award is greater than $500,000
E. None of the above.
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Module 2: Assistance Agreement Awards
Reflection
Pause a moment to consider how your
organization handles administrative
functions.
How does your organization keep
up-to-date on federal regulations,
legal decisions, OMB Circulars,
and the like?
Who is your Nation's authorized
certifying official?
Start the Project
1. Read the award document very carefully.
2. Keep a copy of the official award in your
files.
3. Set up accounts.
4. Meet with project team.
5. Begin record keeping.
How do we get started once the award is
received?
Get the project off to a good start. Take the
following initial steps.
1. Read the award document very
carefully.
1. The project manager should:
a. Read the award document very
carefully.
b. Be able to explain to each member
of the project team their
responsibilities for the:
Work plan
Budget
"Terms and conditions"
Reporting requirements
2. Keep a copy of the official
award in your files.
Meet with EPA regional Grants Specialist and
Project Officer.
Do not make any changes
to the award document.
2. Keep a copy of the official award in your files.
The Tribal Nation's Project Manager should
contact the EPA Grants Specialist partner
within three weeks (21 calendar days) of the
receipt of the award document. Tell the Grants
Specialist that you have accomplished all the
steps toward good grants management
operations.
Misunderstandings and problems can be
avoided if everyone fully understands what
can and cannot be accomplished in the project.
If you do not understand something, ask the
EPA Project Officer or EPA Grants Specialist
to explain.
Do NOT make any changes to the award
document. All changes must be made in
concurrence with EPA. EPA must make all
changes after the agreement is official. To
make sure changes are made quickly and
accurately, discuss all proposed changes with
the EPA Grants Specialist or Project Officer
immediately.
Track receipt of all documentation exchanged
with EPA.
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3. Set up accounts.
Tribal
match
Direct
Costs
Indirect
Costs
3. Work with accounting staff to establish a
separate set of accounts for the grant award and the
Tribal Nation's match (if a match is required) in
your financial system and enter the award and
match budget into the accounting system.
Policies and procedures must comply with cost
principles outlined in the Office of
Management and Budget (OMB) Circular A-
87, revised from the Code of Federal
Regulations (CFR) Title 2 Grants and
Agreements, Part 225 Cost Principles for
State, Local and Indian Tribal Governments
(hereafter referred to as OMB Circular A-87).
Learner Notes
Practice writing policies and procedures in
Activity 3.a (found online at
www.petetribal.org).
4. Meet with project team.
Review budget.
Review administrative procedures,
Review financial and accounting procedures.
Determine deadlines for reporting.
Assign respective duties.
Design strategies for success.
4. Meet with the project team to review the
budget that has been put into the financial system
and to review the Tribal Nation's grants
management policies and procedures.
The Tribal Nation should work with
accounting staff to set up a separate set of
budget accounts for the award. The project
budget is submitted to accounting to enter it
into their accounting system.
Everyone involved in the project (e.g., grant
directors, project staff, and accountants - all
key people who will have responsibility
working on your project) should meet to
discuss the new award. They should go over
specific details of the assistance award, like
deadlines for reporting, drawing down funds,
budget line items, allowable costs, and so on.
5. Begin record keeping.
Each grant must have its
own file(s).
Color code paper folders,
may provide additional
designation.
Keep electronic copies.
File must be safe from theft,
fire, and water damage.
5. Start a file of records including:
a. A copy of the assistance agreement
and the award letter
b. The grants management calendar
and tracking chart
c. Work plan and budget detail
d. Notes and communications
Keep all documentation in a separate file.
Though grant documentation is legally the
property of the Tribal Nation, it should be kept
in its own file - preferably in the same labeled
and color coded folders as the files kept at the
regional office - so records are easily available
to project auditors for review.
EPA regional directors highly recommend
files match the files held at the regional office.
Files should be:
Color coded
Kept in both paper and electronic
format
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Module 2: Assistance Agreement Awards
Safely secured
Files should be kept in a fire-proof
cabinet. Grant recipients are held
accountable even when files are lost
due to natural phenomenon like fire,
flood, and human error.
It is a good idea to backup
electronic files regularly. There are
many internet-based remote backup
options available, but electronic
records can also be stored in an out-
of-office location. It is important to
backup electronic files in case something
happens to the originals. Paper files should be
copied and kept in two different locations, just
in case.
What is the first thing we should do after
receiving the assistance agreement award
document?
A. Notify our administration.
B. Contact the EPA regional office.
C. Read the document carefully.
D. Start a new file for the project.
Terms and Conditions
There are three types of "terms and conditions"
that maybe included in an award document:
i. Administrative - applicable to all grant
programs
2. Programmatic - specific to a particular grant
program
3. High Risk - additional requirements for
recipients classified as "high-risk" agencies
Terms and Conditions
What types of "terms and conditions" are in an
assistance agreement award document?
There are three types of "terms and conditions"
that may be included in an award document:
Administrative (applicable to all grant
programs)
Programmatic (specific to a particular grant
program)
High Risk (additional requirements for
recipients classified as "high-risk" agencies)
What are administrative "terms and conditions"?
Administrative
Applicable administrative provisions for EPA
assistance agreements can be found in Title 40 of
the Code of Federal Regulations (CFR), Chapter 1,
SubchapterB, Part 31. For example, an
administrative term or condition might read:
"In accordance with EPA
guidance and OMB Circular
A-87, as appropriate, the
Tribal Nation agrees that it
will use assistance funds
(Federal or non-Federal
share) for fully authorized
and budgeted project
activities only."
What are the programmatic "terms and
conditions"?
Programmatic
Programmatic "terms and conditions" are listed in
the assistance agreement award document under
"Programmatic Conditions". For example:
The Tribal Nation agrees to
submit biannual progress
reports to the EPA Project
Officer partner within thirty
days after the end of each
reporting period.
"Substantial involvement terms and conditions"
may be included if the project is awarded under a
cooperative agreement.
The EPA Project Officer
partner will participate in
planning sessions for each
phase of the project for the
purpose of providing
technical input.
What are the high risk "terms and conditions"?
High Risk
High Risk is a classification that is given to any
recipient, regardless of affiliation (whether they
are a state, local, or Tribal government, non-profit,
college, or university) when the recipient:
Has a history of unsatisfactory performance
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 2: Assistance Agreement Awards
Is not financially stable
Has a management system that does not
meet the management standards set forth in
40CFRPart31
Has not conformed to the "terms and
conditions" of a previous award, or
Is otherwise considered not responsible
When a grantee is considered to be high risk, EPA
works closely with the grant recipient in order to
help them understand and meet the programmatic
and/or administrative requirements of the grant.
Examples of high risk "terms and conditions":
Payments are made on a reimbursement
basis and not automatic drawdown
Restricting grant recipient from proceeding
to the next phase of a project until
performance in previous phases is
acceptable
Requiring the grant recipient to submit more
detailed financial reports
The EPA Project Officer reviews the grant
recipient's project progress more closely and
more often when the grant recipient is
classified high risk.
Having the above "terms and conditions" in an
award does not mean the grantee is necessarily
classified as "high risk". Many of these steps are
taken for other reasons as well. Each federal
agency has its own definition for high risk. An
audit high risk classification does not mean EPA
automatically considers the grantee to be a high
risk.
When officially classified as a high risk agency,
however, the grantee's name is added to a list of
past award recipients classified as high risk and is
circulated to other agencies. This could delay or
even prevent anyone with a high risk classification
from receiving funds from other federal agencies,
not just EPA.
An organization that habitually fails to comply
with regulations will be placed on the debarred list.
An organization that is on the debarred list
cannot receive EPA assistance agreement
awards.
Stay off the Debarred List!
Organizations identified on the debarred list
have failed to comply with regulations to the
degree that federal agencies no longer trust
their ability to manage federal award funds.
Debarred entities cannot receive grant
funding.
Debarred entities are listed in the Excluded
Parties List System at https: //www.sam.gov
Learner Notes
Activity 3.b (found at www.petetribal.com')
asks you to examine the "terms and
conditions" listed in your assistance
agreement award document. Share your
observations with those seated at your
table, as terms and conditions may vary
between programs and regions.
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Module 2: Assistance Agreement Awards
An organization will not receive an EPA
assistance agreement award if it is:
A. Cited for non-compliance
B. Not following regulations
C. Listed as a high risk agency
D. Identified on EPA's debarred list
E. All of the above
How might a high-risk
classification affect our award?
A, It may delay the application process.
B. Project progress may be reviewedmore
frequently.
C. We may be required to submit more detailed
reports than other award recipients.
D. It may be more difficultfor us to win another
award in the future.
E. All of the above are correct.
in
witfci^©ur
Projtet Qfftear
Grants Specialist
L ..
Reporting and Monitoring
How often should we communicate with EPA
regional officials?
A very important part of having a good program is
frequent contact with the Project Officer and the
Grants Specialist. Monthly communication
should be sufficient to keep things running
smoothly, but you are encouraged to ask
questions whenever issues arise.
It is good to let EPA know about the things you are
able to achieve with the assistance agreement as
well as difficulties you encounter. Address issues
before they become problems. It is better to address
issues as they come up rather than wait until the
end of the project.
Communicate with the EPA Project Officer (PO)
on programmatic technical issues related to the
project. The EPA Project Officer is the project
specialist. Inform your Project Officer if problems
arise that could jeopardize the completion of the
project. The Project Officer will work with the
Tribal Nation to rectify the situation.
Communicate with the EPA Grants Specialist (GS)
on administrative and budget issues. The Grants
Specialist provides technical assistance to the
Tribal Nation on administrative, financial, and
accounting issues.
Contact both if uncertain about who to contact
regarding a particular question or issue. In this
instance, email is the best method of
communication, as the question or issue can be
posed to both at the same time.
How often should we communicate
with regional officials?
A. Daily
B. Weekly
C. Monthly
D. Semi-armually
E. Annually
Compliance Reviews
EPA has the right to review a grant recipient's:
= Administrative and Financial Systems
° Policies and procedures
' Project Files
a Personnel
= Internal Controls
° Monitoring. Tracking, and Reporting Process
What is a compliance review?
Compliance Reviews occur when EPA visits to
review the Tribal Nation's policies and procedures
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Module 2: Assistance Agreement Awards
as well as the Tribal Nation's project files, which
reflect monitoring and tracking. A compliance
review may also be called a limited desk review.
Take advantage of this opportunity to identify
weaknesses in systems and obtain suggestions that
may help you work more efficiently. This is your
chance to get free accounting advice.
Copies of the EPA Administrative and Financial
Onsite Review Questionnaire are provided in the
Appendix and in Module 10.
Check your award "terms and conditions" for
requirements specific to your award.
Closeout Letter
Once all of the required documents have been
submitted and accepted by the various EPA
partners, the Tribal Nation will receive a closeout
letter. The Grants Specialist sends the closeout
letter to the address specified on the award
document.
Discussion
What operational processes does your
organization have for:
Submitting programmatic progress
reports?
Establishing a process to track,
monitor, and report on
environmental results?
Closeout
Submit all final reports.
Receive an EPA Closeout Letter.
Keep records safe for as long as indicated in the
"terms and conditions" of the agreement.
. 1 ^,1 1
] ml ml
J . J . J
What is closeout?
Final reporting takes place when the project is
within ninety (90) days of completion and/or time
for the assistance agreement to expire. The
assistance agreement goes into the final closeout
phase.
Reports
The closeout phase requires the submission of:
Final project and financial reports
Disadvantaged Business Enterprise reports
Regional offices may request additional forms.
Retention
Records must be made available for review by
EPA should any questions arise after the agreement
is completed. Records retention requirements
depend on the program. Typically records are kept
for a minimum three (3) years after the final
financial Status Report is submitted. Some
programs require records to be kept for up to ten
(10) years.
EPA suggests:
Program records be kept as long as they are
needed
Financial records be disposed of when the
retention period ends
As long as the files are available, they can be
audited. Retention dates freeze when the
organization is under an audit. This can prolong
the time records are required to be kept on file.
Contact your Grants Specialist, if you are unsure of
your retention dates.
When grant support is
continued or renewed at
annual or other intervals,
the retention period for the
records of each funding
period starts on the day the
grantee orsubgrantee
submits to the awarding
agency its single or last
expenditure report for that
period. However, if grant
support is continued or
renewed quarterly, the
retention period for each
year's records starts on the
day the grantee submits its
expenditure report for the
last quarter of the Federal
fiscal year. In all other cases,
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 2: Assistance Agreement Awards
the retention period starts
on the day the grantee
submits its final expenditure
report. If an expenditure
report has been waived, the
retention period starts on
the day the report would
have been due.
Discussion
How does your organization manage:
Policies and procedures to ensure
compliance with the financial
requirements in 40 CFR Part
31.20(b)?
An internal auditor, audit staff, or
other financial expert that provides
for an independent review of the:
o Accounting and
financial management
process
o Cash receipts and
payments
o Safeguarding of assets
Policies and procedures to ensure
compliance with closing out
assistance awards after the
performance and budget periods, as
required in 40 CFR Part 31.50?
40 CFR Part 31 is available online at
http://ecfr.gpoaccess.gov and provided in this
manual's Appendix. Essential forms are
available online at
http://www.epa.gov/ogd/forms/forms.htmand
in the Appendix.
When can we dispose of the files?
A. EPA receives the final report
B. It varies, usually 3-1O years. Check with the
Proj ect Officer
C. The Tribal Nation receives a closeout letter
from EPA
D. All project funds are spent
E. Ninety days after the award expires
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Module 2: Assistance Agreement Awards
Attachment to Module 2
Answers to Quizdom Actionpoint Questions
r"
"
A Tribal Nation might NOT receive an EPA assistance agreement award if the proposed
project involves an organization:
A. Never cited for non-compliance
B. Complies with regulations
C. Listed as a high risk agency
D. Never cited with high risk audit findings
E. All of the above are correct.
High risk agencies are organizations that have been cited for not complying with federal
regulations. A Tribal Nation with a history of non-compliance might have that record counted
against them when they are being scored by reviewers in a competitive program. It doesn't
necessarily knock them off the list, but it can hurt their chances.
13
Who is responsible for the success of an assistance agreement award program?
A. EPA
B. The Tribal Nation
C. Regional EPA Officers
D. Project Managers
E. All of the above are correct.
The "terms and conditions" of the agreement make each party responsible for the conditions that
apply to them.
17
What types of assistance are available to a Tribal Nation after receiving an assistance
agreement award?
A. Administrative and financial guidance manual
B. Training sessions
C. Web-based training modules
D. Regional support personnel
E. All of the above are correct.
The manual, training sessions, and regional support personnel are already in place to assist Tribal
Nations. Web-based training modules will be available soon.
20
Where can we learn how to manage our award?
A. EPA website
B. EPA Regional Office
C. Guidance manual
D. Training
E. All of the above are correct.
EPA is dedicated to assisting Tribal Nations in as many user-friendly ways as possible.
Last Updated April 2013
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 2: Assistance Agreement Awards
35
Question (bold font indicates correct answe
Who must sign the assistance agreement award document to legally bind the Tribal
Nation to the agreement?
A. Yes
B. No
C. Only if the award is greater than $50,000
D. Only if the award is greater than $500,000
E. None of the above.
OGD has eliminated the requirement for recipients to submit a signed Affirmation of Award for
new awards or amendments. Recipients demonstrate their commitment to carry out an award by
either:
1) Drawing down funds within 21 days afterthe EPA award or amendment mailing date;
or
2) Not filing a notice of disagreement with the award terms and conditions within 21 days
afterthe EPA award mailing date.
45
What is the//rsf thing we should do after receiving the assistance agreement award
document?
A. Notify our administration.
B. Contact the EPA regional office.
C. Read the document carefully.
D. Start a new file for the project.
All of these are important first steps. However, before anything else, read the document to be
sure you fully understand what it says. Then call a meeting of all involved in its successful
completion.
51
An organization will not receive an EPA assistance agreement award if it is:
A. Cited for non-compliance
B. Not following regulations
C. Listed as a high risk agency
D. Identified on EPA's debarred list
E. All of the above are correct.
A Tribal Nation with a history of non-compliance might have that record counted against them
when they are being scored by reviewers in a competitive program. An organization that
habitually fails to comply with regulations will be placed on the debarred list. An organization that
is on the debarred list cannot receive EPA assistance agreement awards.
54
How might a high-risk classification affect our award?
A. It may delay the application process.
B. Project progress may be reviewed more frequently.
C. We may be required to submit more detailed reports than other
award recipients.
D. It may be more difficult for us to win another award in the future.
E. All of the above are correct.
High-risk classification can make it more difficult to receive and report on a grant now and in the
future. It also requires more frequent interaction with EPA during the award period.
Last Updated April 2013
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Module 2: Assistance Agreement Awards
How often should we communicate with regional officials?
A. Daily
B. Weekly
C. Monthly
D. Semi-annually
E. Annually
Monthly communication should be sufficient to keep things running smoothly, but you are
encouraged to ask questions whenever issues arise.
63
When can we dispose of the files?
A. EPA receives the final report
B. It varies, usually 3-10 years. Check with the Project Officer
C. The Tribal Nation receives a closeout letter from EPA
D. All project funds are spent
E. Ninety days after the award expires
Records must be saved for three to ten years following closeout. The award period can be
extended for various reasons. Ask your EPA grants specialist for the exact dates of your records
retention period.
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Module 3: Federal Funding Accountability and Transparency Act
Module 3: Federal Funding Accountability and Transparency Act (FFATA)
Tribal, U.S. Territories and
Insular Areas Administrative
and Financial Guidance for
Assistance Agreements
Modules:
Federal Funding
Accountability and
Transparency Act (FFATA)
What is the Federal Funding Accountability
and Transparency Act (FFATA)?
The Federal Funding Accountability and Transparency Act
(FFATA) or Transparency Act was signed on September 26. 2006
and requires information on federal awards (federal financial
assistance and expenditures) be made available to the public via a
single, searchable website, which is www.USASpending.gov.
Reporting requirements were phased in at certain dollar levels
beginning in July 2010. All prime awardees of federal funds are
now required to be in full compliance with the Federal Funding
Accountability and Transparency Act (FFATA).
Module 3:Federal Funding Accountability and
Transparency Act (FFATA)
Module 9: Disadvantaged
Business Enterprises (DBEs)
Module 10: Assistance Agreei
Monitoring and Closeout
Module i: The Grant
Application Process
Module 3: Federal
Funding
Accountability and
Transparent Vi
'FFATA)
Module 4: Grants
agement Sj"Stejns
- Module 5:
Components
Questions addressed in this module
What is the Federal Funding Accountability and
Transparency Act (FFATA)?
Why was the regulation passed'
Who does the regulation pertain to?
What are the reporting requirements?
Where can I go to access resources and assistance?
Overview
What is the Federal Funding Accountability and
Transparency Act (FFATA)?
The Federal Funding Accountability and
Transparency Act (FFATA) was signed on
September 26, 2006. The intent is to empower
every American with the ability to hold the
government accountable for each spending
decision. The end result is to reduce wasteful
spending in the government. The FFATA
legislation requires information on federal awards
(federal financial assistance and expenditures) be
made available to the public via a single,
searchable website, which is
www.USASpending.gov.
What is the purpose of FFATA?
"The intent is to empower
every American with the
ability to hold the
government accountable
for each spending decision.
The end result is to reduce
wasteful spending in the
government."
Transparency and Accountability
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Module 3: Federal Funding Accountability and Transparency Act
Federal Agency Responsibilities
All federal agencies
are required to
report accurate
information to
USASpending.gov
no later than 30
days following the
award or
modification of a
grant.
What are the responsibilities of federal agencies
under FFATA?
All federal agencies are required to report accurate
information to USASpending.gov no later than 30
days following the award or modification of a
grant.
On a bi-monthly basis, EPA submits information
on its assistance awards, including reference data
about prime recipients, to USASpending.gov in a
government-wide format known as the Federal
Assistance Award Data System (FAADS) Plus.
On a quarterly basis the Agency must provide
assurances to OMB about the timeliness and
quality of its FAADS Plus submissions.
How is EPA Helping to Reduce Reporting
Requirements ?
On a bi-monthly basis, EPA submits information on its assistance
awards, including reference data about prime recipients, to
USASpending.gov (USASpending).
Information about prime recipients will pre-populate FSRS records
to the maximum extent possible.
Definitions
Prime Awardee: an entity that directly
receives Federal financial assistance from an
agency to implement projects.
Prime Contractor: an entity that directly
receives a procurement contract from a federal
agency or financial assistance recipient.
Definitions, Continued
Sub Contractor: An entity that performs work
for a prime contractor that is not an employee of
the prime.
Sub-recipient or Sub-grantee: an entity that
is accountable to the Recipient for the use of
federal funds.
Sub Award: an award of financial assistance in
the form of money, or property in lieu of money,
made under an award by a recipient to an
eligible sub-recipient or by a subrecipient to a
lower tier sub-recipient.
Definitions
The Term subcontractor is also used to describe an
entity that receives a procurement contract from a
recipient or subrecipient.
The term subaward also includes financial
assistance when provided by any legal agreement,
even if the agreement is called a contract, but does
not include procurement of goods and services nor
does it include any form of assistance which is
excluded from the definition "award" in §215.2(e).
A subrecipient or subgrantee is an entity that is a
subrecipient under the standards in OMB Circular
A-133 and is accountable to the recipient for the
use of federal funds. The term subgrantee does not
include vendors who provide commercial goods
and services to the recipient under terms that
provide for a profit. Subrecipients are subject to the
OMB Cost Principles and the federal grant
regulations with regard to financial management
and procurement.
What is a sub-award?
The Office of Management & Budget issued
guidance identifying the requirement to report first-
tier sub-awards on April 6, 2010 and that guidance
may be found at the OMB Open Government site
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Module 3: Federal Funding Accountability and Transparency Act
at http://www.whitehouse.gov/omb/open. That
guidance defines a sub-award as generally referring
to a monetary award made as a result of a Federal
award to a grant recipient or contractor to a sub-
recipient or sub-contractor respectively.
What new reporting is required?
Prime contract awardees of Feders
contracts of $25K or more must
report associated first-tier sub-
contracts of $25K or more.
Prime grant awardees of Federal
grants of $25K or more must report
associated first-tier sub-grants of
$25X01-more.
Prime awardees must repor
executive compensation inform;
for prime and sub-awardees if 1
meet reporting requirement;
NOTE: While a new award of less than
$25,000 is not subject to reporting, EPA may
subsequently add funds to meet or exceed the
$25,000 threshold. If that occurs, the
reporting requirements apply absent an OMB-
specified exception and the Agency would
have to amend the award to include the
standard OMB award term. If funding is
deobligated from the agreement to reduce
the award amount to less than $25,000, the
reporting requirements continue to apply.
What federal grants and contracts are
subject to FFATA Executive Compensation
Data Reporting?
New federal grants
awarded on or after
October i, 2010 in an
amount equal to or
greater than $25,000
New federal contracts
awarded on or after
March i, 2011 in an
amount equal to or
greater than $25,000
What federal contracts and grants are subject to
FFATA subaward and executive compensation
reporting requirements?
The subaward/executive compensation reporting
requirements generally apply to "new"
discretionary and mandatory EPA assistance
agreements, equal to or exceeding $25,000,
awarded on or after October 1, 2010. EPA must
notify affected prime recipients of these
requirements using a standard award term and
condition published by OMB at 2 C.F.R. Part 170
Appendix A. Grants Management Offices (GMOs)
must include the standard term and condition in all
new awards of $25,000 or more, except for awards
to individuals (i.e., where the recipient receives the
award as a natural person unrelated to any business
or non-profit organization they may own or operate
in their name).
What grants are NOT subject to the
Transparency Act's reporting requirements?
Cooperative Research and Development Agreements (CRDAs), as
defined under 15 U.S.C. 37103;
Federal awards to individuals who apply for or receive Federal
awards as natural persons;
Federal awards to entities that had a gross income, from all
sources, of less than $300,000 in the entities' previous tax year;
and
Federal awards, if the required reporting would disclose classified
information.
What federal contracts and grants are NOT
subject to the Transparency Act's reporting
requirements?
In addition to the award amount threshold, the
following are not subject to the Transparency Act's
reporting requirements:
Grants, whether existing or new as of
October 1, 2010, that are funded by the
Recovery Act. Rather, such awards will
continue to report those awards and
related subawards through
FederalReporting. gov;
Transfers of title between Federal
agencies of Federally owned property;
Federal inter-agency transfers of award
funds;
Cooperative Research and Development
Agreements (CRDAs), as defined under
15 U.S.C. 3710a;
Federal awards to individuals who apply
for or receive Federal awards as natural
persons (i.e., unrelated to any business or
non-profit organization he or she may
own or operate in his or her name);
Federal awards to entities that had a gross
income, from all sources, of less than
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$300,000 In the entities' previous tax
year; and
Federal awards, if the required reporting
would disclose classified information.
What does Executive Compensation
Data reporting entail?
Names and
total
compensation
of the five
most highly -<
compensated
officers must
be reported,
IF:
The entity in the preceding fiscal year
received 80 percent or more of its annual
gross revenues in Federal awards; AND
$25,000,000 or more in annual gross
revenues from Federal awards; AND
The public does not already have access to
this information under the Securities and
Exchange Act of 1934.
Prime recipient executive
compensation data
The prime recipient
must include data in
its SAM registration
profile (formerly
CCR) by the end of
the month following
the month it receives
an award, and
annually thereafter.
SAM - are you in compliance?
ISAM
SYSTEM FOR AWARD MANAGEMENT
The System for Award
Management (SAM) was
deployed as a replacement for
CCR on July 30, 2012.
SAM is combining 8 federal
procurement systems & the
Catalog of Federal Domestic
Assistance (CFDA) to provide
one streamlined, more user-
friendly system.
more later in the Module
Reminder: What Federal contracts and grants are
subject to the FFATAsubaward and executive
compensation reporting requirements?
New grants $25,000 and over. The grants subaward
reporting functionality is available via www.fsrs.gov.
Reporting of Sub-contracts of Federal contracts and sub-
grants of Federal grants where these sub-contracts and
sub-grants are $25,000 and over.
Why is subaward information being collected?
The Federal Funding Accountability and Transparency
Act requires OMB to "ensure the existence and
operation of a single searchable website" for Federal
awards.
The Transparency Act's definitions of "Federal
awards" include not only prime awards for grants,
cooperative agreements, loans, and contracts, but also
sub-grants and sub-contracts.
Why is sub-award information being collected?
The Federal Funding Accountability and
Transparency Act (Transparency Act) requires
OMB to "ensure the existence and operation of a
single searchable website" for Federal awards. The
Transparency Act's definitions of "Federal awards"
include not only prime awards for grants,
cooperative agreements, loans, and contracts, but
also sub-grants and sub-contracts.
What is required to be reported as part of
the Transparency Act?
FFATA prescribes specific pieces of information to be reported.
i. The following data for subawards equal to or greater than $25K is required:
a. Name of entity receiving award
b. Amount of award
c. Funding agency
d. NAICS code for contracts / CFDAprogram number for grants
e. Program source
(http s ://www. fe deral repo rting .g ov/federal rep orti ng/pr ogramSourceCodes.do)
f. Award title descriptive of the purpose of the funding action
h. Place of performance (including congressional district)
i. Unique identifier of the entity and its parent; and
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Reporting
What is required to be reported as part of the
Transparency Act?
FFATA prescribes specific pieces of information to
be reported:
1. The following data about sub-awards greater
than $25K
a. Name of entity receiving award
b. Amount of award
c. Funding agency
d. NAICS code for contracts / CFDA
program number for grants
e. Program source
f. Award title descriptive of the purpose of
the funding action
g. Location of the entity (including
congressional district)
h. Place of performance (including
congressional district)
i. Unique identifier of the entity and its
parent; and
j. Total compensation and names of top five
executives (same thresholds as for primes)
2. The Total Compensation and Names of the
top five executives if:
a. More than 80% of annual gross revenues
are from the Federal government, and
those revenues are greater than $25M
annually, and
b. Compensation information is not already
available through reporting to the SEC.
Classified information is exempt from the prime
and sub-award reporting requirement as are
contracts with individuals.
What does total compensation entail?
2 CFR Part 170 e.5 of the award term in Appendix
A: Total compensation means the cash and noncash
dollar value earned by the executive during the
recipient's or subrecipient's preceding fiscal year
and includes the following (for more information
see!7CFR229.402(c)(2)):
i. Salary and bonus.
ii. Awards of stock, stock options, and stock
appreciation rights. Use the dollar amount
recognized for financial statement
reporting purposes with respect to the
fiscal year in accordance with the
Statement of Financial Accounting
Standards No. 123 (Revised 2004) (FAS
123R), Shared Based Payments.
iii. Earnings for services under non-equity
incentive plans. This does not include
group life, health, hospitalization or
medical reimbursement plans that do not
discriminate in favor of executives, and
are available generally to all salaried
employees.
iv. Change in pension value. This is the
change in present value of defined benefit
and actuarial pension plans.
v. Above-market earnings on deferred
compensation which is not tax-qualified.
vi. Other compensation, if the aggregate
value of all such other compensation (e.g.
severance, termination payments, value of
life insurance paid on behalf of the
employee, perquisites or property) for the
executive exceeds $10,000.
As of October 1, 2010, definitions for data
elements may be found at the data dictionaries
maintained on www.USAspending.gov.
What is NAICS?
North American Industry
Classification System
° Was developed by OMB as the
standard for use by Federal
agencies in classifying business
establishments for collection.
tabulation, presentation and
analysis of statistical data
describing the US economy.
° It provides uniformity and
comparability in the presentation
of these statistical data.
What is required to be reported as part of
the Transparency Act? Continued:
2. Prime and Sub-recipients Executive Compensation Data:
Name and total compensation of the five most highly compensated
officers if:
a) Receives more than 80% of annual gross revenues from the
federal government, and those revenues are greater than
$25M annually and
b) Compensation information is not already available through
reporting to the Securities and Exchange Commission
(SEC).
To access company information at the SEC qo to: http://www.sec.qov/answers/execomp.htm
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How Long Do I Have To Report?
Prime awardees must report first-tier subaward
information by the end of the month/allowing the month
the award or award's obligation was made
' For example, if a subaward is made on August 5 the
prime awardee would have until September 30 to report
the subaward
subawards made during August all have until September
30 to report
How much time does a prime awardee have to
report executive compensation or sub-award
information?
The prime recipient will have until the end of the
month plus one additional month after an award or
sub-award is obligated to fulfill the reporting
requirement. For example, if a sub-award was
made on March 5,2012 the prime recipient had
until April 30, 2012 to report the sub-award
information.
How are applicants informed of FFATA
requirements?
Two clauses in Section VI of announcements:
1. Applicants must ensure that they have the necessary
processes and systems in place to comply with the
subaward and executive total compensation reporting
requirements established under OMB guidance at 2
CFR Part 170 unless they qualify for an exception from
the requirements, should they be selected for funding.
How Does Reporting Occur?
Prime awardees must:
Register with the System for Award Management (SAM;
formerly CCR)
° Subawardees must register with Dun & Bradstreet to
get a DUNS number.
Respond to the executive compensation questions
through SAM
Report first-tier subaward information through the
FFATA Subaward Reporting System (FSRS)
Are subawardees required to report information
directly into FSRS in compliance with this
Guidance and the Transparency Act?
A. Yes
B. No
Funding Announcements, Continued
2. System for Award Management (SAM) and Data
Universal Numbering System (DUNS) Requirements
Unless exempt from these requirements under OMB guidance at 2 CFR
Part 25 (e.g., individuals), applicants must:
I. Be registered in SAM prior to submitting an application or proposal
I. Maintain an active SAM registration with current information at all times
during which it has an active Federal award or an application or proposal
II. Provide its DUNS numbei
agency.
ich application or proposal it submits to the
Please note: SAM and DUNS will be covered in more detail later in the Module
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Note: Please note that while the DUNS/SAM
clause requires that applicants be registered
in SAM and have a DUNS number at time of
proposal submission, applicants who fail to
do so will not be rejected from the
competition. Rather, as provided in the OMB
guidance, the effect of noncompliance is
measured at the time of award and the
Agency may not make an award to an entity
if they have not complied with the
SAM/DUNS requirements. In such cases, the
Agency may determine that the applicant is
not qualified to receive an award and may
use that determination as a basis to make an
award to another applicant.
What exemptions are therefrom the SAM and
DUNS requirements?
Exemptions listed in 2 CFR Part 25.110:
(b) Exemptions for individuals. None of the
requirements in this part apply to an individual
who applies for or receives Federal financial
assistance as a natural person (i.e., unrelated to
any business or non-profit organization he or she
may own or operate in his or her name).
(c) Exemptions for Federal agencies. The
requirement in this part to maintain a current
registration in SAM does not apply to an agency of
the Federal Government that receives an award
from another agency.
(d) Other exemptions. (1) Under a condition
identified in paragraph (d)(2) of this section, an
agency may exempt an entity from an applicable
requirement to obtain a DUNS number, register in
SAM, or both.
(i) In that case, the agency must use a generic
DUNS number in data it reports to
USASpending.gov if reporting for a prime award
to the entity is required by the Federal Funding
Accountability and Transparency Act (Pub. L.
109-282, hereafter cited as "Transparency Act").
(ii) Agency use of a generic DUNS should be used
rarely for prime award reporting because it
prevents prime awardees from being able to fulfill
the subward or executive compensation reporting
required by the Transparency Act.
(2) The conditions under which an agency may
exempt an entity are
(i) For any entity, if the agency determines that it
must protect information about the entity from
disclosure, to avoid compromising classified
information or national security or jeopardizing the
personal safety of the entity's clients.
(ii) For a foreign entity applying for or receiving an
award or subaward for a project or program
performed outside the United States valued at less
than $25,000, if the agency deems it to be
impractical for the entity to comply with the
requirement(s).
How Are Recipients Notified of
FFATA Requirements?
FFATA requirements
will be listed in the
Terms and Conditions
of the grant award.
Read carefully!
How are recipients notified of the FFATA
requirements?
FFATA requirements will be listed in the Terms
and Conditions of the grant award. Read carefully!
Identification Requirements
How are recipients notified of the System for Award Management and Universal Identifier requirements?
System for Award Management and Universal Identifier requirements will be listed in the Terms and
Conditions of the grant award.
I. System for Award Management and Universal Identifier Requirements.
A. Requirement for System for Award Management (SAM). Unless you are exempted from this
requirement under 2 CFR 25.110, you as the recipient must maintain the currency of your information
in SAM until you submit the final financial report required under this award or receive the final
payment, whichever is later. This requires that you review and update the information at least annually
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after the initial registration, and more frequently if required by changes in your information or another
award term.
B. Requirement for Data Universal Numbering System (DUNS) numbers. If you are authorized to make
subawards under this award, you:
1. Must notify potential subrecipients that no entity (see definition in paragraph C of this award term)
may receive a subaward from you unless the entity has provided its DUNS number to you.
2. May not make a subaward to an entity unless the entity has provided its DUNS number to you.
C. Definitions. For purposes of this award term:
1. System for Award Management (SAM) means the Federal repository into which an entity must
provide information required for the conduct of business as a recipient. Additional information
about registration procedures may be found at the SAM Internet site (currently at
http://www.sam.gov).
2. Data Universal Numbering System (DUNS) number means the nine-digit number established and
assigned by Dun and Bradstreet, Inc. (D&B) to uniquely identify business entities. A DUNS
number may be obtained from D&B by telephone (currently 866-705-5711) or the Internet
(currently at http://fedgov.dnb.com/webform).
3. Entity, as it is used in this award term, means all of the following, as defined at 2 CFR part 25,
subpart C:
a. A Governmental organization, which is a State, local government, or Indian tribe;
b. A foreign public entity;
c. A domestic or foreign nonprofit organization;
d. A domestic or foreign for-profit organization; and
e. A Federal agency, but only as a subrecipient under an award or subaward to a non-Federal
entity.
4. Subaward:
a. This term means a legal instrument to provide support for the performance of any portion of
the substantive project or program for which you received this award and that you as the
recipient award to an eligible subrecipient.
b. The term does not include your procurement of property and services needed to carry out the
project or program (for further explanation, see Sec. --.210 of the attachment to OMB Circular
A-133, "Audits of States, Local Governments, and Non-Profit Organizations").
c. A subaward may be provided through any legal agreement, including an agreement that you
consider a contract.
5. Subrecipient means an entity that:
a. Receives a subaward from you under this award; and
b. Is accountable to you for the use of the Federal funds provided by the subaward.
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What is a DUNS Number?
The Data Universal Numbering System or DUNS
Number is a means of identifying business entities
on a location-specific basis. Assigned and
maintained solely by Dun and Bradstreet, this
unique nine-digit identification number has been
assigned to over 100 million businesses
worldwide.
Do you know if your organization has a DUNS number?
How do we get the Data Universal Numbering
System (DUNS) number?
The Dun and Bradstreet (D&B) Data Universal
Numbering System (DUNS) number is an
application requirement from the Office of
Management and Budget (OMB). Assistance
agreement applicants must have a DUNS number.
You can get a DUNS number in two ways:
By calling the toll-free DUNS number request
line at 1-866-705-5711.
Online at http://www.dnb.com/
http://fedgov.dnb.com/webform/displayH
omePage.do.
A DUNS number will be issued in one business
day at no cost.
The DUNS Number
Request a Dun and Bradstreet
Data Universal Numbering System (DUNS) number
1-866-705-5711Free
http://fedgov.dnb.com/webform
When issuing subawards under prime federal
awards received by the Tribal Nation, will the
subrecipient be required to obtain a DUNS
Number?
Yes. In accordance with FFATA, all subrecipients are
required to have a DUNS number before the Tribal Nation
can execute a subaward or subcontract.
Make sure you keep track of your DUNS number expiration date!
Why does an organization have to provide a
DUNS number?
The federal government's Office of Management & Budget has
adopted the use of DUNS numbers as a way to keep track of how
federal grant money is awarded and dispersed.
'Sy
^
The DUNS number must be registered annually.
Overlooking this requirement to update your
registration may cause delays in future funding for
your organization!
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What is the System for Award Management
(SAM)?
The System for Award Management (SAM) is the
official, on-line registrant database for the U.S.
Federal Government. SAM Collects, validates,
stores and disseminates data in support of agency
acquisition and award missions.
Unless exempt from these requirements under
OMB guidance at 2 CFRPart 25 (e.g., individuals),
applicants must:
1. Be registered in SAM prior to submitting an
application or proposal under this announcement.
SAM information can be found at
https://www.sam.gov.
2. Maintain an active SAM registration with
current information at all times during which it has
an active Federal award or an application or
proposal under consideration by an agency.
What is the System for Award Management (SAM)?
The System for Award Management (SAM) is a
Federal Government owned and operated free website
that consolidates the capabilities of CCR/FedReg,
ORCA, and EPLS.
SiSAM
SAM was deployed July 30, 2012.
Future phases of SAM will add the capabilities of other
systems used in Federal procurement and awards processes.
Who is required to register in SAM?
Anyone (sole proprietors, corporations, partnerships and
governmental organizations) desiring to do business with
the federal government must register in SAM.
Exception: SAM registration is not required for individuals
seeking grants.
Do you know if your organization is registered in SAM?
The Migration from CCR to SAM
What do I need to do?
I am already registered with CCR: You need to create an
account with SAM. You will need to know the email address and
username from your CCR account in order to migrate your existing
information and permissions into your new SAM account.
My CCR registration is incomplete: Any information entered
into CCR will be moved to SAM. You can complete the registration
there.
I am not yet registered with CCR: Go to SAM and create your
account there; CCR is no longer active.
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How does an organization create an
account in SAM?
NEW users:
Step i: Access the SAM online registration at www.satn.gov. Click on
"Register New Entity" from the left side navigation pane. Toil must
have a Data Universal Numbering System (DUNS) number
in order to begin the registration process.
Step 2: Complete and submit the online registration. If you already
have the necessary information on hand, the online registration
takes approximately 30 minutes to complete, depending upon the size
and complexity of your business or organization.
rage the organizations you are working with to become registered through SAM!
Online SAM Help
SSAM
How long does it take to get a
SAM application processed?
New registrations can take an
average of 3-5 business days to
process in SAM.
.^
^
SAM does notify customers (usually electronically) when
they need to renew their registration. However, if your
Points of Contact (POC's) change, the reminder email may
go to someone who is no longer in your organization. To
change the Point of Contact, you need to contact the
Federal Service Desk directly.
What does it cost to register in SAM?
How long does it take to get a SAM
application processed?
Because SAM is a federally mandated and funded
program, there is no cost to registrants for registering in
SAM.
A. Within 24 hours
B. Two days
C. One week
D. Six months
E. 3-5 days
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Now let's review the FFATA
reporting process:
www.FSRS.eov
IT IS YOUR RESPONSIBILITY
Is there someone within your
organization delegated with the
responsibility to acquire/maintain:
SAM I DUNS
registration registration FFATA
anrl nnrla-t-orl I arirl nnrla-t-orl \
information information
What is the FSRS?
The Reporting System
What is FSRS?
The FFATA Subaward Reporting System (FSRS)
is the reporting tool Federal prime awardees (i.e.
prime contractors and prime grant recipients) use to
capture and report subaward and executive
compensation data regarding their first-tier
subawards to meet the FFATA reporting
requirements. Prime contract awardees will report
against sub-contracts awarded and prime grant
awardees will report against sub-grants awarded.
The sub-award information entered in FSRS will
then be displayed on www.USASpending. gov
associated with the prime award, thereby furthering
Federal spending transparency.
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Introduction/Background
The Federal Funding Accountability and Transparency Act (FFATA)
necessitates a system to allow prime grant/contract recipients to be
able to report on subaward activity and executive compensation.
FFATA Subaward Reporting System - FSRS.gov
* July 2010, "FSRS.gov" launched as the resource for Prime Awardees to report on
FFATA-required Contract sub-contract activity and executive compensation
* October 2010 "FSRS.gov" expanded to incorporate FFATA-required Grant
subaward and executive compensation reporting
* Prime Awardees are those recipients of the grant/contract awards.
Note: Sub-contractors/awardees do not report through the system (only Prime
Awardees)
https://www.fsrs .gov/
Reporting Timeline for Grant Recipients, continued
For those new Federal grants as of October 1, 2O1O. if the
initial award is equal to or greater than $25,000, reporting of
subaward and executive compensation data is required.
If the initial award is below $25,000 but subsequent grant
modifications result in a total award equal to or over $25,000,
the award will be subject to the reporting requirements, as of the
date the award exceeds $25,000.
If the initial award equals or exceeds $25,000 but funding is
subsequently de-obligated such that the total award amount falls
below $25,000, the award continues to be subject to the
reporting requirements of the Transparency Act and this
Guidance.
Who is required to file a FFATA
report in FSRS?
The FFATA Subaward Reporting
System (FSRS) will collect data
from Federal prime awardees on
subawards they make:
A prime grant awardee is
required to report on its sub-
grants, and
A prime contract awardee is
required to report on its sub
contracts.
Reporting Timeline for Prime Contractors
In accordance with Federal Acquisition Regulation clause
52.204-10 (Reporting Executive Compensation and First-
Tier Sub-contract Awards), Prime Contractors awarded a
federal contract or order are required to file a FFATA
subaward report by the end of the month following the
month in which the prime contractor awards any sub-
contract greater than $25,000.
The reporting timeline was phased-in. Starting March 1,
2011, reporting on all sub-contracts greater than $25,000
became mandatory.
Reporting Timeline for Grant Recipients
In accordance with 2 CFR Chapter i, Part 170 REPORTING subaward
AND EXECUTIVE COMPENSATION INFORMATION, Prime
Awardees awarded a federal grant are required to file a FFATA
subaward report by the end of the month following the month in
which the prime awardee awards any sub-grant equal to or greater
than $25,000. The reporting requirements are as follows:
This requirement is for both discretionary and non-discretionary
grants awarded on or after October l, 2010.
All subaward information must be reported by the prime awardee.
If an award recipient receives a grant from a federal
agency that is equal to or greater than $25,000, and
meets the other threshold criteria, the prime awardee
must report its own executive compensation data by:
A. The end of the month following the month the award
or obligation was made
B. Within six months from the date of the award
C. Within twelve months from the date of the award
D. By the end of the grant project
E. None of the above
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If an award recipient issues a subaward or subcontract to
another organization, is it required to report executive
compensation data of the subrecipient?
A. Yes, regardless of the amount awarded
B. No
C. Yes, if the award amount equals or exceeds $25,000
D. It depends on the Terms and Conditions of the award
E. All of the above
recipients to electronically report their
sub-award activity.
July 2010, launched "FSRS.gov" to serve
as the resource for prime awardees to
report on FFATA-required contract
sub-award activity and executive
compensation.
October 2010, "FSRS.gov" expanded to
incorporate FFATA-required grant
sub-award and executive compensation
reporting.
FSRS Awardee Login Page
FSRS System Overview
The FSRS System Overview
The Federal Funding Accountability and
Transparency Act (FFATA) necessitated a system
to allow prime grant award and prime contract
recipients to report sub-award activity and
executive compensation.
The FFATA Sub-award Reporting
System - FSRS.gov - is the system that
allows grant award and contract award
How do new users set up an account?
New Users:
Users point their browser to
https://www.FSRS.gov. Note: users do not need to
re-register if they have an existing Electronic
Subcontracting Reporting System (eSRS)
Contractor user account (www.esrs.gov).
1. The awardee clicks on the "Awardees"
link within the "Log-In" or "Register
Now" box
2. To register, the user clicks the "Register"
button under the "new awardees: register"
section.
3. The registrant completes the two step
process that opens (forms capture
registration data).
Note: Throughout the system a red asterisk (*)
designates that the field is required.
4. The user enters their organization's
DUNS Identification Number and clicks
the "Next" button.
5. Some form data may already be populated
on the form from SAM.gov. This is based
on the DUNS entered in step one.
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6. Users must complete all required fields
(indicated with a red asterisk) and click
the "submit" button.
7. After submitting this form, a confirmation
email is sent to the email address provided
during the registration. The confirmation
email presents instructions on how to
finalize the registration process. An
account is only activated after the user
follows the instructions presented in the
email that is sent to them.
8. After a user has confirmed their
registration, as outlined in the email that
they received, the user can return to the
Log-In page (see Existing Users, page 14
of the FSRS Users Guide -
https://www.fsrs.gov/documents/FSRS_Award
ee User Guide.pdf). They can then enter
their e-mail address and password (e-mail
address will be the user "login ID"), and
click the "Login" button, to login to
FSRS.
Terms of Use Agreement
1. All users are required to agree to the
Terms of Use for FSRS.
2. Use the side scroll bar resource to review
the terms and conditions in their entirety.
3. A user can click "OK" to move forward or
"Log-Off' to exit.
FSRS Awardee Home Page
it home
Ji alerts
. create FFATA
" report
announcements
2. The "Alerts" section shows messages that
require a user's attention.
3. "Announcements" are created by FSRS
administrators.
4. The quicklink buttons on the left hand
side of the screen allow users to quickly
create a new FFATA Report, or to link an
award to their work list. Please see the
corresponding sections of the FSRS Users
Guide for more information. (See link
above)
Creating a Profile
1. If a user clicks on "Profile" in the top
navigation menu bar, they can review
their core contact information on this
screen.
2. To edit profile information, the user
should click the "Edit" button. After
making desired changes, the user should
click the "submit" button to enter the
changes.
3. To change a password, users click on the
"Password" tab near the top of the page.
Users may enter a new password on that
page. The user should click "save
password" when done. For security
purposes, passwords must meet the
following criteria:
a. Must be between 10 and 14
characters
b. Must contain 2 of each of the
following: lower case letter, upper
case letter, number, special character
In FSRS, PrimeAwardees Can.
Manage FFATA Reports
- Search for an Award
- Create New FFATA Subaward Report
- Save Draft FFATA Subaward Report
- Delete Draft FFATA Subaward Report
- Submit New FFATA Subaward Report
- Reopen and Revise Submitted FFATA Subaward Report
- Copy Existing FFATA Subaward Report
- Manage FFATA Subaward Report List
- Submit Multiple FFATA Subaward Reports
Manage Awardee Worklist
- Organize Prime Awards Associated with Registered DUNS
-Search for Prime Award
- Add Prime Award to / Remove Prime Award from Worklist
Home Page Features
1. The Navigation bar at the top of the
screen allows users to move through the
system. This bar is available on every
screen throughout the system. Please read
"Section 2.2 Navigation Overview" of the
FSRS Users Guide for more information.
https://www.fsrs.gov/documents/FSRS Award
ee_User_Guide.pdf )
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Module 3: Federal Funding Accountability and Transparency Act
Overview of the Worklist
1. The Worklist main navigation allows the
prime awardee to manage and review the
awards for which they have reporting
responsibility.
2. The user can search for and add awards
(both contracts and grants awarded to
their registered DUNS number) to their
worklist from contracts reported in the
Federal Procurement Data System - Next
Generation (FPDS-NG) and grants
reported through the Agency's Federal
Assistance Award Data System
(FAADS+) submissions to USAspending.
3. From the worklist they can create new
FFATA sub-award reports against those
prime awards.
4. Users can view unassigned prime
contracts and/or grants awarded to their
registered DUNS number and add them to
their worklist.
5. This navigation provides a way to review
an award and all associated reports for
that award (view existing reports).
Step 2 - Enter Contract / Award # (1 of 3)
''.."" I.
Step 2 - Enter Contract / Award # (2 of 3)
Create New FFATA Subaward Report
T »»
.
31 "
announcements
Step 2 - Enter Contract / Award # (3 of 3)
Step 1 - Instructions
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Module 3: Federal Funding Accountability and Transparency Act
Step 3 - Grant Award Details
XFFATArepom
8T-
Step 4 - Prime Award Details (3 of 5)
Step 4 - Prime Award Details (1 of 5)
Step 4 - Prime Award Details (4 of 5)
Then answer 17
., " - '-
Step 4 - Prime Award Details (2 of 5)
Step 4 - Prime Award Details (5 of 5)
T--
m
s-
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 3: Federal Funding Accountability and Transparency Act
Step 5 - Subawardee Data (1 of 3)
Step 6 - Review
Step 5 - Subawardee Data (2 of 3)
'BB
Step 7 - Submit Report
Step 5 - Subawardee Data (3 of 3)
What is the FFATA Subaward Reporting
System (FSRS)?
A. A government contractor
B. An optional reporting tool
C. The reporting tool Federal prime awardees use
to capture and report subaward and executive
compensation data regarding their first-tier
subawards to meet reporting requirements
D. None of the above
E. All of the above
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Module 3: Federal Funding Accountability and Transparency Act
3. There is also a navigational link for the
FSD (help desk) contained in the lower
navigational bar that is presented when a
user is logged into the system.
4. Clicking the FSD link opens a transition
page introducing the Federal Service Desk
(FSD) where users can secure assistance.
5. The link to access the FSD is presented on
this screen (FSD.gov).
6. Users are automatically re-directed to the
FSD 30 seconds after navigating to the
transition page.
Service Desk (1 of 4)
Clicking on the "For
Help: Federal Service
Desk" link on the home
page, or anywhere within
the site, takes the user to
a splash screen
The user can either click
the logo to be quickly
redirected immediately
or wait 30 seconds and be
sent to the FSD home
Where Can I Find Help?
FSRS is one of several systems
served by the Federal Service
support
The FSRS home page has a
For Help: Federal Service
Desk link directing users to
the multi-channel FSD
FSRS also has system FAQs
posted on the home page and
again within the site on the
Resources Page
Service Desk (2 of 4)
The Help Desk
1. Users can access the Federal Service Desk
(FSD) directly from within the system.
FSD is the help desk organization that
provides help desk support for FSRS.gov.
1. A link to the FSD is presented on the
home page.
There are multiple ways to find
information within the FSD site; the
easiest is the Answer Center
Users can enter search terms in the box
or narrow the search by system
FSRS feeds the Answer Center with
new questions and updated
BB81BS,._
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Module 3: Federal Funding Accountability and Transparency Act
Service Desk (3 of 4)
Frequently Asked Questions (FAQ)
Enter search terms and the
results are provided with links
to other like
Service Desk (4 of 4)
Users can also establish an
account to use "Ask a Question"
web form
In addition, live FSD Customer Servic.
Representatives are available from 8
Friday at:'
l. U.S. Calls: 866-606-8220
2. International Calls: 334-206-7828
FFATAin a nutshell
Executive
Compensation
Data
about Sub-
recipients
80% or more
gross funding
from Federal
Awards
Public doesn't
already have
access to data
through the SEC
access througl
SEC
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Module 3: Federal Funding Accountability and Transparency Act
Questions? Contact:
Make sure to identify who is responsible
for coordinating FFATA requirements:
- DUNS number
n SAM Registration
- FSRS Database
Check to make sure you are in compliance!
Laurice Jones
U.S. Environmental Protection
Agency
Office of Grants and Debarment
1200 Pennsylvania Avenue, N.W.
Mail Code: sgosR
Washington, DC 20460
202-564-0223
Jones .laur ice(S epa. gov
Elizabeth January
Program Analyst
U.S. Environmental Protection
Agency
11 Technology Drive
Mail Code: EQA
N. Chelmsford, MA 01863
617-918-8655
January, elizabeth (S epamail.epa.gov
OR YOUR GRANT SPECIALIST!
Forms available for download athttD://www.eDa.gov/ogd/forms/forms.htm
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Module 3: Federal Funding Accountability and Transparency Act (FFATA)
Attachment to Module 3
Answers to Quizdom Actionpoint Questions
23
Are subawardees required to report information directly into FSRS in
compliance with this Guidance and the Transparency Act?
A. Yes
B. No
No. The prime awardee must report all information associated with a Federal grant, either
regarding executive compensation data for prime awardees or subawardees, or any other
information associated with subawards.
Thesubawardee, however, has an obligation to provide to the prime grant awardee all
information required for such reporting. This includes subawardee entity information, subawardee
DUNS number, subawardee Parent DUNS number, if applicable, and relevant executive
compensation data, if applicable. If the subawardee is registered in SAM, this information may be
migrated into FSRS to facilitate the prime awardee's reporting, as required under this guidance.
46
How long does it take to get a SAM application processed?
A. Within 24 hours
B. Two days
C. One week
D. Six Months
E. 3-5 days
New registrations can take an average of 3-5 business days to process in SAM. This timeframe may
be longer if the information you provide is flagged for manual validation. If you notice your
registration has had a "Submitted" status for longerthan 10 business days, and you have not
otherwise been contacted to correct or update information, please contact the Federal Service
Desk at 866-606-8220 or https://www.fsd.gov.
59
If an award recipient receives a grant from a federal agency that is equal to
or greater than $25,000, and meets the other threshold criteria, the prime
awardee must report its own executive compensation data by:
A. The end of the month following the month the award or
obligation was made
B. Within six months from the date of the award
C. Within twelve months from the date of the award
D. By the end of the grant project
E. None of the above
Prime awardees who meet threshold criteria must report executive compensation data by the end
of the month following the month the award or obligation was made. For example, if a Federal
agency awards a grant to a prime awarded on October 1, the prime awarded must report
executive compensation data by November 30.
Last Updated April 2013
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Module 3: Federal Funding Accountability and Transparency Act (FFATA)
62
font indicates correct ans
If an award recipient issues a subaward or subcontract to another
organization, is it required to report executive compensation data of the
subrecipient?
A. Yes, regardless of the amount awarded
B. No
C. Yes, if the award amount equals or exceeds $25,000
D. It depends on the Terms and Conditions of the award
E. All of the above
Yes, if the award amount equals or exceeds $25,000 the reporting of executive compensation of
the subrecipient is required.
Note:
If the initial award is below $25,000 but subsequent grant modifications result in a total award
equal to or over $25,000, the award will be subject to reporting requirements, as of the date the
award exceeds $25,000
If the initial award equals or exceeds $25,000 but funding is subsequently de-obligated such that
the tola I award amount falls below $25,000, the award continues to be subject to the reporting
requirements of the Transparency Act of this Guidance.
86
What is the FFATA Subaward Reporting System (FSRS)?
A. A government contractor
B. An optional reporting tool
C. The reporting tool Federal prime awardees use to capture and
report subaward and executive compensation data regarding
their first-tier subawards to meet reporting requirements
D. None of the above
E. All of the above
The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime awardees (i.e.
prime contractor and prime grant recipients) use to capture and report subaward and executive
compensation data regarding their first-tier subawards to meet FFATA reporting requirements.
Prime contract awardees will report against subcontracts awarded and prime grant awardees will
report against subgrants awarded. The subaward information entered in FSRS will then be
displayed on www.USASpending.gov associated with the prime award furthering Federal spending
transparency.
Last Updated April 2013
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Module 4: Grants Management Systems
Module 4: Grants Management Systems
Tribal, U.S. Territories and
Insular Areas Administrative and
Financial Guidance for
Assistance Aareements
Module 4:
Grants Management Systems
Module 4: Grants Management Systems
Required Systems
\.liiitnisIi-Mli\r ."
Guide the project
(iuide the people working on
the project
.\ssuir jKToun t;\bi lily
Identity roles and
responsibilities
Delegate authority
Monitor progress
.Assess results
Document the source of hinds
Determine how funds are
being used
Guide how money is controlled
Tracking and reporting
Financial systems guide how we control the
money. They tell us:
Where the money comes from
Who is authorized to spend it
How expenses are tracked and reported
A successful grants management system requires
the grantee to:
1. Have written policies and procedures,
2. That conform to federal requirements, and
3. Provide internal controls to ensure
policies and procedures are followed.
Responsibilities Timeline: Management
What is the most important reason why we
need administrative systems?
A. To assign personnel to specific tasks
B. To document the awards process
C. To ensure accountability and consistent
progress
D. To evaluate personnel according to EPA
standards
E. All of the above
Required Systems
Why do we need grants management systems?
Administrative systems guide the project and the
people working on it to assure accountability.
Administrative systems identity roles and
responsibilities for the delegation of authority, to
monitor progress, and assess results. Financial
systems help to document the source of funds and
determine how funds are being used.
Why do we need financial systems?
A. To document the source of funds
B. To determine how the funds arebeingused
C. To comply with regulations
D. Because there are so many objectives and costs
to track
E. All of the above
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Module 4: Grants Management Systems
One Financial System
Separate ('
Accounts
Separate
Accounts
Separate
Accounts
Tribal Nation
Why are financial systems so important?
The source of funds (where the money comes
from) is especially important when a Tribal Nation
has multiple funding sources: EPA, Bureau of
Indian Affairs (BIA), Indian Health Service (IHS),
U.S. Department of Agriculture (USDA), Housing
and Urban Development (HUD).
When a Tribal Nation accepts an assistance
agreement award from any federal agency, it must
set up a separate set of expense and revenue
accounts to track those funds. The funds received
from EPA need to be reported separately from
funds generated through Tribal businesses and
other federal assistance agreement awards. If funds
are not reported separately, it could jeopardize the
Tribal Nation's ability to receive future funds.
Why are administrative and financial
systems so important?
A. Written policies assure consistent
management
B. Each award needs to be tracked separately
C. Written procedures ensure control of all
awards
D. Regulations require these systems
E. All of the above
Improve Your Grants Management System
Some grants can be re\ised to provide funds for
system improvements.
Ask your EPA Project Officer for details.
Obje
Computer and <
SFTE % of Total Funds Costs per FY
25%
30%
100%
15%
10%
45%
$7,500
$5,000
$22,500
$15,000
Sample Budget Summary: Financial Systems Upgiade
Can we use award funds to develop or improve
grants management systems?
Yes, especially if you have a General Assistance
Program (GAP) grant. Tribal Nations need to have
administrative and financial systems in place to
properly implement grants and provide accurate
reports to EPA after an assistance agreement is
awarded.
Does your Tribal Nation want to improve
administrative and/or financial systems?
Does your Tribal Nation have a General
Assistance Program (GAP) grant?
A revision can be made to some assistance
agreement awards, which allows a Tribal Nation to
use part of the funds and work hours to assist in
developing, implementing, or improving the Tribal
Nation's grants management systems. If your
Tribal Nation applies for a General Assistance
Program (GAP) grant, and you want to improve the
administrative and/or financial systems, explain
what you wish to do in the work plan. The EPA
Project Officer must approve adjustments and
revisions to your Tribal Nation's General
Assistance Program work plan.
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Module 4: Grants Management Systems
Table 2: Standard Industry Classification (SIC) Codes
How can General Assistance Program award
funds be used on grants management
systems?
A. To develop ne\v components
P. To develop new strategies
C. To improve existing systems
D. Only when written into the GAP work plan
E. All of the above
Record Keeping is Crucial
Having up-to-date and accurate information is
critical for managing financial accounts, and:
Forms the basis for providing information to
decision makers
Allows for the comparison of budgets with actual
expenditures
What is the value of a record keeping system?
A Tribal Nation needs to know how funds are
being used. Tribal Nations need to know:
Which programs or projects are the funds
being applied against?
Who or which organization within the Tribal
Nation is using the funds?
Who requested and who authorized the
expenditures?
Are the funds being spent according to the
EPA-approved budget?
Are the funds spent in accordance with
applicable federal cost standards?
Are the funds being spent within the agreed
upon budget?
For example, Standard Industry Classification
(SIC) codes are used by accountants as reference
codes for line items.
Good management is all about the paperwork.
Standard Industry Classification (SIC) codes
The following standard industrial classification codes maybe relevant
on EPA funded projects.
Activity
Construction
SIC Code
Industrial buildings
Heavy construction water/sewer
Other heavy construction (non-residential)
Concrete work
Excavation work
1541
1623
1629
1771
1794
Equipment/Supplies
Services
Manufacturers
If items purchased from manufacturer
Office furniture 2521, 2522, 2531, 2441, 2424, 2591, 2599
Office supplies (paper, etc.) 2676, 2677, 2678
Computer/Office 3571, 3572, 3575, 3577, 3578, 3579
Lab equipment 3826, 3829
Retail Equipment/Suppliers
Courier services
Local tracking
Travel agencies
Telephone services
Clean-up (oil spills, pesticides)
Furniture sales (office)
Office equipment
Computer
Office supplies
Motor Vehicle Supplies
Wholesale sales
Parts
Tires
Dealers
Gasoline
Motor Vehicle Services
Rental (cars)
Rental (tracks)
Motor vehicle repairs
Computer Services
Rental
Maintenance
Professional Services
Engineering services
Architects
Surveyors
Accountants
Testing laboratories
Miscellaneous Services
Hotels
Photocopying
Pest control
Janitorial
4215
4212
4724
4822
4959
5021
5044
5045
5046
5012
5013,5015,5531
5014
5511
5541
7514
7513
7532-7539
7377
7378, 7379
8711
8712
8713
8721
8734
7011
7334
7342
7349
Air conditioning/heating service and repair 7623
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Module 4: Grants Management Systems
Tribal Nations can see from the explanations and
examples provided that having up-to-date and
accurate information is critical for managing the
Tribal Nation's financial business. Grants
management systems help to ensure that what the
Tribal Leaders have agreed to is being
accomplished in an effective and efficient manner.
Systems facilitate communication while
providing checks and balances for effective
internal control.
Tribal leaders I Administrators
'inance Office
Grants
Management
Team
Systems Implementation
How should we structure our administrative
systems?
Administrative systems establish methods for
compliance with grant requirements through:
Operational effectiveness and efficiency
A workable system of internal controls
Updates to written grants management
policies and procedures, as needed
Effective checks and balances
Separation of duties
Clearly defined lines of authority
Adequate administrative systems provide accurate
and reliable information. In a system of checks and
balances, duties are separated and assigned to
trained and experienced personnel. Administrative
personnel typically include Tribal Leaders, a
general manager, a grants manager, and a financial
officer.
Tasks can be monitored and reminders provided by
other groups, so reports are accurate and filed on
time. Division of responsibilities prevents total
control of funds by one group or individual.
Supervisors in each department regularly review
the work in other departments to ensure all
essential functions are performed as proposed.
Linear or
Hierarchical
Systems
A linear or
hierarchical
system does
not provide the
necessary
internal
control.
Each
department is
separate from
the other.
Communicatio
n flows in only
one direction
(usually from
the top down).
Decisions are
made by a
single
individual.
Circular or Flat
Systems
A circular or flat
system of control
provides checks
and balances
necessary for
effective internal
control.
Work is processed
by three people to
avoid errors.
All departments
work together
sharing information
vital to project
success.
Information flows
in all directions
facilitating the
decision making
process.
Decisions are made
based on input from
teams of people.
Figure 17: Administrative Systems Control
Communication between all groups or individuals
involved in the grant is very important to ensure
the systems are set up properly. Administrative
personnel should meet periodically to discuss the
grant and determine if the systems are working
properly and update the written policies and
procedures when necessary.
Having a comprehensive administrative and
financial system in place will greatly enhance a
Tribal Nation's ability to achieve award objectives.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 4: Grants Management Systems
A financial system should:
1 Provide accurate and complete disclosure of
financial results
Adequate!}'identify source and use of funds
1 Establish effective controls and accountability
for all grant assets, including:
- Cash
° Accounts Receivables
° Equipment
" Buildings
- Etc.
EPA reviews a Tribal Nation's written policies and
procedures to help determine the adequacy of the
system. The intended use of this training manual is
to identify and describe the elements a Tribal
Nation's business and financial operations must
have in order to apply for and accurately report on
the financial activities of each EPA assistance
agreement awarded to them.
For example, a financial policy and
procedure might authorize the
environmental program director to review
accounting entries to ensure accuracy. The
person that makes deposits should not be
the same person that balances the accounts.
Trust, but verify.
A financial system should: (continued)
Compare actual expenditures to the budgeted
amounts
Ensure applicable Office of Management and
Budget cost principles are followed
Maintain adequate support documentation
Maintain adequate cash management
procedures
How do we set up grants management systems?
The systems explained in this training manual are
systems that a Tribal Nation should have, not only
to report on EPA and other federal government
projects, but also to administer the Tribal Nation's
financial resources effectively and report back to
Tribal Leaders.
EPA does not require a Tribal Nation to install,
implement, or purchase any specific accounting,
management, financial, budgeting, integrated
system, or information technology. However, EPA
does require there be a financial management
system that:
Provides accurate and complete disclosure
of financial results
Adequately identifies source and use of
funds
Establishes effective controls and
accountability for all grant assets, including
cash, supplies, equipment, buildings, etc.
Is able to compare actual expenditures to the
budgeted amounts
Ensures applicable Office of Management
and Budget cost principles are followed
Maintains adequate support documentation
Maintains adequate cash management
procedures
Learner Notes
Please take a few minutes to do Activity
4.a (found online at www.petetribal.orgX
You will search the Appendix to locate
key information, such as federal codes,
goals and objectives for administrative and
financial guidance, checklists, surveys, the
onsite questionnaire, and examples of
policies and procedures. Knowing where
to find the information is "half the battle"
when managing federal grants.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 4: Grants Management Systems
Which systems are required to comply with
federal and EPA regulations?
A. Administrative and financial systems
supported by written policies and procedures
B. A computerized accounting system supported
by standardized financial forms
C. Separate financial systems for each award
D. Formal evaluation systems
E. All of the abi >ve
Internal Review and Approval Process
Everyone must agree and sign their approval
Internal Review and Approval
Processes
What policies and procedures are needed?
A Tribal Nation should have written policies and
procedures that identify responsibilities in the
process. A single individual should be responsible
within each process for granting approval or
concurrence on official documents by signing his
or her name.
For many Tribal Nations, the process will require
approvals or concurrence from Tribal Leaders,
program administration, financial and budget
personnel, and/or human resources. This process
may take a few weeks or more.
Learner Notes
The administrative and financial structures
described below are generalized examples.
Individual Tribal Nations may structure
their systems differently.
Human Subjects at Risk
Tribal Nations may find the Institutional Review
Board (IRB) internal review process to he a
helpful grants management strategy.
A written policy on research involving human
subjects is required for all EPA projects.
The National Science Foundation (NSF) has
expanded the definition of "risk". NSF now
requires proposals to go through an internal review
process. An Institutional Review Board (IRB) is
established by the grant recipient to review
proposals before they are submitted. An IRB will
determine if there is human risk involved in the
project. This process assures that research
involving human subjects protects those subjects
from risk.
Human Risk now includes any "soft or social
science" (personal) questions, such as those found
on an average survey. Any questions that can be
traced back to the person responding are now
covered under the definition of Human Risk. The
expansion of this definition protects personal and
community information from misuse made possible
by new technologies. With advancements in
computer science, it is now possible to trace
seemingly disparate information back to the person
interviewed.
An Institutional Review Board is developed by the
grant recipient. Tribal Nations may find the
institutional review board, internal review process
to be a helpful grants management strategy. For
NSF and EPA the IRB process requires a written
policy. A written policy might include:
The Tribal Nation does not
conduct research involving
human subjects and is
therefore exempt from the
Basic Health and Human
Services Policy for Protection
of Human Research Subjects
as stated in 45 CFR 46.101.
No human beings will be at
risk from involvement in this
EPA project as determined
by an Institutional Review
Board.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
tast Updated April 2013 Page 100 of 279
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Module 4: Grants Management Systems
Administrative Unit
Grants Management
Identify or approve parties responsible for:
Writing
° Reviewing
- Approving
° Signing
Applications, awards, and anic-iidmenls
Communicating \vith EPA
Administration
What should an administrative unit do to ensure
the application approval process flows smoothly?
Part of the administrative unit's role in the
application approval process is to identify or
approve parties responsible for writing, reviewing,
approving, and signing applications, awards, and
amendments, and communicating with EPA.
Administrative approval should clearly indicate
which individuals within the Tribal Nation's
leadership have authority to approve a funding
assistance application.
Monitor and oversee awards once they are
received from EPA.
Ensure compliance \\ith EPA's "terms and
conditions".
Authorized Certifying Official
Named on the award document
Responsible for ensuring compliance with
federal regulations
This approval process is usually tied to the
administration functions in the organizational
chart, which identifies departments with
responsible parties listed first. The designated party
is the Authorized Certifying Official named on
the award document. The Authorized Certifying
Official is responsible for ensuring compliance
with federal regulations.
Grants Management
What is the role of grants management?
Grants management's role is to monitor and
oversee awards once they are received from EPA.
Management procedures ensure compliance with
EPA's "terms and conditions".
Grants Managers are typically responsible for:
Ensuring compliance with EPA "terms and
conditions"
Submitting programmatic progress reports to
EPA
Regularly communicating with the EPA
regional office personnel
Tracking, monitoring, and reporting on
environmental results
Establishing and obtaining approval of a
quality action plan (QAP if required).
Your region may refer to this as a:
Quality Assurance Project Plan
(QAPP),
Quality Management Plan
(QMP), or
Tribal Quality Action Plan
(TQAP).
Larger Tribal Governments may have a Grants and
Contract Analyst or Administrator to coordinate
administrative requirements.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 4: Grants Management Systems
-SK
Finance
Ensure proper tracking of:
= Funds received and disbursed
0 Costs incurred
' Payments nuidt-
Establishing new accounts, reports, and cost
centers
Finance
What is the role of the finance department?
Financial policies and procedures are important to
ensure that program and financial personnel within
a Tribal Nation are informed about proposed
projects and can ensure proper tracking of funds,
received and disbursed, costs incurred, and
payments made (e.g., establishing new accounts,
new reports, and new cost centers).
The finance department ensures policies and
procedures comply with EPA regulations for cash
management and closeout of awards after the
performance and budget periods. Reports are
scheduled and completed on a regular basis.
An internal auditor, audit staff, or Tribal
Administrator arranges an independent audit of the
accounting and financial management process,
cash receipts and payments, and safeguarding of
assets. This assures their internal controls are
maintained for all assets.
The Chief Financial Officer (sometimes the
Treasurer) is responsible for:
Establishing:
o Accounts
o Cost centers
Tracking:
o Funds (received and disbursed)
o Costs incurred
o Payments made
Complying with EPA regulations
Submitting financial status reports
Arranging Audits
o Filing OMB A-133 single audit
statements
Safeguarding assets
Closing out awards
Accounting
The budget and accounting process ensures:
" Award funds
ij Program income, and
c Matching funds are:
Identified
Authorized
unted lor, and
Limitations pbeed on usage
Accounting
How does the budget and accounting function
work within the finance process?
Some Tribal nations maintain a separate
accounting department. The budget and
accounting process ensures award funds,
program income, and matching funds are
identified, authorized, accounted for, and
limitations placed on usage. Someone other than
the finance department should be involved in the
budget and accounting process.
At least monthly, environmental directors should
review the budget as entered in the accounting
system and accounting entries made to the funds
for which they are responsible. If the budget and
accounting review process is separate from the
financial process it gives Tribal Leaders assurance
that it is within the Tribal Nation's resources to
complete the project and use of project funds is
beneficial to the Nation.
Accountants:
Make entries in project accounts
Ensure expenditures are reasonable,
allowable, and allocable
Provide monthly budget statements
Learner Notes
Some Tribal Nations have separate finance
and accounting departments. If so, policies
and procedures need to be clearly defined
so that each department knows what must
be done and who is responsible.
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Module 4: Grants Management Systems
Human Resources
Written policies and procedures establish:
Sulury Wildes mul sUmdurds for each pi >siti< >n
* Describing the
I >u lies
KespoHMliililk-s. ,UK!
Actions expected
Which administrative unit ensures proper
tracking and reporting of award funds?
A. Administration
B. Grants Management
C. Finance
D. Accounting
E. Human resources
Human Resources
Which functions could human resources manage?
The human resources department ensures that the
costs associated with the project's human capital
are identified correctly and appropriate costs are
charged to the project.
Written policies and procedures establish salary
ranges and standards for each position, describing
the duties, responsibilities, and actions expected.
Also, when there are new employees to be hired, a
Tribal Nation can plan a recruiting strategy.
Human resource policies and procedures establish
standards for each project position, such as:
Salary ranges
Recruitment
Hiring and firing
Benefits
Duty and responsibility descriptions
The human resources process manages personnel
functions, such as employment, and may include
payroll, leave, benefits, conflict of interest, travel
policy, etc., even if the finance units do not.
Human resources personnel may manage functions,
such as:
Payroll
Authorizations and vouchers
Signature routing
File initiation and maintenance
Conflict resolution
Which administrative unit manages
personnel?
A. Administration
B. Grants Management
C. Finance
D. Accounting
E. Human resources
Which administrative unit approves a party as
the authorized certifying official?
A. Administration
B. Grants Management
O. Finance
D. Accounting
E. Human resources
Which administrative unit monitors
progress and compliance?
A. Administration
B. Grants Management
C. Finance
D. Accounting
E. Human resources
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Module 4: Grants Management Systems
Which administrative unit ensures budgetary
records are accurate?
A. Administration
B. Grants Management
C. Finance
D. Accounting
E. Human resources
Organizational Policies and Procedures
Organizational Policies and
Procedures
What written organizational policies and
procedures are necessary for proper grants
management?
A Tribal Nation should have the following policies
and procedures documented in their management
systems. Nations may choose to have additional
written policies and procedures in place. Only the
basic ones are described in this manual.
Policies and procedures described in this manual
include:
Application review and approval process
Documentation process for financial and
programmatic recordkeeping
Internal controls for protection of EPA
funds
Personnel and payroll processes
Time and effort tracking, monitoring
and reporting; conflict of interest
disclosure; and codes of conduct
Financial management
EPA-Electronic Funds Transfer
enrollment and processing functions
Procurement (equipment, supplies,
and services)
Organizational chart with administrative
policies for checks and balances and
internal controls with defined lines of
authority
Personnel and payroll processes
are described in Module 5.
Organizational Chart
Organizational Chart
How can an organizational chart help?
Internal control policies should include an
approved organizational chart showing various
responsibility centers within the Tribal Nation. The
chart aligns with administrative procedures for
checks and balances on internal systems with
clearly defined lines of authority.
An organizational chart is helpful to have when
initiating the grant application process. It helps to
identify key personnel and show EPA that the
Tribal Nation has the ability to properly manage
the grant.
One benefit of having an updated
organizational chart is to ensure better
communications and understanding
within a Tribal Nation's organizations.
Additional benefits may include teaching
visitors and federal agencies how the
Tribal Nation's government is
organized. The organizational chart also
helps to educate others on a Tribal
Nation's cultural values.
If a Tribal Nation does not have something
showing responsibilities and workflow, it becomes
more difficult for the organization to ensure proper
procedures and processes are followed by the
individuals involved in applying or accepting
responsibility for EPA funds. However, an
effective system enables personnel to work
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Module 4: Grants Management Systems
together, within and between departments, to
ensure work is complete and of good quality.
Learner Notes
Activity 4.b (found online at
www.petetribal.org') asks you to sketch an
organizational chart for your Tribal
Nation's administrative and financial
systems. Knowing who is responsible for
what makes work a lot easier.
What does an organizational chart do?
A. Delineate various responsibility centers within
the Tribal Nation
B. Facilitate communications and understanding
within a Tribal Nation's organizations
C. Educate others about how the Tribal Nation's
government is organized
D. Show that a Tribal Nation has the
capabilities to manage an EPA grant ^ \
E. All of the above ^'
Documentation Process
' Demonstrates
how funds are:
° Controlled
° Disbursed
° Safeguarded
Include records
from project
development up
to and including
the final closeout
letter
Documentation Process
What kind of documentation process needs to be
in place?
A paper trail of all required documents with
signatures should be kept on file and made
available to anyone concerned. Once a Tribal
Nation accepts an award, they agree to provide
documentation to EPA demonstrating how funds
are controlled, disbursed, and safeguarded.
A signature sheet (similar to the sample pictured
below) should be circulated with the application
package. Official signatures indicate the enclosed
EPA assistance agreement application has been
reviewed and approved.
Signature Sheet
Authorized Certifying Official
Grants Management
Finance
Accounting
Human Resources
Circulate a signature sheet \\ith the application
package to ensure department heads have
renewed and approved the project plan.
Documentation of procedures and policies may
include:
Official written policies detailing the
procedures listed in the application review
and approval process
Official file(s) showing all documentation
starting with the:
Initial application
Additional guidance received from EPA
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Module 4: Grants Management Systems
Official signed assistance agreement
award document granting funds to the
Tribal Nation
Revisions or adjustments to the award
Official file(s) holding all documentation,
both programmatic and financial, once the
assistance agreement is received from
EPA and accepted by the Tribal Nation
The documentation process should include records
from project development up to and including the
final closeout letter. Records must be kept for at
least three years and possibly up to ten years
following receipt of the closeout letter.
remedied immediately. It won't have time to
become a bigger problem.
Ketfuill documents
pertainingto a single
project together.
Folders in the grants management file include
anything with a signature, such as:
Narrative
Budget
Budget modifications
Communications with EPA officials
Partnerships with sub-awardees and
contractors
Progress reports
Financial status reports
Closeout
Keep records safe. Don't rely on forensic
accounting to recreate files. Backup all paper
copies with electronic versions and store backup
files in an off-site location. In the eyes of federal
agencies, "If you don't have documentation,
then it never happened."
EPA recommends you email a summary of your
understanding after a face-to-face or phone
conversation. This way both parties have a record
of what was discussed and any decisions that were
made. If there is any misunderstanding, it can be
Documentation should:
A. Include \vritten policies and procedures
B. Demonstrate how funds are managed
0. Track programmatic progress
IX Maintain financial and accounting records
E. All of the above
Internal Controls
Ensure funds are:
= Protected from:
Waste
Fraud
Abuse
Mismanagement
° Managed by trained personnel using accurate and
reliable accounting practices
" Managed in a way that complies with all
applicable laws and regulations
Internal Controls
How do we protect the funds?
All award recipients should have administrative
and financial policies and procedures in place to
provide internal controls that reasonably ensure
funds are protected from:
Waste
Fraud
Abuse
Mismanagement
Managed by accurate and reliable
accounting practices and personnel
Managed in a way that complies with all
applicable laws and regulations
These policies and procedures are especially
important once an EPA assistance agreement is
accepted by a Tribal Nation. These policies and
procedures are necessary to show that actual
practices of the Tribal Nation are being carried out
as prescribed in the "terms and conditions" of the
award document.
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Module 4: Grants Management Systems
Examples of Internal Controls
Signatures
Duplicationofservices
Audits
Training
Oversight
Authorization
Trip reports
Copies of Invoices
- MonthlyrecondKationof
program records
Establish a policy for effective communication and transition consistency
Inventory
Follow-up emails
Tagging of equip me nt a nd
supplies
Regular meetings
Bate and initial stamps
Checks andbalances
Monthly review of general ledger
Conflict of li
Reflection
Consider your own systems:
What policies and procedures
are in place to comply with
EPA's cash management
requirements?
How can you improve on
current protection practices?
Do you use an internal or
external auditor to
independently review
accounting and financial
management processes, cash
receipts and payments and
safeguarding of assets?
Grant recipients must have a
conflict of interest policy
that clearly defines
disciplinary actions and/or
consequences for non-compliance.
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Module 4: Grants Management Systems
Attachment to Module 4
Answers to Quizdom Actionpoint Questions
uestion (bold font indicates correct answer
What is the most important reason why we need administrative systems?
A. To assign personnel to specific tasks
B. To document the awards process
C. To ensure accountability and consistent progress
D. To evaluate personnel according to EPA standards
E. All of the above
An administrative system ensures the Tribal Nation's award projects address the goals
and objectives stated in the work plan and continue to make sufficient progress toward
achievement.
Why do we need financial systems?
A. To document the source of funds
B. To determine how the funds are being used
C. To comply with regulations
D. Because there are so many objectives and costs to track
E. All of the above
Documenting the source of funds and how the funds are used help a Tribal Nation
comply with EPA regulations that require tracking the many objectives and tasks
involved in an award project and the costs required to accomplish the objectives.
12
Why are administrative and financial systems so important?
A. Written policies assure consistent management
B. Each award needs to be tracked separately
C. Written procedures ensure control of all awards
D. Regulations require these systems
E. All of the above
The funds received from EPA need to be reported separately from funds generated
through Tribal businesses and otherfederal assistance agreement awards. Systems
facilitate communication while providing checks and balances for effective internal
control.
16
How can General Assistance Program award funds be used on grants management systems?
A. To develop new components
B. To develop new strategies
C. To improve existing systems
D. Only when written into the GAP work plan
E. All of the above
If your Tribal Nation has a General Assistance Program (GAP) grant, you may use part of
the funds and work hours to assist in developing or improving grants management
systems.
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Module 4: Grants Management Systems
24
Question (boldfoi
Which systems are required to comply with federal and EPA regulations?
A. Administrative and financial systems supported by written policies and
procedures
B. A computerized accounting system supported by standardized financial
forms
C. Separate financial systems for each award
D. Formal evaluation systems
E. All of the above
Administrative and financial systems must be in place but they need not be
computerized, formally evaluated, or separate from other systems serving the Tribal
Nation. Establish one system with separate accounts for each federal award.
35
Which administrative unit ensures proper tracking and reporting of award funds?
A. Administration
B. Grants Management
C. Finance
D. Accounting
E. Human resources
37
Which administrative unit manages personnel?
A. Administration
B. Grants Management
C. Finance
D. Accounting
E. Human resources
39
Why administrative unit approves a party as the authorized certifying official?
A. Administration
B. Grants Management
C. Finance
D. Accounting
E. Human resources
41
Which administrative unit monitors progress and compliance?
A. Administration
B. Grants Management
C. Finance
D. Accounting
E. Human resources
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Module 4: Grants Management Systems
Which administrative unit ensures budgetary records are accurate?
A. Administration
B. Grants Management
C. Finance
D. Accounting
E. Human resources
YourTribal Nation may have different names for each of these administrative
responsibilities and the personnel charged with implementing policies and procedures.
The essential functions remain and acceptance of an EPA assistance agreement award
means you agree to manage those functions in accordance with EPA rules and
regulations.
49
What does an organizational chart do?
A. Delineate various responsibility centers within the Tribal Nation
B. Facilitate communications and understanding within a Tribal Nation's
organizations
Educate others about how the Tribal Nation's government is organized
Show that a Tribal Nation has the
capabilities to manage an EPA grant
All of the above
An organizational chart facilitates communications and understanding within a Tribal
Nation's operating organizations.
C.
D.
E.
55
Documentation should:
A. Include written policies and procedures
B. Demonstrate how funds are managed
C. Track programmatic progress
D. Maintain financial and accounting records
E. All of the above
Documentation is extremely important. Keeping records of all plans and activities
enable a Tribal Nation to explain how the award was used.
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Module 5: Administrative System Components
Module 5: Administrative System Components
Tribal, U.S. Territories and
Insular Areas Administrative and
Financial Guidance for
Assistance Agreements
Modules:
Administrative System
Components
Module 5: Administrative System Components
Module 9; Disadvant
Business EntEtprjs;
Module 10: Assistance
AgreementMOQUcrtig and
Module i: The Grant
Application Process
Modules Assistance
Agreements
Module 3: Federal
Funding ActBuntatiiry
andTransparaicyAa
Module 6: Financial system
Requi rements
Module ~ Accounting Pol
and procedure
Modules: source
Module 4: Grants
Management svstans
Module 5:
Administrative
If you do not already have administrative and
financial management policies and procedures,
contact your EPA regional Grants Specialist. Your
specialist will be happy to help.
Administrative System Components
What are some of the most important
administrative requirements to be addressed in
our written policies and procedures?
Personnel and payroll, along with financial policies
and procedures, need to be in place and in writing
in order to comply with the requirements of an
EPA award. Written personnel and payroll policies
and procedures can be used for good management
of a Tribal Nation as well as for EPA awards.
Key administrative requirements to be addressed
include the following:
Personnel
Payroll
Travel
Non-federal Contributions or recipient
match
Program Income
Procurement (includes purchasing)
Cost and Price Analysis
Records
Administrative and financial regulations with
which the recipient must comply are listed in OMB
Circular A-87 and 40 CFR 31 provided in the
Appendix. The Tribal Nation's policies and
procedures should address each "item of cost" that
applies to their grants management program.
If you have administrative and financial
management policies and procedures,
make sure they are reasonable conditions an
ordinary person can live up to.
Administrative System Components
andrnct
Analysis
harin&Mat
and In-kind
Program Income
Personnel
Personnel
What information do we need in our personnel
policies and procedures?
The Code of Federal Regulations and Office of
Management and Budget Circulars recommend
organizations receiving federal awards have
Personnel and Payroll policies and procedures that
address:
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Module 5: Administrative System Components
Personnel working on the award or
subaward(s)
Qualifications for each position
Duties and responsibilities
Salary ranges
Conflict of Interest Disclosure forms
The Tribal Nation's Equal Employment
Opportunity (EEO) policy*
Annual performance appraisals
Types and levels of fringe benefits
Standards of conduct governing duties and
responsibilities (also called "Codes of
Conduct")
Disciplinary actions for not adhering to the
standards
*Though Tribal Nations may be exempt from many
aspects of the Equal Employment Opportunity
policy, they are required by federal law to follow
and enforce sexual harassment law.
For example:
It is the Tribal Nation's
policy to ensure Equal
Employment Opportunity for
all employees and applicants
regardless of their race,
color, religion, sex, age,
national origin, and sexual
orientation, mental or
physical disability.
Discrimination and sexual
harassment policies are
strictly enforced. In
accordance with federal
guidelines, the Tribal Nation
maintains an affirmative
employment and
disadvantaged business
enterprise outreach
program.
Personnel regulations are explained in the OMB
Circular A-87, Sections Compensation for
personnel services provided in the Appendix. The
OMB Circular A-87 can be downloaded at
http://www.whitehouse. gov/omb/circulars/a087/a87 200
4.pdf.
Reflection
Pause a moment to consider your own
situation.
Do your personnel policies
include all of the above
information?
Do your policies provide
adequate separation of duties?
What information do you need to
add to your files?
How can this additional
information benefit your Tribal
Nation?
Payroll
The Payroll Process
What requirements should be addressed in
payroll policies and procedures?
Most Tribal Nations have a centralized payroll
department. This is a good internal control and is
useful for a Tribal Nation in protecting its funds
from fraud, waste, and/or misappropriation.
The payroll department should have in place
written policies and procedures detailing:
How employees get paid and how often
they are paid
The information needed on the time sheets
When to turn time sheets in and to whom
Supervisory review of timesheets
Proper allocation of pay and benefits
Pay grades
Deductions
W-4s and I-9s
Fringe benefits
Employer and employee paid benefits
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Module 5: Administrative System Components
Allocating Personnel Time
Hours Worked and Documented onTimesheet
100%
4Ohrs
20% 50% 30% 10W 90%
Shrs 20hrs 12 hrs 4hrs 36 hi
EPA EPA PPG NSF EPA Tribal
Semi-Annual Reporting Timesheets Timesheets
*
K
No one project can be funded for more than 100
percent of personnel time. If a project is funded
by multiple sources, the total funding from all
sources cannot exceed 100 percent of the time
allocated in the grant budget.
The payroll department should also have
information regarding how the financial
information from the payroll system is used in a
Tribal Nation's overall accounting system. When
there is no central payroll department, the same
rules apply for each program handling their own
payroll.
Grants must be charged actual hours worked. If pay
is based on budget hours, accounting must
reconcile the actual payroll expended with budget
hours predicted.
The Appendix contains the OMB Circular A-87,
Section 8.h regulations for payroll processing and
internal controls.
Reflection
Consider your own situation again.
Does your organization have written
payroll policies and procedures?
How does your payroll
process protect project
funds?
Are salaries and wage rates
established, authorized, and
approved in your organization to
ensure equity?
Does your payroll process ensure
that all deductions from employee's
salaries are:
Authorized by the employee?
Properly applied?
How are payrolls distributed?
If checks are distributed
manually, are there sufficient
controls to ensure that
payroll checks are distributed
to the correct employee?
How might your system be
improved?
Sample Timesheet
Which of the following is the most important
requirement of an EPA payroll processing
system?
A. Pay grades
B. Timesheets
C. Internal controls
D. How employees are paid
E. All of the above
How should time sheets be prepared?
Time sheets for staff are required when and if
employees are charging their time and effort to
more than one funding source. An employee
charging time to a single funding source only
requires a signed certification prepared at least
semi-annually.
Each employee's time sheet must show:
Employee name
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Module 5: Administrative System Components
Department/ department charge code
Hours worked on the project(s), by date
Tasks performed
If an employee works on more than one project
during the pay period, list the actual hours
worked on each project (not estimated or
allocated hours). Do not fill out timesheets in
advance of hours worked, even if you work the
same hours each week. The payroll department
should have "charge codes" that are issued to the
departmental managers to ensure proper charging.
The procedures should include where the
manager/time keeper submits approved time sheets
for payroll processing.
Grant recipients may use their own time
sheets. The following is a model.
Grantees without their own forms are
encouraged to adopt this form.
Learner Notes
Activity 5.a (found at www.petetribal.org')
asks you to examine the sample timesheet
on the previous page. Sick leave is paid
out of fringe benefits accrued. (See the
bottom left-hand corner.)
Appendix document OMB Circular A-87, Section
8.h contains the regulations for time reporting.
Which of the following does not need to be
included on personnel time sheets?
A. Employee's name
B. Employee's social security number
C. Hours worked and on which project
D. Department/project budget codes
E. Department for which the employee works
"-ssr.
Personnel time sheets track work by the:
A. Employee's social security number
B. Hours worked and on which project
C. Inventor)' codes and dates
D. Project name and task responsibilities
E. All of the above
Fringe Benefits
Fringe benefits are services,
privileges, or compensation
to employees in addition to
salary, such as:
= Serial security contributions
(patent InsuranceconmturioniAcc-FICA)
° Worker's compensation
a Retirement plans
= Insurance
Benefits
What are fringe benefits?
Fringe benefits are services, privileges, or
compensation to employees in addition to salary,
such as:
Social security contributions (Federal
Insurance Contributions Act (PICA) tax)
Worker's compensation
Retirement plans
Insurance
And perks, like membership dues to a
health club or professional organization.
All fringe benefits are charged to the grant as a
single line item.
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Module 5: Administrative System Components
Table 3: Sample Timesheet
Example Tribe Environmental Protection Program
Employee: Jane Doe
I.D. No.: 9876
Department: Grants Management
Primary Program: EPA Grant and Loan Projects
Program/Activity
106WQ
Air Pollution
GAP
Pesticides
Non-federal activity 1
Non-federal activity 2
Indirect activity
Total Regular
Annual
Sick
Comp
Holiday
Admin
School Act.
LWOP
Sun
11/9
0
Begin Balance
Hours Earned
Hours Available
Hours Used
Ending Balance
Mon
11/10
5
3
8
Tue
11/11
8
8
Annual
120
80
80
0
80
76
Wed
11/12
8
8
Thu
11/13
6
2
8
Sick
80
4
84
8
0
Comp
0
0
0
0
Supervisor
Fri
11/14
8
8
Sat
11/15
0
Pay Period:
Beginning Date:
Ending Date:
Sun
11/16
0
Mon
11/17
0
8
Tue
11/18
5
3
8
11/09/11
11/22/11
Wed
11/19
8
8
Thu
11/20
8
8
Fri
11/21
8
8
Sat
11/22
0
(input beginning date)
Total
Hours
48
18
0
0
6
0
0
72
0
8
0
0
0
0
0
Payroll
Allocation %
67%
25%
0%
0%
8%
0%
0%
100%
JS
v g,
Q> 0)
"CD ^
BO
2 '-8
ll
= «
0 c
-c o
8 "8 e.
|8S
h- -a -n
I certify that the time distribution presented above is a true and accurate accounting of activities/programs I worked during the pay period.
fate'Doe 11/23/2011
Employee
fae Jena
Date
11/24/2011
Date
Last Updated April 2013
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Module 5: Administrative System Components
According to the OMB Circular A-87, Section 8(d):
d. Fringe benefits.
(1) Fringe benefits are allowances and services provided by employers to their employees
as compensation in addition to regular salaries and wages. Fringe benefits include, but
are not limited to, the costs of leave, employee insurance, pensions, and unemployment
benefit plans. Except as provided elsewhere in these principles, the costs of fringe
benefits are allowable to the extent that the benefits are reasonable and are required by
law, governmental unit-employee agreement, or an established policy of the
governmental unit.
(2) The cost of fringe benefits in the form of regular compensation paid to employees
during periods of authorized absences from the job, such as for annual leave, sick leave,
holidays, court leave, military leave, and other similar benefits, are allowable if:
(a) they are provided under established written leave policies;
(b) the costs are equitably allocated to all related activities, including Federal awards;
and,
(c) the accounting basis (cash or accrual) selected for costing each type of leave is
consistently followed by the governmental unit.
(3) When a governmental unit uses the cash basis of accounting, the cost of leave is
recognized in the period that the leave is taken and paid for. Payments for unused leave
when an employee retires or terminates employment are allowable in the year of
payment provided they are allocated as a general administrative expense to all activities
of the governmental unit or component.
(4) The accrual basis may be only used for those types of leave for which a liability as
defined by Generally Accepted Accounting Principles (GAAP) exists when the leave is
earned. When a governmental unit uses the accrual basis of accounting, in accordance
with GAAP, allowable leave costs are the lesser of the amount accrued or funded.
(5) The cost of fringe benefits in the form of employer contributions or expenses for social
security; employee life, health, unemployment, and worker's compensation insurance
(except as indicated in section 25, Insurance and indemnification); pension plan costs (see
subsection e.); and other similar benefits are allowable, provided such benefits are granted
under established written policies. Such benefits, whether treated as indirect costs or as
direct costs, shall be allocated to Federal awards and all other activities in a manner
consistent with the pattern of benefits attributable to the individuals or group(s) of
employees whose salaries and wages are chargeable to such Federal awards and other
activities.
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Vacation and Sick Leave Policy
Personnel working on a federal assistance
agreement project cannot he the only personnel
within the Tribal Nation receiving leave benefits.
° If EPA project personnel get leave benefits,
'- So must everyone else on the pavrc >ll.
What's included in vacation and sick leave
policies and procedures?
Vacation and sick leave are considered to be part of
employee benefits. Written procedures should
contain sufficient detail, such as:
Valid categories of leave time
Time sheet codes for charging various
categories of leave
How leave is authorized
The amount each person receives
How the leave is earned
How leave is charged
How leave is allocated to programs and
projects
Policies and procedures must ensure fair and
equitable charges when more than one funding
source is involved. The area of leave is a very
personal item. The proper handling of leave is
important and helps maintain morale within an
organization.
If vacation and sick leave are fringe benefits
offered to employees working on assistance
agreements, everyone working for the Tribal
Nation must receive vacation and sick leave.
Personnel working on a federal assistance
agreement project cannot be the only personnel
within the Tribal Nation receiving leave benefits.
A policy might read:
The Tribal Nation offers all employees
the opportunity to earn paid vacation
and leave time. Vacation and leave are
accrued at the rate of one day for each
month worked. Paid leave covers
vacation, illness, personal and family
necessity. The maximum number of
days earned per year is 12.
Leave may be carried over to the
following year, but an employee may
not accumulate more than 90 days.
Sick leave lasting more than five days
requires a doctor's note explaining
the illness and any actions taken.
Vacation must be requested in
writing at least one week before the
scheduled leave. Leave is not
approved until the request is signed
and returned to the employee.
Accumulated leave will be paid when
an employee quits the job but not if
the employee is fired.
The Appendix contains OMB Circular A-87, which
explains fringe benefit regulations.
A grantee can provide leave for personnel working on a
federal assistance agreement project even if other
employees do not get leave.
A. True
B. False
0. It depends on the "terms and conditions" of
the award
D. It depends on the type of award granted
E. Yes, when so stated in Lhe Tribal Nation's
payroll policy.
Overtime Compensation
Overtime rates should be:
r- Written in the pk
n Detailed so that no abuse occurs and sufficient
funds are available
Compensation of time may be granted when
funds are not available - "comp time"
How should we handle overtime hours?
Policies and procedures for overtime
compensation, along with overtime rates, should be
spelled out in sufficient detail so as to protect a
Tribal Nation's resources. The use of overtime
should have sufficient controls in place to
reasonably ensure that overtime is not abused and
there are sufficient funds to complete the tasks and
projects.
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For example:
/t ;'s the policy of this Tribal
Nation to reduce to a minimum
the necessity for overtime work.
All overtime must be approved in
writing in advance by the
immediate supervisor and the
General Manager. If a supervisor
assigns an employee overtime,
the employee must work the
additional time.
Overtime compensation shall be
paid to non-exempt employees
when they work in excess of an
eight hour day or a forty hour
work week at one and one half
times the employee's normal
rate of pay. Non-exempt
employees required to work on a
scheduled holiday will be paid
double their regular rate of pay
for any hours worked. Paid time
off for holidays, jury duty,
vacation, sick leave or any leave
of absence will not be credited as
a regular work day for
computation of weekly overtime.
All employees classified as
exempt from overtime
compensation under state and
federal law shall not be eligible
to receive overtime
compensation, unless prescribed
by law. Exempt status will be
indicated in all appropriate
position descriptions, and
employees will be notified of
their status when hired or upon a
change in status as approved by
the General Manager and the
Council.
What about employees who give more than
100%?
Compensatory time is a method of paying people
for working above and beyond their regular work
duties when there may not be any funds to pay for
overtime. The procedures for giving "comp" time
should be handled in the same manner as overtime.
Written procedures should detail:
Who is eligible
How compensatory time is earned and
tracked
How compensatory time is used (usually
through time off for extra time worked)
Plan ahead. Do not wait until you find you need a
policy. Make it part of the Tribal Nation's regular
payroll process. For example:
Wo employee is entitled to
take "comp time" for hours
worked outside of his or her
regularly scheduled work
day or work week.
Non-exempt employees shall
accrue overtime
compensation pursuant to
Article II, sections 2, and
Article IV, section 7. An
adjusted work schedule can
be arranged upon mutual
agreement of the employee
and the supervisor where for
one particular day, the hours
are changed to meet certain
situations.
Exempt employees shall not
accrue overtime or
compensatory time.
Table 4: Sample Compensation Policy
Non-Exempt Exempt Employee
Employee
Pay Rate
Overtime
Compensation
Policy
Sample
Compensation
Schedule 40 hours
per week
Overtime
compensated at
time and a half
45 hours
40 x $10 per hour =
$400
5x$15= $75
$400 + $75 =$475
Salary $480 per week
Overtime compensated
as arranged with
supervisor
45 hours
$480
Plus 2-hour leave on
Friday of the following
week
The cost principles for wages, salary, and fringe
benefits are in the OMB Circular A-87, Section 8
(Compensation for personal services). A copy is
provided in the Appendix.
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Expenses must he
in Hie budget and
reasonably priced.
Travel
What requirements should be addressed in travel
policies and procedures?
Travel is a vulnerable area for most Tribal Nations.
A Tribal Nation needs to have travel policies and
procedures in place that treat all employees in the
same manner. This means employees working on
EPA award project(s) will follow the same travel
procedures as individuals working on non-federally
funded project(s).
Travel expenses must be budgeted in the
assistance agreement and approved in the
award document before they can be covered.
Expenses must be in the budget and reasonably
priced.
Plan ahead!
Travel to conferences may be allowed under a
Tribal Nation's travel policy but may not be
allocated to an EPA award because there is no plan
for conference travel in the work plan or the
budget.
Equipment and travel budgets are subject to
statutory law and therefore must be preapproved
with the Project Officer. If equipment or travel is
not in the budget, then its cost will not be
reimbursed.
o A list of allowable costs that can be
reimbursed by the Tribal Nation
o A list of required receipts
Explanation of how employees learn which
reimbursement requests are allowed and
which are not
o Explanation of how employees learn
which costs are allocable to an
assistance agreement (a cost may be
allowed under a Tribal Nation's
travel policy, but not reimbursed
under a specific EPA award)
Travel Costs
-ar.
If you do not have a written travel policy,
use the General Services Administration (GSA) guidelines.
What if we don't have a written policy related to
travel costs?
The Tribal Nation must establish its own travel
policies. If a Tribal Nation does not have a written
travel policy related to travel costs, they may use
the GSA allowable cost rates and amounts
established by the General Services Administration
(GSA) as guidance for developing policies. View
the travel cost guidelines and scan other offerings
on the GSA website, http://www.gsa.gov/.
Travel authorizations, vouchering after the trip, and
trip reporting are explained in OMB Circular A-87,
Section 43, which is provided in the Appendix.
Example forms are provided in Module 8.
Travel policies provide a detailed written
procedure for travel approval and expense
reimbursement including:
Travel authorization and approval of trips
prior to taking them
Travel vouchers detailing the costs of
various travel-related expenses when
requesting reimbursement
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Table 5: Sample Travel Authorization Form
Travel Authorization
Department: Grants Office Authorization No. 9876543
Name: Jane Doe Title: Project Manager
Date: 09/15/08
You are authorized to travel as indicated below and to incur necessary expenses in accordance with Tribal Rules and Regulations.
Places of Travel
From: Somewhere, ST
Purpose:
Hotel Rate:
Per Diem Allowance:
Period of Travel:
To: Washington, DC
Initial meeting EPA grant
Maximum $300.00 per day
$60.00 per day ($15 breakfast, $15 lunch, $30 dinner)
Beginning 10/01/08
Ending 10/02/08
Mode of Travel
Common carrier D Extra fare D Tribal-owned Vehicle D
Privately owned Vehicle 0 At mileage rate: $0.52 per mile*
Estimated Costs
/ hereby certify that travel is advantageous to the Nation.
Transportation:
Per Diem:
Miscellaneous:
Hotel Rate:
TOTAL
$119.60
$75.00
$15.00
$300.00
S629.20
Charged to account #: 0000123
Private car
(approximately 230 miles)
Meals
Internet Services
1 night's stay
Signatures:
:ine DC
Requester 's Signature
^roject Manage.
Title
James Stone
Authorizing Officer 's Signature
Fiscal Officer 's Signature
Table 6: Sample Travel Voucher
Staple
Receipts
Here
DATE
10/01/08
10/02/08
NAME
ADDRE
SS
TRAVEL EXPENSE CLAIM CITY
SS#/or
VN#
DESTINATION
From: To:
Somewhere,
ST
Washington,
DC
Washington,
DC
Somewhere, ST
TRIP
PURPOSE
Initial Meeting
EPA grant
MILEAGE
Miles
CHARGE
Amount*
$ per mile $0.52
117
117
$60.84
$60.84
IV
Breakfist
0.00
15.00
[EALS
Lunch
15.00
15.00
Dinner
30.00
HOTEL
200.00
I hereby certify that the above expenses were
incurred and the amounts are correct and should
be paid from the appropriate fund. BUDGET CODE IN-STATE
BUDGET CODE OUT-OF-STATE
SIGNATURE Jane Doe
Claims must be submitted within 90 days of trip and all
claims for the current fiscal year should be submitted
in time to be paid in that fiscal year. APPROVED BY James Fern
Jane Doe
1234 Rural Route 2
Somewhere, ST 12345
SS2938475
MISC.
Explain
Internet
EXPENSE
Amount
15.00
TOTAL
TOTAL
$320.84
$90.84
$411.68
01-00-0000123**
DATE 10/05/08
DATE 10/06/08
...Travel forms are described in greater detail in Module 8...
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Travel policy example:
A Travel Authorization (TA)form must be filled out by all individuals traveling with Tribal
Nation's funds to receive payment for travel and per diem. Airline reservations will be
made at the lowest possible fare. Receipts are required for all reimbursable expenditures.
Per Diem is paid by the full and half day and is intended to cover lodging and meals while
on official business for the Tribal Nation. Per Diem amounts are based on federal per diem
rates for federal and non-state programs and state rates for state programs. Any expenses
incurred without prior approval may not be reimbursed; it is solely at the discretion of the
General Manager. Expenses other than lodging and meals may be reimbursed as allowed
under federal and state per diem regulations. Such expenses include lodging taxes, taxi,
and parking costs, official phone charges, and laundry. A trip report should be required
reflecting all reimbursable expenses.
Travel advances and per diem payments will be made promptly to employees engaged in
official business. Air travel will be arranged by and purchased directly through the Tribal
Nation's designated agent. All employees will be required to fill out a Travel Authorization
form which must be approved and signed by the traveler's immediate supervisor and the
General Manager. 10% of travel advances will be withheld pending the completion of a
Trip Report which shall be completed with 10 days of traveling on official business. To be
entitled to compensation for travel costs, employees must also adhere to the following
policies and procedures:
a) Attend all trainings, workshops or other official business for which travel costs and per
diem has been provided.
b) Employees traveling on trips that begin and end on the same day will be entitled to one
half the normal per diem rate regardless of the time spent or place traveled to during the
day.
c) Any employee that attends to official business under the influence of drugs or alcohol
will forfeit their per diem for that day. If an employee misses the majority of any business
for which she or he has been authorized to travel for, the employee may be required to
repay all costs associated with the travel and may be subject to further disciplinary action
as provided under these policies. Repayment decisions shall be made by the Council upon
recommendation of the General Manager.
d) Any employee that develops a pattern of violating subsection (c) above will be
prohibited from traveling for the Tribal Nation for a period of time to be determined by the
Council and may be required to pay back per diem and travel costs for any trip where
documented abuses have occurred.
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Module 5: Administrative System Components
Procurement and purchasing are
explained more fully in Module 8.
Reflection
Take a few minutes to consider your
assistance agreement award's budget.
Does it authorize travel?
Does your organization have
written travel policies and
procedures?
Are internal controls in place to
ensure that employees follow the
Nation's travel policy?
o Are there levels of review prior
to authorizing payment?
o How do you ensure that the
travel was associated with the
specific grant project?
o Are internal controls in place to
ensure that travel and time
reporting support the
employee's activities while on
travel?
o Who determines that the travel
is necessary?
o How does your organization
ensure time sheets completed
during travel are accurate (e.g.,
comparison with itinerary filed
before travel, receipts, meeting
agendas)?
Reimbursement of travel expenses for personnel
working on federal awards are handled the same as
those for other employees of the Tribal Nation.
A. True
B. False
r. It depends on the "terms and conditions" of
the award
D. It depends on the type of award granted
E. Only when so staled in the Tribal Nation's
travel policy
The Tribal Nation's travel policies must comply with the
U.S. General Services Administration's |GSA) allowable
costs.
A. True
B. False
0. It depends on the "terms and conditions" of
the award
D. It depends on the t\pe of award granted
E. Only when costs are not addressed by the
Tribal Nation's policies
Procurement and Purchasing
When awarding subgrants, contracts, or
subcontracts, Indian Tribe or Indian Intertribal
Consortium are required , to the extent feasible,
to give preference to Indian organizations and to
Indian-owned economic enterprises.
Guidance is provided in the document entitled
Purchasing Supplies, Equipment, and Services
Under EPA Grants to Local Government.
Procurement and Purchasing
What needs to be in our procurement and
purchasing policies and procedures?
There are many requirements for procuring or
purchasing goods and services under assistance
agreements. According to the Indian Self
Determination Act (40 CFR Part 31.38), to the
extent feasible, a Tribe must give preference to
Indian organizations and Indian-owned economic
enterprises when awarding subgrants and
subcontracts. The Tribe must also require, to the
extent feasible, that preferences and opportunities
for training and employment in connection with the
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administration of tribal contracts or grants be given
to Indians.
For example:
It is the policy of the Tribal
Nation to purchase only
those goods and services
that are needed and
necessary to support
approved business
operations and programs
and which are considered
necessary and allowable
under all grants and
contracts which the Tribal
Nation may administer. It is
also the policy of the Tribal
Nation to maximize program
and service delivery by
purchasing goods and
services at the lowest
possible cost and whenever
possible from Indian-owned
businesses.
To help Tribal Nations obtain the best products,
goods, or services at the most economical price,
EPA has developed extensive guidance.
Purchasing Supplies, Equipment, and Services
Under EPA Grants to Local Government is
provided in the Appendix.
Procurement standards are explained for:
Supplies, equipment, and services
Contracting and subcontracting
Competition
Cost and price review
Purchasing methods
Reviews and audits
The following procurement regulations are also
provided in the Appendix.
40 CFR 31.36 contains procurement
standards for contracts and subawards.
40 CFR 31.32 contains the requirements
for equipment purchase, use, and
disposition.
40 CFR 31.33 contains the requirements
for purchase of supplies, title, and
disposition.
American Recovery and Reinvestment Act
The American Recovery and Reinvestment Act
requires recipients of federal funding to report use
of funds to the federal government beginning July
15, 2009. This includes all subawards, subgrants,
contracts, and subcontracts. For details visit
Recovery.gov at http://www.recovery. gov/.
Learner Notes
This is a great time to clarify the
differences between easily confused terms.
Take a few minutes to do Activity 5.b
(online at www.petetribal.org). Work
together first, then check the Glossary in
your Appendix to see how well you did.
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Subawards and Subcontracts
Costs to do the work
Contract
Subcontract
else to do the work
Subaward
Subgrant
The grant recipient controls The other party controls the
when, where, and how the work decision-making process.
is completed.
Remember compliance requirements under FFATA!
What is the difference between subawards and
subcontracts?
Federal grants are assistance awards. Procurements
or acquisitions require contracts.
A subaward is a subgrant, not a subcontract.
A subcontract is entered into between a
contractor and a subcontractor.
A grant recipient can enter into a contract using
grant funds. This is procurement under a grant, not
a subcontract.
Subawards and Subcontracts
Stepl
Remember compliance requirements under FFATA!
How do subawards and subcontracts work?
Subawards and contracts are made by the grantee
to an eligible:
Subgrantee (subaward recipient or
subrecipient)
Subrecipient (e.g., prime contractor,
consultant)
Lower tier subrecipient by a primary
subrecipient
Subcontracts are made by a prime contractor to
other organizations.
Subawards to eligible subgrantees and recipients
are awards of financial assistance in the form of:
Money
Property in lieu of money
Contractual legal agreements that do not
include procurement of goods and services
Procurement (contract) and subgrant regulations
can be found in 40 CFR 31.3 6 in the Appendix.
Award Relationships
Remember compliance requirements under FFATA!
What are the requirements for subcontracts?
Subcontracts are awarded in accordance with your
Prime Contractor's contracting policy. Like any
governmental unit, Tribal Nations have many
needs that are accomplished by contractors which
in turn may use subcontractors.
Subcontracting is one form of procurement with
special requirements. It is the grant recipient's
responsibility to ensure the Prime Contractor is
aware of the "terms and conditions" specific to the
award under which subcontracts are made.
The grantee, subgrantee, and prime contractor
policies must address:
A written code of conduct that includes
conflict of interest disclosure statements and
disciplinary actions
Competing transactions in a free and open
manner
o A review to avoid unnecessary
purchases
o A review of lease versus purchase
alternatives (when appropriate)
Conducting solicitations with a clear scope
of work and bidder requirements
Conservation of natural resources
Utilization of disadvantaged business
enterprises (whenever possible)
Both the grantee and prime contractor's contracting
policies must also address:
Performing and documenting cost and price
analyses for competitive bidding and small
purchase procurement actions
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Documenting the basis for all procurement
selections, justifying a lack of competition
and basis for award costs
Pre-award review of the procurement when
the award or contract modification exceeds
$100,000, is not competed, or only one bid
is received
Purchase/agreement/contract cost thresholds
for small purchases versus major
procurements and personnel required to
approve procurements
Provisions that no contract or subaward will
be entered into with parties that are
debarred, suspended, or excluded from
federal assistance programs
Below is an example to help you develop your own
policies:
All contracts or agreements for
less than $5,000 and which
have been included in an
approved budget line item
may be executed by the
General Manager. Contracts
which exceed $5,000 shall be
executed by the President.
Required Information:
Business payment: All
payments to a company
or business shall require
the following information
to be recorded on the
check request prior to
payment being made:
(1) company or
business name;
(2) copy of business
license;
(3) tax ID number;
and
(4) mailing address
and phone number.
Individual Payment: All
payments to individuals
shall require the
following information to
be recorded on the check
request prior to payment
being made:
(1) individuals
name;
(2) Social Security
number; and
(3) mailing address
and phone number
(if available).
Other Information: All check
requests shall also include a
description and number of the
item(s) being purchased; the
date of the request and the
due date for requested
payment; the dollar amount of
the purchase and the program
and account coding to which
the payment is to be charged.
All vendors, subcontractors,
contractors, consultants,
students, general assistance
recipients, Council members
and any others receiving
payments should fill out a W-9
form which should be held on
file by the Accounting
Department.
Learner Notes
Typically over $100,000 paid to a single
supplier is "sole source procurement" and
must be justified in writing. The EPA
Project Officer is notified when any sole
source procurements are made. With that
much money, it is hard to justify using a
single source.
Consultants
Purchasing policy must address consulting
agreements and specify:
° Services to be provided
° Engagement duration
° Reporting requirements
Including information for FFATA compliance
- Work location
° Pay rates, including:
Base rate
Fringe benefits
Overhead
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What are policy requirements for consultants?
Purchasing policy must address consulting
agreements and specify:
Services to be provided
Engagement duration
Reporting requirements
Work location
Pay rates, including:
o Base rate
o Fringe benefits
o Overhead
For example:
Consultants may be used to
provide specialized and expert
services beyond the scope of
available staff resources when it
becomes apparent that their
expertise is essential to the well-
being of the organization. When
obtaining the services of
consultants the purchasing
provisions provided below shall
generally be followed. The
consultant's fee must be
appropriate considering the
qualifications of the consultant,
the consultant's normal fees, and
the nature of the services
rendered by the consultant. Cost
is not the deciding factor, but
rather one of several, such as
quality, timeliness, location,
previous experience, etc.
Regulations for consultant agreements are provided
in 40 CFR 31.36(j) in the Appendix.
If consultants are budgeted for in the award
agreement, the "terms and conditions" will include
a compensation rate for the current fiscal year. For
example:
Payment to consultants. EPA
participation in the salary rate
(excluding overhead) paid to
individual consultants retained
by recipients or by a recipient's
contractors or subcontractors
shall be limited to the maximum
daily rate for a Level IV of the
Executive Schedule (formerly GS-
18), to be adjusted annually. This
limit applies to consultation
services of designated
individuals with specialized skills
who are paid at a daily or hourly
rate. As of January 1, 2009, the
limit is $587.20 per day and
$73.40 per hour. This rate does
not include transportation and
subsistence costs for travel
performed (the recipient will pay
these in accordance with their
normal travel reimbursement
practices).
Subagreements with firms for
services which are awarded
using the procurement
requirements in 40 CFR 30 or 31,
as applicable, are not affected by
this limitation unless the terms
of the contract provide the
recipient with responsibility for
the selection, direction, and
control of the individuals who
will be providing services under
the contract at an hourly or daily
rate of compensation. See 40
CFR31.36(j)or30.27(b).
Consultants should be competed. EPA prefers grant
recipients obtain bids from a number of
consultants. Competition is encouraged to provide
opportunity to all available consultants and ensure
costs are reasonable.
Consultants should provide bids at an "unloaded
rate". This rate does not include fringe benefits or
overhead, such as travel, temporary lodging, and
food. Consultants can be expensive. Do not go
over the amount listed in the budget. Consultants
should be paid hourly and cannot invoice at a
loaded rate. They must be responsible for their own
fringe benefits and overhead costs.
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Questions?
Contact your EPA
Grants Specialist.
If there are any further questions, contact your
regional EPA Grants Specialist.
Disadvantaged Business Enterprises
Grantees must comply with the Disadvantaged
Business Enterprise rule to use disadvantaged
business enterprises when making procurements
under grants and EPA financial assistance
agreements performed entirely within the United
States, whether the work is performed by a
recipient or its prime contractor, for construction,
equipment, services, or supplies.
...more in Module <)...
What are the requirements for using
disadvantaged business enterprises?
Generally, small businesses, minority-owned firms,
women-owned business enterprises, and labor
surplus area firms are all considered disadvantaged
business enterprises (DBEs).
Grantees must comply with the DBE rule by
making good faith efforts to use disadvantaged
business enterprises when making procurements
under grants and EPA financial assistance
agreements performed entirely within the United
States, whether the work is performed by a
recipient or its prime contractor, for construction,
equipment, services, or supplies.
Provisions for utilizing Disadvantaged Business
Enterprises are explained in 40 CFR Part 33 in the
Appendix.
Disadvantaged business enterprise
recommendations are explained more
fully in Module 9.
Price Analysis
Comparison of:
= Price quotations submitted by hopeful vendors
a Market prices and similar indicators
Miscounts and package deals
Price and Cost Analysis
How important is it to compare prices before
purchasing goods and services?
Regulations require the performance and
documentation of cost and price analyses for
competitive bidding and small purchase
procurement actions. Analyses apply to all
procurements no matter what the cost.
A price analysis may be accomplished in various
ways, including the comparison of:
Price quotations submitted by hopeful
vendors
Market prices and similar indicators
Discounts and package deals
Price analysis requirements are explained in 40
CFR 31.36(f) in the Appendix.
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Cost Analysis
Evaluation of each major cost category
to determine the
° Reasonableness,
° Allocahility. and
° Allowuhility
of each category and of the total cost
of a contract or change order.
How important is it to analyze costs before
purchasing goods and services?
A cost analysis is the evaluation of each major cost
category to determine the reasonableness of each
category and of the total cost of a contract or
change order.
Tribal Nations need to perform a cost analysis, if:
The statement of work requires contractors
to specify the elements of their proposed
total contract cost.
Competition is lacking, for:
Sole source procurements
Contract modifications
Change orders
Procurement methods are explained in 40 CFR
31.36(d), provided in the Appendix.
Cost Analysis
S.T.S.P. $950 $25,000 S6S.OOO 5562,987 520,000 $186.732 $838.169
N.J.&W. $1,250 $27,300 $78,000 $963,258 $23.750 $247,652 $1.341.210
Victors $795 $21,432 $57.000 $398,000 $24,125 $203,890 $705.242
A cost analysis is the review and evaluation of
each element of cost to determine
reasonableness, allocability, and allowability.
Reflection
Pause a minute to consider your own
situation.
Does your organization have
written procurement policies and
procedures?
Has your organization awarded
contracts or subagreements under
any of your current award
agreements?
o Were contracts awarded in
accordance with your
organization's contracting
policy?
o Does your organization have
guidelines for documenting
its contract files?
o Do any of your
organization's contracts for
grant projects exceed the
federal small purchases
threshold of $100,000?
If so, did EPA request to review the
contract prior to the time that you
awarded the contract?
Has your organization established
an affirmative procurement system
for recycled materials and
compliance with environmental
statutes?
Are internal controls in place to
ensure that your organization does
not charge EPA assistance
agreements more than the
authorized amount?
Has your organization awarded
contracts to consultants under
current assistance agreements?
Cost analysis is particularly important for sole
source procurements (when there is only one
reasonable source for the items needed). Sole
source analysis also requires justification as to why
the proposed contractor is the only one able to
perform the work due to qualifications and
experience. Your EPA Project Officer can write
you a justification.
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What is sole source procurement?
40 CFR 31.36(d)(4) explains sole source
procurement as follows:
(4) Procurement by noncompetitive
proposals is procurement through
solicitation of a proposal from only
one source, or after solicitation of a
number of sources, competition is
determined inadequate.
(i) Procurement by noncompetitive
proposals may be used only when
the award of a contract is
infeasible under small purchase
procedures, sealed bids or
competitive proposals and one of
the following circumstances
applies:
(A) The item is available only
from a single source;
(B) The public exigency or
emergency for the requirement
will not permit a delay resulting
from competitive solicitation;
(C) The awarding agency
authorizes noncompetitive
proposals; or
(D) After solicitation of a number
of sources, competition is
determined inadequate.
(ii) Cost analysis, i.e., verifying the
proposed cost data, the projections
of the data, and the evaluation of
the specific elements of costs and
profits, is required.
(Hi) Grantees and subgrantees may
be required to submit the proposed
procurement to the awarding
agency for pre-award review in
accordance with paragraph (g) of
this section.
Compare Cost Data
Subcontracting
5652,987
5252,195
$6573
5206,732
5950
NA
51,068,558
Included above
S9768
5271.402
51,250
NA
5476,432
5119.108
510,579
5228,110
S795
5250.000
P. Though Victors is less expensive
igh quality materials, they tend to
: on fees later in the project and don't pay
their employees enough to keep good workers
on the job throughout an entire project.
What data do we collect and analyze?
To obtain the information, a Tribal Nation needs to
conduct a cost analysis and must instruct
contractors to provide cost data with their bid
proposals.
Data to be specified might include:
Personnel
Fringe benefits
Travel
Subcontracting
Indirect costs
Profit
EPA does not prescribe a form for this cost data, so
unless you have a standard form, contractors may
submit their cost data in any format. Tribal Nations
should require bidders to certify that the cost
information they submit is complete, current, and
accurate.
Cost and price analysis are explained in 40 CFR
31.36(f), which is provided in the Appendix.
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Reflection
Consider the following questions as they
pertain to your Tribal Nation's policies
and procedures.
Do your purchasing policies and
procedures require performing and
documenting an analysis for sole
source procurements based on cost,
experience, and qualifications?
Does your policy use a pre-qualified
list of persons, firms, or products to
acquire goods and services?
If so, does it follow federal
procurement policies to place and
update vendors on your list?
Does your organization have
internal controls to ensure that
goods and services are:
o Acquired in quantities
needed?
o Required for execution of
the project?
o Paid for by the
accounting/finance
department?
Price analysis is the comparison of:
A. Contractor relationship
B. Vendor proximity
0. Market price
D. Free shipping
E. All of the above
Cost analysis requires which kinds of data:
A. Totals per cost category
B. Contractor relationship
C. Vendor location
D. Free shipping
E. All of the above
Property Management System
A written policy is required to comply \vith
regulations on:
- Equipment- tangible, non-expendable, personal
properly having a useful life greuler than c me year
and an acquisition cost of .$5,000 or more per
unit.
° How equipment was acquired.
isilic in i >f equipment after the award peril id
endsor at the end of the equipment's life.
Property Management System
Why do we need a property management
system?
At a minimum, a grantee needs to have policies
and procedures to identify and control acquired
property. This is especially critical when property
is acquired under an award, whether it is part of
non-federal contributions or purchased with federal
funds. A Tribal Nation needs to be familiar with
federal requirements for property management, and
must address them in the Nation's written policy.
The Tribal Nation keeps an
inventory list of equipment with a
value of $5,000 or more or a useful
life of one year or more. The
information includes the item, date
of purchase, value, and funds used.
It is updated every time a new item
is purchased. When equipment is
disposed of, the date is noted on
the list and this information may
be given to the auditors so they
can update their depreciation or
use schedule (if any).
What are the regulations on equipment?
Equipment is tangible, non-expendable, personal
property having a useful life greater than one year
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and an acquisition cost of $5,000 or more per unit.
The Tribal Nation's definition of capital equipment
may be different than the federal definition,
provided that the Nation's definition would at least
include all equipment as defined above. The Tribal
Nation's definition of capital should be used if it is
lower than the federal guideline. For instance, a
policy would be acceptable if it identifies capital
equipment as property with a useful life greater
than one year and an acquisition cost of $3,500 or
more per unit.
Supplies are tangible, expendable, personal
property that costs less than $5,000 per unit,
including paper, ink, pens, paper clips, and other
expendable products. Supplies are items that can be
easily lost or borrowed, "pilferable" objects. They
are easy to lose track of and can be stolen more
easily than equipment. Computers are supplies
not equipment Computers generally cost less than
$5,000 per unit. Laptops can be misplaced and
appropriated without malicious intent.
Who gets the equipment after the award period
ends?
EPA regulations as explained in 40 CFR 31.32,
govern the disposition of equipment acquired under
a grant or subgrant. (See the Appendix for 40 CFR
31.32). Property and equipment that are donated
and/or acquired under an EPA award need to be
recorded and controlled within a Tribal Nation's
accounting/property management system.
An assistance agreement will identify the
equipment that was donated or acquired
under the agreement.
The EPA Proj ect Officer will detail the
equipment disposition process to be
followed at the end of the assistance
agreement.
The Tribal Nation's policies and procedures
should also address disposition of equipment
at the conclusion of a project or at the end of
the equipment's life.
If equipment disposition is an issue, the Tribal
Nation and EPA should work out disposition
details early on in the project period. This is
important so that the closeout process will not be
delayed.
For example:
Surplus Property
All departments and program
coordinators are responsible for reporting
surplus or excess property to the Financial
Officer. Once surplus property has been
identified, the Financial Officer will
proceed to dispose of such property under
the guidelines provided below in
subsection (E).
Property Disposal
Property disposal decisions are made
through several methods.
These include:
* A date decided upon at the time the
property was acquired;
* Based upon condition and other factors
noted in annual inventory reports;
* When property is deemed by the
Financial Officer in consultation with the
grants manager to be obsolete;
* When maintenance is no longer cost
efficient;
* If the intended use is no longer valid and
there is no other application for other
Tribal programs.
It is the policy of the Tribal Nation to
make every effort to donate equipment or
other property that has been deemed by
the Financial Officer, in consultation with
the grants manager to be surplus to the
needs of program operations. Such
property shall be made available first to
other Tribal organizations, and in the
event that such equipment cannot be
donated, will be made available to staff
on a lottery basis.
The Financial Officer and grants manager
may establish a fair market value for
items of significant value. Where a price
has been placed on the property the
payment shall be made by the recipient
before the property is turned over and the
funds generated deposited into the
General Fund. In the event that staff does
not request such property, it may be
made available to the general public by
lottery, sealed bid or such other method
as the FO and grants manager may
determine is appropriate. With
concurrence by the President, such
property may be donated directly to a
worthy tribal member with a
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demonstrated need. Electronic equipment
deemed surplus will have all identifying
data removed or deleted prior to disposal.
All property will be offered as-is with no
express or implied warranty or technical
assistance as to use or set-up. In
disposing of property, the Financial
Officer shall be responsible for ensuring
that all federal, state, or other contract
and grant requirements are complied
with.
How should we handle leased property?
Leased equipment is not tracked, because the
grantee does not actually own the property.
However, grantees must ensure they follow the
details of the lease agreement. Fees or penalties for
not complying with the lease agreement cannot be
charged to the federal program.
Vehicles used by a program to do the work can be
paid for on a "user fee" based schedule rather than
purchased or leased outright. The Tribal Nation can
purchase vehicles and charge user fees to grant
funded projects as needed.
Inventory Control System
Capital equipinentpurchased under a federal
award must be documented in records that:
= Identify the equipment purchased by asset
number
= Identify where the asset is physically located
= Identify the life of the asset and when it should be
disposed
= Detail property dispositions
date of purchase and cost 2012
The Tribal Nation's property management
system should:
A. Be internally controlled for a impliunce \vith
federal regulations
B. Identify and inventory properly acquired
under an award
C. Include written policies and procedures
D. Explain equipment disposition after the award
period or at the end of the equipment's
useful lite
E. All of the above
Disposition of acquired property, after the
award period or at the end of the equipment's
useful life, depends on how it is:
A. Negotiated in the work plan and budget
B. Handled in the written policies and procedures
C. Valued when purchased and after use
D. Described in the "terms and conditions" of the award
E. All of the above
Why do we need an inventory control system?
An inventory control system is necessary for
capital equipment and recommended for smaller
purchases. A property inventory should be
conducted at least once every two years. Capital
equipment purchased under a federal award must
be documented in records that:
Identify the equipment purchased; each asset
should be given an asset number so it can be
easily located.
Identify where the asset is physically located
Identify the life of the asset and when it
should be disposed
Detail property dispositions (date of
purchase and cost)
For example:
Responsibility for
maintaining an inventory
control system shall rest
with the Accounting
Department. The inventory
control system will enable
the Tribal Nation to verify
actual physical inventories
against book inventories. As
part of this system, all of the
Nation's equipment,
furniture, and hard supplies
with an expected life span of
one (1) year or more shall be
labeled and recorded in the
inventory system. A
complete organizational
inventory shall be conducted
at least annually, the results
of which shall be reconciled
to the property records.
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Below is a sample property list. It can be combined
with depreciation/asset management schedules or
the Tribal Nation can get asset management
modules from EPA.
Appendix documents 40 CFR 31.31, 31.32, and
31.36 explain the regulations for:
Equipment and property purchases
Cost analysis
Purchase and use of goods and services
Inventory
Disposition of property at the end of the
project or at the end of its life
Reflection
Consider how the following policies
and procedures help manage grants.
Does your organization have
written property management
policies and procedures?
Has your organization
purchased capital equipment on
any of its active assistance
agreements?
Does your organization have an
inventory control system?
Cost Share and Matching
The portion of allowable project costs that a recipient
contributes toward completing its project. Common to
tribal grants is a 2O96 cost share/match of a federal award.
20% cost shard/match
Federal ihare Re&piert tetsh.
Check the Terms and Conditions to make sure the match percent is
not a calculation against total project costs.
Cost Sharing, Matching, and In-kind
Contributions
Cost Share
How do we account for cost sharing, matching,
and in-kind contributions?
Cost Share is defined as the portion of allowable
project costs that a recipient contributes toward
completing its project - costs not borne by the
Federal Government (40 CFR Part 31.24).
In-kind services can also be added to an assistance
award by the recipient. Some examples of a
recipient's in-kind contribution to an award are:
volunteer hours, personnel hours, equipment,
supplies and so on. Recipients' may choose to meet
their cost share or match requirements through in-
kind contributions.
The award recipient must state how they will meet
the match requirements (either cash or in-kind
contributions) in the application work plan and
budget. If in-kind contributions are proposed, the
plan must explain these contributions.
Cost Share and Matching (continued)
Mandatery - when stated in the Catalog of
Federal Domestic Assistance (CFDA)
program listing
Voluntary - negotiated in the agreement and
required after signing the award
Match
Cost Share and Match are essentially the same
(and are often used interchangeably), and it can be
mandatory or voluntary.
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It is mandatory when the statute or program
requires it (usually stated in the CFDA). It's usually
required in the form of a percentage of the total
project costs ("matching" the federal costs...so if
it's 50% cost share/match, it would be 50% of the
total project cost and would match the federal share
dollar for dollar). Mandatory cost share
percentages are provided in the award document.
Voluntary cost share is exactly what it sounds
like- the recipient volunteers to provide it even
when it is not required by the program. But once
they do volunteer it and the award agreement
becomes official, they are required to provide it -
they've made a commitment.
Both mandatory match and voluntary match can
occur in the same grant. This happens when the
applicant chooses to provide more match than is
required. Offering additional match provides
leverage. It can increase an applicant's chances to
be selected for an award.
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Module 5: Administrative System Components
Table 7: Sample Property List
Environmental Protection Department
Property Records
As of September 30, 2011
Asset
Description
Truck
Car
Copy
Machine
Fax
Machine
Computer -
desktop
Computer-
laptop
Phone
ID or
Serial
#
123456
654321
99999
Cost
$15,000.00
13,000.00
6,000.00
Source
of
Funds
EPA
EPA/
Tribe
EPA
% Fed
Participation
100%
50%
100%
Title
Held
by
EPD
EPD
EPD
Date
Purchased
06/01/11
10/20/8
01/15/08
Date
Sold
Sales
Price
Inventory
Date
09/30/1 1
09/30/09
09/30/10
09/30/1 1
09/30/09
09/30/10
09/30/1 1
Condition
New
like new
New
12000 miles; like new
23000 miles; OKcond
35000 miles; OKcond
New
20000 copies; OK cond
55000 copies; OK cond
83000 copies; OK cond
Location
EPD
EPD
EPD
EPD
EPD
EPD
EPD
EPD
EPD
EPD
Use
Brownfields
Brownfields/UST
GAP/§106
GAP/§106
GAP/§106
GAP/§106
All Env. Programs
All Env. Programs
All Env. Programs
All Env. Programs
Optional at Department Level:
Estimated Useful
Life (months)
60
Estimated Disposal
Value
$3,000.00
Depreciation. Method
SL
Depreciation for Period
$800.00
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Match must be allocable to the grant.
No alcohol or other unallowable expenses
can be counted!
Leveraged match need not be stated in dollar
amounts. It is often better to provide a narrative
statement. For example, "The city of Denver has
agreed to donate transportation services (school
buses and drivers) for the duration of this project."
Leverage funds to increase your
competitive edge.
In-Kind Contributions
Non-monetary contributions with a quantifiable
value, such as donations of:
" Time and effort = actual/market value
= Goods or services = market value
" Supplies or equipment = market value
Third-party- contributed by someone other
than the recipient or EPA
In-Kind Contributions
In-kind contributions and services can be used as
match if not from a federal agency. It is a non-
monetary contribution that can be quantified
monetarily in some way. Third-party in-kind just
means it is an in-kind contribution coming from
someone other than the recipient or grantor. This
may be a partner or someone with whom they are
collaborating.
When EPA provides in-kind services (e.g., lab
services, office space, etc.), they cannot be used as
match because they count as part of the federal
government's contribution.
In-kind contributions and services cannot be paid
for with federal funds from any program, except
health care provided under the Indian Serf-
Determination and Education Assistance Act
(ISDEA), Public Law 93-638. For an explanation
of the Self-Determination Act, download Tribal
Self-Determination from the Indian Health Service
(IHS) at http://info.ihs.gov/TreatiesLaws/2-
TribalSelfDetermination-Jan2005.doc.
I
Document Worth
1 Cost sharing, matching, and in-kind
contributions are gifts or donations of time,
goods, and/or services made toward the project
by the Tribal Nation or other benefactors.
1 Track and account for all funding in the same
way, including market value of donations.
1 Contact your EPA Project Officer if you think
your organization may qualify for a cost share
Documentation
Cost sharing, matching, and in-kind contributions
are gifts or donations of time, goods, and/or
services made toward the project by the Tribal
Nation or other benefactors. These contributions
must be tracked and accounted for in the same
manner as EPA funding. Accounting for third party
in-kind contributions provides an accurate record
of the true cost of the project.
For example:
Record of supplies donated by a third party
need to be kept in a separate file with:
A signed form from the third party
Description of the contribution and
how the supplies were used
A copy of the invoice from the third
party, if possible
Supplies should be valued at market
value when reporting the contribution
and cannot be paid for with any
federal funds.
Time donated by the Tribal Nation needs to:
Be recorded by the employee
Explain how much time was donated
on the project
Contain the employee' s signature
State that time and effort recorded
were spent on the project
This time cannot be paid for with any
federal funds.*
* Note that a cost share or match requirement may
be met by costs borne by another Federal grant if
and only if there is a federal law permitting you to
use the other federal funds to satisfy the match
requirement under your EPA grant.
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Waivers
Under some grant programs your organization may
request a waiver of the cost share requirement, if
the cost share will impose an undue hardship.
Check with your EPA Project Officer to see if your
organization can and should request a waiver.
How to account for and report cost sharing,
matching, and in-kind contributions is explained in
the following documents provided in the Appendix.
40CFR31.24
OMB Circular A-87
Reflection
Consider how cost sharing impacts
management of your assistance agreement
award.
Does your organization currently
have any matching, cost sharing,
and/or in-kind contributions
included in any active awards?
Does your organization anticipate
any of these types of costs in the
foreseeable future?
If you answered "yes" to either of
the above questions:
o Where do your matching costs
come from?
o Are these cost percentages
described in the "terms and
conditions" of the assistance
agreement?
o Does your organization track,
record, report, and verify these
costs?
o Are all matching costs
verifiable from accounting
records and valued according
to applicable OMB Circular
A-87 cost principles?
Program Income
PROFIT & LOSS
20,500.00
3.s::.3c
5,000.0]
4,300.00
1,200.00
400.00
SOO.OO
1.3Q3.00
40.000.00
Ordinary Income/Expense
Income
Income
Total Income
Expense
Personnel
Fringe Benefits
Travel
Equipment
Supplies
Contractual
Constructor
Other
Indirect
Total Expense
Program Income
What do we do if award activities actually make
money?
A Tribal Nation may at times receive income in
addition to the funds on an assistance agreement.
Program income is defined as "gross income
received by the grantee directly generated by a
grant supported activity, or earned only as the
result of the grant agreement during the grant
period." Program income includes fees from
services performed under the grant, and income
from sale of commodities or items fabricated under
a grant agreement. Revenue you receive from
sources to support the program that doesn't directly
result from grant activities is not program income.
Anticipated program income will be detailed in
the application.
Examples of Program Income:
Fees charged to register participants for a
workshop or conference during the grant
period.
Revenue realized through the sale of
products made under a grant program
during the grant period.
Membership fees charged to individuals
and organizations for grant related
activities during the grant period.
Rental or usage fees charged for use of
supplies or equipment purchased with
grant program funds during the grant
period.
Example that is NOT Program Income:
Funds donated to be used for a project, but without
restriction that services be provided in return, are
NOT program income
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The handling of income will be calculated into the
total amount of the assistance award. Regulations
allow grantees various ways to dispose of program
income, including adding or deducting it from the
amount of federal funds awarded. Project Officers
include this as part of their negotiations of the work
plan and budget.
When an assistance agreement contains
program income, a Tribal Nation must account
for and track these funds in the same manner as
expended federal funds. Again, it is very
important to track the program income funds in
a separate charge code from the EPA funds.
A Tribal Nation needs to ensure that adequate
internal controls are in place to properly account
for these funds. Funds must be specifically
identified in the project budget and in Financial
Status Reports (FSRs).
Cost reports show all income and related expenses.
Which of the following is not considered
program income?
Fees charged to register participants for a workshop or conference
during the grant period
Revenue realized through the sale of products made under a grant
program during the grant period
Revenue you receive from sources to support the program that
doesn't directly result from grant activities
D. Membership fees charged to individuals and organizations for
grant related activities during the grant period
E. All of the above
B.
C.
Reflection
Consider how the following might impact
management of your assistance agreement.
Has any program income been used
as matching or contribution for any
current award?
Has any program income been
added to the funds committed for
the project?
Does the project budget allow
adding program income?
In the award's "terms and
conditions", is there a condition that
permits the use of program income
for match requirements?
If not specified in the proj ect budget
or award "terms and conditions",
has the program income been
deducted from the total allowable
project cost in your award budget?
Save all
Records
Write policies
and procedures
on records
management
and retention.
Program income regulations are provided in the
Appendix in 40 CFR Part 31.25.
Records Management and Retention
Do we need policies and procedures on records
management and retention?
Tribal Nations need written policies and
procedures that address the types of files and
documentation required for records management.
A good filing system ensures adequate
documentation. Each assistance agreement award
must have its own file kept separate from other
awards and grants. Folders can be kept in different
departments as long as a record of where they are
located is included in the master file.
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Module 5: Administrative System Components
Thorough documentation describes the activities
conducted under an assistance agreement.
Documentation shows how activities are properly
carried out, in accordance with a Tribal Nation's
leadership and EPA/federal requirements.
Basic files needed for managing EPA assistance
agreement awards include:
The original application and certifications
including the work plan and budget
Initial award and amendment documents
Request and/or approvals for
scope/budget changes
Federal Financial Report (FFR) Standard
Form (SF) 425, if applicable
General ledger detailing revenues,
expenditures, assets, and liabilities
Support documents for expenditures
Basic files needed for managing EPA assistance
agreement awards also include:
Equipment files and usage logs
Payment requests
Progress reports
Contracts/subawards
Correspondence (letters, emails, and notes
taken during phone conversations)
The following guidelines are provided in the
Appendix.
40 CFR 31.30(a)(b)(c) address request for
and approvals of scope and/or budget
changes
40 CFR 31.41 (b) address financial status
reports and reimbursement requests
40 CFR 31.21 address payment requests
backed up by financial records
40 CFR 31.40(b) address progress reports
40 CFR 31.37 refer to subgrants
40 CFR 31.42 records retention
regulations
Records Retention
Check with your EPA Proj ect Officer for specific
dates applied to )*our award.
Project Period Closeout Records Retention
Jarruaryl,2005-December 312009 February 1, 2010 January I, 2009-January 31, 20S3
I I 1
Sample Retention Period
How long do we need to keep the records?
Records retention requirements depend on the
grant program. EPA policy requires that records be
retained for at least three (3) years after the award
period ends. Tribal Nations who receive Superfund
money may be required to keep records for up to
ten (10) years. The retention period can be
extended for a variety of reasons. Check with your
EPA Project Officer for specific dates applied to
your award.
;=(g)
Assistance agreement records:
A. Document financial activities
B. Describe program and project activities
C. Show how award activities are performed
D. Are kept separate from other grants
E. AH of the above
How long must EPA assistance
agreement records be kept on file?
A. 1-2 years
B. 3-5 years
C. 5-10 years
D. It varies, usually 3-10 years. Check with your Project
Officer
E. As long as you think it is necessary
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Module 5: Administrative System Components
Attachment to Module 5
Answers to Quizdom Actionpoint Questions
Which of the following is the most important requirement of a payroll processing
system?
A. Pay grades
B. Time sheets
C. Internal controls
D. How employees are paid
E. All of the above
Though all of the above are important, EPA is mainly concerned that the payroll process has
internal controls to protect award funds from fraud, waste, and misappropriation.
11
Which of the following does not need to be included on personnel time sheets?
A. Employee's name
B. Employee's social security number
C. Hours worked and on which project
D. Department/project budget codes
E. Department for which the employee works
To protect employee privacy, do not include personal information such as home address, phone
number, or social security number on time sheets.
14
Personnel time sheets track work by the:
A. Employee's social security number
B. Hours worked and on which project
C. Inventory codes and dates
D. Project name and task responsibilities
E. All of the above
The most efficient and effective way to track employee time spent working on a project is to
require personnel to fill out time sheets. Time sheets track work by the number of hours worked
on each project for which they are responsible.
19
A grantee can provide leave for personnel working on a federal assistance agreement
project even if other employees do not get leave.
A. True
B. False
C. It depends on the "terms and conditions" of the award.
D. It depends on the type of award granted.
E. Yes, when so stated in the Tribal Nation's payroll policy.
Benefits are only given to grant personnel when all personnel working for the grantee are given
the same benefits.
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Reimbursement of travel expenses for personnel working on federal awards are
handled the same as those for other employees of the Tribal Nation.
A. True
B. False
C. It depends on the "terms and conditions" of the award.
D. It depends on the type of award granted.
E. Only when so stated in the Tribal Nation's travel policy
Travel expenses should be processed the same way for all the Tribal Nation's employees.
29
The Tribal Nation's travel policies must comply with the U.S. General Services
Administration (GSA) allowable costs.
A. True
B. False
C. It depends on the "terms and conditions" of the award.
D. It depends on the type of award granted.
E. Only when costs are not addressed by the Tribal Nation's policies
The Tribal Nation must establish its own travel policies. If they do not want to have a policy related
to costs, they may use the GSA allowable costs for lodging and meals.
47
Price analysis is the comparison of:
A. Contractor relationship
B. Vendor proximity
C. Market price
D. Free shipping
E. All of the above
Price analysis compares prices quoted by possible vendors/suppliers or contractors and standard
market prices.
50
Cost analysis requires which kinds of data:
A. Totals per cost category
B. Contractor relationship
C. Vendor location
D. Free shipping
E. All of the above
Cost analysis requires the grant recipient to collect and examine as much data as possible before
making a decision on procurement or purchasing issues.
54
The Tribal Nation's property management system should:
A. Be internally controlled for compliance with federal regulations
B. Indentify and inventory property acquired under an award
C. Include written policies and procedures
D. Explain equipment disposition after the award period or at the end
of the equipment's useful life
E. All of the above
These are true for all award management and administrative systems.
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Disposition of acquired property, after the award period or at the end of the
equipment's useful life, depends on how it is:
A. Negotiated with the work plan and budget
B. Handled in the written policies and procedures
C. Valued when purchased and after use
D. Described in the "terms and conditions" of the award
E. All of the above
Disposition of property should be negotiated during work plan and budget discussions with the
EPA project officer prior to award. The value of the property may influence negotiated "terms and
conditions", which are stated in the award document.
67
Which of the following is not considered program income?
A. Fees charged to register participants for a workshop or conference
during the grant period
Revenue realized through the sale of products made under a grant
program during the grant period
Revenue you receive from sources to support the program that
doesn't directly result from grant activities
Membership fees charged to individuals and organizations for grant
related activities during the grant period
All of the above
Funds donated to be used for a project, but without restriction that services be provided in return,
are NOT program income. Revenue you receive from sources to support the program that doesn't
directly result from grant activities is not program income.
B.
C.
D.
E.
73
Assistance agreement records:
A. Document financial activities
B. Describe program and project activities
C. Show how award activities are performed
D. Are kept separate from other award documents
E. All of the above
Records should be kept on all activities associated with an award.
76
How long must EPA assistance agreement records be kept on file?
A. 1-2 years
B. 3-5 years
C. 5-10 years
D. It varies, usually 3-10 years. Check with the Project Officer
E. As long as is indicated in the "terms and conditions"
Records should be kept for a minimum of three years, but this varies by funding program. Check
with your EPA Project Officer for specific dates.
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Module 6: Financial System Requirements
Module 6: Financial System Requirements
Tribal, U.S. Territories and
Insular Areas Administrative and
Financial Guidance for
Assistance Asreements
Module &
Financial System Requirements
The Grants Management Process
Module 9: Disadvantage*
r = t^:
Module UK Assistance
Agreanent Monitoring and
Closeout
ModuleiiThe Grant
Appl katJon Process
Module 2: Assistance
Agreements
Module 3: Federal
Funding
Accou nab ility and
Trans parenc r Act
7FA7A) '
.Module 6: Firencial
System Requirements
. Module -: Accounting Pol:
and Procedure
Module 8: Source
Documentation and
Purdiasing
lie 4: Grants
i na Eminent Systems-
Module 5:
Administrate System
Components
Financial Management System
Module 6 will cover the essentials of an effective
financial management system that a grant recipient
will need to successfully administer a grant.
Financial System Requirements
Financial Policies and Procedures
Accounting Processes
Finance Tracking
Financial Reporting
Financial policies and procedures must be in
writing. Develop procedures. Learn the rules and
regulations. Review and update procedures often.
Apply policies and procedures consistently
across programs and projects.
Establish an accounting
process using:
Chart of
accounts
Document
reference
numbering
General journal
entries
General ledger
entries
Track award finances
using:
Posting
reference
numbers
Debit
columns
Credit
columns
Balance
columns
Submit financial status reports to EPA. Include a
summary of activities. Send reports semi-annually.
Financial System Requirements
Maintain separate accounts for each federally issued
assistance agreement.
Keep accurate hooks and records.
° Failure to maintain accurate financial records will
impact the recipient's ability to receive future federal
funding.
Every department needs to be trained.
n Each staff member needs to understand his or her r< ile
and responsibility in the process.
Each project must be tracked independently.
Financial System Requirements
Why do we need a financial system?
EPA regulations require recipients (i.e., Tribal
Nations) to maintain separate accounts for each
federally issued assistance agreement to avoid
confusion about how the funds are spent or how
much is received per project. A financial
management system enables a Tribal Nation to
keep accurate books and records. Failure to
maintain accurate financial records will impact the
recipient's ability to receive future federal funding.
Because financial management systems require
different departments to enter data into the system,
every department needs to be trained. Each staff
member needs to understand his or her role and
responsibility in the process. The financial
management system is a central depository for
tracking federal funding. It is important to
remember that each project must be tracked
independently, so that there is no mixing of funds
from different federal programs.
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Module 6: Financial System Requirements
Ensure Compliance
Compliance \\ith EPA regulations is renewed by
auditors.
EPA auditors use the EPA Administrative and
Financial Onsite Review Questionnaire.
Recipients should he able to implement each of
the processes listed on the questionnaire, or
explain why they are not necessary.
Write Policies and Procedures for:
Accounting
Personnel / Timekeeping [^
Personnel / Payroll
What does an effective financial management
system need?
EPA auditors review a Tribal Nation's accounting
and financial management system to ensure that the
system is in compliance with EPA regulations. The
EPA Administrative and Financial Onsite Review
Questionnaire lists goals and objectives that an
auditor uses to monitor a recipient's compliance.
This guidance is for tribal governments that are
eligible for any grant awards. Your Tribal Nation
must have a set of written financial and accounting
policies. Your Tribal Nation should be able to
implement each of the processes listed or explain
why they are not necessary for your organization.
The EPA Administrative and Financial Onsite
Review Questionnaire is provided in Module 10
and the Appendix.
Financial Policies and Procedures
Financial policies and procedures are necessary for
effective management of the following systems:
Accounting
Personnel
o Timekeeping
o Payroll
Travel
Matching
o Cost Sharing
o In-Kind Contributions
o Program Income
Procurement
o Contracts
o Subagreements
o Purchasing
Disadvantaged Business Enterprises
Property Management
Internal Controls
Travel
Matching, Cost Sharing, In-Kind Contributions
and Program Income
Procurement / (Contracts / Subagreements
Disadvantaged Business Enterprises
Pr< >pertv Management
Internal Controls
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Module 6: Financial System Requirements
Learner Notes
The "goals and objectives" for an efficient
and effective financial management
system are outlined in the EPA
Administrative and Financial Onsite
Review Questionnaire.
The EPA Administrative and
Financial Onsite Review
Questionnaire is provided in the
Appendix and in Module 10 of this
Manual.
The Appendix also contains the
Code of Federal Regulations, 40
CFR Part 31, which includes
31.20(b), an administrative
checklist for reviewing
administrative and financial
systems.
Use it to make sure you have
the necessary systems in
place and operational before
you need them.
Please take a few minutes to locate and
examine the EPA Administrative and
Financial Onsite Review Questionnaire.
An effective financial management
system must account for:
A. Award funds drawn down and dispersed
B. Award project expenses and income
0. Environmental compliance
D. Subcontracts and subawards
E. All of the above
Know the Terminology
What basic financial terminology do we need to
understand?
Before getting into the seven financial management
standards, it would be helpful to understand a few
basic terms.
Many useful terms are provided in:
The Appendix
EPA's online glossary at
http://www.epa.gov/ogd/recipient/glossarv.htm
If you would like additional examples or
explanations, ask your Grants Specialist. Your
Grants Specialist will be happy to provide
individual assistance.
Learner Notes
It is time for another vocabulary exercise.
Take a minute to complete Activity 6.a
(online at www.petetribal.orgX
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Module 6: Financial System Requirements
Fund accounts record financial resources and
obligations in object class categories established
in the:
A. Assistance agreement award
B. EPA document of limitations
C. EPA regie mill office policies
1). Federal restrictions for grant management
E. All of the above
Who is responsible for implementing internal
controls to safeguard resources ensuring accuracy,
reliability, and compliance?
A. EPA headquarters
B. EPA regional officials
C. The Tribal Nation / Recipient
D. The award project manager
E. All of the above
Essential Components of a
Financial Management System
What are the essential components of a financial
management system?
A financial management system ensures proper
reporting and control at all levels of the Tribal
Nation's government. A system must be in place
and operating for the Tribal Nation to be in
compliance with federal regulations.
The essential components of a financial
management system include:
1. Accounting Policies and Procedures
2. Internal Controls
3. Inventory and Equipment
Management
4. Budget Controls
5. Real and Personal Property
Assignment
6. Cost Accounting (direct, indirect,
reasonable, allowable, and allocable)
7. Source Documentation
These components are described in Modules 6, 7,
and 8.
Confidential Business Information
Tribal Nations request the confidential
business exception, like any other recipient,
but EPA \sill determine whether or not
information will be considered "confidential
business information" (CB1).
What are the EPA rules for confidentiality?
Tribal Nations are unique entities, differing
substantially from state, local, and federal
governments. However, EPA documents are public
documents regardless of the entity that they are
awarded to. There are no special EPA rules for
confidentiality for Tribal Nations; rules are the
same for all recipients. Tribal Nations request the
confidential business exception, like any other
recipient, but EPA will determine whether or not
information will be considered "confidential
business information" (CBI).
For example, after September 11, 2001 security
issues increased in importance. EPA funded an
initiative to map all water sources, their
tributaries and flow patterns. The data gathered
was determined to be "confidential business
information". The grant recipient for this project
was authorized to keep project records private,
not sharing vital documents with the public.
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Module 6: Financial System Requirements
Federal Regulations
Accepting an award agreement means the recipient
agrees to comply with:
Title 40 CFR Part 31 - Administrative Requirements
OMB Circular A-8y-Cost Principles
codified in Title 2 CFR Part 225
OMB Circular A - 133 (When the recipient spends
$500,000 or more in federal funds)
All documents are available to the public upon request.
Which financial rules are we agreeing to follow
when we get an award?
When the Tribal Nation accepts a federal assistance
award they agree to follow the accounting and
financial standards established in the federal
regulations 40 CFR Part 31 (Administrative
Requirements) and the OMB Circular A-87 (Cost
Principles).
EPA, the Inspector General, the Comptroller of the
United States, or any other duly authorized
representative has the right to timely and
unrestricted access to any books, documents,
papers, or other records of the Tribal Nation that
are pertinent to the awards. They have the right to
conduct audits, examinations, and take excerpts,
transcripts, and copies of such documents. This
right also includes timely and reasonable access to
Tribal personnel for the purposes of interviews and
discussions related to such documents.
Additional Guidance
Native American
Finance Officers
Association guidelines
the Atir Financial
Reporting Model for
Tribal Governments -
Implementing
Government Accounting
Standards Board
(GAMS) Statement 34
In addition to the guidance contained in this
Manual, Tribal Nations can go to the Native
American Finance Officers Association website at
http://www.nafoa.org/ to find guidelines from their
publication New Financial Reporting Model for
Tribal GovernmentsImplementing Government
Accounting Standards Board (GASB) Statement 34.
The Government Accounting Standards Board
Statement is available at http://www. gasb.org/.
In 2002 the Aleutian/Pribilof Islands Association
developed a manual of management and
administrative policies and procedures. You may
find it helpful as a guide when writing your own
policies and procedures. This manual is provided in
the Appendix.
Which of the following is necessary for
financial accounting information to be
protected by EPA as "confidential business
information"?
A. Generally Accepted Accounting Principles
(GAAP) '
B. Public disclosure of information policies
C. Approval of request for confidential business
information protection
D. Financial reporting and tracking
E. All of the above
Accrual Accounting Method
The accrual method of
accounting is
recommended by EPA.
= Income is counted-uhen the
underlying grant eligible
expenditures are made,
= Expenses are counted when
the goods or services are
received or incurred.
Accounting Processes
Which accounting system is recommended?
There are two types of accounting methods: cash
and accrual. The recipient needs to choose either
the cash or accrual accounting method and use it
throughout the award period. It is important to
understand the basics of these two principal
methods of keeping track of income and expenses.
These methods differ only in the timing of
transactions, including sales and purchases, when
they are credited or debited to your accounts.
The accrual method or accrual basis accounting
is the more commonly used method of accounting.
Under the accrual method, transactions are counted
when the order is made, the item is delivered, or
the services occur, regardless of when the money
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Module 6: Financial System Requirements
for them (receivables) is actually received or paid.
In other words, income is counted when the sale
occurs, and expenses are counted when the goods
or services are received. You don't have to wait
until you see the money, or actually pay money out
of your checking account, to record a transaction.
Do we need to use an automated or
computerized accounting system?
The federal assistance agreement requirements do
NOT specify the type of accounting system a
Tribal Nation must have, but the requirements do
specify what the accounting system must be able to
do.
Cash Accounting Method
The cash method of
accounting is accepted
when used consistently
throughout the award
period.
= Income is not counted until
cash (or a check) is actually
received.
= Expenses are not counted
until they are actuaBypaid,
Under the cash method or cash basis accounting,
income is not counted until cash (or a check) is
actually received, and expenses are not counted
until they are actually paid.
The method you use is your decision although
accrual is generally the accepted system for
nonprofit organizations. EPA highly recommends
the accrual basis of accounting.
Which accounting method does EPA
recommend?
A. Accrual basis
B. Assets and liabilities
0. Cash basis
D. Fund basis
E. None of the above
Computerized Accounting System
A computerized
accounting system is
not required by
EPA, but it does
make record
keeping easier.
As Tribal Nations receive more federal awards,
they may decide to convert to a computerized fund
accounting system, if they have not already done
so. Various accounting systems are used for
tracking federal funds.
Which of the following is not a necessary
requirement for your Tribal Nation's
accounting system?
A. Compliance with federal regulations
B. Computerized record keeping
C. Personnel dedicated to managing award funds
and reports
D. Separate, accurate, current, and complete
records
E. Documented accounting policies and
procedures
Accounting Procedures
Accounting procedures are
part of a financial system
that consists of:
3 Policies,
= Procedures, and
= Documents
Supporting the:
= Collecting
= Recording,
= Disbursing, and
° Reporting
Of all the award recipients financial activity.
What are the required accounting procedures?
Accounting procedures are the processes a Tribal
Nation uses to record all of its financial
transactions. Accounting procedures are part of a
financial system that consists of policies,
procedures, and documents supporting the
recording, disbursing, and reporting of the Tribal
Nation's financial activity, so that the Tribal
Nation's leadership (elected administration),
department heads, and the federal government have
good information about the financial status of a
project.
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Module 6: Financial System Requirements
Sample Policy and Procedure Categories
Financial Management Policies and Procedures
Section
Section
Section
Section
Section
Section
Section
Section
Section
Section
Section
Section
Section
100
1 00
5.00
4.00
5.00
6.00
7.00
8.00
9.00
10.00
11.00
12.00
1 1 00
14.00
Introduction/Purpose
C^nlMai-rirrM.fici! Pulilii Ai , diifi'.H-it K.PAj
Consullants
Cash Receipts and Deposits
Computerized Check Register
Check Writing and Supporting Documentation
Purchasing
Documentation of Expenditures
Inventory/Property Management
Payroll Preparation
Budgeting Process Program Reporting
Financial Reports
Reporting Requirements
Audits
Indirect Costs
Pagol
fits: 1
Page 2
Pagi 2
Pages
Page 3
P.igi: J
Page 6
Page?
!'di'.j ti
Page9
Page 10
PJEC'll
fVii-V U
Page 13
Each award recipient is unique. For example, your
Tribal Nation may or may not need to address
these sample categories in your written policies
and procedures.
A financial accounting system consists of
policies, procedures, and documents that
support the of a Tribal Nation's
financial activity.
A. collecting
B. recording
C. disbursing
D. reporting
E. All of the above
Finance Tracking
A flexible accounting system
manual iir auli'in;itu
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Module 6: Financial System Requirements
Chart of Accounts
The chart of accounts is
the "backbone" of an
accounting system and
lists all of the accounts in
the general ledger.
Each transaction is
coded to an account.
025-1300 Bank checking.'savings
025-1800 Accounts Re-eeh-able
025-2.100 Accounts Payable
025-2200 Salary Payable
025-3300 salary Benefits payable
025-2350 Deferred Revenue
025-4000 Income
025-5000 Salary
025-5900 sal ary Benefits
025-6000 Contract Labor
025-6320 Supplies
025-6500 Equipment Rental
025-6650 Group Meetings
025-6-00 Travel
035-6800 indirect
Chart of accounts
What is the chart of accounts?
The chart of accounts lists all of the accounts in the
general ledger of the Tribal Nation. Each account is
identified with an account number and it is used to
record and classify financial data including revenue
and expenses. The chart of accounts could include
EPA projects or "funds," rent, utilities, and other
essential expenses.
Document Reference Numbering System
Recorded in the General.] ournal
Identifies transactions
Needs to beused consistently
Cash Disbursements Journal for FY 20011/2012
DRfJ Date Description Amount
Q1OO21
O1OO22
010023
12/o8/2Olt
12/16/2Q11
12/17/2011
Excavation
GateinstaDation
Clarifer
529,600.00
$537.84
S548.35
Document reference numbering system
What does a document reference numbering
system do?
A document reference numbering system is
designed by a Tribal Nation to identify the
transactions that are entered into the general
journal. The Tribal Nation needs to use this system
consistently for like transactions.
If the document reference number is the Check
Number, then every time a check is written, the
Check Number is used, rather than a file number or
other identifier.
What does a document reference numbering
system do?
A. Code project ledgers
B. Enter items into the general journal
C. Identity transactions
D. Inventories equipment
E. All of the above are possible.
General Journal
Also known as the
Book of Original Entry
Is the accounting
record of transactions
Is recorded in
chronological order
Note: With accounting software packages, otherjoumals such as payroll,
cash receipts, cashdisbursemente.procurement accounts payable and
accounts recehBbteareoften used instead of the general journal.
General Journal
What should be recorded in the general journal?
The general journal, also called the Book of
Original Entry, is the first place the Tribal Nation
records anything affecting their financial well-
being. The general journal is the accounting record
where transactions are initially recorded in
chronological order.
The general journal is a daily log of transactions. It
needs to include the following:
Date the item is being recorded
Account number and name of the
transaction that it affects
Debit columnthe amount that is debited
to the account (subtracted from the
balance)
Credit column the amount that is
credited to the account (added to the
balance)
Transaction descriptionan explanation
of why the transaction was recorded into
the Tribal Nation's accounting records
Document reference numberthe Tribal
Nation's reference code for the kind of
transaction being recorded.
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For example, when payments are made the
reference number can be the Check Number. If a
receipt of ordered supplies is recorded, then the
vendor's invoice number or a voucher number may
be used.
General Ledger
Compilation of all accounts that show detailed
transactions by account.
Accounts are listed in account number order in the
ledger.
Journal transactions are posted in the General Ledger by
Account number.
Shows account:
Beginning balances
Detail of changes
Ending balances ^^f ^ ^pl
^''^f-
General Ledger
What goes in the general ledger?
A general ledger contains all asset, liability, and
equity accounts for the Tribal Nation. It lists the
beginning balance, the detail of changes, and the
ending balance in each account. The entire group
of accounts maintained by a Tribal Nation is
referred to collectively as the ledger.
Dating Accounting Records
The journal records original date and
the ledger records data by account.
General
Journal
Date of
transaction
General
Ledger
vas recorded in
theGeneral
Journal
Which date do we put in the ledger?
The date entered into the general ledger must be
the same date that appears in the general journal.
The date in the general journal is the date the
information is originally recorded in the general
journal.
Posting Reference Number
Each posting to the General Ledger is given a
Posting Reference Number (PRN)
The PRN identifies the page of general journal or
any other journal (such as payroll) on which the
transaction is recorded.
Differentsystails mayhaw usedifferentidentifiers such as
*journal,r or ^entries."
What is a posting reference number?
The posting reference number refers to the page of
the general journal that the transactions come from.
General journal pages are usually numbered
sequentially for the entire year.
General Ledger Column Entries
Debit Deduct amount paid or
expenses
Oedit + Add deposits, refunds,
and income
Balance ~ Debits and credits must
balance equally
What goes in the debit column?
The debit column must contain the deducted or
paid amount that was recorded in the general
journal.
What goes in the credit column?
The credit column must contain the amount added
(i.e., deposit, refund, etc.) that was recorded in the
general Journal.
What goes in the balance column?
The balance column reports the result of adding
and subtracting from the account. Debit and credit
columns must balance equally.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 6: Financial System Requirements
Table 8: Sample General Journal
December 31, 2011
Trans#
1
1
2
2
3
3
4
4
4
5
5
6
6
7
7
8
8
9
9
10
10
11
11
11
12
12
13
13
13
13
14
14
15
15
TOTAL
Type
check
check
check
check
check
check
wire
wire
wire
check
check
check
check
check
check
check
check
check
check
check
check
wire
wire
wire
JE
JE
JE
JE
JE
JE
JE
JE
JE
JE
Date
12/06/11
12/06/11
12/07/11
12/07/11
12/11/11
12/11/11
12/12/11
12/12/11
12/12/11
12/12/11
12/12/11
12/13/11
12/13/11
12/15/11
12/15/11
12/16/11
12/16/11
12/20/11
12/20/11
12/20/11
12/20/11
12/26/11
12/26/11
12/26/11
12/30/11
12/30/11
12/30/11
12/30/11
12/30/11
12/30/11
12/31/11
12/31/11
12/31/11
12/31/11
DRN#
ck92
ck92
ck93
ck93
ck94
ck94
w#25
w#25
w#25
ck95
ck95
ck96
ck96
ck97
ck97
ck98
ck98
ck99
ck99
cklOO
cklOO
w#26
w#26
w#26
jel
jel
je2
je2
je2
je2
je3
je3
je4
je4
Name
AA Airlines
AA Airlines
Ox Rentals
Ox Rentals
Rest Hotel
Rest Hotel
Tribal Bank
Tribal Bank
Tribal Bank
ABC Supply
ABC Supply
XYZ Hall
XYZ Hall
Computer
Supp.
Computer
Supp.
J. Doe
J. Doe
USA
construct.
USA
construct.
Office Supply
CO.
Office Supply
CO.
Tribal Bank
Tribal Bank
Tribal Bank
EPA
EPA
Tribal Bank
Tribal Bank
Tribal Bank
Tribal Bank
USA
construct.
USA
construct.
Tribe indirect
Tribe indirect
Memo
J. Doe airline ticket
J. Doe airline ticket
rent for Dec-08
rent for Dec-08
J. Doe hotel exp.
J. Doe hotel exp.
Payroll ending 12/12/08
Payroll ending 12/12/08
Payroll ending 12/12/08
parts for EPA project
parts for EPA project
Start-up EPA meeting
Start-up EPA meeting
Computer supplies
Computer supplies
travel per diem
travel per diem
12/01/08-12/17/08
12/01/08-12/17/08
Office supplies
Office supplies
Payroll ending 12/26/08
Payroll ending 12/26/08
Payroll ending 12/26/08
Dec-08 accrual
Dec-08 accrual
Payroll accrual 12/31/08
Payroll accrual 12/31/08
Payroll accrual 12/31/08
Payroll accrual 12/31/08
12/18/08-12/31/08
12/18/08-12/31/08
Dec-08 indirect
Dec-08 indirect
Account
025-6700 - Travel
025-1300 -Bank
025-6500 - Equip. Rent
025-1300 -Bank
025-6700 - Travel
025-1300 -Bank
025-5000 - Salary
025-5900 - Salary Ben.
025-1300 -Bank
025-6320 - Supply
025-1300 -Bank
025-6650 - Group meet.
025-1300-Bank
025-6320 - Supplies
025-1300-Bank
025-6700 -travel
025-1300-Bank
025-6000 - Contract
025-1300-Bank
025-6320 - Supplies
025-1300-Bank
025-5000 - Salary
025-5900 -Salary Ben.
025-1300-Bank
025-4000 - Income
025-1800 -A/R
025-5000-Salary
025-5900-Salary Ben.
025-2200-Salary Payable
025-2300-Sal.Ben.Payable
025-6000 - Contract
025-1300 -A/P
025-6800 - Indirect
025-2100-A/P
Debit
700.00
1,200.00
800.00
9,000.00
1,530.00
2,800.00
400.00
1,500.00
600.00
2,000.00
500.00
8,500.00
1,440.00
40,000.00
3,000.00
530.00
3,000.00
2,500.00
80,000.00
Credit
700.00
1,200.00
800.00
10,530.00
2,800.00
400.00
1,500.00
600.00
2,000.00
500.00
9,940.00
40,000.00
3,000.00
530.00
3,000.00
2,500.00
80,000.00
Page 1
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013 Page 152 of 279
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Module 6: Financial System Requirements
Learner Notes
Activity 6.b (online at www.petetribal.org')
provides you with the opportunity to
practice entering information into a
General Ledger.
iBB
Why do we need both a general
journal and a general ledger?
A. Cross checking requires the bookkeeper to look
at transactions in different ways.
B. It helps accountants check mathematical
accuracy.
C. The journal records data on multiple accounts.
D. The ledger tracks data by separate accounts.
E. All of the above
Common Financial Reports
Balance Sheet
Income Statement/Profit & Loss
Budget vs. Actual Expenditures
Financial Reporting
What must be reported?
Accurate, current, and complete disclosure of the
financial results of financially-assisted activities
must be made in accordance with the financial
reporting requirements of the assistance agreement
award. The provisions of 40 CFR 31.41 discuss
financial reporting requirements in greater detail.
40 CFR Part 31 is provided in the Appendix.
Which financial reports are prepared and when?
Two financial reports are produced by a Tribal
Nation from the general ledger accounts on a
monthly basis a (1) balance sheet and (2) financial
statement.
A balance sheet lists:
All the assets
Things of value
Liabilities (payments due to third parties)
Fund balance or fund equity
Sample Balance Sheet
BALANCE SHEET SUMMARY
AccoLnts Oece'wab*
ToM Current Assets
TOTAL ASSETS
LIABILITIES & EQUITY
Current L
3. 50O.OO
1000.00
600.QO
Total Current LjatHbties
TOTAL LIABILITIES & EQUITY
S.1QO.OQ
Bl.WXXOO
A statement of revenues, expenditures, and
changes in fund balance breaks down the funds
into various revenue streams (e.g., assistance
agreements). Each grant has its own budget with
different line-item or cost categories. These cost
categories are established in the chart of accounts.
The statement of revenues, expenditures, and
changes shows how much money has been spent
from each cost category and how much of the
budgeted balance remains.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
tast Updated April 2013
Page 153 of 279
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Module 6: Financial System Requirements
Sample Income Statement
INCOME STATEMENT/PROFIT & LOSS
December 31,2011
Expense
Personnel
F-'nje Een«Tts
"Bavtf
Suppfei
Contractual
rz -jrt
fct»l Expense
3.K3O.OO
E,000.00
4.BQO.OQ
1,200.00
4QO.QO
EOO.OO
UQO.flO
Budget vs. Actual
BUDGET vs. ACTUAL
Decentlw31,Z4)lt
Budget
J:. :::::
Personne-.
Ffrge Eerefts
fwd
22.000.00 20,500.00
3,700.00
7.000.00
5,000.00
1,200.00
600.00
3ODJM
I.9OD.OO
1,700.00
: ::o.;o
5.000.00
4.300.00
UOO.OQ
400.00
SOO.OO
140O.OO
:: :-: :c
1,50000
200 J30
2,000.00
200.00
0.00
200.00
1.00 JM
Ei'j ::
Sample Comparison of Budget and Actual Expenses
A financial statement of revenues, expenditures,
and changes in fund balance shows:
Break-downs in the funds into various
revenue streams
The budget
What has been put against the project
funds in specific cost categories
Balances remaining in funds
Yearly Financial Reporting
Federal Financial
Report (FFR) SF 425
Check the"termsand
conditions" of the award
Las Vegas Finance
Center (LVFC)
This form is used to dose out a grant or cooperative agreement and
may a/so be needed if the terms and conditions of the award
require interim or annual financial status reports.
When is the report sent to EPA?
As of October 1, 2009, the Federal Financial
Report (FFR) Standard Form (SF) 425 replaced:
Standard Forms 269 and 269A Financial
Status Report (FSR)
Standard Forms 272 and 272A Federal
Cash Transactions Report
as the only financial status report accepted by the
Las Vegas Finance Center (LVFC).
SF 425 is used to close out a grant or cooperative
agreement and may also be needed if the terms and
conditions of the award require interim or annual
financial status reports. Grant recipients are no
longer required to submit Federal Cash Transaction
information formerly reported on the SF 272.
Tribal Nations must submit a final Federal
Financial Report (FFR) SF 425 no later than 90
days after the end of the budget/project period.
Some regions require interim financial status
reports, read the "administrative terms and
conditions" of your award very carefully for your
specific reporting requirements. If your assistance
agreement requires submission of an interim or
annual financial status report, please submit the SF
425 FFR following the schedule stipulated in the
terms and conditions of the agreement.
Please be advised. The Federal Financial Report
(FFR) Standard Form (SF) 425 replaced
Standard Forms 269,269A and 272,272A
on October 1,2009.
Financial Report Due Dates
Monthly
Finance Department
Balance Sheet
Statement of Revenues
expenditures, and
changes
Yearly
toLVFC
SF 425 Federal
Financial Report
Copies of the Federal Financial Report (FFR)
Standard Form (SF) 425 are available in Activity 6c
(online at www.petetribal.org) and the Appendix.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
Page 154 of 279
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Module 6: Financial System Requirements
Reflection
What do the "administrative terms
and conditions" in your award say
about financial management
systems?
How often does your award require
financial status reporting?
Monthly reports are kept in the recipient's
files. Yearly reports are sent to the Las
Vegas Finance Center.
What does a financial statement show?
A. Chart of accounts
B. Debit, credit, and balance columns
C. Generaljournalandledger entries
D. Summary of financial activities by project
E. None of the above
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 6: Financial System Requirements
Table 9: Sample General Ledger for a Single Account
General Ledger Detail by Account
As of December 31, 2011
Type Date PRN
025-4000 Income
JE* 12/30/11 Je* 1
Total 025-4000 Income
025-5000 Salary
wire 12/12/1 IT wire 25
wire 12/26/11 wire 26
JE 12/30/11 je2
Total 025-5000 Salary
025-5900 Salary
Benefits
wire 12/12/11 wire 25
wire 12/26/11 wire 26
JE 12/30/11 je2
Total 025-5900 Salary Benefits
025-6000 Contract Labor
check 12/20/11 ck 99
JE 12/30/11 je3
Total 025-6000 Contract Labor
025-6320 Supplies
check 12/12/11 ck 95
check 12/15/11 ck 97
check 12/20/11 ck 98
Total 025-6320 Supplies
025-6500 Equipment Rental
check 12/07/11 ck93
Total 025-6500 Equipment Rental
025-6650 Group Meetings
check 12/13/11 ck 96
Total 025-6500 Group Meetings
025-6700 Travel
check 12/06/11 ck92
check 12/11/11 ck94
check 12/16/11 ck97
Total 025-6700 Travel
025-6800 Indirect
JE 12/31/11 je4
Total 025-6800 Indirect
Totals for 025
Name
EPA
Tribe Salaries
Tribe Salaries
Tribe Salaries
Tribe Salaries
Tribe Salaries
Tribe Salaries
USA Construction
USA Construction
ABC Supply Co.
Computer Supply
Co.
Office Supp. Co.
Ox Rentals
XYZ Hall
AA Airlines
Rest Hotel
J. Doe
Tribe Indirect
Memo
Dec-08 accrual
pay ending 12/12/08
pay ending 12/26/08
pay accrual 12/31/08
pay ending 12/12/08
pay ending 12/26/08
pay accrual 12/31/08
12/01/08-12/17/08
12/18/08-12/31/08
parts for project
computer supplies
office supplies
rent for Dec-08
start-up EPA Meeting
J. Doe airline ticket
J. Doe hotel exp.
travel per diem
indirect on EPA project
Debits
9,000.00
8,500.00
3.000.00
20,500.00
1,530.00
1,440.00
530.00
3,500.00
2,000.00
3000.00
5,000.00
2,800.00
1,500.00
500.00
4,800.00
1.200.00
1,200.00
400.00
400.00
700.00
800.00
600.00
2,100.00
2.500.00
2,500.00
40,000.00
Credits Balance**
40.000.00
40.000.00 -40,000.00
20,500.00
3,500.00
5,000.00
4,800.00
1,200.00
400.00
700.00
2,100.00
2.500.00
40,000.00 00.00
Page 1
*JE/je means the transaction was entered manually on the general journal.
"Balances represent expenses by category. General journals for grants should balance evenly. There should be
the same amount of income/credits as there are expenses/debits.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 6: Financial System Requirements
Financial reporting is
an important project
management tool.
How does financial reporting help our Tribal
Nation?
Timely and accurate financial reporting is an
important project management tool for both the
Tribal Nation and EPA. It enables the Tribal
Nation and EPA to ensure that the project is on
track and alerts the Tribal Nation and EPA if a
project has developed issues that need to be
resolved. Not supplying the proper and timely
financial status reports could jeopardize additional
and/or future funding.
Financial reporting is a great internal control. A
project's administrative and financial personnel
should meet on a regular basis, such as once each
month. Getting everyone together provides them
with an appreciation for the scope of the project,
reporting progress and discovering problems.
At the administrative and financial personnel
meeting discuss the status of the project, for
example:
Where are we now? What is the timeline and
how are we doing?
What, if any changes have been made since
the last meeting?
Are there any needs at this time? If so, how
can we best meet those needs?
What is due before the next meeting?
What happens if the Tribal Nation is unable to file
financial reports as required?
A. Award funds become unavailable or are
withheld.
B. Draw-down of funds requires additional
documentation.
C. The Tribal Nation may experience budget
problems.
D. It becomes more difficult to win assistance
awards in the future.
E. All of the above are possible.
Financial Status Reports
Invokes I ^Financial
Status
"- Financial Report
Statements
CHECK YOUR "TERMS AND CONDITIONS" FOR DETAILS.
Financial Status Reports
What are the requirements?
Accounting records must support the costs claimed
on each financial status report. Different EPA
programs may have different financial reporting
requirements. See the "administrative terms and
conditions" in the award for more details.
How do we prepare financial reports?
Once the transaction has been put in the general
journal, it is posted to the general ledger by
account. The accounting system generates a
summary of total balance of all accounts in the
general ledger and is used to prepare and provide
"financial statements" that report the Tribal
Nation's financial activities by project.
The accounting system needs to produce a
Federal Financial Report (FFR), which is used
to reconcile requests for advances or
reimbursements from EPA. This report is also
used for budget control within the Tribal Nation
and departments responsible for performing tasks
in the project work plans.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 6: Financial System Requirements
Federal Financial Report Instructions
Report Submissions
1) Recipients will be instructed by Federal agencies to submit the Federal Financial Report (FFR) to a
single location, except when an automated payment management reporting system is utilized. In this case,
a second submission location may be required by the agency.
2) If recipients need more space to support their FFRs, or FFR Attachments, they should provide
supplemental pages. These additional pages must indicate the following information at the top of each
page: Federal grant or other identifying number (if reporting on a single award), recipient organization,
Data Universal Numbering System (DUNS) number, Employer Identification Number (BIN), and period
covered by the report.
Reporting Requirements
1) The submission of interim FFRs will be on a quarterly, semi-annual, or annual basis, as directed by the
Federal agency. A final FFR shall be submitted at the completion of the award agreement. The following
reporting period end dates shall be used for interim reports: 3/31, 6/30, 9/30, or 12/31. For final FFRs, the
reporting period end date shall be the end date of the project or grant period.
2) Quarterly and semi-annual interim reports shall be submitted no later than 90 days after the end of each
reporting period. Final reports shall be submitted no later than 90 days after the project or grant period end
date.
Note: For single award reporting:
1) Federal agencies may require both cash management information on lines 10(a) through 10(c) and
financial status information lines 10(d) through 10(o).
2) 10(b) and 10(e) may not be the same until the final report.
Line Item Instructions for the Federal Financial Report
FFR
Number
Reporting Item
Instructions
Cover Information
1
2
3
4a
4b
5
6
7
Federal Agency and
Organizational Element to
Which Report is Submitted
Federal Grant or Other
Identifying Number
Assigned by Federal
Agency
Recipient Organization
DUNS Number
EIN
Recipient Account Number
or Identifying Number
Report Type
Basis of Accounting
(Cash/Accrual)
Enter the name of the Federal agency and organizational element identified in
the award document or as instructed by the agency.
For a single award, enter the grant number assigned to the award by the Federal
agency. For multiple awards, report this information on the FFR Attachment. Do
not complete this box if reporting on multiple awards.
Enter the name and complete address of the recipient organization including zip
code.
Enter the recipient organization's Data Universal Numbering System (DUNS)
number or Central Contract Registry extended DUNS number.
Enter the recipient organization's Employer Identification Number (EIN).
Enter the account number or any other identifying number assigned by the
recipient to the award. This number is for the recipient's use only and is not
required by the Federal agency. For multiple awards, report this information on
the FFR Attachment. Do not complete this box if reporting on multiple awards.
Mark appropriate box. Do not complete this box if reporting on multiple awards.
Specify whether a cash or accrual basis was used for recording transactions
related to the award(s) and for preparing this FFR. Accrual basis of accounting
refers to the accounting method in which expenses are recorded when incurred.
For cash basis accounting, expenses are recorded when they are paid.
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Module 6: Financial System Requirements
8
9
10
Project/Grant Period,
From: (Month, Day, Year)
Project/Grant Period, To:
(Month, Day, Year)
Reporting Period End
Date: (Month Day, Year)
Indicate the period established in the award document during which Federal
sponsorship begins and ends.
Note: Some agencies award multi-year grants for a project period that is funded
in increments or budget periods (typically annual increments). Throughout the
project period, agencies often require cumulative reporting for consecutive
budge periods. Under these circumstances, enter the beginning and ending dates
of the project period not the budget period. Do not complete this box if reporting
on multiple awards.
See the above instructions for "Project/Grant Period, From: (Month, Day,
Year)."
Enter the ending date of the reporting period. For quarterly, semi-annual, and
annual interim reports, use the following reporting period end dates: 3/31, 6/30,
9/30, or 12/31. For final FFRs, the reporting period end date shall be the end
date of the project or grant period.
Transactions
Enter cumulative amounts from date of the inception of the award through the end date of the reporting period
specified in line 9.
Use Lines lOa through lOc, Lines lOd through lOo, or Lines lOa through lOo, as specified by the Federal
agency, when reporting on single grants.
Use Line 12, Remarks, to provide any information deemed necessary to support or explain FFR data.
Federal Cash (To report multiple grants, also use FFR Attachment)
lOa
lOb
lOc
Cash Receipts
Cash Disbursements
Cash On Hand (Line lOa
Minus Line lOb)
Enter the cumulative amount of actual cash received from the Federal agency as
of the reporting period end date.
Enter the cumulative amount of Federal fund disbursements (such as cash or
checks) as of the reporting period end date. Disbursements are the sum of actual
cash disbursements for direct charges for goods and services, the amount of
indirect expenses charged to the award, and the amount of cash advances and
payments made to subrecipients and contractors.
For multiple grants, report each grant separately on the FFR Attachment. The
sum of the cumulative cash disbursements on the FFR Attachment must equal
the amount entered on Line lOb, FFR.
Enter the amount of Line lOa minus Line lOb. This amount represents
immediate cash needs. If more than three business days of cash are on hand, the
Federal agency may require an explanation on Line 12, Remarks, explaining
why the drawdown was made prematurely or other reasons for the excess cash.
Federal Expenditures and Unobligated Balance: Do not complete this section if reporting on multiple awards.
lOd
lOe
Total Federal Funds
Authorized
Federal Share of
Expenditures
Enter the total Federal funds authorized as of the reporting period end date.
Enter the amount of Federal fund expenditures. For reports prepared on a cash
basis, expenditures are the sum of cash disbursements for direct charges for
property and services; the amount of indirect expense charged; the value of
third-party in-kind contributions applied; and the amount of cash advance
payments and payments made to subrecipients. For reports prepared on an
accrual basis, expenditures are the sum of cash disbursements for direct charges
for property and services; the amount of indirect expense incurred; the value of
in-kind contributions applied; and the net increase or decrease in the amounts
owed by the recipient for (1) goods and other property received; (2) services
performed by employees, contractors, subrecipients, and other payees; and (3)
programs for which no current services or performance are required. Do not
include program income expended in accordance with the deduction alternative,
rebates, refunds, or other credits. (Program income expended in accordance with
the deduction alternative should be reported separately on Line lOo.)
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 6: Financial System Requirements
lOf
lOg
lOh
Federal Share of
Unliquidated Obligations
Total Federal Share (Sum
of Lines lOeandlOf)
Unobligated Balance of
Federal Funds (Line lOd
Minus Line lOg)
Unliquidated obligations on a cash basis are obligations incurred, but not yet
paid. On an accrual basis, they are obligations incurred, but for which an
expenditure has not yet been recorded. Enter the Federal portion of unliquidated
obligations. Those obligations include direct and indirect expenses incurred but
not yet paid or charged to the award, including amounts due to subrecipients and
contractors. On the final report, this line should be zero unless the awarding
agency has provided other instructions.
Do nof include any amount in Line lOf that has been reported in Line lOe. Do not
include any amount in Line lOf for a future commitment of funds (such as a long-
term contract) for which an obligation or expense has not been incurred.
Enter the sum of Lines lOe and lOf
Enter the amount of Line lOd minus Line lOg.
Recipient Share: Do not complete this section if reporting on multiple awards.
lOi
10j
10k
Total Recipient Share
Required
Recipient Share of
Expenditures
Remaining Recipient Share
to be Provided (Line lOi
Minus Line lOj)
Enter the total required recipient share for reporting period specified in line 9.
The required recipient share should include all matching and cost sharing
provided by recipients and third-party providers to meet the level required by
the Federal agency. This amount should not include cost sharing and match
amounts in excess of the amount required by the Federal agency (for example,
cost overruns for which the recipient incurs additional expenses and, therefore,
contributes a greater level of cost sharing or match than the level required by the
Federal agency).
Enter the recipient share of actual cash disbursements or outlays (less any
rebates, refunds, or other credits) including payments to subrecipients and
contractors. This amount may include the value of allowable third party in-kind
contributions and recipient share of program income used to finance the non-
Federal share of the project or program. Note: On the final report this line should
be equal to or greater than the amount of Line 1 Oi.
Enter the amount of Line 1 Oi minus Line 1 Oj. If recipient share in Line 1 Oj is
greater than the required match amount in Line 1 Oi, enter zero.
Program Income: Do not complete this section if reporting on multiple awards.
101
10m
lOn
lOo
11
lla
lib
lie
lid
lie
llf
Hg
Total Federal Program
Income Earned
Program Income Expended
in Accordance With the
Deduction Alternative
Program Income Expended
in Accordance With the
Addition Alternative
Unexpended Program
Income (Line 1 01 Minus Line
1 Om or Line 1 On)
Enter the amount of Federal program income earned. Do not report any program
income here that is being allocated as part of the recipient's cost sharing amount
included in Linel Oj.
Enter the amount of program income that was used to reduce the Federal share
of the total project costs.
Enter the amount of program income that was added to funds committed to the
total project costs and expended to further eligible project or program activities.
Enter the amount of Line 1 01 minus Line 1 Om or Line 1 On. This amount equals the
program income that has been earned but not expended, as of the reporting
period end date.
Indirect Expense: Complete this information only if required by the awarding agency and in accordance with
agency instructions.
Type of Rate(s)
Rate
Period From; Period To
Base
Amount Charged
Federal Share
Totals
State whether indirect cost rate(s) is Provisional, Predetermined, Final, or Fixed.
Enter the indirect cost rate(s) in effect during the reporting period.
Enter the beginning and ending effective dates for the rate(s).
Enter the amount of the base against which the rate(s) was applied.
Enter the amount of indirect costs charged during the time period specified.
(Multiply 1 Ib. x lid.)
Enter the Federal share of the amount in lie.
Enter the totals for columns lid, lie, and 1 1 f .
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 6: Financial System Requirements
Remarks, Certification, and Agency Use Only
12
13a
13b
13c
13d
13e
14
Remarks
Typed or Printed Name and
Title of Authorized
Certifying Official
Signature of Authorized
Certifying Official
Telephone (Area Code,
Number and Extension)
E-mail Address
Date Report Submitted
(Month, Day, Year)
Agency Use Only
Enter any explanations or additional information required by the Federal
sponsoring agency including excess cash as stated in line 1 Oc.
Enter the name and title of the authorized certifying official.
The authorized certifying official must sign here.
Enter the telephone number (including area code and extension of the individual
listed in Line 1 3a.
Enter the e-mail address of the individual listed in Line 1 3a.
Enter the date the FFR is submitted to the Federal agency using the month,
year format.
day,
This section is reserved for Federal agency use.
Line Item Instructions for the Federal Financial Report Attachment
(To be completed if reporting on cash management activity for multiple grants.)
There is not a separate attachment form.
Attach one FFR for each award providing the information described below for each additional award.
Box
Number
1
2
3a
3b
4
5
Reporting Item
Federal Agency and
Organizational Element to
Which Report is Submitted
Recipient Organization
DUNS Number
EIN
Reporting Period End Date:
(Month Day, Year)
Federal Grant Number
Recipient Account Number
Cumulative Federal Cash
Disbursement
Total
Instructions
Enter the name of the Federal agency and organizational element identified in
the award document or as instructed by the agency. (This information should be
identical to that entered in Box 1 , FFR.)
Enter the name and complete address of the recipient organization including zip
code. (Same information as entered in Box 3, FFR.)
Enter the recipient organization's Data Universal Numbering System (DUNS)
number or Central Contract Registry extended DUNS number. (Same
information as entered in Box 4a, FFR.)
Enter the recipient organization's Employer Identification Number (EIN). (Same
information as entered in Box 4b, FFR.)
Enter the ending date of the reporting period of this report. (Same information as
entered in Box 9, FFR.)
Enter the grant number assigned to each award by the Federal agency.
Enter the account number or any other identifying number assigned by the
recipient to the award. This number is for the recipient's use only and is not
required by the Federal agency.
Enter the cumulative amount of the Federal share of cash disbursed for each
award. Cash disbursements are the sum of actual cash disbursements for direct
charges for goods and series, the amount of indirect expenses charged to the
award, and the amount of cash advances and payments made to subrecipients
and contractors.
Enter the total for the Cumulative Cash Disbursement. This column should equal
the amount reported on Line lOb, FFR.
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Module 6: Financial System Requirements
FEDERAL FINANCIAL REPORT
(Follow form instructions)
1. Federal Agency and Organizational Element
to Which Report is Submitted
United States Environmental Protection Agency
2. Federal Grant or Other Identifying Number Assigned by Federal Agency
(To report multiple grants, use FFR Attachment)
Page
Of
Pages
3. Recipient Organization (Name and complete address including Zip code)
4a. DUNS Number
4b. EIN
5. Recipient Account Number of Identifying Number
(To report multiple grants, use FFR Attachment)
6. Report Type
D Quarterly
D Semi-Annual
D Annual
D Final
7. Basis of Accounting
D Cash D Accrual
Project/Grant Period
From: (Month, Day, Year)
To: (Month, Day, Year)
9. Reporting Period End Date
(Month, Day, Year)
10. Transactions
(Use lines a-c for single or multiple grant reporting)
Federal Cash (To report multiple grants, also use FFR Attachment):
a. Cash Receipts
b. Cash Disbursements
c. Cash on Hand (line a minus b)
(Use lines d-o for single grant reporting
Federal Expenditures and Unobligated Balance:
d. Total Federal funds authorized
e. Federal share of expenditures
f. Federal share of unliquidated obligations
Total Federal share (sum of lines e and f)
h. Unobligated balance of Federal funds (line d minus g)
Recipient Share:
Total recipient share required
j. Recipient share of expenditures
k. Remaining recipient share to be provided (line I minus j)
Program Income:
I. Total Federal program income earned
m. Program income expended in accordance with the deduction alternative
n. Program income expended in accordance with the addition alternative
o. Unexpended program income (line I minus line m or line n)
11. Indirect
Expense
a. Type
b. Rate
c. Period From
e. Amount Charged
f. Federal Share
g. Totals:
12. Remarks: Attach any explanations deemed necessary or information required by Federal sponsoring agency in compliance with go verning legislation:
13. Certification: By signing this report, I certify that it is true, complete, and accurate tot eh best of my knowledge. I am aware that any false,
fictitious, or fraudulent information may subject me to criminal, civil, or administrative penalties. (U.S. Code, Title 18, Section 1001)
a. Typed or Printed Name and Title of Authorized Certifying Official
c. Telephone (Area code, number and extension)
d. Email address
b. Signature of Authorized Certifying Official
e. Date Report Submitted (Month, Day, Year)
14. Agency use only:
Federal Share Calculation
Standard Form 425
OMB Approval Number: 0348-0061
Expiration Date: 10/31/2011
Paperwork Burden Statement
According to the Paperwork Reduction Act, as amended, no persons are required to respond to a collection of information unless it displays a valid OMB Control Number. The valid OMB control
number for this information collection is 0348-0061. Public reporting burden for this collection of information is estimated to average 1.5 hours per response, including time for reviewing instructions,
searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate or any other
aspect of this collection of information, including suggestions for reducing this burden, to the Office of Management and Budget, Paperwork Reduction Project (0348-0060), Washington, DC 20503.
Table 10: Federal Financial Report, SF425
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Module 6: Financial System Requirements
Learner Notes
Practice completing a Federal Financial
Report, Standard Form 425 in Activity 6.c
(found online at www.petetribal.org').
Federal Financial Reports (FFRs) should
include which of the following information?
A. Assets and liabilities
B. Costs and remaining funds
C. EPA advancements and reimbursements
D. Revenues and expenditures
E. All of the above
Track All Costs
How do we know if our financial reports are
sufficient?
By establishing the document requirements of a
complete accounting system, Tribal Nations are
able to track all costs.
A complete accounting system allows a Tribal
Nation to receive reimbursement for allowable,
reasonable, and allocable costs, as stated in the
OMB Circular A-87.
Examples of financial reports are provided in the
Appendix.
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Module 6: Financial System Requirements
11
Attachment to Module 6
Answers to Quizdom Actionpoint Questions
Question (bold
tes correct answe
An effective financial management system must account for:
A. Award funds drawn down and dispersed
B. Award project expenses and income
C. Environmental compliance
D. Subcontracts and subawards
E. All of the above
The financial management system keeps records on every aspect of the project
with monetary value.
15
Fund accounts record financial resources and obligations in object class categories
established in the:
A. Assistance agreement award
B. EPA document of limitations
C. EPA regional office policies
D. Federal restrictions for grant management
E. All of the above
Fund categories must align with special regulations, restrictions, or limitations,
such as those indicated in the assistance agreement award.
18
Who is responsible for implementing internal controls to safeguard resources
ensuring accuracy, reliability, and compliance?
A. EPA headquarters
B. EPA regional officials
C. The Tribal Nation / Recipient
D. The award project manager
E. All of the above
The Tribal Nation or grant recipient is responsible for safeguarding the resources
granted in EPA assistance agreement awards.
25
Which of the following is necessary for financial accounting information to be
protected by EPA as "confidential business information"?
A. Generally Accepted Accounting Principles (GAAP)
B. Public disclosure of information policies
C. Approval of request for confidential business information protection
D. Financial reporting and tracking
E. All of the above
The financial activities of a Tribal Nation are private and confidential. When a
financial agreement is signed with another governmental entity, such as EPA, the
other entity must be given permission and access to financial information
pertaining to that agreement only. However, a Tribal Nation may request that the
information be protected as "confidential business information" by EPA.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 6: Financial System Requirements
30
tion (bold font indicates correct answer)
Which accounting method does EPA recommend?
A. Accrual basis
B. Assets and liabilities
C. Cash basis
D. Fund basis
E. None of the above
The accrual basis of accounting is recommended by EPA.
34
Which of the following is not a necessary requirement for you Tribal Nation's
accounting system?
A. Compliance with federal regulations
B. Computerized record keeping
C. Personnel dedicated to managing award funds and reports
D. Separate, accurate, current, and complete records
E. Documented accounting policies and procedures
Though computerized accounting systems can make your job easier, they are not
required.
39
A financial accounting system consists of policies, procedures, and documents that
support the of a Tribal Nation's financial activity.
A. collecting
B. recording
C. disbursing
D. reporting
E. All of the above
Reporting the financial status of a project requires recording all financial
transactions, including how funds are disbursed.
43
What is the greatest value of a flexible accounting system?
A. It automatically fixes our errors.
B. It lets us account for more than one source of funding.
C. It lets us manually make changes.
D. It monitors accounts receivable and payable.
E. None of the above
A flexible accounting system allows the grant recipient to track multiple funding
sources and expense accounts.
46
Which of the following are not necessary components in a Tribal Nation's
accounting system?
A. Debit, credit, and balance columns
B. Time stamps and personnel initials
C. Dates and posting reference numbers
D. General journal, ledger, and chart of accounts
E. Flexible accounting and document reference numbering systems
The grant recipient need not time stamp each entry or authorize specific
personnel to initial items after approval. However, recipient may choose to use
these methods for internal control of the financial management system.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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Module 6: Financial System Requirements
lion (bold font indicates correct answer]
What does a document reference numbering system do?
A. Code project ledgers
B. Enter items into the general journal
C. Identify transactions
D. Inventories equipment
E. All of the above are possible.
A document reference numbering system assigns a unique number to each
transaction. Document reference numbers make it easier to track financial
activity (e.g., supplies and equipment, contractors and subawards).
60
Why do we need both a general journal and a general ledger?
A. Cross checking requires the bookkeeper to look at transactions in
different ways.
B. It helps accountants check mathematical accuracy.
C. The journal records data on multiple accounts.
D. The ledger tracks data by separate accounts.
E. All of the above
Data is recorded in the general journal as transactions occur and for all active
accounts. Data from the general journal is transferred to the general ledger, and
categorized by the account to which it is applied. This makes reporting easier.
69
What does a financial statement show?
A. Chart of accounts
B. Debit, credit, and balance columns
C. General journal and ledger entries
D. Summary of financial activities by project
E. None of the above
A financial statement is a report that summarizes a Tribal Nation's financial
activity by project. The financial statement is based on but does not include the
chart of accounts, debit, credit, and balance columns, general journal and ledger
entries.
73
What happens if the Tribal Nation is unable to file financial reports as required?
A. Award funds become unavailable or are withheld.
B. Draw-down of funds requires additional documentation.
C. The Tribal Nation may experience budget problems.
D. It becomes more difficult to win assistance awards in the future.
E. All of the above are possible.
Without timely and accurate financial reports, neither the Tribal Nation nor EPA
is able to monitor how award funds are being used.
77
Federal Financial Reports (FFRs) should include which of the following information?
A. Assets and liabilities
B. Costs and remaining funds
C. EPA advancements and reimbursements
D. Revenues and expenditures
E. All of the above
Federal Financial Reports (FFRs) are comprehensive reports of all financial activity
during a specific time frame.
EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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Module 7: Accounting Policies and Procedures
Module 7: Accounting Policies and Procedures
Tribal, U.S. Territories and
Insular Areas Administrative and
Financial Guidance for
Assistance Agreements
Module 7:
Accounting Policies and Procedures
The Grants Management Process
- Module i: The Grant
Applicaosn Process
Module 2; Assistants
Module 3; Federal Fund ing
Ac conn tabifcp' and
,pareney Act (FFATA)
Module f: Accounting
Policies and Procedures
Module &. Sour<
and Pur-chaiing
Accounting Personnel
Accounting Personnel
Whom does the Tribal Nation need to employ?
For any Tribal Nation to be able to provide
accurate, current, and complete disclosure of
finances under federal awards, Tribal Nations have
personnel who:
Have experience in accounting and/or an
accounting education
Have education or experience with federal
assistance agreements and award
requirements
Are able to prepare and keep accurate and
timely assistance agreement records and
files
Are able to produce financial reports that
can be compared with the award work plan
and the budget
The Tribal Nation is ultimately held accountable
for any discrepancies, not the accountants.
What is Accounting?
Accounting is the recording of financial data for all
receipts, expenditures, assets, liabilities and net worth for
the entire Tribal Nation and includes analysis and
measurement of this information.
= Accounting information is reported to decision
makers.
Keep separate records for each federal assistance
agreement award.
= Records must be separated by funding source.
Accounting Requirements
What is accounting?
Accounting is the recording of financial data for all
receipts, expenditures, assets, liabilities and net
worth for the entire Tribal Nation and includes
analysis and measurement of this information.
The Tribal Nation's accounting department must
keep separate records for each federal assistance
agreement award. Records must be separated by
funding source, such as the Environmental
Protection Agency, Bureau of Indian Affairs,
Indian Health Service, and United States
Department of Agriculture. The Tribal Nation's
accounting records must be accurate, current, and
complete.
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