EPA Publication Number 202K09001
                           EPA Contract Number EP-W-08-042
         Learner Manual - Module 10
 Assistance Agreement Monitoring and Closeout
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.
Office of Environmental Justice, U.S. EPA
U.S. Environmental Protection Agency
Updated August 2013

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             Module 10: Assistance Agreement Monitoring and Closeout
      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).
                                   Contents
MODULE 10: ASSISTANCE AGREEMENT MONITORING AND CLOSEOUT .
  WORKING TOGETHER	3
    Compliance Checklist	3
  THE MONITORING PROCESS	7
  AUDITING ASSISTANCE AGREEMENTS	8
    EPA Audits	8
    Internal Audits	8
    External Audits	10
  CLOSEOUT REQUIREMENTS	14
  RECORDS RETENTION	17
  CONCLUSION	19
  ATTACHMENTS TO MODULE 10	20
    EPA Administrative and Financial Onsite Review Questionnaire	20
    Answers to Self-Assessment Questions	33
        EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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                 Module 10: Assistance Agreement Monitoring and Closeout
                Module 10:  Assistance Agreement Monitoring and Closeout
   Tribal, U.S. Territories and
   Insular Areas Administrative and
   Financial Guidance for
   Assistance Agreements
   Module in:
   Assistance Agreement
   Monitoring and Closeout

   The Grants Management Process
   Project Monitoring
                       • EPA and Tribal Nations
                        work together to ensure
                        project success.

                       • Both parties are
                        responsible for monitoring
                        the administrative and
                        financial progress of the
                        award.
            Working Together
Who monitors the project?
Once a final assistance award document is in place
and work has begun, the recipient needs to monitor
the administrative and financial progress of the
award. EPA is there to help.

The EPA and Tribal Nations work together to
deliver and improve the performance of
environmental protection with assistance
agreement projects. The EPA Project Officer, the
EPA Grants Specialist, and the Tribal Nation's
award personnel need to communicate regularly
about the grant work plan, budget, and
administrative issues.

When EPA reviews a program, the reviewer:
    •   Reads the grant recipient's written
        policies and procedures, then
    •   Applies those policies and procedures to
    •   Program records and
    •   Project budgets,
    •   To ensure compliance with original intent
        of the award.

            Compliance Checklist
The Office of Grants and Debarment or the Office
of Inspector General  may visit your organization to
see how you are managing your assistance
agreement. Some previous on-site visits have
resulted in disallowance of costs, stop-work
actions, and even termination of awards because
the organizations lacked adequate financial and
administrative systems.

Table 1: Sample Compliance Checklist	
In order to avoid this, you MUST do the
following:

•   Have a financial management system that
    tracks all costs expended for your project.
    You can use a simple spreadsheet to track
    your costs and identify those costs to your
    project by using your grant identification
    number.

•   Compete all procurement transactions. If
    competition is not performed, you must have
    on file a sole-source justification.

•   Perform a cost or price analysis on every
    procurement transaction and keep it in your
    file.

•   Have the following internal policies on file:

    S  Time Sheets:  Each employee must have a
        time sheet to show the amount of time
        spent on the project. Time sheets should
        at a minimum be signed and dated by the
        employee and the supervisor.

    S  Personnel Policy
          EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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                  Module 10: Assistance Agreement Monitoring and Closeout
        Travel Policy: Travel costs can be
        charged on an actual, per diem, or
        mileage basis. If you do not have a
        written travel policy, Federal rates for
        travel will be enforced.

        Procurement Policy

        Codes of Conduct: You must have a
        policy that ensures that no conflict of
        interest will involve contract selection,
        award or administration using these grant
        funds.

        Disadvantage Business Enterprise
        Utilization:  You must have a DBE policy
        that ensures you have made positive
        efforts to utilize small businesses,
        minority-owned firms, and women's
        enterprises.
        Each account should be assigned a
        number in your chart of accounts to track
        all costs to the appropriate project. For
        instance, you may want to use your EPA
        grant identification number or your own
        internal identification number to track the
        costs of the project. To better understand
        financial statements, the Small Business
        Administration has information at:
        http://www.sba.gov/content/financial-
        statements .

        You MUST be prepared to provide
        documentation that supports the  costs, if
        you are ever audited or visited by an EPA
        on-site team
Table 3: Sample Compliance Checklist (continued)
   Financial Systems Compliance

    • All transactions imi.sl be recorded in the
     accounting system.

    • All documentation must be approved by the
     project manager or authorized financial officer.

    • Transactions should he numbered and tracked.

    • Documentation must he available to EPA
     officials.
It would be a good idea to hire an accountant to
construct a financial system if you do not already
have one. If this poses a financial burden on your
organization, there are some low cost alternatives
available:

            S  You can contact a local
                university's business school and
                offer an internship to a graduate
                student for accounting services
                at very low costs.

            ^  You can contact your local
                chamber of commerce and ask
                for a list of affordable
                accounting services.
Table 2: Sample Compliance Checklist (continued)
Financial Systems Checklist

We are devoting a separate section to financial
systems because it is extremely important to have
an adequate system in place to ensure that Federal
funds are being used properly. At a minimum:

    •S  ALL monetary transactions in connection
        to the project should have sales invoices,
        checks, freight bills, etc. as
        documentation, and these transactions
        MUST be recorded in an accounting
        system.

    S  ALL documentation must be approved by
        the project manager or other authorized
        person who has authority over charges to
        the project.
   Typical Reporting Schedule
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           EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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                  Module 10: Assistance Agreement Monitoring and Closeout
Table 4: Sample Compliance Checklist (continued)	

Reporting Requirements Checklist

Throughout the life of your grant, you will have to
submit various reports to the EPA Regional Office
(usually the Project Officer), the Office of Grants
and Debarment (OGD), and the Las Vegas Finance
Center (LVFC). The chart above is designed to
help you keep track of the various reports you
MUST submit.
   Remember!
   Changes

   The EPA Project ( )!Tieer must lie notified of unv
   and all changes lo the original project proposal.
     c Re\isions to the objectives or scope of the project
     •  Mo\ing costs from one cost category to another
       (can he done by letter)
     •= Changes in key personnel
     c Time extensions for your project period
       Acquiring third party services
Table 5: Sample Compliance Checklist (continued)

Changes to Your Proposal Checklist
You must notify the EPA Project Officer of all
changes to your proposal. If in doubt, ask.
This includes:

    S  Revisions to the objectives or scope of the
        project

    S  Moving costs from one cost category to
        another (can be done by letter)

                Ex. Decreasing travel costs to
            increase personnel costs

    S  Changes in key personnel

    S  Time extensions for your project period

    S  Acquiring third party services

                Ex. Awarding sub-grants or
            contracts that were not specified in
            the original budget
           3 award

     Docum&pt...Document...Document.

     Make sure costs are reasonable, allowable and allocated
     properly.
                                                            Follow proper procurement procedures.
Important Things To Remember Checklist

•   Always Document!

    S  When auditors look through your file and
        do not see any form of documentation,
        they will assume that EPA has not
        approved any of the actions you have
        taken.

    S  Documentation includes all
        communications, memos, e-mails, etc.

•   Make sure that the costs are allowable!

            •S   EPA will not pay for any type of
                cost. If an auditor finds
                unallowable costs were paid
                through this grant, you will have
                to return the money.  Examples
                of unallowable costs include
                alcohol, lobbying, and paying
                off bad debts.

            S   You can check to see if costs are
                unallowable at:
                http://www. whitehouse. gov/omb/cir
                culars/a087/a87_2004.html.

•   Read your award document!

    S  Your award document outlines  all the
        activities and requirements that you will
        be held responsible for. Once the award is
        official, you have agreed to ALL of the
        terms and conditions  in the document.
           EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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                  Module 10:  Assistance Agreement Monitoring and Closeout
   If a problem arises...

    • Contact your EPA:
      = Project Officer
       (Primary POC)
            OR
      = Grants Specialist
What if things aren't going so well?
It is very important that anytime a Tribal Nation
has a problem that jeopardizes, or has the potential
to jeopardize, the completion of a project; you
contact the EPA Project Officer or Grants
Specialist without delay.
       Learner Notes
       Activity lO.a (online at www.petetribal.org')
       gives you a chance to share your own "war
       stories".
   Communication with EPA
                          Communication takes place
                          = Overthe phone:
                            • Write a summary of the
                             conversation.
                          • Viaemail:
                            • Printthe conversation.
                          = ThroughU.S.Wail:
                            • Copytheletterormemo.

                          Save communications in theprogram
                          orprojectfiles!
                          Incorporate communication into
                          \\Titten pr o gr es s r eports.
Why should we contact EPA representatives
when we encounter a problem?
Contacting the appropriate EPA representative
demonstrates the Tribal Nation is effectively
monitoring the award and managing its programs.
It also demonstrates that the Tribal Nation has
identified a problem and is willing to address it or
wants EPA to make the necessary changes.

During work on the award, both the Tribal Nation
and EPA will encounter issues that need to be
resolved. Working together they can address these
issues and ensure progress is made according to the
project, budget, and work plan.
To eliminate confusion or misunderstandings, here
are a few tips:

    •   If communication takes place over the
        telephone, summarize what was said in
        writing and save it in your project files.

    •   If communication occurs through email,
        print the conversation and save it in your
        project files.

    •   If you receive correspondence via U.S.
        Mail, be sure to save it in your project
        files.

Information transmitted between EPA and the
Tribal Nation should be documented in writing and
incorporated into written progress reports. It is
important that a recipient begin organizing
documents and records from the very beginning of
the project.
           EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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                  Module 10:  Assistance Agreement Monitoring and Closeout
   Who monitors an EPA award project?

   A. EPA grants specialist
   B. EPA project officer
   C. Tribal Nation's administrative contact
   D. Tribal Nation's project personnel
   E. All of the above
   Why should we contact the EPA project
   officer and/or grants specialist when a
   problem arises?
   A. They can help us solve the problem.
   15. EPA must document and evaluate the problem.
   ('. Problems must be reported to the EPA
      director.
   D. EPA can send a specialist out lo solve the
      problem.
   E. All of the above arc possible solutions.    faM
   The Monitoring Process

    • Perform cost re\ie\vs
    • Follow cost principles
    • Ensure charges are reasonable, allocuble, and
     allowable
     Assign costs consistently

    • Adhere I u the "terras mul conditions''
     agreement
)flhe
         The Monitoring Process
How does our Tribal Nation benefit from cost
reviews?
In order for an award to be fully successful, the
Tribal Nation should perform cost reviews of the
charges and follow the cost principles in OMB
Circular A-87. Tribal responsibilities include
knowing the cost principles so that charges to the
assistance agreement are reasonable, allocable, and
allowable.

There must also be consistency in assigning costs
to the grant. Costs must be treated consistently for
all work in the Tribal Nation, regardless of the
source of funding. Direct costs are always assigned
as direct costs and indirect costs are always
assigned as indirect costs. Also, make sure that any
                                                       "terms and conditions" related to costs in the award
                                                       letter are strictly followed.
                                                                   -*-I = r-r
                                                                   F- nje Einefts
                                         22OOOCC
                                         3,700.00
                                         7,OOO.OO
                                         5,030.00
                                         1,30O.OO
                                          600.00
                                          9O3.00
                                         190000
                                         2.700.00
                                         i--.::.::
                              20303.00
                              3.5QO.OO
                              5OOOJDO
                              4-KH.OO
                              UQOOO
                               100.00
                               KJO.OO
                              1.300.OO
                              2.5tM.OO
                              3; :::.::
                                                                                              20O00
                                                                                               OflC
                                                                                              200.00
                                                                                              10OOO
                                                                                              e:o :o
                                                                                              200.00
              Sample comparison of Budget and Actual Expense;
How do we monitor the work plan?
The Tribal Nation and EPA work together to
monitor progress. The Tribal Nation reports the
progress in writing. The reporting requirements and
schedule are sometimes included in the award
"terms and conditions".

For example:
    In accordance with 40 CFR 31.40, the
    recipient agrees to submit performance
    reports that include brief information on
    each of the following areas:
    1) a comparison of actual
    accomplishments to the
    outputs/outcomes established in the
    assistance agreement work plan for the
    period,
    2) the reasons for slippage if established
    outputs/outcomes were not met; and
    3) additional pertinent information,
    including, when appropriate, analysis and
    information  of cost overruns or high unit
    costs.
                  Conditions will vary by award agreement.
                  The Tribal Nation must submit written reports at
                  least annually, and no more than quarterly,
                  depending on the "terms and conditions" in the
                  award document. Reports are the Tribal Nation's
                  responsibility. The EPA may or may not send
                  reminders of due dates for progress reports.
                  Written reports must satisfy the requirements of 40
                  CFR 31.40(b). Some EPA programs provide
                  specific report formats that must be used and
                  completed as directed.

                  In addition to written reports on the work plan,
                  progress reports contain financial and
                  administrative information. This information
           EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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                  Module 10:  Assistance Agreement Monitoring and Closeout
accurately reflects allowable costs that have been
incurred.

Reports reflect a Tribal Nation's project budget
(i.e., showing funds authorized, spent, and
remaining to be spent). It is good practice to
associate expenditures with specific tasks being
performed. This is done to show progress on the
work plan objectives, outputs, and environmental
outcomes.
   File Regular Federal Financial Reports
Federal Expenditures and Unobligated Balance:
a. Total Federal funds authorized
a. Federal shaie of expenditures
a. Federal share of unliquidated obligations
a. Total Federal share .sum of lines e and fi
a. Unobligatedbalanceof Federal funds dine d minus gj
SI 0.000.00
$9.000.00

$9.000.00
$1.000.00
Recipient Share:
a. Total recipient share required
a. Recipientshais of expenditures
a. Remaining recipient share to be provided (line 1 mtnusjf
$5.000.00
$1.500.00
$3.500.00
   What is not required in a cost review?

    A. Consistent treatment of costs
    B. Compliance with award "terms and conditions"
    C. Credentials of staff
    D. Alignment with federal cost principles
    E. Determination of reasonable, allocable, and
      allowable costs
     What types of Audits are there?
     EPA programs and proj ects

Grantee pro grains andprojecb

  Administrativesystems

  Financial systems

  Personnel

  Ac counting records

  Intern a! Controls

  Financial Statements

  Compliance
                                 Auditing Assistance Agreements
                                               EPA Audits
                             How does EPA monitor assistance agreement
                             awards?
                             EPA is authorized to audit EPA financially-assisted
                             activities of any recipient organization, including
                             Tribal Nations. However, it is federal policy to
                             place maximum reliance on a recipient's own
                             audits like the OMB A-133 single audit (discussed
                             below in this section), if it is carried out in
                             accordance with applicable federal audit standards.

                             Auditing is described in detail here so that you will
                             be prepared should your Tribal  Nation be selected
                             for EPA auditing. EPA audits both internal and
                             external programs.  Audits ensure compliance with
                             regulations and keep systems operating efficiently.
                             Audits are required by law; they should not be
                             viewed as a form of punishment or discipline.
                                                      Everyone gets audited at one time or another;
                                                                 it is part of the system.
                                                                       Internal Audits
                                Audits help to ensure
                                compliance with
                                regulations and keep
                                systems operating
                                efficiently.
                Internal Audits
The EPA Office of Inspector General (OIG) audits
EPA programs and their award recipients to assure
that EPA follows all the required rules and
regulations in carrying out awards. Internal audits
test the effectiveness of financial operations,
operating procedures, program results, and
resource management.

Internal audits are evaluations that examine the
programs or operations of federal agencies. Tribal
Nations may be expected as part of an internal
audit to provide information about the performance
of a federal agency that is not already included in
the annual financial reports.
           EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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                       Module 10: Assistance Agreement Monitoring and Closeout
                                     Sample    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)

                                                                         GA 97312300
                                                                                                                   Page
                                                                                                                             Pages
3.  Recipient Organization (Name and complete address including Zip code)
                                                          Tribal Nation
                                                         123 JayHawk Dr
                                                      Las Cruces, NM 84752
4a.  DUNS Number
    12345687987
                      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
                                                                                             @ Final
                                                                                                              7. Basis of Accounting
                                                                                                               I Cash  D Accrual
   Project/Grant Period
   From:  (Month, Day, Year)
                9/1/2011
                                           To: (Month, Day, Year)
                                                            9/30/2011
Reporting Period End Date
(Month, Day, Year)
                9/30/2011
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
                                                                                                                         $10,000.00
   e. Federal share of expenditures
                                                                                                                          $9,000.00
   f.  Federal share of unliquidated obligations
   g. Total Federal share (sum of lines e and f)
                                                                                                                          $9,000.00
   h. Unobligated balance of Federal funds (line d minus g)
                                                                                                                          $1,000.00
Recipient Share:
     Total recipient share required
                                                                                                                          $5,000.00
  j.  Recipient share of expenditures
                                                                                                                          $1,500.00
   k. Remaining recipient share to be provided (line I minus j)
                                                                                                                          $3,500.00
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 governing 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
                                 John Brown, President
                                                                                        c.  Telephone (Area code, number and extension)
                                                                                                  (505) 987-6543 ext. 1212
                                                                                        d.  Email address
                                                                                                      ibrown@lccc.edu
b.  Signature of Authorized Certifying Official
                                                                                        e.  Date Report Submitted  (Month, Day, Year)
                                                                                                        10/15/2011
                                                                                        14.  Agency use only:
                                                                                        Federal Share Calculation   85.71%
Table 6: Sample Federal Financial Report, SF425
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                  Module 10:  Assistance Agreement Monitoring and Closeout
The Office of the Inspector General Hotline
number is 1.888.546.8740 for all non-government
locations outside the Washington, D.C.
metropolitan local calling area and 202.260.4977
for those inside the area.
   External Audits

    • Audits ensure proper
     use of taxpayer money.
External audits are
conducted by:
• The award recipient's
 independent auditor
• EPA Office of Inspector
 General of (DIG)
• EPA Administrative
 Reviews
• Government
 Accountability Office
 (GAO)
                External Audits
EPA Program Offices require external audits of
assistance agreements because grantees must
demonstrate that they are properly monitoring
taxpayer money. External in this instance means
not directly controlled by EPA. These are the
audits that a grantee performs on its own financial
systems.
   Grantee Audits
Examples of grantee (external to EPA) audits
include:
  •   Pre-award audits are reviews conducted to
      evaluate prospective cost or pricing data.
  •   OMB Circular A-133 single audits are
      financial and compliance audits that
      conform to OMB Circular A-133
      requirements.
        The OMB Circular A-133 single audit is
            mandated by statutory law. It must be
            complete and cannot be waived.
        The cost of an OMB A-133 single audit is
            an allowable cost. Applicants should
            generally include audit costs in their
            indirect cost rate (or financial and
            administrative cost pool).
    •   Indirect cost audits review the assignment
        of indirect costs to funding sources. The
        same rate should apply to each source.
        They ensure only allowable costs are
        included in the indirect costs allocated to
        federal agencies.
    •   Interim and final cost audits are reviews
        conducted to assess the allowability of
        costs claimed under the assistance
        agreement or contract. They ensure
        compliance with the applicable
        requirements and award conditions.

Requests for an audit are made by EPA on Form
5700-29, the Assistance Audit Request form. The
Project Officer  submits the form directly to the
appropriate Divisional Office of the Assistant
Inspector General of Audits (DIGA), but to the
extent possible  the Project Officer should
coordinate requests for audits with the Grants
Management Official.
                                External audits are used to test the
                                effectiveness of a grant recipient's:


                                A. Financial operations
                                B. (ipcrating procedures
                                0. Program results
                                D. Resource management
                                E. All of the above
                                Who may conduct audits of EPA award
                                programs?
                                A. EPA's Inspector General's Office (DIG)
                                B. Government Accountability Office (GAO)
                                C. The Tribal Nation receiving the award
                                D. EPA's Audit Contractors
                                E. All of the above
           EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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                  Module 10: Assistance Agreement Monitoring and Closeout
                                                        OMB Circular A-133 is provided in the Appendix.

   Required Audits

    • An OMB A-i;j3 single audit is required when the
     recipient spends:
       $500,000 or more
       In federal funds
       Per accounting year
       (culcnduror fiscal, just he consistent)

What audit is absolutely required of all recipients
with a total of $500,000 or more annually in
federal awards?
The Office of Management and Budget establishes
consistent and uniform audit requirements and
defines federal responsibilities for implementing
and monitoring such requirements for states, local
governments, Tribal Nations, and other non-profit
organizations receiving federal funds.

An OMB A-133 single audit is required
whenever a Tribal Nation expends $500,000 or
more of federal funds per accounting year.
Tribal Nations that expend less than $500,000 in an
accounting year are exempt from an OMB A-133
single audit but records must be available for
review or audit by appropriate officials of the
federal agency and general accounting office.

The Tribal Nation chooses the dates for their
accounting year. The accounting year can align
with either the fiscal or calendar year. Check with
your accounting department to find out when your
accounting year begins and ends.

What is an OMB Circular A-133 single audit?
Audit as referred to in the  General Assistance
Program (GAP) is the single audit required by
OMB Circular A-133. This is an organization-wide
audit of the Tribal Nation's entire accounting
system. It is used to determine if the Tribal Nation
is using Generally Accepted Accounting Principles
(GAAP) to account for all of the funds they receive
from the government.

OMB A-133 single audits do not limit the authority
of federal agencies, including the EPA Inspector
General or the Government Accountability Office,
to conduct or arrange for additional audits. Any
additional audits are to be planned and performed
in such a way as to build upon work performed by
other auditors.
   A Successful Audit
    For a successful audit, you MUST:
      • Man1 ;t fiiumcial management si stem lluil trucks
       :ill i.-i .sts L'\pcnJi.'d,
       •. 'ompete a]] procurement transactions,
       or have nn file a sole-source justification,
     11 Perform a cost or price analysis on CVITJ
       priKjuivmenL transaction and keep in your file.
       1 1 .!• i' the following internal policies on file:
       • Travel 1'i'ilirv
                             • Tndfsol ( 'fnuliif'1
                             • DIH-l'tiliMilion
How should we prepare for an audit?
To have a successful OMB A-133 single audit, a
Tribal Nation must have all the financial and
administrative systems in place to produce the
required financial statements to be submitted to
personnel performing the  audit.

Audits may be performed before, during, or
after the completion of a project. The project file
should be maintained in audit ready status at all
times.

Audits made in accordance with OMB Circular A-
133 can replace any financial audit required under
individual federal awards. To the extent OMB A-
133 single audits meet a federal agency's needs;
the agency should rely upon and use these audits.

Auditors  can examine all  records related to
expenditures, such as:
    •   Source documents
    •   Payroll
    •   Time and effort sheets
    •   Interviews with employees
        Make sure the budget matches
           the list of expenditures.
           EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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                  Module 10: Assistance Agreement Monitoring and Closeout
   Up-to-Date Audits

    • Tribal Nations must
     have a current audit.
    • Ensure "internal
     controls" are in place
     and operating.
    • Playilstife; hireu
     professional auditor.
How current must our audit be?
Tribal Nations must have a current audit. Audits
should be conducted on a yearly basis. Methods
that a Tribal Nation may use to make sure their
internal controls are in place and operating:
    •   Employ someone within the Tribal Nation
        to perform a cursory audit function and
        report directly to Tribal leaders.
    •   Employ an external auditor to perform
        review functions that are more extensive
        than just a review of the books and
        records.
Are audit expenses reimbursable?
The cost of a single audit is an allowable cost;
however, an EPA grant cannot cover the full cost
of an audit, unless the project is 100% funded by
EPA funds. If the Tribal Nation receives other
sources of funding, then the cost of an audit must
be allocated fairly and equitably between funding
sources. The cost of an audit should be prorated to
all federal funds, not just EPA funds. Applicants
should either include audit costs in their indirect
cost rate or, if the cost is not included in the
indirect cost rate, as a direct cost to the assistance
agreement.
   Allocation of Audit Expenses
     Determine the percentage
     of money received by the
     Tribal Nation from each
     federal agency.

     Allocate the cost of an
     audit fairly and equitably
     between funding sources.
     = Include in the negotiated
       In direct Cost Rate
   When are audits conducted?

    A.  Before the award period begins only
    B.  During the project start and end dates only
    C.  Before, during and after the award period or
       after eloseout but before retention ends
    D.  After the award period only
    E.  None of the above are correct
   Audit Expenses

    • The cost of an OMB Circular A-133 single
     audit is an allowable cost.

    • The cost should be allocated in accordance
     with the guidelines in OMB Circular A-Sy.
     All activities/programs that benefit from
     the audit should be allocated a proper
     share of the audit costs.
                 EPA - Environmental Protection Agency
                           Tribal Nations General Fund
                           DOE - Department of Labor
           USDA - United States Department of Agriculture

EPA is not the only federal agency granting
money; therefore, an EPA General Assistance
Program (GAP) grant, for example, should not be
paying for the total cost of the audit. The GAP
grant should only pay for a portion of the cost. One
way to allocate this cost is to determine the
percentage of money received from each federal
agency and to share the costs proportionally.

Include the cost of a yearly OMB Circular A-
133 single audit in your calculated indirect cost
rate. This method insures the money is available
when you need it.

View the OMB Circular A-133 at
http://www.whitehouse.gov/omb/circulars_default. or
download a copy at
http://www.whitehouse.gov/sites/default/files/omb/assets
/al33/al33_revised_2007.pdf. This document is also
provided in the Appendix.
           EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
tast Updated April 2013
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                  Module 10: Assistance Agreement Monitoring and Closeout
                                                          Audit Reports
                                                             Provide a copy of the findings section

                                                             Explain corrective actions

                                                             Prepare a corrective action plan

                                                             Fix any problems
      Reflection
      Consider your own situation.
           •    How do you conduct audits?
           •    Who is responsible for ensuring
               audits are conducted properly and
               on a regular basis?
           •    What is audited?
           •    What staff assists in the audit
               process?
           •    How might  your audit process be
               improved?
      Learner Notes
      Have you been through an audit? If so,
      share what you learned. Activity lO.b may
      help you to better understand your own
      situation (found online at
      www.petetribal.org').
   How do we pay for auditing?

   A. EPA award funds
   B. With grant funds from agencies other than
      EPA
   C. The cost of an audit is an allowable cost when
      allocated fairly and equitably between funding
      sources
   D. With in-kind contributions only
   E. With a Tribal Nations general budget only ,  VJs
                                           •  .
What needs to be reported after an OMB A-133
single audit?
You need to explain corrective actions and provide
a copy of the findings section of an OMB A-133
single audit if there were any findings, material
weaknesses, or reportable conditions identified.
The Tribal Nation is responsible for follow-up and
corrective action on all audit findings. The Tribal
Nation needs to prepare a corrective action plan for
all current year audit findings. If you have any
questions, please contact your EPA regional audit
coordinator.
Following is the current standard headquarters'
administrative condition for grant awards:
      In accordance with OMB Circular A-
      133, which implements the single
      Audit Act, the recipient hereby
      agrees to obtain a single audit
      from an independent auditor if it
      expends $500,000 or more in total
      Federal funds in any fiscal year.
      Within nine months after the end
      of a recipient's fiscal year or 30
      days after receiving the report
      from the auditor, the recipient shall
      submit a copy of the SF-SAC and a
      Single Audit Report Package.

      For fiscal periods 2008 and beyond
      the recipient MUST submit a copy
      of the SF-SAC and a Single Audit
      Report Package, using the Federal
      Audit Clearinghouse's Internet
      Data Entry System. Complete
      information on how to accomplish
      the 2008 and beyond Single Audit
      Submissions you will need to visit
      the Federal Audit Clearinghouse
      Web site:
      http://harvester. census, gov/fac/
          EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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                 Module 10: Assistance Agreement Monitoring and Closeout
          By working together,
   we make the world beautiful again.
   Closeout Requirements
         Closeout Requirements
Closeout is a process for finalizing an assistance
agreement award project.
   Closeout
    • Closeout is a systematic process to ensure that
     nil work requirements and administrative
     demands have been finalized.
    • flnseout is initiated when a project ends due to
     completion or termination.
What is closeout?
The closeout of an assistance agreement award is a
systematic process followed to make sure that all
technical work (e.g., products, construction) and
administrative requirements (i.e., the final
Financial Status Report sent to and approved by
EPA) have been finalized.
    •   The Las Vegas Finance Center conducts a
        financial closeout.
    •   The EPA regional office conducts project
        closeout.
When do we close out an award?
Project closeout is initiated when a project ends
due to completion or termination.
    •   Completion of a project occurs when all
        of the objectives have been met.
    •   A project may be terminated because of:
        Insufficient funds
        Non-funding of a renewal, or a
        Decision by a Tribal Nation and/or EPA
            not to continue the project or program
What happens if we cannot comply with the
terms of an award?
EPA may take an enforcement action against an
award recipient, should that recipient fail to
comply with regulations or "terms and conditions"
of the agreement. The consequences of
noncompliance vary according to individual
circumstances. EPA can take several enforcement
actions, such as disallowing certain costs or
terminating the agreement. EPA or the award
recipient may also terminate the agreement for
convenience; however, this termination would not
be part of an enforcement action but the result of a
mutual agreement.

Enforcement action options are described in 40
CFR 31.43(a), provided in the Appendix.

   Required Closeout  Documents
                All closeout
            documents are due
                   within
                  calendar days
            after grant project /
            budget period ends
Which documents do we need for the closeout
process?
All closeout documents are due within ninety (90)
calendar days after the project or budget period of
the grant ends. Submit the closeout documents to
the appropriate EPA regional office
representatives. Check the "terms and conditions"
of the award for contact information.
          EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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                 Module 10: Assistance Agreement Monitoring and Closeout
   Send  Closeout Documents To:

    Project Officer:
     ฐ Final Performance/Technical Report

    Grants Specialist:

       I""'u;ii.'i,i>. required hythe tl'AivRimul office or
       specific giants pmgiMin
    DBE (  i iiirdii ial 11[ :

     ซ Final F.F'A Form r,2(Ki---A .\Il;E,''\\~t:f-:riilizutiซn
       Under Federal Assistance Agreements and
                           n >r
Agreements and Inter agency Agreements Report,
EPA Form 5200-52A. The DBE Utilization form
ensures the grantee made efforts to use minority
and women owned businesses.
   Las Vegas Finance Center

    • Final Payment Request
     (EPA Form 190 or SF 271 for construction)

    • Final Federal Financial Report
     CSF425)
Submit to the Project Officer the Final
Performance/Technical Report. This is the final
progress report to summarize activities conducted
under the grant. It explains how the recipient
achieved the objectives described in the work plan.
Instructions for other required documents are
provided in the "terms and conditions" of the
award.

Submit to the Grants Specialist any documents
required by the EPA regional office or specific
grants program. Documents that may be required,
if applicable, include:
    •   Invention Disclosure Report
    •   Federally Owned Property Report, if a
        Tribal Nation used any federally owned
        property.
        A Tribal Nation must make sure of the
            proper disposal of this property
            before closeout can be completed.
        A Tribal Nation must send a list of
            federally owned property to the
            Grants Specialist (as stipulated in 40
            CFR31.50(b)).
        Once the Grants Specialist receives the
            Tribal Nation's list of federally
            owned property, the EPA must notify
            the Tribal Nation of what is to be
            done with that property (see "terms
            and conditions" of the grant award).
    •   Property Inventory  of all Federally  Owned
        Property
    •   The Lobbying and Litigation Certification
        for Grants and Cooperative Agreements
        (EPA Form 5700-53) is no longer
        required by the federal government, but
        may still be required under certain
        programs and in some regional offices.

Submit to the DBE Coordinator the Final
MBE/WBE Utilization Under Federal Assistance
The Las Vegas Finance Center may require a
final Payment Request (EPA Form 190 or Standard
Form 271 for construction). The final Federal
Financial Report (SF 425) enables reconciliation of
any over- or under-payments in grant funds. Final
financial forms should be submitted within ninety
(90) days after the end of the budget period.
 Please be advised. The Federal Financial Report
          (FFR) Standard Form (SF) 425
   replaced Standard Forms 269,269A and 272,
            272A on October 1, 2009.
   Closeout Reporting
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                               "^n
                                          r;: ฎ
   Additional Requirements
       Sonic- regions and/or grant programs
            may require submission of
          additional forms for closeout.

                Please refer to the
    "terms and coiiditinivj" of your gnuit award
    for a description of t'loseout requirements
    iir call your EPA Regional Grants Specialist.
          EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
                                    Page 15 of 34

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                  Module 10: Assistance Agreement Monitoring and Closeout
   Las Vegas Finance Center

    • The I.VTC inii\ send a letter to noli I \ the
     recipient that:
     1  A draw from ASAP is necessary
     =  A final EFT payment is being made to their
       account
       Retu rn of fu nds is due to EPA
       • 1 >> ปMi;;alioii of funds greater than $.1.01)11 is b;ist'd
        mi tin. finiil financial status report
What does the Las Vegas Finance Center do?
The Las Vegas Finance Center sends financial
closeout notifications to recipients when the
award's budget period expires.

First Letter - "Reminder Letter" is generated and
mailed or emailed to recipients within 10 days after
the budget period end date.  The regional closeout
guidance page is included with the letter.

Second Letter - "Overdue Notification" is
generated and mailed or emailed to recipients.
•   Region 7 sends to recipients 60 days after the
    budget period.
•   Headquarters and all other Regions' send to
    recipients 90 days after the  budget period.

Assistance Adjustment Notice (AAN) is sent to
recipients to notify them the grant is financially
closing and one or more of the following actions
must be accomplished:
•   To notify the recipient that  a draw from ASAP
    is necessary.
    o   Accounts are opened for 30 days from the
        date of the AAN.
•   To notify the recipient that  a final EFT
    payment is being made to their account.
•   To notify the recipient that  a return of funds is
    due to the EPA.
•   To notify the recipient of deobligation of funds
    greater than $5,000  based on the final Federal
    Financial Report.

LVFC may also send a copy of the financially
closed FFR back to the recipient for their records.
Bill for Collection - Is sent to notify the recipient
that a return of funds is due to the EPA.
     •  Initial bill is sent with the corresponding
        Assistance Adjustment Notice.
       •  Subsequent bills will be sent showing
          principal and interest accrued due to non-
          payment of initial debt.

  The Tribal Nation must immediately refund to
  EPA any balance of unobligated (unencumbered)
  cash advanced that the grantee is not authorized (in
  writing) to retain for use on other assistance
  agreements.
                                                           During Closeout
      • A final accounting of expenditures is
       submitted.

      • Project work is assessed.

      • Closeout procedures are set by the EPA
       regional nrticc.

      • A "closeoul [filer" is sent to the recipient
       with the official closeout date.

      • All assistance agreements are subject to
       an audit, which can occur after the
       agreement is closed out.
  What happens during closeout?
  Closeout at the project end date ensures a final
  accounting of expenditures by the Tribal Nation
  and an assessment by the EPA that all technical
  work has been completed and is satisfactory.
  Closeout procedures are established by regional
  and headquarters' Grants Management Officials.
  You should receive a "closeout letter" stating the
  official closeout date.

  All assistance agreements are subject to an audit.
  An assistance agreement may be closed out before
  an audit is conducted. In this case, the official
  closeout date may be delayed.
Keep anything with a signature in a safe place.
  It is important for a Tribal Nation to understand
  that:
      •   The award may be audited at a later date.
      •   An audit or review may start any time up
          to the date that records for an assistance
          agreement are no longer required to be
          maintained by a Tribal Nation.
      •   Tribal Nations are responsible for
          maintaining records for the length of the
          record retention period specified for that
          particular program (as stipulated in 40
          CFRPart 31.42(b) and Part 35.6705 for
          Superfund grants).
           EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
                                       Page 16 of 34

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                 Module 10: Assistance Agreement Monitoring and Closeout
The regulations for post-award monitoring and
closeout are provided in the Appendix, 40 CFR
Part 31.40-31.52.
Closeout is a systematic process to end
an award when the award:

A. Audit reveals discrepancies
B. I 'n lied runs nut < if supplies < ir equipment
C. Partners decide it is completed or terminated
D. Policies and procedures fail to comply with
   EPA regulations
E. All of the above
   Records Retention
     TWE-* I  A(K*UDOn
                   Sunup  I Mirafemem
            Records Retention
Which records should be retained?
Records retention requirements apply to all
supporting documentation, including
documentation of:
    •   The project application
    •   Preaward reviews
    •   Funding decisions
    •   Scope of work/work plan
    •   Significant actions and decisions
    •   Cost records
    •   Correspondence
   The Onset of Records Retention
                                                          Records retention begins
                                                          when the final Federal
                                                          Financial Report (FFR)
                                                          SF-425 is submitted to
                                                          the Las Vegas Finance
                                                          Center.
       Maintain all records.

When does retention begin?
The start date of the retention period is governed
by 40 CFR 31.42(c) Retention and access
requirements for records.

    (c) Starting date of retention period — (1)
    General. 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, 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.
        The date the grantee submits the
    Final Federal Financial Report to the LVFC
        is the official award end date and
          records retention start date,
           unless otherwise arranged.
                                                     For reimbursement programs, records retention
                                                     requirements start with the final payment request.
                                                     This request is made with either the U.S. EPA
                                                     Payment Request (EPA Form 190-F-04-001) or the
                                                     Outlay Report and Request for Reimbursement for
                                                     Construction Programs (SF 271) form.
          EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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                  Module 10:  Assistance Agreement Monitoring and Closeout
If litigation, claim, negotiation, audit, or other
action involving the record stated before the end of
the retention period is still in progress, Tribal
Nations must keep records until either the
completion of the action and resolution of all issues
which arose from the action, or until the end of the
established retention period, whichever is later. If
an audit is underway prior to closeout, all issues
must be resolved before closeout can take place.

Formal closeout can occur only when both the
Tribal Nation and EPA are satisfied:
    •   With the final product
    •   That all eligible costs have been accepted
    •   That all repayments have been received
    •   That all "terms and conditions" contained
        in the assistance agreement have been met

The timing of closeout depends primarily on the
type of agreement. Closeout of most assistance
agreement awards begin when the project period
has expired and final paperwork is submitted and
approved by EPA. Ninety days prior to the project
expiration date, the EPA partner may send a
"reminder letter" to the Tribal Nation regarding
closeout requirements.
   Records Retention

    • Records are retained for at least three years,
     • Retention maybe required for up to ten veal's.


How long should assistance agreement award
records be kept on file?
Records should be retained for at least three years.
Check the "terms and conditions" of your award
document for the records retention period that
applies to your grant.
   Access to  Records
     Timely and reasonable access to:

     • Documents

     • Personnel

     Must be granted to:
     • U.S. Government
     • Tribal Nation

     Throughout the grant period and the records retention

     period
Who has the right to access our Tribal Nation's
award records?
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 purpose of interviews and
discussions related to such documents. The rights
of access in this paragraph are not limited to the
required retention period but shall last as long as
records are retained.

Likewise, the grant recipient has the right to access
EPA records and personnel regarding the award.

Post award reviews may be done at any time during
the three-year post-award period. Post award
reviews may include accessing records, interviews
with personnel, and other tasks performed during
the award period.
   Who does not have the right to access
   our Tribal Nation's award records?
   A, Subcontractors and Subrecipients
   B. EPA officials
   C. The Inspector General
   D. Controller of the United States
   E. Duly authorized federal representative
                 Do NOT dispose of records until the full post award phase has passed.
           EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last U pdated April 2013                                                                           Page 18 of 34

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                   Module 10: Assistance Agreement Monitoring and Closeout

       Learner Notes
       "The best defense is a prepared offense."
       Examine your systems in Activity lO.c
       (online at www.petetribal.org). Complete the
       EPA Administrative and Financial Onsite
       Review Questionnaire.
                  Conclusion
   Conclusion

    • If the regional EPA office wants something
     different than what is presented in this Manual,
     then follow Lheir directions.
       These are the standards.
     = Regional requirements may vary.
                                                             Questions?  Contact:
                                                                   Laurice Jones
                                                              U.S. Environmental Protection
                                                                      Agency
                                                              Office of Grants and Debarment
                                                              1200 Pennsylvania Avenue, N.W.
                                                                  Mail Code: ggogR
                                                                 Washington, DC 20460
                                                                   202-564-0223
                                                                 Jones-laurice^ epa.'ZQv
                               Elizabeth January
                                ProgramAnahst
                            U.S. En vinmmental Protection
                                  Agency
                            5 Post Office Square - Suite 100
                               Mail Code: ORAoi-3
                              Boston, MA02109-3912
                                 61^-918-1315
                           ianiarv.elkaberiigeaaimn.eaa.gov
                                                               Forms availablefor download athtii:  A.V.V i-i
What if we still have unanswered questions or
concerns?
EPA hopes you have found this manual and
assistance training helpful. Contact your EPA
Regional Office with any other concerns regarding
regional policies and procedures. If there are any
lingering questions or concerns, contact Elizabeth
January or Laurice Jones.

EPA grantee forms are available online at
http://www.epa.gov/ogd/forms/forms.htm.
Code of Federal Regulations can be accessed at
http://ecfr.gpoaccess.gov.
Office of Management and Budget Circulars are
available at http://www.whitehouse.gov/omb/circulars/.
   Learner Notes
   The Qwizdom questions and answers can be
   found at the end of each Module of this Manual.
   The Grants Management Process
  • Module 9: Disadvantaged
   Business Enterprises (DBEs)

   Agreement Monitoring and
   Closeout
  Module 6: Financial


  Policies and Proceduri
  Module 8: S
  Documentatio
           EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
Last Updated April 2013
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                  Module 10: Assistance Agreement Monitoring and Closeout


                                   Attachments to Module 10
                   EPA Administrative and Financial Onsite Review Questionnaire
 I.   Organization Policies and Procedures
     A.   General Information / Policies and Procedures.
         Many of these questions have "Yes" or "No" answers. For "Yes" answers, please provide the specific
         reference to your policies and procedures. Please explain all "No" and "Not Applicable" answers.
 Thank you in advance for completing this questionnaire.
 Note:   40 CFR 31 and OMB Circular A-87 (codified as Title 2 CFR 225) references apply to States, Local
         Governments, and Indian Tribes.
 1.         Who or which office(s) in your organization is/are responsible for reviewing, approving, and signing
	applications, awards, and amendments?	
 2.         Who or which office(s) in your organization is/are responsible for monitoring and overseeing
	assistance agreements once received from EPA?	
 3.         Do you have a current Organizational Chart? Show or explain any non-   D Yes D No  D N/A
	profit or for profit organization and/or entities your affiliated with.	
 4-         How does your organization keep up-to-date on federal regulations, legal decisions, OMB Circulars,
           etc.?
 5.         Does your organization have provisions for seeking written prior         D Yes D No  D N/A
           approvals for specific revisions, from the awarding agency under certain
           conditions?
	(40 CFR 31.30)	
           The Code of Federal Regulations (40) and OMB Circulars require organizations receiving federal
           assistance agreements to have written policies and procedures for the following areas. (40 CFR
           31.20 and 31.21) Do your policies and procedures address the items described below?
     a-     Personnel, including qualifications for each position, duties and         D Yes D No  D N/A
           responsibilities, salary ranges, EEO, annual performance appraisals,
           types and levels of fringe benefits, and standards of conduct governing
           duties and responsibilities including disciplinary actions for not
           adhering to the standards,  for employees engaged in the award and
           administration of contracts. (OMB A 87 / 2 CFR Part 225, Appendix
	B, section 8)	
           EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
 Last Updated April 2013                                                                         Page 20 of 34

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                 Module 10:  Assistance Agreement Monitoring and Closeout
    b.     Time reporting, tracked to each project; (OMB A 87/2 CFR Part 225,    D Yes  D No D N/A
   	Appendix B, Section 8.h)	
    c.     Redistributions (Chargeback's); (i.e., other organizational department    D Yes  D No D N/A
   	costs; written, established rates required)	
    d.     Payroll processing and internal controls; (OMB A 87 / 2CFR Part 225,    D Yes  D No D N/A
   	Appendix B, Section 8.h)	
    e.     Overtime (if allowed); (OMB A-87/2CFR Part 225, Appendix B,       D Yes  D No D N/A
   	section 8)	
    f.     Vacation and Sick Leave (if offered by your organization); (OMB A      D Yes  D No D N/A
   	87 / 2 CFR Part 225, Appendix B,  section 8.d)	
    g.     Compensatory time (if allowed).	D Yes  D No D N/A
    h.     Equipment and property purchases including cost and price analysis,     D Yes  D No D N/A
          purchase, use of, inventory and disposition of at the end of the project;
          (40 CFR 31.31,  31.32 & 31.36(f))	
 (A cost analysis is the review and evaluation of each element of cost to determine reasonableness, allocability,
and allowability when you do not have other proposals to compare costs against. A price analysis may be
accomplished in various ways, including the comparison of price quotations submitted, market prices, and
similar indicators, together with discounts.)
i.
Electronic Funds Transfers (EFT) drawdowns from EPA' s accounts.
Does your policy address who is authorized to request payment from
the federal government, what procedures are used to verify that the
request are accurate, and when drawdown of funds will occur etc.; (40
CFR31.20(b)(7)and31.21)
DYes DNo D N/A


j-
Receipt and deposit of advanced payments (40 CFR 31.21
(c)&(e))
DYes DNo D N/A

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    k.     Records retention. (40 CFR 31.42)	D Yes D No D N/A
    1.     Travel, authorizations, vouchering after the trip and, if required, trip      D Yes D No D N/A
   	reporting; (OMB A 87 / 2CFR Part 225, Appendix B, section 43)	
    m.    Procurement Standards for supplies, expendable property, equipment,    D Yes D No D N/A
          real property, and services. Standards for contracting, purchasing,
          consultant agreements, sub-awards or grants (if applicable, especially
          for monitoring sub grantees) and other types of awards that transfer
          federal funds outside of your organization; (40 CFR 31.36, 40 CFR
          31.37and31.40(a))	
    n.     Provisions for utilizing Small Businesses, Minority Owned Firms,       D Yes D No D N/A
          Women's Business Enterprises, and Labor Surplus Area Firms (where
          possible) (40 CFR Part 33)	
    o.     Program income. Is it identified, authorized, accounted for, and are      D Yes D No D N/A
   	limitations placed on its use; (40 CFR 31.25)	
    p.     Cost sharing, matching, and In-Kind contributions. Is it identified,       D Yes D No D N/A
          accounted for and reported; (40 CFR 31.24 and OMB A 87 / 2CFR
   	Part 225, Appendix B, section 12)	
7.         Do you have the following documents for each grant award:

    a.     Original application and certifications; (SF 424, 424A, et al.)	D Yes D No D N/A
    b.     Work plans and/or statement of work;	D Yes D No D N/A
    c.     Initial award and all amendment documents;	D Yes D No D N/A
    d.     Request for and approvals of scope and/or budget changes; (40 CFR     D Yes D No D N/A
          31.30(a),(b)&(c))	
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    e.     Financial Status Reports and reimbursement requests, if applicable; (40   D Yes D No D N/A
          CFR31.41(b))	
    f.     Payment requests backed up by financial records to support the          D Yes D No D N/A
          request; (40 CFR 31.20(a)(2))	
    g.     Progress reports; (40 CFR 31.40(b))	D Yes D No D N/A
    h.     Contracts / Subgrants; (40 CFR 31.37)	D Yes D No D N/A
    i.     Purchases; (40 CFR 31.32 for equipment, 40 CFR 31.33 for supplies)     D Yes D No D N/A
          Consultant agreements; (40 CFR 31.36(j))	D Yes D No D N/A
    k.     Correspondence and approvals, including emails to and from EPA       D Yes D No D N/A
          officials.
II.  Accounting and Financial Management

    Many of these questions have "Yes" and "No" answers. For "Yes" answers, please provide the specific
    reference to your policies and procedures. Please explain all "No" and "Not Applicable" answers.

    A.   Accounting
1.
Does your organization have an accounting manual? (40 CFR 3 1.20)
The CFR requires certain accounting practices / procedures addressed
in the questions below to be written.
DYes DNo D N/A


2.
Does your organization's accounting and financial management
system(s) follow Generally Accepted Accounting Principles (GAAP)?
(OMB A 87 / 2CFR Part 225, Appendix B, section 8)
DYes DNo D N/A

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 3.         Does your organization's accounting and financial management          D Yes  D No D N/A
           system(s) provide accurate, current and complete disclosure of the
           financial results of each federally-sponsored project or program (i.e.
           each award is accounted for separately) (40 CFR 31.20(b)(l)), and
           produce financial reports in accordance with the requirements of 40
           CFR 31.41?
 4.         Does your organization's financial management system(s) provide        D Yes  D No D N/A
           records that adequately identify the source and application of funds for
           federally-sponsored activities, such as authorizations, obligations,
           unliquidated obligations, assets, outlays, income, and interest? (40
	CFR31.20,.21&.22)	
 5.         Does your organization's accounting and financial management          D Yes  D No D N/A
           system(s) provide accurate, current and complete disclosure of the
           financial results of each federally-sponsored project or program (i.e.
           each award is accounted for separately) (40 CFR 31.20(b)(l)), and
           produce financial reports in accordance with the requirements of 40
           CFR 31.41?
 6.         Does your organization have written policies and procedures to ensure    D Yes  D No D N/A
           that costs are reasonable, allocable, and allowable? (40 CFR 31.20
	(b)(5);  OMB Circular A-87 / 2CFR Part 225, Appendix A, Section C)	
7.
Does your organization monitor allowable costs to ensure they are
charged to the grant within the specified period? (40 CFR 3 1.23)
DYes DNo D N/A

           Does your financial management system(s) report and provide for a       D Yes  D No D N/A
           comparison of outlays or grant project expenditures, with budget
           amounts for each grant project/award or have the capability to do so?
           (40CFR31.20(b)(4))	
 9.         Does your organization have budgetary controls to preclude incurring     D Yes  D No D N/A
	excess expenditures? (40 CFR 31.20(b)(4))	
 10.        Does your accounting system have provisions for reviewing and          D Yes  D No D N/A
           monitoring project budgets and program plans, and reporting and
           rectifying deviations that may occur in them? (40 CFR 31.20(b)(4) and
	31.30)	
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 11.	Do you have a current audit? (40 CFR 31.26)	D Yes  D No D N/A
 12.        If your organization expended more than $500,000 of Federal funds in    D Yes  D No D N/A
           the most recent fiscal year, did you obtain an audit in accordance with
	OMB Circular A-133? (40 CFR 31.26(a))	
 13.        If your organization had an OMB A-133 Single Audit performed, were   D Yes  D No D N/A
           there any findings, material weaknesses, or reportable conditions
           identified? If there were, briefly explain or provide a copy of the
	findings section and your corrective actions taken.	
 14.        If your organization requests reimbursement for indirect costs under      D Yes  D No D N/A
           the grant award, does your organization have an approved indirect cost
	rate? (OMB Circular A-87 / 2CFR Part 225, Appendix E)	
 15.        Does your organization have written procedures for drawing grant        D Yes  D No D N/A
           funds and issuing payments? (40 CFR 31.20(b)(7) and 31.21 (b) and
           (c)) Note: Payment requests should be restricted to immediate needs,
           i.e. drawing down funds 3 to 5 working days in advance of
           disbursements.
16.
What type of accounting and financial management system(s) does
your organization use? Name of automated system(s)?
DYes DNo D N/A


17.
Are accounting records supported by source documentation? (40 CFR
31.20(b)(6))
DYes DNo D N/A

    B.  Personnel / Timekeeping
        (Reference: OMB Circular A-97 / 2 CFR Part 225, Appendix B, section 8)

        Many of these questions have "Yes" or "No" answers. For "Yes" answers, please provide the specific
        reference to your policies and procedures. Please explain all "No" and "Not Applicable" answers.
1.
Does your organization have written payroll policies and procedures?
DYes DNo D N/A


2.
Do your employees record: actual hours worked directly on all
projects, indirect or administrative time not charged directly to a
project, and leave taken?
DYes DNo D N/A

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3.         For those employees required to work away from the office, are actual    D Yes D No D N/A
          hours worked documented?
4.         Do payroll registers and reports match up with costs for each employee   D Yes D No D N/A
          whose compensation is charged to an assistance agreement?	
          Are timesheets required to be signed by the individual or supervisor?     D Yes D No D N/A
    C.  Personnel / Payroll

        Many of these questions have "Yes" or "No" answers. For "Yes" answers, please provide the specific
        reference to your policies and procedures. Please explain all "No" and "Not Applicable" answers.

Does your organization's written policies and procedures provide for the following controls for the payroll
function?
L _ Does the policy provide adequate separation of duties? _ D Yes D No D N/A
2.
Are salaries and wage rates established, authorized, and approved in
your organization to ensure equity?
DYes DNo D N/A

3.         Does your payroll process ensure that all deductions from employee's    D Yes D No D N/A
          salaries are authorized by the employee, and proper?	
          How are payrolls distributed?	DEFT  D Manual Checks D Both
5.         If checks are distributed manually, are there sufficient controls to        D Yes D No D N/A
          ensure that payroll checks are distributed to the correct employee?	
    D.  Travel (Ref: OMB Circular A-87/ 2 CFR 225, Appendix B, section 43)

        Many of these questions have "Yes" or "No" answers. For "Yes" answers, please provide the specific
        reference to your policies and procedures. Please explain all "No" and "Not Applicable" answers.
L _ Does your organization have written travel policies and procedures? _ D Yes D No D N/A
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1.
Are internal controls in place to ensure that employees follow your
organization's travel policy, i.e. levels of review prior to authorizing
payment and that the travel was associated with the specific grant
project?
DYes DNo D N/A


3.
Are internal controls in place to ensure that travel and time reporting
support the employee's activities while on travel?
DYes DNo D N/A


4.
Do the policies and procedures include provisions to ensure that travel
costs are allowable, allocable, and reasonable?
DYes DNo D N/A

    E.  Matching, Cost Sharing, In-Kind Contributions and Program Income

    40 CFR 31.24 (a) to (e) provides criteria on the acceptability, purpose, and types of contributions made in
    relation to cost sharing or matching purposes, and the support for such. 40 CFR 30.24 and 31.25 addresses
    the accounting for Program Income related to federally funded projects.

        Many of the questions below have "Yes" or "No" answers. For "Yes" answers, please provide the
        specific reference to your policies and procedures. Please explain all "No" and "Not Applicable"
        answers.
1.
Does your organization currently have any Matching, Cost Sharing
and/or In-Kind costs included in any active awards or anticipate any of
these types of costs in the foreseeable future?
No (Skip this entire section)
Yes (Please complete the rest of this section.)
DYes DNo D N/A


2.
Do any of the matching costs come from another federal grant(s)? (If
Yes, it must be authorized in the terms and conditions of the assistance
agreement)
DYes DNo D N/A


3.
Are these costs identified in the approved grant project budget?
DYes DNo D N/A


4.
Does your organization track, record, report and verify these costs?
DYes DNo D N/A


5.
Are all matching costs verifiable from accounting records and valued
according to applicable OMB Circular cost principles?
DYes DNo D N/A

OMB Circular A-87 / 2CFR Part 225, Appendix B, paragraphs 8 & 12
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                 Module 10: Assistance Agreement Monitoring and Closeout
6.
Has any program income been used to satisfy the recipient's
contribution for any current award or added to the funds committed for
the project?
DYes DNo D N/A


7.
Is there a term and condition in the award that permits the use of
program income for match requirements or for adding it to the funds
committed to the project?
DYes DNo D N/A


8.
If there is no term and condition, has the program income been
deducted from the total allowable project cost?
DYes DNo D N/A

    F.   Procurement / Contracts / Sub agreements

        Many of these questions have "Yes" or "No" answers. For "Yes" answers, please provide the specific
        reference to your policies and procedures. Please explain all "No" and "Not Applicable" answers.
1.
Does your organization have written procurement policies and
procedures?
DYes DNo D N/A


2.
Has your organization awarded contracts or subagreements under any
of the award agreements being reviewed? (Agreements refer to
subgrant(s). Subgrant(s) mean an award of financial assistance in the
form of money, or property in lieu of money, made under a grant by a
grantee to an eligible subgrantee, subrecipient or by a subrecipient to a
lower tier subrecipient. This includes financial assistance when
provided by contractual legal agreement, but does not include
procurement purchases of goods and services.) (40 CFR 31.3)
DYes DNo D N/A

3.         Were contracts awarded in accordance with your organization's contracting policy and does this
          policy comply with 40 CFR Part 30.40 to 30.48 or Part 31.36 & .37, as described below:
a.
Contains a written code of conduct that addresses conflict of interests
and disciplinary actions. (40 CFR 31.36(b)(3))
DYes DNo D N/A


b.
Provides for competing transactions in a free and open manner. (40
CFR31.36(c))
DYes DNo D N/A

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     c.     Provides for a review to avoid unnecessary purchases, a review of       D Yes D No  D N/A
           lease vs. purchase alternatives (when appropriate), conducting
           solicitations with a clear scope of work and bidder requirements,
           conserving natural resources, and utilizing small, MBE and WBE firms
           when possible. (40 CFR 31.36(c)(3))	
     d.     Requires performing and documenting a cost analysis for sole source     D Yes D No  D N/A
           procurements. (A cost analysis is the review and evaluation of each
           element of cost to determine reasonableness, allocability, and
           allowability when you do not have other proposals to compare costs
           against.) (40 CFR 31.36(f))	
e.
Requires performing and documenting a price analysis for competitive
bidding and small purchase procurement actions. (A price analysis may
be accomplished in various ways, including the comparison of price
quotations submitted, market prices, and similar indicia, together with
discounts.) (40 CFR 31.36(f))
DYes DNo D N/A

    f.     Requires documenting the basis for all procurement selections,          D Yes D No  D N/A
           justifying a lack of competition and basis for award cost and price. (40
           CFR31.36(b)(9))	
     g.     Provides for the Grantor'spre-award review of the procurement when    D Yes D No  D N/A
           the award or contract modification exceeds $100,000, is not competed,
           or only one bid is received. (40 CFR 31.36(g)(2))	
     h.     Discusses purchase/agreement /contract cost thresholds (small           D Yes D No  D N/A
           purchases vs. major procurements) and personnel required to approve
    	procurements.	
     i.      Have provisions that no contract or sub award will be entered into with   D Yes D No  D N/A
           parties that are debarred, suspended, or excluded from Federal
    	assistance programs. ( 40 CFR 31.35)	
 4.         Do any of your organization's contracts for grant projects exceed the     D Yes D No  D N/A
	Federal Small Purchases threshold, ($100,000)?	
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 5.         If Yes, did EPA request to review the contract prior to award? (40 CFR   D Yes D No  D N/A
	31.36(g)(2))	
           If Yes, did EPA provide written comments?	D Yes D No  D N/A
 7.         Does your organization use a pre-qualified list of persons, firms, or      D Yes D No  D N/A
	products to acquire goods and services?	
           Did your organization follow its procurement policies to place and       D Yes D No  D N/A
           update vendors on the list?	
 9.         Has your organization established an affirmative procurement system    D Yes D No  D N/A
           for recycled materials and compliance with environmental statutes? (40
	CFR 31.13)	
 10.        Does your organization have internal control processes to ensure that     D Yes D No  D N/A
           only required goods and services are acquired in quantities needed? (40
	CFR31.36(b)(4))	
 11.        Does your organization have internal control processes to ensure that     D Yes D No  D N/A
           only acceptable goods and services are paid for by the
	accounting/finance department? (40 CFR 31.20(b)(5))	
 12.        Does your organization have guidelines for documenting its contract     D Yes D No  D N/A
           files?
 13.        Has your organization awarded contracts to consultants under current    D Yes D No  D N/A
	assistance agreements?	
 14.        Are internal controls for consulting agreements in place to ensure that    D Yes D No  D N/A
           your organization does not charge EPA assistance agreements more
	than the authorized direct salary cap? (40 CFR 31.36(j))	
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 15.        Do your consulting agreements specify the services to be provided,       D Yes D No D N/A
           engagement duration, reporting requirements, work location, and pay
	rates including base rate, fringe benefits, and overhead?	
    G.  Small Businesses, Minority Owned Firms,  Women' Business Enterprises and Labor Surplus Area
        Firms (where applicable). (40 CFR Part 33)

        For "Yes" answers, please provide the specific reference to your policies and procedures. Please
        explain all "No" and "Not Applicable" answers.
 1.         Does your organization submit timely reports      D Yes, date of the last submittal to EPA
           (MBE/WBE Reports) to EPA, on business         	Date
	activities with these types of firms?	D No, please explain.	
    H.  Property Management (40 CFR 31.31 & 40 CFR 31.32)

        Many of these questions have "Yes" or "No" answers. For "Yes" answers, please provide the specific
        reference to your policies and procedures. Please explain all "No" and "Not Applicable" answers.
1.
Does your organization have written property
and procedures?
management policies
DYes DNo D N/A


2.
Has your organization purchased capital equipment on any of its active
assistance agreements?
Yes 	 (Please complete this section.)
No (Go to Section I.)
DYes DNo D N/A

Equipment, under Federal Guidelines, is equipment that is considered tangible items with a useful life greater
than one year and greater than $5,000 in value. Grantees may have limits that are different than the Federal
Guidelines. That is acceptable as long as the limits are not greater than the Federal Guidelines.
3.
Does your organization have an inventory control system? (40 CFR
31.32)
DYes DNo D N/A


4.
Does your organization maintain property records that identify
equipment purchased, either entirely or partially, with Federal funds?
(40CFR31.32(d))
DYes DNo D N/A


5.
Does your organization perform a property inventory at least every two
years? Date of last inventory
DYes DNo D N/A


6.
Does your organization maintain records of property dispositions?
DYes DNo D N/A

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    I.   Internal Controls
        Many of these questions have "Yes" or "No" answers. For "Yes" answers, please provide the specific
        reference to your policies and procedures. Please explain all "No" and "Not Applicable" answers.
1.
Does your organization have policies and procedures to ensure
compliance with the cash management requirements in 40 CFR
31.20((b)(3)?
DYes DNo D N/A


a.
Does your organization have an internal auditor, audit staff or someone
on the Board of Directors that provides for an independent review of
the accounting and financial management process, cash receipts and
payments, and safeguarding of assets?
DYes DNo D N/A


2.
Does your organization have policies and procedure to ensure
compliance with closing out assistance awards after the performance
and budget periods? (40 CFR 3 1.50)
DYes DNo D N/A

3.         Does your organization have a process in place to ensure compliance with the Programmatic Term
          and Conditions in the following areas:
A.
Submitting programmatic progress reports;
DYes DNo D N/A


B.
Establishing and obtaining approval of a Quality Action Plan, if
required;
DYes DNo D N/A


C.
Establishing a process to track, monitor, and report on Environmental
Results?
DYes DNo D N/A

The annual public reporting and recordkeeping burden for this collection of information is estimated to average
30 hours per respondent. If you wish to comment on the Agency's need for this information, the accuracy of the
provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of
automated collection techniques, send them to US EPA, Collections Strategies Division (2822T), 1200
Pennsylvania Ave. NW, Washington, DC 20460.

OMB control number 2030-0020                                                         EPA form number 6600-01
          EPA Tribal, U.S. Territories and Insular Areas Administrative and Financial Guidance for Assistance Agreements
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                                                         Answers to Self-Assessment Questions
11
                                       SIDE
                                             caies correct answer)
         Who monitors an EPA award project?
             A.   EPA grants specialist
             B.   EPA project officer
             C.   Tribal Nation's administrative contact
             D.   Tribal Nation's project personnel
             E.   All of the above
                                                                       The EPA and Tribal Nations are partners in delivering and performing environmental
                                                                       protection with assistance agreement projects. The EPA project officer, the EPA grants
                                                                       specialist, and the Tribal Nation's project personnel need to communicate regularly on
                                                                       the grant work plan, project budget, and administrative issues.
14
Why should we contact the EPA project officer and/or grants specialist when
a problem arises?
     A.   They can help us solve the problem.
     B.   EPA must document and evaluate the problem.
     C.   Problems must be reported to the EPA director.
     D.   EPA can send a specialist out to solve the problem.
     E.   All of the above are possible solutions.
EPA personnel are there to assist Tribal Nations so that EPA awarded projects are
successful. Stopping the problem before it becomes insurmountable ensures success
for everyone involved in the project.
20
What is not required in a cost review?
     A.   Consistent treatment of costs
     B.   Compliance with award "terms and conditions"
     C.   Credentials of staff
     D.   Alignment with federal cost principles
     E.   Determination of reasonable, allocable and allowable costs
Cost reviews require a look at consistency in assigning costs across all programs,
compliance with "terms and conditions" of the award, and a determination that costs
are reasonable, allocable, and allowable according to OMB Circular A-87, found in Title
2 CFR Part 225, Appendix B.
27
External audits are used to test the effectiveness of a grant recipient's:
     A.   Financial operations
     B.   Operating procedures
     C.   Program results
     D.   Resource management
     E.   All of the above
External audits are used to test the adequacy of an organization's regulatory
compliance and financial reporting as well as the effectiveness of an agency's resource
management, operating procedures, program results, and financial operations. External
audits may evaluate the entire organization or only one or two of the organization's
programs or operations.
30
Who may conduct audits of EPA award programs?
     A.   EPA's Inspector General's Office (DIG)
     B.   Government Accountability Office (GAO)
     C.   The Tribal Nation receiving the award
     D.   EPA's Audit Contractors
     E.   All of the above
Any of the agencies and organizations listed may be called upon to audit the financial
status of an EPA award project or program. However, it is federal policy to rely on a
recipient's own audits (i.e., OMB A-133 single audit) as long as they are carried out in
accordance with applicable federal audit standards.

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                                           Module 10:  Assistance Agreement Monitoring and Closeout
36
                          estion (bold font indicates correct answe
When are audits conducted?
      A.   Before the award period begins only
      B.   During the project start and end dates only
    C.   Before, during and after the award period or after closeout but
         before retention ends
      D.   After the award period only
      E.   None of the above are correct
Audits may be performed before, during, or after the completion of a project.
42
How do we pay for auditing?
     A.   EPA award funds
     B.   With grant funds from agencies other than EPA
     C.   The cost of an audit is an allowable cost when allocated fairly
          and equitably between funding sources
     D.   With in-kind contributions only
     E.   With a Tribal Nations general budget only
The cost of a single audit is an allowable cost when allocated fairly and equitable
between funding sources.
56
Closeout is a systematic process to end an award when the award:
     A.   Audit reveals discrepancies
     B.   Project runs out of supplies or equipment
     C.   Partners decide it is completed or terminated
     D.   Policies and procedures fail to comply with EPA regulations
     E.   All of the above
The closeout of an assistance agreement award is a systematic process followed to
make sure that all technical work (e.g., products, construction) and administrative
requirements (i.e., the final Progress Report and Financial Status Report are sent to and
approved by EPA) have been finalized. Closeout is initiated when a project ends due to
completion or termination. A project is usually terminated by an EPA enforcement
action. Usually projects end according to the project's timeline which identifies the end
date.
63
Who does not have the right to access our Tribal Nation's award records?
     A.   Subcontractors and Subrecipients
     B.   EPA officials
     C.   The Inspector General
     D.   Controller of the United States
     E.   Duly authorized federal representative
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.
Last Updated April 2013
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